Marpol Brochure Tcm4-383718

8/6/2019 Marpol Brochure Tcm4-383718

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Technical and Operational implications

Marpol 73/78 Annex VIRegulations or the Prevention o Air Pollution rom Ships


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1. INTRODUCTION page 3

2. ANNEX VI IN GENERAL page 4

3. REGULATION 12 OZONE DEPLETING page 5SUBSTANCES

4. REGULATION 13 NITROGEN OXIDES (NOX) page 6-134.1 Regulations/denitions rom Annex VI4.2 Certication and onboard verication4.2.1 Engine parameter check method4.2.2 Simplied measurement method4.2.3 Direct measurement and monitoring method4.3 Spare parts and imo-marking

4.4 Surveys and inspections4.5 Engines with technical le and eiapp certicates approved

and is sued by another company4.6 Change o fag

5. REGULATION 14 - SULPHUR OXIDES (SOX) AND page 14-19PARTICULATE MATTER

5.1 General5.1.1 Equivalents5.2 EU directive 1999/32/EC and 2005/33/EC amendments5.3 Low sulphur heavy uel5.3.1 Fuel tank/system conguration5.3.2 Change-over procedures

5.3.3 Bunker management5.3.4 Charts

6. REGULATION 15 VOLATILE ORGANIC page 20COMPOUNDS

7. REGULATION 16 SHIPBOARD INCINERATION page 21

8. REGULATION 18 FUEL OIL AVAILABILITY AND page 22-26QUALITY

8.1 General8.2 Operational issues8.2.1 Bunker delivery notes8.2.2 MARPOL 73/78 Annex VI uel oil samples (retained sample)

8.2.3 Sampling procedures8.2.4 Sample inventory8.2.5 Suppliers responsibility8.2.6 Fuel Oil Availability8.2.7 Third party inspections

APPENDIX 1 page 27-29

Content


3/32MARPOL 73/78 ANNEX VI 3

1. INTRODUCTION

MARPOL 73/78 Annex VIRegulations or the preventiono Air Pollution rom shipsenteredinto orce on 19 May 2005.

This Annex includes many newaspects related to design oships, but even more related tooperational issues.

The intention with this paper is to highlight some o the most important aspects o MARPOL Annex VI

or the guidance o Ship owners and Managers, as well as DNV surveyors.


4/324 MARPOL 73/78 ANNEX VI

2. ANNEX VI IN GENERAL

MARPOL ANNEX VI applies to all ships,xed and foating drilling rigs and otherplatorms, but the certication require-ments are depending on size o the vesseland when it is constructed. Ships o 400gross tons and above engaged in interna-tional voyages involving countries thathave ratied the conventions, or shipsfying the fag o those countries, arerequired to have an International AirPollution Prevention Certicate (IAPPCerticate).

The IAPP certicate will be issued ollow-ing an initial survey carried out by the Flag

Administration or by a recognised organiza-tion (e.g. Det Norske Veritas) on behal o

the Flag Administration, conrming com-pliance with MARPOL Annex VI. For shipswith the fag o an Administration that havenot yet ratied Annex VI, a Certicate oCompliance with Annex VI may be issuedby DNV.

Annex VI also requires diesel engines(as described above) to carry individualcerticates with regard to NOx emissions,named Engine International Air PollutionPrevention (EIAPP) Certicates.

Annex VI requires that every ship o 400

gross tonnage or above and every xed andfoating drilling rig and other platormsshall be subject to the ollowing surveys:n An initial survey beore the ship is put

Annex VI in general

into service or beore the IAPP Certi-cate is issued or the rst time.

n Periodical surveys at intervals speciedby the Administration, but not exceed-ing ve years

n A minimum o one intermediate surveyduring the period o validity o the cer-ticate.

In the case o ships o less than 400 grosstons, the Administration may establishappropriate measures in order to ensurethat Annex VI is complied with.

The Administration shall arrange or un-scheduled inspections during the period o

validity o the certicate. I the Administra-

tion establishes mandatory annual surveys,these unscheduled inspections shall not beobligatory, and or this purpose DNV hasso ar considered that all Administrations

will apply a system with mandatory annualsurveys.

Annex VI has requirements to the ollow-ing main issues, which will be highlightedmore in detail in this paper.n Regulation 12 - Emissions rom Ozone

depleting substances rom rerigeratingplants and re ghting equipment

n Regulation 13 - Nitrogen Oxide (NOx)

emissions rom diesel enginesn Regulation 14 - Sulphur Oxide (SOx)

emissions rom shipsn Regulation 15 - Volatile Organic com-

pounds emissions rom cargo oil tankso oil tankers

n Regulation 16 - Emissions romshipboard incinerators

n Regulation 18 - Fuel Oil quality.

The adoption o MARPOL Annex VI has ollowed some years odebate within organisations. At the same time the Technicalcode on the Control o Emissions o Nitrogen Oxides rom MarineDiesel Engines was adopted. MARPOL Annex VI and the TechnicalCode have retroactive requirements or the ollowing:

Diesel engines o 130 KW andabove installed on ships keel-laid on or ater 1 January 2000

Diesel engines installed on shipskeel-laid between 1 January1990 and 1 January 2000

Incinerators installed onboardon or ater 1 January 2000.



3. REGULATION 12

Ozone depleting substances

All the ships subject to the requirements o Annex VI, shall maintaina list o equipment containing ozone depleting substances and incase a ship will have rechargeable systems cont-aining ozone deplet-ing substances, an Ozone depleting Substances Record Book shall bemaintained on board.

Annex VI prohibits any deliberate emissions oozone-depleting substances.

OZONE-DEPLETING SUBSTANCES, andequipment containing such substances,shall be delivered to appropriate recep-tion acilities when removed rom a ship.

Installations which contain ozone-deplet-ing substances, other than hydrochloro-fuorocarbons, are prohibited :n On all ships constructed on or ater

19.05.2005,n In the case o ships constructed beore

19 May 2005, which have a contractualdelivery date o the equipment to theship on or ater 19 May 2005, or, in theabsence o a contractual delivery date,the actual delivery o the equipment tothe ship on or ater 19 May 2005.

Installations containing hydrochlorfouro-

carbons (HCFCs) are prohibited on shipsconstructed on or ater 1.01.2020.

For the ships under regulation 12 oMarpol Annex VI, a list o equipment con-taining ozone depleting substances shallbe maintain and in case a ship will haverechargeable systems containing ozonedepleting substances, an Ozone depletingSubstances Record Book shall be main-tained on board.

The use o Halon in re extinguishing sys-tems and equipment is already prohibitedor new buildings. For new buildings, thisrequirement in Annex VI will thereorealways be complied with. More restrictiverequirements or ozone depleting substanc-es are in place regionally, e.g. in the Euro-pean Union (EU). (E.g. EC 2037/2000)

According to EC No. 2037/2000, produc-ers and importers shall not place HCFCson the market ater 31 December 2009.

Virgin HCFCs will consequently not beavailable within the EU. However, thererigerant system can utilize reclaimed

HCFCs until 31 December 2014, ater thisdate all HCFCs is prohibited.



4. REGULATION 13

4.1 REGULATIONS/DEFINITIONS FROMANNEX VIRegulation 13 o Annex VI concernsNOx-emission rom diesel engines andshall apply to:n Each diesel engine with a power output

o more than 130 kW which is installedon a ship constructed on or ater1 January 2000.

Nitrogen Oxides (NOx)

n Each diesel engine with a power outputo more than 130 kW which undergoesa major conversion on or ater1 January 2000.

n Each diesel engine with a power outputo more than 5000 kW and a per cylin-der displacement at or above 90 litreswhich is installed on a ship constructedon or ater 1 January 1990 but prior to1 January 2000.

This regulation does not apply to:n Emergency diesel engines, engines

installed in lie boats or or any equip-ment intended to be used solely in caseo emergency.

n Engines used solely to drive machinerydedicated to exploration, exploitation andassociated oshore processed o seabedmineral resources

The phrase major conversion, means amodication o an engine where:n The engine is replaced by a new engine

built on or ater 1 January 2000, orn Any substantial modication is made

to the engine, as described in the NOxTechnical Code 1.3.2 (e.g. changing cam-shat, uel injection system, or any otherNOx-related settings or components), or

n The maximum continuous rating o theengine is increased by more than 10%

For this purpose, Substantial Modicationis dened as ollows:n For engines installed on vessels

constructed on or ater 1 January 2000,a Substantial Modication means anymodication to an engine that couldpotentially cause the engine to exceedthe emission standards set out in Regu-lation 13 o Annex VI. Routine replace-ment o engine components by partsspecied in the Technical File that donot alter emission characteristics shallnot be considered a Substantial Modi-cation, regardless o whether one partor many parts are replaced.

n For engines installed on vesselsconstructed beore 1 January 2000,

a Substantial Modication means anymodication made to an engine whichincreases its existing emission charac-teristics established by the simpliedmeasurement method as described in6.3 in excess o the allowances set out in6.3.11(Re. NOx Technical le.). Thesechanges include, but are not limited to,changes in its operations or in its techni-cal parameters (e.g. changing camshat,uel injection systems, air systems, com-bustion chamber conguration,or timing calibration o the engine)



4. REGULATION 13

Tier I (current limits)For diesel engines installed on ships constructed rom1 January 2000 to 1. January 2011 allowable emissionso total weighted NOx depending on engine speed, n, are:17,0 g/kWh when n is less than 130 rpm45,0 n(-0,2) g/kWh when n is 130 or more but less than2000 rpm9,8 g/kWh when n is 2000 rpm or more

Tier IIFor diesel engines installed on ships constructed on or ater1 January 2011 allowable emissions o total weighted NOxdepending on engine speed, n, are:n 14,4 g/kWh when n is less than 130 rpmn 44,0 n(-0,23) g/kWh when n is 130 or more but less thann 2000 rpmn 7,7 g/kWh when n is 2000 rpm or more

Regulation 13 contains urther a 3-Tier approach as ollows:

The below graph illustrates the allowable NOx emissions rom diesel engines:

TotalWeightedNOxemission,

[g/kWh]

Engine speed, [rpm]

18

16

14

12

10

86

4

2

0

200

400

600

800

1000

1200

1400

1600

1800

2000

2200

Tier I

Tier II

Tier III

Tier IIIShips constructed on or ater 1 January 2016 will haveadditional limitations when operating in an Emission ControlArea. For the purpose o NOx emissions no Emission ControlAreas (ECAs) have yet been designated, but it is expectedthat both the Baltic Sea and the North Sea will be designatedwell ahead o 1 January 2016.

For Tier III ships operating in the NOx ECAs the allowable

emissions o total weighted NOx depending on engine speed,n, are:n 3,4 g/kWh when n is less than 130 rpmn 9,0 n(-0,2) g/kWh when n is 130 or more but less than 2000 rpmn 2,0 g/kWh when n is 2000 rpm or more

Tier III limits will not apply to engines installed on a ship witha length o less than 24 metres when it is designed and usedsolely or recreational purposes, or an engine installed on aship with a combined nameplate diesel engine propulsionpower o less than 750 kW i it is demonstrated that the shipcannot comply with the standards set orth in paragraph5.1.1 o this regulation because o design or constructionlimitations o the ship.



Engine above 130 kW(Except from engines used solely in case of emergency)

Installed on a vessel constructed (keel laid) on or

after 2011-01-01 (Tier II)

Installed on a vessel constructed (keel laid) on orafter 2000-01-01 (Tier I)

Installed on a vessel constructed (keel laid) on or after1990-01-01 and prior to 2000-01-01 and above5,000 kW and cylinder di splacement above 90 litres

Any major conversion made to the engine on or after2000-01-01

EIAPP Certificate required No EIAPP Certificate required

EIAPP Certificate already obtained

EIAPP Certificate issued by another IACS member

Documents to be submitted to DNV: Engine Technical File EIAPP issued by IACS member

Documents accepted by DNV

Vessel ready for IAPP initialsurvey according to Reg 13of Annex VI (NOx)

Approach Engine Manu-facturer for furtherassistance

No

Yes

No

No

No

No

No

Yes

Installed on a vessel constructed (keel laid) on orafter 2016-01-01 (Tier III)(Except engines installed on recreational vessels withlength less than 24m and total propulsion power lessthan 750 kW)

Yes

Yes

Yes

Yes

Yes

No

Yes

EIAPP Certificate issued by DNVYes

Yes

No

No

No

4. REGULATION 13

NOx Emission Limits for Engines

Installed on Ships Constructed Prior to

1 January 2000

Ships constructed on or ater 1 January

1990 but prior to 1 January 2000 shallcomply with the Tier I NOx emission limits.However, the requirement is limited toengines with a power output o more than5000 kW and a per cylinder displacementat or above 90 litres.

Moreover, compliance is only required ian Approved Method or obtaining thenecessary NOx reduction is available orthe engine(s) in question. There is also amechanism in the regulation to ensure thatan Approved Method should meet a costeectiveness criterion which will set a maxi-

mum cost or purchasing and installation oa method.

Necessary engine adjustments or tting oNOx reducing kits shall take place no laterthan the rst renewal survey that occurs 12months or more ater approval o a methodapplicable. However, i the supplier o an

Approved Method is not able to deliver atthis renewal survey installation may takeplace at the ollowing annual survey. Detailrequirements or approval o NOx reduc-ing methods have been included in therevised NOx Technical Code.

4.2 CERTIFICATION AND ONBOARDVERIFICATIONThe EIAPP (Engine International AirPollution Prevention) certicate is requiredor all diesel engines as described above, andwill be issued or marine diesel engines aterdemonstrating compliance with NOx emis-sion limits. The certication process is tobe carried out in accordance with the NOxTechnical Code (2008) issued by IMO.

In order to decide whether your engineneeds an EIAPP Certicate or not, we canadvise you to consider the ollowing or

your vessels and engines:n Engine power output above 130 kW?n Is the vessel constructed (keel laid) ater

1 January 1990 (Tier I)?- Is the power output rom the engine

above 5000 kW and is the cylinderdisplacement above 90 litres?

- Is there an Approved Method availableor that engine?

n Is the vessel constructed (keel laid)beore 1 January 2000?

n Is the vessel constructed (keel laid)ater 1 January 2000 (Tier I)?

n Is the vessel constructed (keel laid)ater 1 January 2011 (Tier II)?

n Is the vessel constructed (keel laid)ater 1 January 2016 (Tier III)?

n Major conversion o the engine onor ater 1 January 2000?

As a general guidance, see the ow chart below.

The ow chart above is meant as a general guidance indicating the neces-sary steps or you to consider regarding the NOx requirements o Annex VI.Please note that the ow chart is only concerning the NOx requirements tothe diesel engines, and this is also what the EIAPP certifcate is covering.I you fnd that your engines are required to carry an EIAPP certifcate, but

or some reason they dont have this, our advice is or you to approach theengine manuacturer or urther assistance.



4. REGULATION 13

Even i DNV holds copies o the EIAPPCerticate and the Technical File, these havebeen issued and approved as a service to theengine manuacturer and hence is the en-gine manuacturers property. In order to get

hold o required EIAPP documentation, therequest should always go through the enginemanuacturer. DNV may be contacted orassistance in order to acilitate the dialogue.

The certication process includes an emis-sion test or compliance with the NOxrequirements on the manuacturers testbed, and approval o the Technical File.All certied engines are delivered with anindividual Technical File that contains theengines specications or compliance withthe NOx regulation, and the applicableonboard verication procedure.

The NOx Technical Code opens or 3dierent onboard verication procedures:n Engine parameter check methodn Simplied measurement methodn Direct measurement and monitoring

method

The applicable onboard vericationprocedure is initially decided by the enginemanuacturer, and is usually a specic chap-ter in the engines Technical File. The byar most common method is the Engine pa-rameter check method, but the ship owneris ree to use the method they preer. I theywish to change to another method than theone specied in the Technical File, the newonboard verication procedure must besubmitted to the Administration (or DNVon behal o the Administration when autho-

rised) or approval beore taken into use.

Cost of Approved Method x 106Ce =

P(kW) x 0,768 x 6000(hours /year) x 5(years) x NOx(g/kWh)

In order to have existing engines certied,installed on vessels keel laid between1 January 1990 and 1 January 2000, theprocess is either o the two ollowing:

1. An Approved Method need to be com-mercially available. This means the

Approved Method is certied by anAdministration (class) and installationo the method is veried by a surveyusing the procedure as specied in the

Approved Method File. In addition, theinstallation cost o the Approved Methodshall not exceed 375 Ce given the or-mula below:

2. The engine is veried to be included in

an already existing engine group.



4. REGULATION 13

4.2.1 ENGINE PARAMETER CHECKMETHODFor the purpose o assessing compliance

with Regulation 13 o Annex VI, it is notalways necessary to measure the NOx level

to know that an engine is likely to complywith the NOx emission limits. It will besucient to know that the present state othe engine corresponds to the speciedcomponents, calibration or parameter-adjustment state at the time o initialcertication.The engines Technical File is identiying itscomponents, settings and operating valuesthat infuences the exhaust emissions, andthese must be checked to ensure complianceduring surveys and inspections. Ship ownersor people responsible or vessels equipped

with diesel engines required to undergoan engine parameter check method shallensure that the ollowing documentationis at all times kept onboard and updated asapplicable:n Original Technical File including the

onboard verication procedure.n Record book o engine parameters or

recording all o the changes made rela-tive to an engines components and set-tings. Also to include technical documen-tation in case o modicationo any o the engines designated compo-nents. This may be a print-out rom thePlanned Maintenance System on-board.

We recommend to include ALL changespotentially aecting the NOx emissioncharacteristics o the engine as FlagStates and Port States may have dierentinterpretations o what to be included.

n Original EIAPP certicate (or Certi-cate/Statement o Compliance) or eachapplicable engine.

The NOx-infuencing components andsettings depend on the design o theparticular engine, and shall be listed in

the engines Technical File. The below listshows typical NOx-infuencing parameters,but are not limited to:n Injection timingn Injection system components

(nozzle, injector, uel pump)n Sotware no, checksums, or other

identication o sotware versionn Hardware or uel injection controln Camshat components (uel cam,

inlet- and exhaust cam)n Valve timingn Combustion chamber (piston, cylinder

head, cylinder liner)

n Compression ratio (connecting rod,piston rod, shim, gaskets)

n Turbocharger type and build(internal components)

n Charge air cooler/charge air pre-heatern Auxiliary blowern NOx reducing equipment water

injectionn NOx reducing equipment emulsied

uel (uel/water emulsion)n NOx reducing equipment exhaust gas

recirculationn NOx reducing equipment selective

catalytic reduction

The actual Technical File o an engine mayinclude less components and/or param-eters other than the list above, dependingon the particular engine and the specicengine design.

4.2.2 SIMPLIFIED MEASUREMENT

METHODFor onboard verication tests duringperiodical and intermediate surveys, theNOx Technical Code opens or a simpli-ed measurement method. Note thatevery rst engine test or certicationshall be perormed on the engine makerstest-bed.

The simplied measurement method is tobe perormed more or less like the parenttesting at the engine manuacturers test-bed, but simplications according to theNOx Technical Code 6.3 are accepted.However, the testing shall be perormed inaccordance with the applicable test cycleas specied in the engines Technical File.This involves ull load running o the en-gine or about 20 minutes, and will in mostcases require a test trial.

Due to the possible deviations when apply-ing the simplied measurement method,an allowance o 10% o the applicableNOx limit value given in Regulation 13 inthe NOx Technical Code is accepted orconrmation tests and during periodical

and intermediate surveys. Another 10%deviation is permitted when using heavyuel oil during the on-board test. However,in no case the total allowable deviation is toexceed 15%.

4.2.3 DIRECT MEASUREMENT ANDMONITORING METHODThe ship-owner will have the option odirect measurement o the NOx emissionsduring the engine operation. Such datacan either take the orm o spot checkslogged with other engine operating data

on a regular basis and over the ull rangeo engine operation, or they can resultrom continuous monitoring and datestorage. Data must be taken within the

last 30 days, and must have been acquiredusing the test procedures given in theNOx Technical Code. These monitoringrecords are to be kept onboard or at leastthree months or verication purposes.We would however recommend maintain-ing the documents, on board or in shore

oce, or a longer period o time.To demonstrate the compliance by thedirect measurement method, sucientdata shall be collected to calculate the



4. REGULATION 13

weighed average NOx emissions in ac-cordance with the NOx Technical Code.The procedure to ollow in order to usethe direct measurement and monitoringmethod is outlined in MEPC Resolution103(49) Guidelines or On-Board NOxVerication Procedure.

DNV requires that the system or directmeasurements is approved and holds avalid DNV Type Approval Certicate.

I the direct measurement and monitoringmethod is the preerred On-Board Verica-tion procedure, an initial survey has to becarried out in order to veriy the instal-lation and the use o the system. Prior tothe initial survey, a ship specic On-boardMonitoring Manual has to be submitted to

DNV Hvik, MGGNO894, or approval.In case the engine is to be adjusted outsidethe limits specied in the Technical File,the uel consumption and load have to be

measured. Procedures describing how thisis intended handled have to be submittedor approval. However, the engine can notbe adjusted beore the On-Board Monitor-ing Manual has been approved and newEIAPP Certicates issued and conrmedavailable on-board. All changes to the

engine shall be logged in the record booko engine parameters. I any adjustment tothe engine is made, new NOx measurementshave to be taken at earliest convenience.



4. REGULATION 13

The operation o the NOx continuousmonitoring system to be perormedaccording to the approved On-BoardMonitoring Manual. I any measuremento NOx is above the allowable limits,

required adjustments have to be madeimmediately and new measurementstaken. I urther inormation about howto proceed in order to change to thedirect measurement and monitoringmethod, DNV Hvik, MGGNO894Machinery Systems can be contacted orassistance.

It should be noted that the two methodsthat involve measurements o the exhaustemissions do not include any kind oidentication markings o the NOx-infuencing components. However,

components should only be changed inaccordance with applicable Class require-ments. In addition, i the engines NOxemissions are no longer to be veriedaccording to the Direct Measurement andMonitoring method, the engine has to beadjusted as per its original Technical File.

4.3 SPARE PARTS AND IMO-MARKINGOne o the main consequences oMARPOL Annex VI is that the onboardverication procedure Engine parametercheck method requires identicationmarkings on the NOx infuencing com-ponents. These components are typicallythose specied in the above list, see 3.2.1.

All the components listed are to be ttedwith identication markings according tothe Technical File, normally reerred to asIMO-marking. Please note that these mark-ings may not be the same as the article nosusually ound on the engine components.

DNV, on behal o the Flag Administration,can not accept components with IMO-mark-

ing other than those stated in the TechnicalFile. Manuacturers producing engines/components on licensee rom an enginedesigner, usually have their own Id Numberson the engine components. It is advisableto always veriy that the purchased sparepart has the same IMO-marking as in theapplicable Technical File. In order to makethe purchasing easier, it could be an ideato keep a copy o the Technical Files in thepurchasing section.

There may be situations where the enginemaker comes up with a new design or

one o the NOx-infuencing components,with a dierent Id No/IMO marking romthe one stated in the Technical File. Thenew design should then be approved by



4. REGULATION 13

the Administration (or DNV on behal oa Flag Administration when authorised)and the change is to be documented inthe Record book o engine parameters.In such a case, the Technical File has to be

amended and the engine manuacturer willhave to document that the NOx emissionsdo not increase with the new design. Thesame is applicable or all other changesthe engine may be approved or during itslietime.

4.4 SURVEYS AND INSPECTIONSFollowing the regime o the IAPP certi-cate, the diesel engines will also be subjector the ollowing surveys:n An initial survey beore the ship is put

into service or beore the IAPP Certi-

cate is issued or the rst time.n Periodical surveys at intervals specied by

the Administration, but not exceeding veyears,

n A minimum o one intermediate surveyduring the period o validity o the cer-ticate.

n Annual Surveys (or a Flag Administra-tion may instead implement unsched-uled inspections as an alternative toAnnual surveys)

n An initial survey i the manager wantsto change to an other onboard verica-tion procedure than the one stated inthe Technical File (the most commonmethod is the Engine Parameter CheckMethod)

I the Engine Parameter Check Methodis the selected onboard vericationprocedure, the surveyor will typically wantto see during initial and periodical surveys:n EIAPP Certicates (or Certicates/State-

ments o Compliance) or all applicablediesel engines onboard

n Approved Technical Files includingOnboard verication procedure or all

the applicable diesel engines onboardn Record Book o Engine parameters or

all the applicable diesel engines onboardn One or all o the identied components,

settings or operating values specied inthe engines Technical File. Available spareparts may be used as an alternative toopening up the engine in order to veriythe IMO-markings on the NOx-infuencingcomponents.

I the Simplied Measurement Methodis the selected onboard verication proce-dure, the surveyor will witness the testing in

addition to review the ollowing documen-tation during initial and periodical surveys:n EIAPP Certicates (or Certicates/

Statements o Compliance) or all appli-

cable diesel engines onboardn Approved Technical Files including

Onboard verication procedure or allthe applicable diesel engines onboard

n All recommendations rom engine

manuacturer and approvals rom theAdministration concerning theSimplied Measurement Method

n Test results

I the Direct Monitoring andMeasurement Method is the selected on-board verication procedure, the surveyor

will typically want to see during initial andperiodical surveys:n EIAPP Certicates (or Certicates/State-

ments o Compliance) or all applicablediesel engines onboard

n Approved Technical Files including

Onboard Monitoring Manual or allthe applicable diesel engines onboard

n Approval o the installed measuring equip-ment (DNV Type Approval Certicate)

n Logged measurement results in order toveriy that the engines comply with theNOx Technical Code (in no case olderthan 30 days).

Regardless o what onboard vericationprocedure the Ship-Owner chooses, theIAPP Certicate or the vessel will be issuedi all other requirements are ound tocomply with the applicable requirements.

4.5 ENGINES WITH TECHNICAL FILE

AND EIAPP CERTIFICATES APPROVED

AND ISSUED BY ANOTHER COMPANY

There are a number o dierent com-panies that are certiying diesel engineswith regards to NOx-emissions. DNV, onbehal o the Flag Administration, canonly accept certication rom companiesthat are authorised by the applicable fagto perorm certication on their behal.Documentation rom another IACS

member is normally accepted as is. Forother organisations, the applicable FlagAdministration has to be contacted oracceptance. In both cases the certica-tion procedure will be on a case-by-caseapproval.

The EIAPP Certicates and Technical Files,including all possible updates, are to besubmitted to DNV or review and ling.

4.6 CHANGE OF FLAGI the vessel changes fag, both IAPPCerticate and EIAPP Certicates have to

be re-issued.



5. REGULATION 14

5.1 GENERAL19 May 2005 Annex VI to MARPOL enteredinto orce. The revised Annex VI to MAR-POL was adopted by IMO on 10 October2008. The sulphur oxide (SOx) andParticulate Matter emissions rom ships willin general be controlled by setting a limiton the sulphur content o marine uel oilsas ollows. The sulphur content o any ueloil used on board ships shall not exceed theollowing limits:n 4.50% m/m prior to 1 January 2012n 3.50% m/m on and ater 1 January 2012n 0.50% m/m on and ater 1 January 2020

Requirements within Emission Control AreasFor the purpose o the regulation, EmissionControl Areas shall include:n The Baltic Sea area as dened in regula-

tion 1.11.2 o Annex I, the North Sea as

dened in regulation 5(1)() o Annex V

Sulphur Oxides (SOx)

and Particulate Matter

n Any other sea area, including port areas,designated by the Organization inaccordance with criteria and proceduresset orth in appendix III to this AnnexWhile ships are operating within anEmission Control Area, the sulphurcontent o uel oil used on board ships

shall not exceed the ollowing limits:- 1.50% m/m prior to 1 July 2010- 1.00% m/m on and ater 1 July 2010- 0.10% m/m on and ater 1 January 2015

The sulphur content o uel oil reerredto in paragraph 1 and paragraph 4 o thisregulation shall be documented by itssupplier as required by regulation 18 othis Annex.

Those ships using separate uel oils to com-ply with paragraph 4 o the regulation and

entering or leaving an Emission Control

Area set orth in paragraph 3 o the regula-tion shall carry a written procedure show-ing how the uel oil change-over is to bedone, allowing sucient time or the ueloil service system to be ully fushed o alluel oils exceeding the applicable sulphurcontent specied in paragraph 4 o the

regulation prior to entry into an EmissionControl Area. The volume o low sulphuruel oils in each tank as well as the date,time, and position o the ship when anyuel-oil-change-over operation is completedprior to the entry into an Emission Control

Area or commenced ater exit rom suchan area, shall be recorded in such log-bookas prescribed by the Administration.

Review ProvisionA review o the standard set orth in sub-paragraph 1.3 o this regulation shall be

completed by 2018 to determine the avail-

Indication of ECAs

Defnition o the ECA



5. REGULATION 14

ability o uel oil to comply with the ueloil standard set orth in that paragraphand shall take into account the ollowingelements:n The global market supply and demand or

uel oil to comply with paragraph 1.3 othis regulation that exist at the time thatthe review is conducted.

n An analysis o the trends in uel oil markets.n Any other relevant issue.

The Parties, based on the inormationdeveloped by the group o experts, maydecide whether it is possible or ships tocomply with the date in paragraph 1.3 othis regulation. I a decision is taken thatit is not possible or ships to comply, thenthe standard in that subparagraph shallbecome eective on 1 January 2025.

It should be noted that the limitationsin sulphur content applies to all uel oils(heavy uel oils, marine diesel oils andgas oils) and regardless o use on board(i.e. in combustion engines, boilers, gasturbines etc.).

Currently, the 3 year average sulphur con-tent in uel oils reported by IMO based onnumbers o samples tested rom uel bun-kered is 2.46%. Results o the comprehen-sive number o uel samples tested by DNVPetroleum Services and others reported to

IMO in 2008 indicate that only 0.02% othe uel oils tested have a sulphur contentexceeding the maximum limit o 4.50%,urther that 24.1% o the uel oils suppliedin 2008 had a sulphur content o 1.50% or

less compared to 20.6% the year beore.

The 2nd IMO 2009 GHG Study estimated areduction in SOx o 42% in 2008. The rst

year in which both sulphur emission con-trol areas (ECAs) have been ully in orce.It has been estimated that the low sulphuruel oil demand in the SOx ECAs is in therange o 20 million tons per year (2007).

While certain owners with a high environ-mental prole already have had a sulphurlimit o 1.5% in their uel specications,the sulphur content o the uel is gener-ally dependent on the composition o the

crude oil rom which it is rened. Increas-ing the output o low sulphur uel oil canbe obtained through the ollowing:n Rening o naturally occurring low

sulphur crude oils.n Re-direct/blend inland grade uel to the

marine uel market.n Re-blending o residual uel oils down to

the required specication.n Residue de-sulphurisation (Note that large

scale investments in residue de-sulphurisa-tion units are not expected to be made un-til a substantial price dierence betweenhigh and low sulphur uels are achieved).

It is generally acknowledged that the abovewill lead to increased prices or low sulphuruel oils depending on method o produc-tion and market availability/demand.

Although it has been indicated that the totalworld wide availability o low sulphur uel isadequate with the current SECAs and associ-ated low sulphur limit (1.50%), it is highlyuncertain as to whether the availability willbe adequate in world wide ports. It shouldurther be noted that currently, low sulphuruel is in general only available to operatorswith contract agreements with Oil Majors.Future spot availability is thus dependent onthe developments in market demand andprice ater entry into orce o ECAs.

5.1.1 EQUIVALENTS

The revised Annex VI to MARPOL hasintroduced a new regulation 4 Equivalents

where the Administration o a Party mayallow any tting, material, appliance orapparatus to be tted in a ship or otherprocedures, alternative uel oils, or compli-ance methods used as an alternative to thatrequired by this Annex i such tting,material, appliance or apparatus or otherprocedures, alternative uel oils, or com-pliance methods are at least as eectivein terms o emissions reductions as thatrequired by this Annex, including any o thestandards set orth in regulations 13 and 14.

Separation and Filtration Plant

Overboard Discharge ocleaned water

Sludge ashore to authorisedcontractor

Scrubbed & re-heatedexhaust gases

Scrubbed gasre-heated section

Sea water

Intimate mixing o exhaustgas and sea water

S.W. to cyclone separation& heat exchanger

S.W.inlet

Exhaust Gases

Exhaust gas cleaning system



5. REGULATION 14

Thus as an alternative to using marine ueloil with low sulphur content in EmissionControl Areas an exhaust gas cleaningsystem or other equivalent system may be al-lowed to be used (abatement technologies).

Development o a type approval standard orsuch systems is ongoing in IMO. Some o thecurrent available abatement technology isbased on seawater scrubbing principles.

There is however a ew concerns related tothese types o scrubber type systems:n Annex VI states that port states may

prohibit discharge o scrubber efuentoverboard in ports within ECAs unlessit can be documented that the efuentcomplies with criteria set by that port state.A mitigating measure is installation o

ltration/treatment systems.n It has been indicated that conventional

scrubber technology may be struggling tomeet the emission criteria at high exhaustgas discharge fows.

n It has been indicated that there is a risko blue-sheen originating rom the scrub-ber overboard discharge. Although, notnecessarily constituting an environmentalhazard, the mere risk o such occurrenc-es is to some operators unacceptable.

n There are space considerations in theengine room and more specically theunnel. Although it has been indicatedthat the more advanced scrubber types canreplace standard silencers, the associatedpiping systems may represent a challenge.Pressure drop in scrubbers has also beenindicated as a limitation, particular in wayo main engines uptakes.

n Tanker owners have had mixed experi-ences with corrosion o inert gas scrub-bers and associated piping systems.

n The EU has been reluctant to acceptscrubbers. However, in the latest pro-posed amendments to the EU directive,they have opened or trials o ship

emission abatement technologies.Based on such trials they have indicatedthat they may accept abatement tech-nology as an equivalent to low sulphuruel. Note that EU has indicated that itwill develop criteria or resulting wastestreams in their ports.

Regrettably, the number o developmentprojects related to new scrubber technologyappears to be limited. However, some proj-ects currently in the prototype phase showpromising results in terms o overcomingthe above indicated constraints. It should

also be taken into account that exhaust gascleaning alternatives will reduce the emis-sion o particulate matter (PM). Particulatematter is considered to be the next ocal

point o IMO and this increases the uturerelevance o exhaust gas cleaning systems.

Despite the indicated installation costs o 1-2mill USD, uture legislation, and elimination

o the problems associated with low sulphuruel bunker management and operation,may lead to exhaust gas cleaning systemsbecoming a cost-benecial alternative worth-while exploring.

5.2 EU DIRECTIVE 1999/32/EC AND2005/33/EC AMENDMENTSIn connection with MARPOL Annex VIone cannot disregard ongoing low-sulphur uel developments in the EU. EUdirective 1999/32/EC has been amendedby 2005/33/EC and in orce today is the

ollowing:n A 1.5% sulphur limit or uels used by

all ships in the Baltic Sea, North Sea &Channel in accordance with theimplementation dates o Annex VI toMARPOL (i.e. starting in 19 May 2006or the Baltic Sea Area). As o 19th May2006, EU member states shall ensuretha the sulphur content in marinediesel oils (ISO 8217 grades DMB andDMC) supplied within their territorydoes not exceed 1.5%.

n A 1.5% sulphur limit or uels used bypassenger vessels on regular servicesbetween EU ports as o 19 May 2006.

n From 1 January 2008 until 31 December2009, a 0.10% sulphur limit applies tomarine gas oils used in EU territory witha viscosity or density alling within theranges o viscosity or density dened orDMX and DMA grades under ISO 8217.The exemption or Greece and the outer-most regions continues to apply.

n From 1 January 2010, the provisionsoriginating rom directive 1999/32 andrelating to the use o marine gas oils inEU territory are now deleted. Instead

a 0.1% sulphur limit is introduced ormarine gas oils placed on the market inEU Member States territory, and a 0.1%sulphur limit starts to apply to all typeso marine uel used by ships at berth inEU ports and by inland waterway vessels.This applies to any use o the uel e.g. inauxiliary engines, main engines, boilers.There are the ollowing exemptions: orships which spend less than 2 hours atberth according to published timetables,or hybrid sea-river vessels while they areat sea, and or ships which switch o allengines and use shore-side electricity.

The outermost regions continue to beexempt rom this provision, but Greecedoes not, apart rom a 2-year derogationor 16 named Greek vessels until 2012.

5.3 LOW SULPHUR HEAVY FUELThe experience in terms o low sulphurresidual (or heavy) uel oil blending is

varying. DNV Petroleum Services has al-ready seen indications that the blending o

low sulphur uel oils may lead to additionalquality problems such as instability, incom-patibility, ignition and combustion dicul-ties and an increase o Aluminium+Siliconlevels due to use o dierent low sulphurblend components. Regrettably one hasalso seen cases where chemical waste hasbeen introduced in such uel. In light othe required demand or low sulphur ueloils, there have also been concerns over thepotential increase o sulphur content inhigh sulphur uel oils.



5. REGULATION 14

5.3.1 FUEL TANK/SYSTEMCONFIGURATIONIt should be noted that when approachingan ECA the uel must be changed over tothe required sulphur content uel oil e.g.

1.50% m/m and completed beore enter-ing the ECA. For ships with standard ueloil system congurations (one service andsettling tank), this will involve lling osettling tanks with low sulphur uel oil,adequate uel treatment o same and sub-sequent lling o service tank, as well asfushing o the uel service piping systemso high sulphur uel oil.

The problems with incompatibility betweenheavy uel oils, and between heavy uel oilsand marine diesels have not disappeared

with increased demands or low sulphur

heavy uel oils (excessive sedimentation/sludging and separator and lter prob-

lems). Considering the dierences in cost,some owners are installing an additional seto service and settling tanks or low sulphuruel oils. Additional bunker tanks areconsidered installed or the same reasons.

Such measures would also simpliy change-over procedures and bunker management.Inadequate availability o low sulphur heavyuel oils may orce owners to increase theconsumption o low sulphur diesel oils

within ECAs. Owners will thereore have toassess whether the diesel oil tank capacityneeds to be upgraded. Taking into accountthe current EU requirements to use o ultralow sulphur distillates within its territories,and not to mention ultra low sulphur uelat berth in EU ports, there is also an issueo whether to allocate or convert existinguel tanks to tanks or marine gas oil.

The dierences in cost between low andhigh sulphur heavy uel oils as well as be-

tween heavy uel oils and low sulphur die-sel oils, has led some owners to considerseparating uel treatment and servicepiping systems. This is increasinglyimportant with respect to the require-

ments to use o ultra low sulphur uels inEU ports (Auxiliary engines and boilers).

In order to acilitate sae and simplechange-over, the installation o separatemarine gas oil/diesel oil supply piping

with heating capabilities should beconsidered. (While separate direct dieseloil supply lines are oten arranged orauxiliary diesel engines, the same is lessrequently encountered or boilers andmain engines.) The below serves as ex-amples o proposed modications regard-ing duplicated heavy uel oil service and

settling tanks and piping systems.



5. REGULATION 14

The below shows the arrangement o uel oil tank piping arrangement as per the optional DNV class notation FUEL,which enables handling o dierent uel qualities.

Handling o dierent uels

It should be noted that the United States Coastguard has recently issued policy letter Guidelines or ensuring compliance

with Annex VI o MARPOL 73/78 as Annex VI became eective or the United States on 8 January 2009 or oreign faggedships operating in U.S. waters as well as U.S. fag ships and has included uel tanks as inspection item i separate uel tanksare used and where it should be veried that high & low sulphur uels cannot be blended/mixed

Possible arrangement or additional uel oil tanks



5. REGULATION 14

5.3.2 CHANGE-OVER PROCEDURESChange-over between heavy uel oil gradesis standard practice and so is change-overrom heavy uel oil to marine diesel oil inconnection with e.g. dry-dockings.

Change-over rom heavy uel oil to marinegas oil is however completely dierent andclearly not common standard. I gas oilis mixed in while the uel temperature isstill very high, there is a high probabilityo gassing in the uel oil service system

with subsequent loss o power. It shouldbe acknowledged that the requency andtiming o such change-over may increaseand become ar more essential upon entryinto orce o ECAs and the EU proposedamendments.

Additionally, the time, ships positions atthe start and completion o change-over toand rom compliant Low Sulphur uel oilmust be recorded in a logbook (e.g. ER log.book), together with details o the tanksinvolved and uel used. It can be antici-pated that the same will be applicable withrespect to the EU proposal upon entry intoorce.

5.3.3 BUNKER MANAGEMENTIn view o the change-over requirements,bunker grade segregation constraints,uncertainty in terms o low-sulphur uel oilavailability and potential quality problems,the fexibility in bunker management maybe impaired. In addition to the potentialincrease in uel oil cost, it could also resultin increased requency o bunkering.Further, owners/managers and charterersmay need to amend their bunker speci-cations, uel supply agreements as well ascharter parties to take the new require-ments into account.

5.3.4 CHARTSDue to the introduction o ECAs and

associated change-over procedures, it needbe ensured that onboard charts areupgraded with respect to ECA borders.



6.REGULATION 15

All tankers which are subject to vapouremission control in accordance with aboverequirements shall be provided with an ap-proved vapour collection system, and shalluse such system during the loading o suchcargoes. The vapour collecting system shallcomply with IMO Guideline MSC/Circ.585.

Existing tankers which are not tted withvapour collection systems may be acceptedor a period o three years ater the dateo which the respective terminal and portrequirements became eective.

DNV has developed class notations orvapour control & recovery systems. Classnotation VCS-1 implies compliance withIMO Guideline MSC/Circ.585, and VCS-2implies compliance with USCG regula-tion 46 CFR Part 33. Any vessel with classnotations VCS-1 or VCS-2 will comply withregulation 15.

Regulation 15 shall only apply to gas car-riers when the type o loading and con-tainment systems allow sae retention onon-methane VOC on board, or their saereturn ashore.

The revision o Annex VI to MARPOLwhich will enter into orce in July 2010 willalso require crude oil tankers above 400grt to implement and keep onboard a VOCmanagement plan upon entry into orcedate o the revision. The plan has to be ap-proved by the Administration (i.e. the Class

Societies provided they have been Autho-rised to do so on behal o the respective

Administrations).

Volatile Organic Compounds

Volatile organic compounds (VOC) Emissions rom tankers can be regulatedby each party to Annex VI in specifc ports and terminals. IMO shall benotifed o such requirements min. 6 months beore they enter into orceand IMO is to circulate a list o such ports and terminals. The list shall includethe notifcation date on which the requirements become eective, as well asspecifcation o size o tankers and which cargoes that requires vapouremission control systems.

The plan is to be ship specic, is to takeinto account Guidelines developed byIMO and shall as a minimum contain theollowing:n Provide written procedures or minimiz-

ing VOC emissions during the loadingand sea passage.

n Give consideration to the additional VOCgenerated during Crude Oil Washing;

n Identiy a person responsible or imple-menting the plan.

n Be written in the working language o themaster and ocers and, i the workinglanguage is not English, French or Span-ish, include a translation to one o theselanguages.

DNV and Intertanko have developed amodel VOC management plan. The guide-line was submitted to IMO Bulk Liquid &Gases sub-committee 13th meeting. Upontheir review the guideline will be issued as

a joint publication to DNV clients.


21/32

1. INTRODUCTION

MARPOL 73/78 ANNEX VI 21

7. REGULATION 16

Incineration o Annex I, II and III cargo resi-dues, o PCBs (Polychlorinated biphenyls),o garbage containing more than traceso heavy metals and o rened petroleumproducts containing halogen compounds isalways prohibited.

For all the ships to which Regulation 16 willbe applicable,also incineration o exhaustgas cleaning systems residues will be alwaysprohibited.

Onboard incineration outside an incinera-tor is prohibited except that sewage sludgeand sludge oil rom oil separators may beincinerated in the main or auxiliary powerplants and boilers when the ship is not inports, harbours and estuaries.

Incineration o PVCs (polyvinyl chlorides)is prohibited except in shipboard incinera-tors type approved according to resolutions

MEPC 59(33) or MEPC 76(40).

Monitoring o combustion fue gas outlettemperature shall be required at all timesand waste shall not be ed into a continu-ous-eed shipboard incinerator when thetemperature is below the minimum allowedtemperature o 850C. For batch-loadedshipboard incinerators, the unit shall bedesigned so that the temperature in thecombustion chamber shall reach 600C

within 5 minutes ater start-up and willthereater stabilize at a temperature notless than 850 C. It must be ensured that

the incinerators fue gas outlet tempera-ture monitoring system is operational.

All incinerators installed on a ship con-structed on or ater 1 January 2000 orincinerator that is installed on board a shipon or ater 1 January 2000 shall be typeapproved in accordance with Resolution

MEPC 76(40) giving the IMO standardspecication or shipboard incinerators. Forsuch incinerators a manuacturers operat-ing manual is required.

Shipboard Incineration

Incineration o Annex I, II and III cargo residues, o PCBs (Polychlorinatedbiphenyls), o garbage containing more than traces o heavy metals ando refned petroleum products containing halogen compounds is alwaysprohibited.

For all the ships to which Regulation 16 will be applicable, also incineration oexhaust gas cleaning systems residues will be always prohibited.


22/32

1. INTRODUCTION

22 MARPOL 73/78 ANNEX VI

8. REGULATION 18

8.1 GENERALPreviously uel oil quality was primarily amatter between owners/managers (andcharterers) and suppliers. With the entryinto orce o Annex VI o MARPOL 73/78,19 May 2005, Fuel Oil Quality became astatutory matter.

The revised MARPOL Annex VI adoptedon 10 October 2008 also contains a addi-tional provision on Fuel Oil Availability.

In addition to requirements controllingthe Sulphur Oxide (SOx) and ParticulateMatter emissions rom ships by limitingthe sulphur content o oil uel, Annex VIcontains requirements preventing theincorporation o potentially harmul sub-stances, and in particular waste streams(e.g. chemical waste), into uel oils.

Regulation 18 specically requires thatuel oil supplied to ships is to be ree rominorganic acids or chemical wastes thatcould jeopardise the saety o the ship,be harmul to ships personnel, or whichwould contribute overall to additional airpollution. The addition o small amountso additives intended to improveperormance is however permitted.

IMO has asked ISO to review the currentedition o ISO 8217 marine uel oil speci-cation and give recommendations to IMO

on the specic parameters related to airquality, ship saety engine perormanceand crew health as well as specic values asappropriate. The ISO working group wasre-established in the spring o 2008 and willconsider the list o parameters and appro-priate limits and report back to IMO. Thework in ISO will be ast-tracked by issuing aPublic Available Standard (PAS) that willbe published in time or the entering intoorce 1 July 2010. It is expected that limitsrelated to Ignition quality (HFO), AcidNumber, Sodium, Lubricity (MGO/MDO)and Hydrogen Sulphide will be included in

these recommendations to IMO.

The requirements to uel oil quality inRegulation 18 are similar to the general

8. Regulation 18 Fuel Oil

Availability and Quality

requirements o ISO 8217, although noreerences have been given by IMO to thesame. Accordingly one question raised hasbeen whether a uel ound o-spec com-pared to ISO 8217 table 2 test parameters,other than those limits specically given byMARPOL Annex VI is in violation o

Regulation 18. Consultations with certainport states indicate that this will likely notbe the regular case. However it has beenindicated that the general requirementso Regulation 18 may be enorced in casea ship is involved in accidents or near-accidents where uel quality is a suspectedcontributor.

8.2 OPERATIONAL ISSUESIt is important to note that elaborationand clarications relating to Regulation

18 are ound in the revised Guidelinesor the sampling o uel or determinationo compliance with Annex VI o MARPOL73/78(MEPC59 resolution). Althoughthis is a guideline, it is expected that theguideline will be used as requirements byport state inspectors. It should be notedthat Intertanko has issued a thoroughand useul guideline related to Annex VIwhich elaborates on the issues at hand.Further certain authorities such as Singa-pore developed their own Code o Prac-tice which should be ollowed in order tocomply with the Annex VI o MARPOL

requirements when bunkering inSingapore.

8.2.1 BUNKER DELIVERY NOTESIt is a requirement o Regulation 18 thatany uel oil or combustion purposesdelivered to and used onboard shall berecorded by means o a Bunker DeliveryNote (BDN). This implies that a bunkerdelivery note shall be presented or everybarge delivery and every grade.

Bunker Delivery Notes are required to

contain all specic inormation as ollows:n Name and IMO number o receiving shipn Portn Date o commencement o delivery

n Name, address, and telephone numbero marine uel oil supplier

n Product name (s)n Quantity in metric tonsn Density at 15 oC, kg/m3 *n Sulphur content (% m/m) **

A declaration signed and certied by the

uel oil suppliers representative that theuel oil supplied is in conormity with theapplicable subparagraph o regulation14.1 or 14.4 and regulation 18.3 o this

Annex. (I.e. that the uel supplied has asulphur level below:4.50% m/m prior to 1 January 20123.50% m/m on and ater 1 January 20120.50% m/m on and ater 1 January 2020and that the uel is ree rom inorganicacid, does not include any added sub-stance or chemical waste which either

jeopardises the saety o ships, adversely

aects the perormance o the machin-ery, is harmul to personnel, or contrib-utes overall to additional airpollution***).

Further, the revised MEPC Resolutionrecommends that the seal number o theassociated MARPOL 73/78 Annex VI uelsample is included in the BDNs orcross-reerence purposes.

The BDNs are to be kept on board andreadily available or inspection at all times.It shall be retained or a period o three

years ater the uel oil has been deliveredon board.

* Fuel oil shall be tested in accordancewith ISO 3675:1998 or ISO 12185:1996.

** Fuel oil shall be tested in accordancewith ISO 8754:2003.

*** IMO has asked ISO review to the ISO8217 marine uel quality specication tobe completed by 1 July 2010. This mayresult in specic parameters and limits



8. REGULATION 18

8.2.2 MARPOL 73/78 ANNEX VI FUEL OILSAMPLES (RETAINED SAMPLE)Regulation 18 requires that every BDNis to be accompanied by a representativesample o the uel oil delivered, taking into

account the revised Guidelines or thesampling o uel or determination o com-pliance with Annex VI o MARPOL 73/78reerred to as retained sample.

The sample is to be sealed and signed bythe suppliers representative and the masteror ocer in charge o the bunker opera-tion on completion o bunkering opera-tions, and retained under the ships controluntil the uel oil is substantially consumed,but in any case or a period o not lessthan 12 months rom the time o delivery.

Although the resolution species that the

volume o the sample bottle should be noless than 400 ml, due to potential need orrepetitive testing, DNV Petroleum Servicesrecommends that the sample volume is notto be less than 750 ml

It should be noted that the practical pur-pose o the retained sample is to enableport states to veriy the sulphur content othe uel, as well as to veriy that the uel oilquality is in accordance with Regulation 18.

As Annex VI species that the Annex VIsample is not to be used or commercialpurposes, DNV Petroleum Services recom-mends that or ships already participatingin a uel oil quality testing scheme, the An-nex VI sample should be the ourth sampleIn case the supplier is not in a position tocomply with the procedural or documen-tary requirements stated in Annex VI o

MARPOL 73/78, the ollowing actionsshould be taken by the ships crew:n A Note o Protest highlighting non-com-

pliance with MARPOL Annex VI require-ments should be issued. The Note o

Protest is to be orwarded to the relevantPort State.

n Reerence to the Note o Protest is to bemade in the BDN (i supplied).

n I the supplier does not provide aMARPOL sample, the ships crew shouldpropose their own representativeMARPOL Annex VI sample to be takenthe ocial MARPOL Annex VI sample.The crew should request counter-signingand sealing by the supplier. I this isaccepted by the supplier, a Note oProtest should not be deemed necessary.



8.2.3 SAMPLING PROCEDURESNote that the revised MEPC Resolutionspecies in detail that the uel sample isto be obtained at the receiving ships inletbunker maniold and is to be drawn con-

tinuously throughout the bunker deliveryperiod. The term continuously drawn isspecied to mean a continuous collectiono drip sample throughout the delivery obunker uel. Sampling methods are urtherclaried as either; manual valve-settingcontinuous-drip sampler (equivalent toDNV Petroleum Services Line sampler),time-proportional automatic sampler, or

8. REGULATION 18

fow-proportional automatic sampler.Further the guidelines speciy that samplebottle labels are to contain the ollowinginormation:n Location at which, and the method by

which, the sample was drawn.n Date o commencement o delivery.n Name o bunker tanker/bunker installation.n Name and IMO number o the receiving

ship.n Signatures and names o the suppliers

representative and the ships representative.n Details o seal identication.n Bunker grade.

8.2.4 SAMPLE INVENTORYThe revised MEPC resolution also con-tains recommendations on sample storagelocation. Specically the samples are to bekept in a sae storage location, outside the

ships accommodation and where person-nel would not be exposed to vapours whichmay be released rom the sample. Further,the retained sample should be stored ina sheltered location where it will not besubject to elevated temperatures, preerablyat a cool/ambient temperature, and whereit will not be exposed to direct sunlight.On tankers, the cargo sample locker wouldbe considered an adequate storage space.

Alternatively, a suitable locker (with open-ing ensuring adequate air fow) in an ad-equately ventilated area o the engine roomlocated at a sae distance rom ignition

sources and hot suraces may be considered

The above guideline also recommends thatthe ships master should develop andmaintain a system (e.g. log book) to keeptrack o the retained samples.

8.2.5 SUPPLIERS RESPONSIBILITYWhile most IMO conventions place ullresponsibility on the ships and shipown-ers, Regulation 18 also places responsibili-ties on the uel suppliers (uel oil qualitydeclaration, BDN and the Annex VI ueloil sample by continuous drip and at thereceiving ships maniold).

Annex VI o MARPOL 73/78 also containsinstruments to encourage port states toensure that suppliers ull their obliga-tions. Port states are thereore required to:n Maintain a register o local suppliers o

uel oil.n Require local suppliers to provide the

BDN and sample, certied by the ueloil supplier that the uel oil meets therequirements o regulations 14 and 18.

n

Require local suppliers to retain a copyo the bunker delivery note or at leastthree years or inspection and verica-tion by the Port State as necessary.

n Take action as appropriate against ueloil suppliers that have been ound todeliver uel oil that does not comply withthat stated on the Bunker Delivery Note.

n Inorm the Flag Administration oany ship receiving uel oil ound to benoncompliant with the requirements oregulations 14 or 18 o this Annex.

n Inorm IMO or transmission to Partiesto the Protocol o 1997 o all cases where

uel oil suppliers have ailed to meet therequirements specied in regulations 14 or 18.



8. REGULATION 18

However, despite the suppliers responsibil-ities and the instruments available, previousexperience rom Port State Controls indi-cates that it is advisable or owners/manag-ers themselves to ensure compliance. In

order to assist ships in ensuring that the op-erational requirements are met, it shouldbe considered to include clauses related toMARPOL 73/78 Annex VI compliance inbunker contracts and agreements with sup-pliers, as well as charter parties. For vesselstaking part in a uel testing scheme it couldbe advantageous to include a clause reer-ring to the 4th sample taken at the receiv-ing vessel maniold as the retained samplein case the supplier is not in a position tocomply with the procedural requirementsstated in Annex VI o MARPOL 73/78

8.2.6 FUEL OIL AVAILABILITYThere is a new provision on Fuel Oil Avail-ability in the revised Annex VI o MARPOLas ollows:1 Each Party shall take all reasonable

steps to promote the availability o ueloils which comply with this Annex andinorm the Organization o the availabil-ity o compliant uel oils in its ports andterminals.

2.1 I a ship is ound by a Party not to be incompliance with the standards or com-pliant uel oils set orth in this Annex,the competent authority o the Party isentitled to require the ship to:

- present a record o the actions taken toattempt to achieve compliance; and

- provide evidence that it attempted topurchase compliant uel oil in accor-dance with its voyage plan and, i it wasnot made available where planned, thatattempts were made to locate alternativesources or such uel oil and that despitebest eorts to obtain compliant uel oil,no such uel oil was made available orpurchase.

8.2.7 THIRD PARTY INSPECTIONSThe limited experience ater implementa-

tion has shown that, class surveyors, portstate inspectors and possibly also vettinginspectors have scrutinised onboard docu-mentation and records (e.g. sampling pro-cedures, change-over procedures, ER logbooks, BDNs, sample inventory log booksetc.), as well as the uel oil sample invento-ry. It should be noted that the United StatesCoastguard has recently issued policy letterGuidelines or ensuring compliance with

Annex VI o MARPOL 73/78 as Annex

VI became eective or the United Stateson 8 January 2009 or oreign fagged shipsoperating in U.S. waters as well as U.S. fagships. It is urther expected that a North

American Emission Control Area (U.S. and

Canada) could be a reality in 2012/2013.

Consultations with port states indicate thatanalysis o the onboard Annex VI sampleswill be carried out upon suspicion, e.g. incase o an accident or near accident. How-ever, the EU has proposed a more requenttesting o both onboard retained samplesand also tank samples to veriy compli-ance. It should also be noted that Dutchauthorities carry out such testing today toveriy compliance with existing low sulphurrequirements to marine distillates as well asSECA compliance. Testing o the representa-

tive sample should be done in accordancewith the Fuel Verication Procedure orMarpol Annex VI Fuel Oil Samples (Appen-dix VI o the revised MARPOL Annex VI).

Based on experiences with port stateinspectors scrutinising o oil record booksrelated to sludge and oily bilge waterinventory and balance, owners and man-agers could expect that similar practicecould be applied with respect to high-



8. REGULATION 18

For urther inormation, please contact

Annex VI in general:DNV, Cargo Handling, Piping Systems, Marpol and Gas Carriers ([email protected] and [email protected])

NOx and engine related inquiries:DNV, Section or Machinery Systems ([email protected]) DNV, Section or Machinery ([email protected])

SOx and uel related inquiries:DNV, Cargo Handling, Piping Systems, Marpol and Gas Carriers ([email protected])DNVPS, DNV Petroleum Services([email protected])

sulphur and low-sulphur uel movementsand consumption when operating inSECAs or the EU (bunker quantity isrequired specied in BDNs). Accordingly,it is advisable that crews are instructed and

trained to thoroughly veriy that the sup-plied quantity is in accordance with thatspecied in the BDNs, or alternatively thatindependent bunker quantity surveyors arehired or this purpose.

It need be emphasised that currently, theAnnex VI sample is only required to beretained under ships control and nottested. However, uel oil quality testingrepresents a pro-active approach, both interms o veriying compliance prior to anyport state control, and more importantlyas a saeguard against the adverse eects o

poor uel oil quality in combustionmachinery. Third parties may also considertest reports rom a reputable andaccredited independent testing laboratory asequivalent to additional testing o onboardsamples.

It should also be noted that the proceduresand documentation o DNV PetroleumServices uel oil quality testing scheme willbe in ull compliance with Annex VI oMARPOL 73/78 and the associated revisedMEPC Resolution. Further participationin such a scheme ensures that ships haveaccess to compliant sampling equipment(sample bottles, seals, line samplers andcubitainers). It urther gives ship operatorsaccess to DNV Petroleum Services bunkeralerts and bulletins as well as comprehen-sive uel oil quality statistics, all o which

will provide ship operators with valuableassistance in their bunker management.



Appendix 1



APPENDIX 1

Appendix 1

Owners Annex VI ChecklistThe ollowing table is a proposed checklist or Owners preparing or theimplementation o Annex VI o MARPOL 73/78 and the initial survey to obtainthe required International Air Pollution Prevention (IAPP) Certifcate.

Item

Regulation 6

When do I need to carry outInitial Survey?

Regulation 12Ozone Depleting Substances

(ODS)

Regulation 13

NOx Certication

Regulation 14

Sulphur Oxides SOx

Comment

Prior to delivery rom yard

n Halonsn CFCsn

HCFCs

n Engines greater than 130kW onships keel laid on or ater:- 1 January 2000; or- 1 January 2011; or- 1 January 2016; or

n Engines greater than 5000 kW and90 litres cylinder displacementinstalled in ships keel laid between1 January 1990 and 1 January 2000;or

n Engines greater than 130kW whichundergoes a major conversion,including replacements by newengines, on or ater 1 January 2000

Max. Sulphur 4.50 % m/m prior to1 January 2012

Max. Sulphur 3.50 % m/m on orater 1 January 2012

Max. Sulphur 0.50 % m/m on or

ater 1 January 2020

Tasks

DNV will perorm initial IAPP surveyon request rom yard

1. Prepare lists o ODSs or all ships2. Prepare instructions or handling

ODSs

1. Get an overview o engines requir-ing NOx Certication

2. Check that these engines arecertied and have the necessarydocumentation; EIAPP Certicateand Technical File

(See also fow-sheet at page 5 o maindocument)

Prepare instructions



APPENDIX 1

Item

Regulation 14SECAs

Regulation 15

VOC

Regulation 16

Shipboard Incineration

Regulation 16Type approved incinerator

Regulation 18

Fuel Quality

Comment

Max. Sulphur 1.50 % m/m prior to1 July 2010

Max. Sulphur 1.00 % m/m on orater 1 July 2010

Max. Sulphur 0.10 % on or ater

1 January 2015

Tankers only, operating at VOCdesignated ports

VOC management Plan or shipsunder Regulation 15

Restrictions on Incineration

Incinerators installed on or ater1 January 2000 to be typeapproved according to resolutionMEPC.76(40)

Requirements or uel quality, docu-mentation and sample storage

Tasks

1. Can all engines and boilers operateon low sulphur uel?

2. Plan bunker strategies3. Calculate Fuel Changeover Time

or all ships.Prepare operational and loginstructions.

Certied VOC return system?

Prepare instructions

1. Gets an overview o incineratorsrequiring type approval.

2. Check that Certicate and opera-tion manual is available

1. Prepare routines or ling o Bun-ker Delivery Notes

2. Prepare instructions or takingsamples

3. Prepare acilities or sample storage.


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DNV (Det Norske Veritas)

NO-1322 Hvik, Norway

Tel +47 67 57 99 00

www.dnv.com

DetNorskeVeritasAS

100/6-2009

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rGraphicServices0906-016