DNV Marpol Annex VI Guide Lines LSHFO Positions
DNV Marpol Annex VI Guide Lines LSHFO Positions
DNV Marpol Annex VI Guide Lines LSHFO Positions
Issued
21 February 2005
Annex VI in general:
DNV, Cargo Handling, Piping Systems, Marpol and Gas Carriers
Design and production: DNVE Graphic Services 0502-029
(MTPNO880@dnv.com)
1. INTRODUCTION ............................................................................................................................ 1
2. ANNEX VI IN GENERAL................................................................................................................ 1
2.1 APPLICATION FOR SHIPS KEEL-LAID BEFORE 1 JANUARY 2000 .................................................... 2
3. REGULATION 12 – OZONE DEPLETING SUBSTANCES........................................................... 2
4. REGULATION 13 – NITROGEN OXIDES (NOX).......................................................................... 3
4.1 REGULATIONS/DEFINITIONS FROM ANNEX VI ............................................................................. 3
4.2 CERTIFICATION AND ONBOARD VERIFICATION ............................................................................. 4
4.2.1 Engine parameter check method....................................................................................... 6
4.2.2 Simplified measurement method ....................................................................................... 7
4.2.3 Direct measurement and monitoring method .................................................................... 7
4.3 SPARE PARTS AND SPARE PARTS POLICY ................................................................................... 8
4.4 SURVEYS AND INSPECTIONS ...................................................................................................... 8
4.5 ENGINES WITH EIAPP CERTIFICATES ISSUED BY ANOTHER COMPANY........................................... 9
APPENDIX 1 – Experience for operation of Engine and Boiler on Low Sulphur fuels.
APPENDIX 2 – Owners Annex VI Checklist
APPENDIX 3 – Status of Ratification (2005-02-02)
1. Introduction
MARPOL 73/78 Annex VI Regulations for the prevention of Air Pollution from ships
will enter into force on 19 May 2005, and includes many new aspects related to
design of ships, but even more related to operational issues.
The intention with this paper is to highlight some of the most important aspects of
MARPOL Annex VI for the guidance of Ship owners and Managers, as well as DNV
surveyors.
2. Annex VI in general
The adoption of MARPOL Annex VI has followed some years of debate within
organisations. At the same time IMO Technical code on the Control of Emissions of
Nitrogen Oxides from Marine Diesel Engines was adopted. MARPOL Annex VI and
the Technical Code have retroactive requirements for diesel engines 130 KW and
above installed on ships keel-laid on or after 1 January 2000, and Incinerators
installed onboard on or after 1 January 2000.
MARPOL Annex VI will apply to all ships, fixed and floating drilling rigs and other
platforms from 19 May 2005, but the certification requirements are depending on size
of the vessel and time of periodical survey.
Ships of 400 gross tons and above engaged in international voyages involving
countries that have ratified the conventions, or ships flying the flag of those countries,
are required to have an International Air Pollution Prevention Certificate (IAPP
Certificate).
This certificate must be on board at delivery for a ship constructed (keel laid) after 19
May 2005.
For ships constructed before this date, the IAPP certificate must be on board at the
first scheduled dry-docking after 19 May 2005, but not later than 19 May 2008.
The IAPP certificate will be issued following an initial survey carried out by the Flag
Administration or by a recognised organization (e.g. Det Norske Veritas) on behalf of
the Flag Administration, confirming compliance with MARPOL Annex VI. For ships
with the flag of an Administration that have not yet ratified Annex VI, a Certificate of
Compliance with Annex VI may be issued by DNV.
Annex VI also requires diesel engines (as described above) to carry individual
certificates with regard to NOx emissions, named Engine International Air Pollution
Prevention (EIAPP) Certificates.
Annex VI requires that every ship of 400 gross tonnage or above and every fixed and
floating drilling rig and other platforms shall be subject to the following surveys:
- An initial survey before the ship is put into service or before the IAPP
Certificate is issued for the first time.
- Periodical surveys at intervals specified by the Administration, but not
exceeding five years.
- A minimum of one intermediate survey during the period of validity of the
certificate.
1
In the case of ships of less than 400 gross tons, the Administration may establish
appropriate measures in order to ensure that Annex VI is complied with.
The Administration shall arrange for unscheduled inspections during the period of
validity of the certificate. If the Administration establishes mandatory annual surveys,
these unscheduled inspections shall not be obligatory, and for this purpose DNV has
so far considered that all Administrations will apply a system with mandatory annual
surveys.
Annex VI has requirements to the following main issues, which will be highlighted
more in detail in this paper.
- Regulation 12 - Emissions from Ozone depleting substances from refrigerating
plants and fire fighting equipment.
- Regulation 13 - Nitrogen Oxide (NOx) emissions from diesel engines
- Regulation 14 - Sulphur Oxide (SOx) emissions from ships
- Regulation 15 - Volatile Organic compounds emissions from cargo oil tanks of
oil tankers
- Regulation 16 - Emissions from shipboard incinerators.
- Regulation 18 - Fuel Oil quality.
2
4. Regulation 13 – Nitrogen Oxides (NOx)
3
According to Annex VI the operation of applicable diesel engines are prohibited
except when the emission of nitrogen oxides from the engine is within the following
limits:
g
(i) 17,0 /kWh when n is less than 130 rpm
(-0,2) g
(ii) 45,0 × n /kWh when n is 130 or more but less than 2000 rpm
g
(iii) 9,8 /kWh when n is 2000 rpm or more
where n = rated engine speed (crankshaft revolution per minute) and the emission
of nitrogen oxides are calculated as total weighted emission of NO2
The table below illustrates the allowable NOx emissions from diesel engines:
18
g 16
NOx /kWh
14
12
10
8
6
4
2
0
0
130
200
400
600
800
1000
1200
1400
1600
1800
2000
Engine rated speed (RPM) 2200
In order to decide whether your engines need EIAPP certificates or not, we can
advise you to consider the following for your vessels and engines:
- Engine power output above 130 kW?
- Is the vessel constructed (keel laid) before or after 1 January 2000?
- Major conversion of the engine on or after 1 January 2000?
4
The flow chart above is meant as a general guidance indicating the necessary steps
for you to consider regarding the NOx requirements of Annex VI. Please note that the
flow chart is only concerning the NOx requirements to the diesel engines, and this is
also what the EIAPP certificate is covering.
If you find that your engines are required to carry an EIAPP certificate, but for some
reason they don’t have this, our advice is for you to approach the engine
manufacturer for further assistance.
The certification process includes an emission test for compliance with the NOx
requirements on the manufacturer’s test bed, and approval of the Technical File.
All certified engines are delivered with an individual Technical File that contains the
engine’s specifications for compliance with the NOx regulation, and the applicable
onboard verification procedure.
The NOx Technical Code opens for 3 different onboard verification procedures:
- Engine parameter check method
- Simplified measurement method
- Direct measurement and monitoring method
The engine’s Technical File is identifying its components, settings and operating
values that influences the exhaust emissions and these must be checked to ensure
compliance during surveys and inspections.
Ship owners or people responsible for vessels equipped with diesel engines required
to undergo an engine parameter check method shall ensure that the following
documentation is kept onboard and updated as applicable:
- Technical File including the onboard verification procedure.
- Record book of engine parameters for recording all of the changes made
relative to an engine’s components and settings. Also to include technical
documentation in case of modification of any of the engine’s designated
components.
- EIAPP certificate (Statement of Compliance) for each applicable engine.
6
The NOx-influencing components and settings depend on the design of the particular
engine, and shall be listed in the engine’s Technical File. The below list shows typical
NOx-influencing parameters:
- Injection timing
- Injection system components (nozzle, injector, fuel pump)
- Injection pressure
- Camshaft components (fuel cam, inlet- and exhaust cam)
- Valve timing
- Combustion chamber (piston, cylinder head, cylinder liner)
- Compression ratio (connecting rod, piston rod, shim, gaskets)
- Turbocharger type and build (internal components)
- Charge air cooler/charge air pre-heater
- Auxiliary blower
- NOx reducing equipment “water injection”
- NOx reducing equipment “emulsified fuel” (fuel/water emulsion)
- NOx reducing equipment “exhaust gas recirculation”
- NOx reducing equipment “selective catalytic reduction”
The actual Technical File of an engine may include less components and/or
parameters other than the list above, depending on the particular engine and the
specific engine design.
The simplified measurement method is to be performed more or less like the parent
testing on the test-bed, but simplifications according to the NOx Technical Code 6.3
are accepted.
However, the testing shall be performed in accordance with the applicable test cycle
as specified in the engine’s Technical File. This involves full load running of the
engine for about 20 minutes, and will in most cases require a test trial.
Due to the possible deviations when applying the simplified measurement method, an
allowance of 10% of the applicable limit value is accepted for confirmation tests and
during periodical and intermediate surveys.
7
be kept onboard for at least three months for verification purposes. We would
however recommend maintaining the documents, on board or in shore office, for a
longer period of time.
To demonstrate the compliance by the direct measurement method, sufficient data
shall be collected to calculate the weighed average NOx emissions in accordance
with the NOx Technical Code.
It should be noted that the two methods that involve measuring of the exhaust
emissions do not include any kind of identification markings of the NOx-influencing
components.
All the components listed are to be fitted with identification markings according to the
Technical File. Please note that these markings may not be the same as the article
no’s usually found on the engine components.
DNV, on behalf of the Flag Administration, can not accept any other markings than
those stated in the Technical File. Manufacturer’s producing engines on licensee
from an engine designer usually have their own Id Numbers on the engine
components. Since these numbers may differ from the designer’s Id Numbers, it may
be advisable to ask the licensee to also include the designer’s Id No’s in the
Technical Files.
In order to make the purchasing easier, it could be an idea to keep a copy of the
Technical Files in the purchasing section.
There may be situations where the engine maker comes up with a new design for
one of the NOx-influencing components, with a different Id No from what’s stated in
the Technical File. The new design should then be approved by the Administration
(or DNV on behalf of a Flag Administration when authorised) and the change is to be
documented in the “Record book of engine parameters”. The same is applicable for
all other changes the engine may be approved for during its lifetime.
8
- Annual Surveys (or a Flag Administration may instead implement
unscheduled inspections as an alternative to Annual surveys)
9
5. Regulation 14 - Sulphur Oxides (SOx)
5.1 General
Upon entry into force of Annex VI to MARPOL on the 19 May 2005, the sulphur oxide
(SOx) emissions from ships will be controlled by setting a limit of 4.5% on the sulphur
content of marine fuel oils.
Further, a limit of 1.5% on the sulphur content of marine fuel oil will apply in
designated SOx Emission Control Areas (SECAs). IMO has currently agreed on the
designation of two SECA’s as per below. The first designated SECA is the Baltic Sea
Area which has been agreed that will enter into force on the 19 May 2006.
The second area, the North Sea Area and the English Channel has also been
agreed, but due to the amendment process in IMO, it has been indicated that it will
not enter into force as a SECA until 19 November 2007. It is expected that further
SECA’s will be designated in the future and IMO has set forth certain criteria for
designating such SECA’s. It should however be noted that the amendment process
within IMO may take considerable time.
For the sake of good order, it should be noted that the limitations in sulphur content
applies to all fuel oils (heavy fuel oils, marine diesel oils and gas oils) and regardless
of use on board (i.e. in combustion engines, boilers, gas turbines etc.).
Indication of SECA’s
Currently, the average sulphur content in fuel oils is in the region of 2.7%. Results of
the comprehensive number of fuel samples tested by DNV Petroleum Services
indicate that only 0.2% of the fuel oils tested have a sulphur content exceeding the
required 4.5%. However, it also indicates that only 4% of the fuel oils supplied today
have a sulphur content of 1.5% or less.
It has been estimated that the low sulphur fuel oil demand in the SECA’s will be in the
region of 14-20 million tons per year, of which approximately 0.7 million tons per year
is available in North West Europe today.
10
While certain owners with a high environmental profile currently have a sulphur limit
of 1.5% in their fuel specifications, the sulphur content of the fuel is generally
dependent on the composition of the crude oil from which it is refined. Increasing the
output of low sulphur fuel oil can be obtained through the following:
- Refining of naturally occurring low sulphur crude oils.
- Re-direct/blend inland grade fuel to the marine fuel market.
- Re-blending of residual fuel oils down to the required specification.
- Residue de-sulphurisation (Note that large scale investments in residue de-
sulphurisation units are not expected to be made until a substantial price
difference between high and low sulphur fuels are achieved).
It is generally acknowledged that the above will lead to increased prices for low
sulphur fuel oils and a price hike from 25 to 100 USD/ton has been indicated
depending on method of production and market availability/demand.
Although it has been indicated that the total world wide availability of low sulphur fuel
is adequate with the current SECA’s and associated low sulphur limit (1.5%), it is
highly uncertain as to whether the availability will be adequate in world wide ports. It
should further be noted that currently, low sulphur fuel is in general only available to
operators with contract agreements with Oil Majors. Future spot availability is thus
dependent on the developments in market demand and price after entry into force of
SECA’s.
11
Development of a type approval standard for such systems is ongoing in IMO. The
current available abatement technology is based on seawater scrubbing principles.
There is however a few concerns related to these types of scrubber type systems:
- Annex VI states that port states may prohibit discharge of scrubber effluent
overboard in ports within SECA’s unless it can be documented that the effluent
complies with criteria set by that port state. A mitigating measure is installation
of filtration/treatment systems.
- It has been indicated that conventional scrubber technology may be struggling
to meet the emission criteria at high exhaust gas discharge flows.
- It has been indicated that there is a risk of blue-sheen originating from the
scrubber overboard discharge. Although, not necessarily constituting an
environmental hazard, the mere risk of such occurrences is to some operators
unacceptable.
- There are space considerations in the engine room and more specifically the
funnel. Although it has been indicated that the more advanced scrubber types
can replace standard silencers, the associated piping systems may represent
a challenge. Pressure drop in scrubbers has also been indicated as a
limitation, particular in way of main engines uptakes.
- Tanker owners have had mixed experiences with corrosion of inert gas
scrubbers and associated piping systems.
- The EU has been reluctant to accept scrubbers. However, in the latest
proposed amendments to the EU directive, they have opened for “trials of ship
emission abatement technologies”. Based on such trials they have indicated
that they may accept abatement technology as an equivalent to low sulphur
fuel. Note that EU has indicated that it will develop criteria for resulting waste
streams in their ports.
Despite the indicated installation costs of 1-2 mill USD, future legislation, and
elimination of the problems associated with low sulphur fuel bunker management and
operation, may lead to exhaust gas cleaning systems becoming a cost-beneficial
alternative worthwhile exploring.
12
5.2 EU Directive 1999/32/EC with proposed amendments
In connection with MARPOL Annex VI one cannot disregard ongoing low-sulphur
developments in the EU.
EU directive 1999/32/EC has been amended a number of times, and in force today is
the following:
- Member states to ensure that Marine Distillates used within their territory from
July 2000 do not exceed 0,2% Sulphur (0,1 % from January 2008).
In other words, ships must ensure that if they are using Marine Distillates in
EU territory (territorial waters including seas 12 nautical miles from shore and
inland waterways), their sulphur content is below 0,2%.
Marine Distillates in this context include both marine gas oils and marine
diesel oils (DMX, DMA, DMB and DMC). As far as DNVPS has been informed
this requirement is currently only enforced by Dutch Authorities
- A 1.5% sulphur limit for fuels used by all ships in the Baltic Sea, North Sea &
Channel in accordance with the implementation dates of Annex VI to MARPOL
(i.e. starting in 19 May 2006 for the Baltic Sea Area). As of 19 May 2006, EU
member states shall ensure that the sulphur content in marine diesel oils (ISO
8217 grades DMB and DMC) supplied within their territory does not exceed
1.5%.
- A 1.5% sulphur limit for fuels used by passenger vessels on regular services
between EU ports as of 19 May 2006.
- A 0.1% sulphur limit on fuel used by inland vessels and by seagoing ships at
berth in EU ports. The Council agreed this limit delayed until 1 January 2010,
to allow single-fuel ships time to adapt their fuel tanks.
- A further two year delay has been proposed given to 16 unifuel (vessels using
heavy fuel oil for both main and auxiliary engines) ferries serving the Greek
islands.
- As of 1 January 2010, EU member states shall ensure that the sulphur content
in marine gas oils (ISO 8217 grades DMX and DMA) supplied within their
territory does not exceed 0.1%.
- For ships arriving from outside the EU, the requirement need only be complied
with upon leaving the EU port of call.
13
cases where chemical waste has been introduced in such fuel. In light of the required
demand for low sulphur fuel oils, there have also been concerns over the potential
increase of sulphur content in high sulphur fuel oils.
The current problems with incompatibility between heavy fuel oils, and between
heavy fuel oils and marine diesels are not expected to disappear with increased
demands for low sulphur heavy fuel oils (excessive sedimentation/sludging and
separator and filter problems). Considering the differences in cost, some owners are
installing an additional set of service and settling tanks for low sulphur fuel oils.
Additional bunker tanks are considered installed for the same reasons. Such
measures would also simplify change-over procedures and bunker management.
Inadequate availability of low sulphur heavy fuel oils may force owners to increase
the consumption of low sulphur diesel oils within SECA’s. Owners will therefore have
to assess whether the diesel oil tank capacity needs to be upgraded. Taking into
account the current EU requirements to use of ultra low sulphur distillates within its
territories, and not to mention the proposal for ultra low sulphur fuel at berth in EU
ports, there is also an issue of whether to allocate or convert existing fuel tanks to
tanks for marine gas oil.
The differences in cost between low and high sulphur heavy fuel oils as well as
between heavy fuel oils and low sulphur diesel oils, has led some owners to consider
separating fuel treatment and service piping systems. This is increasingly important
with respect to potential requirements to use of ultra low sulphur fuels in EU ports
(Auxiliary engines and boilers).
In order to facilitate safe and simple change-over, the installation of separate marine
gas oil/diesel oil supply piping with heating capabilities should be considered.
(While separate direct diesel oil supply lines are often arranged for auxiliary diesel
engines, the same is less frequently encountered for boilers and main engines.)
14
The below serves as examples of proposed modifications regarding duplicated heavy
fuel oil service and settling tanks and piping systems.
H.F.O.
H.F.O
Slop
H.F.O. tank
settl. H.F.O. H.F.O.
tank no 2 Service Settling
Tank Tank
P Room
no.1 & 2 no.1
Slop
tank
H.F.O H.F.O.
The below shows the arrangement of fuel oil tank piping arrangement as per the
optional DNV class notation FUEL, which enables handling of different fuel qualities.
Overflow pipe
H.F.O
Low
Service Settling H.F.O. H.F.O.
Sulpur
Tank tanks, storage storage
Settling Service Tank
12 hrs 24 hrs tank tank
To tank tank To
engines
MCR MCR engines
F.O. heaters
Fuel oil
purifier
15
5.3.2 Change-over procedures
Change-over between heavy fuel oil grades is standard practice and so is change-
over from heavy fuel oil to marine diesel oil in connection with e.g. dry-dockings.
Change-over from heavy fuel oil to marine gas oil is however completely different and
clearly not common standard. If gas oil is mixed in while the fuel temperature is still
very high, there is a high probability of gassing in the fuel oil service system with
subsequent loss of power.
It should be acknowledged that the frequency and timing of such change-over may
increase and become far more essential upon entry into force of SECA’s and the EU
proposed amendments
Additionally, the time, ship’s positions at the start and completion of change-over to
and from 1.5% fuel oil must be recorded in a logbook (e.g. ER log. book), together
with details of the tanks involved and fuel used. It can be anticipated that the same
will be applicable with respect to the EU proposal upon entry into force.
5.3.4 Charts
Due to the introduction of SECA’s and associated change-over procedures, it need
be ensured that onboard charts are upgraded with respect to SECA borders.
16
6. Regulation 15 – Volatile Organic Compounds
Emissions of volatile organic compounds (VOCs) from tankers may by each party to
Annex VI be regulated in its ports and terminals. Such requirements shall be given in
a list published by IMO. The list shall also specify size of tankers, and which
cargoes, that requires vapour emission control system.
All tankers which are subject to vapour emission control in accordance with above list
shall be provided with an approved vapour collection system, and shall use such
system during the loading of such cargoes.
Existing tankers which are not fitted with vapour collection systems may be accepted
for a period of three years after the terminal was included in the above list.
DNV has for many years had class notations VCS 1 and 2 for vapour control systems
complying with IMO Guidelines (MSC/Circ.585), and USCG regulations. It may be
noted that a vessel complying with VCS- 1 or 2 will comply with regulation 15.
This regulation shall only apply to gas carriers when the type of loading and
containment systems allow safe retention of non-methane VOCs on board, or their
safe return ashore.
Monitoring of combustion flue gas outlet temperature shall be required at all times
and waste shall not be fed into a continuous-feed shipboard incinerator when the
temperature is below the minimum allowed temperature of 850°C. For batch-loaded
shipboard incinerators, the unit shall be designed so that the temperature in the
combustion chamber shall reach 600°C within 5 minutes after start-up. It must be
ensured that the incinerators' flue gas outlet temperature monitoring system is
operational.
17
8. Regulation 18 – Fuel Oil Quality
8.1 General
While fuel oil quality is currently primarily a matter between owners/managers (and
charterers) and suppliers, it will under Annex VI of MARPOL 73/78 also become a
statutory matter.
In addition to requirements limiting the sulphur content of oil fuel, Annex VI contains
requirements preventing the incorporation of potentially harmful substances, and in
particular waste streams (e.g. chemical waste), into fuel oils.
Regulation 18 specifically requires that fuel oil supplied to ships is to be free from
inorganic acids or chemical wastes that could jeopardise the safety of the ship, be
harmful to ships' personnel, or which would contribute overall to additional air
pollution. The addition of small amounts of additives intended to improve
performance is however permitted.
Incidentally, the requirements to fuel oil quality in Regulation 18 are more or less
identical to the general requirements of ISO 8217, although no references are made
to the same. Accordingly one question raised has been whether a fuel found off-spec
compared to ISO 8217 test parameters is in violation of Regulation 18. Consultations
with certain port states indicate that this will likely not be the case. Instead it has been
indicated that Regulation 18 may be enforced in case a ship is involved in accidents
or near-accidents where fuel quality is a suspected contributor.
Bunker Delivery Notes are required to contain all specific information as follows:
- Name and IMO number of receiving ship
- Bunkering Port
- Date of commencement of bunkering
- Name, address, and telephone number of marine fuel oil supplier
- Product name
- Quantity (metric tons)
- Density at 15 oC (kg/m3)
- Sulphur content (% m/m)
18
- A declaration signed and certified by the fuel oil supplier's representative that
the fuel oil supplied is in conformity with regulation 14 and 18 (I.e. that the fuel
supplied has a sulphur level below 4.5% and that the fuel is free from
inorganic acid, does not include any added substance or chemical waste
which either jeopardises the safety of ships, adversely affects the performance
of the machinery, is harmful to personnel, or contributes overall to additional
air pollution).
The BDN’s are to be kept on board and readily available for inspection at all times. It
shall be retained for a period of three years after the fuel oil has been delivered on
board.
The sample is to be sealed and signed by the supplier's representative and the
master or officer in charge of the bunker operation on completion of bunkering
operations, and retained under the ship's control until the fuel oil is substantially
consumed, but in any case for a period of not less than 12 months from the time of
delivery. Although MEPC.96(47) specifies that the volume of the sample bottle should
be no less than 400 ml, due to potential need for repetitive testing, Intertanko has
recommended that the sample volume is not to be less than 750 ml.
For the sake of good order it should be noted that the practical purpose of this
sample is to enable port states to verify the sulphur content of the fuel, as well as to
verify that the fuel oil quality is in accordance with Regulation 18.
As Annex VI specifies that the Annex VI sample is not to be used for commercial
purposes, DNV Petroleum Services recommends that for ship’s already participating
in a fuel oil quality testing scheme, the Annex VI sample should be the fourth sample
(in addition to the sample sent to laboratory for testing, suppliers sample and the
retained onboard sample). The reason is that it is considered an advantage to always
have an Annex VI sample onboard in case of port state controls.
19
sampler), time-proportional automatic sampler, or flow-proportional automatic
sampler.
Further the guidelines specify that sample bottle labels are to contain the following
information:
- Location at which, and the method by which, the sample was drawn
- Bunkering date
- Name of bunker tanker/bunker installation
- Name and IMO number of the receiving ship
- Signatures and names of the supplier’s representative and the ship's
representative
- Details of seal identification
- Bunker grade.
The above guideline also recommends that an inventory system is developed (e.g.
log book) to keep track of the retained samples.
20
declaration, BDN and the Annex VI fuel oil sample by continuous drip and at the
receiving ships manifold).
Consultations with port states indicate that analysis of the onboard Annex VI samples
will be carried out upon suspicion, e.g. in case of an accident or near accident.
However, the EU has proposed a more frequent testing of both onboard retained
samples and also tank samples to verify compliance. It should also be noted that
21
Dutch authorities carry out such testing today to verify compliance with existing low
sulphur requirements to marine distillates.
Based on experiences with port state inspectors scrutinising of oil record books
related to sludge and oily bilge water inventory and balance, owners and managers
could expect that similar practice could be applied with respect to high-sulphur and
low-sulphur fuel movements and consumption when operating in SECA’s or the EU
(bunker quantity is required specified in BDN’s). Accordingly, it is advisable that
crews are instructed and trained to thoroughly verify that the supplied quantity is in
accordance with that specified in the BDN’s, or alternatively that independent bunker
quantity surveyors are hired for this purpose.
Annex VI in general:
DNV, Cargo Handling, Piping Systems, Marpol and Gas Carriers (MTPNO880@dnv.com)
22
MARPOL 73/78 Annex VI Technical and Operational Implications
Appendix 1
Calcium compounds form the major part of the lube oil additives and has proven
efficient in terms of neutralising the sulphur oxides and thus prevent liner corrosion,
as well as providing adequate cylinder oil detergency. For many years BN 70-80
cylinder lube oils have been standard and used successfully in two-stroke engines.
However, experience has indicated that for long term operation on heavy fuel oils
with sulphur level below 1.5%, using such high base number lube oils may lead to
overdosing the combustion chamber with deposit generating calcium compounds.
Such deposit build-up on piston crowns and piston ring grooves have led to liner
scuffing.
The experiences with and the maximum time for operating on fuel oils with sulphur
content of 1-1.5% and high base number (BN) lube oils appears to vary substantially
depending on engine make, type, age, load profile, liner temperature, efficiency of
water mist catchers, installation of scraper rings, as well as cylinder lube oil feed rate
and lubrication system.
Calcium has been an important compound with respect to detergency and dispersion
of cylinder lube oils. I.e. despite the reduced calcium compound in low BN lube oils,
full detergency and dispersion capacity must be maintained. This implies that the
competence and experience of the lube oil supplier is a key factor in terms of
development of suitable low BN lube oils.
- Appendix 1-
MARPOL 73/78 Annex VI Technical and Operational Implications
For vessels that will operate on both high- and low sulphur fuel oils, considerations
have been made for installing an additional cylinder oil tank.
The below serves as an example of such an arrangement with one tank containing
BN 40 lube oil for low sulphur service and one tank for BN 70 for high sulphur fuel oil
operation.
For the sake of good order, the concerns related to lube oil BN versus fuel oil sulphur
level is primarily applicable for cylinder lubrication oils for two-stroke engines. Engine
manufacturers have indicated that for four-stroke engines, equal challenges related
to lube oils are not expected.
With respect to change-over procedures from heavy fuel oil to low-sulphur marine
diesel oil or gas oil, the high pressure fuel pumps were initially highlighted as the area
of concern.
The concerns was related to gassing and thermal shock to fuel pumps upon rapid
change-over from heated to non-heated fuels, with associated risk of fuel pump
damages.
Needless to say, to operate fuel pumps designed for a viscosity in the range 12-18
cSt on distillate fuels having a viscosity below 2 cSt and in violation of makers
instructions is of concern.
Firstly there is the potential for increased internal fuel pump leakage which may result
in reduced pump pressure, a reduction in delivered oil quantity, delayed injection and
impaired fuel atomization.
Secondly there are differences in ignition delays.
- Appendix 1-
MARPOL 73/78 Annex VI Technical and Operational Implications
Lastly, it should also be noted that experiences from the automotive industry raises
some concerns in terms of gasket material (nitrile rubber) compatibility with marine
gas oil or diesel with reduced aromatisation.
3. Boiler Operation
As previously indicated the low sulphur requirements apply also to main and auxiliary
boilers. Although operation on low-sulphur fuel oil is not assumed to represent a
problem, the operation on ultra low sulphur distillates could (ref. EU amendment
proposal).
Marine boiler burner installations have generally been designed for normal operation
on heavy fuel oils, and not very low viscosity fuel oils such as marine gas oils. (The
associated “pilot burners” required for main burner ignition exempted).
- Appendix 1-
MARPOL 73/78 Annex VI Technical and Operational Implications
The main concerns related to boiler operation on low viscosity marine gas oil and
diesel oils are as follows:
• Very likely damages to fuel pumps due to reduced viscosity and reduced
lubrication ability of low sulphur marine gas oils and diesels (typically below 4-
5 cSt). For pumps running continuously when the boiler is in stand by mode,
one could consider modifying the control system to stop pumps when running
on low viscosity marine gas oils and diesel oils.
• Potential problems with gassing of marine gas oil and diesel oil within a heated
boiler fuel oil service piping system during change-over. To avoid this, the
heaters need be bypassed and fuel pipe tracing shut-off. The alternative is to
convert the piping system to enable simplified and safe change-over (direct
feed).
• Potential increased smoking and local heating of boilers designed for high
density/viscosity heavy fuel oil, when operating on low density/viscosity marine
gas oil. This may require replacement of nozzles (pressure jet or atomizing
steam burners) and/or modifications to enable adjustment of fuel pump
pressures for different fuel viscosities.
• Although the marine gas oils are expected to evaporate rapidly in the
combustion space, increased frequency of ignition failures may validate the
implementation of automatic post-purging sequences (currently not a
requirement by all class societies). Further, it may be advisable to modify the
control system to avoid activation of main burner if the ignition flame is absent.
• The higher calorific value for marine gas oils compared to heavy fuel oils
should not have significant impact, but an adjustment of the air/fuel ratio may
be required to avoid increased smoking.
- Appendix 1-
MARPOL 73/78 Annex VI Technical and Operational Implications
Appendix 2
Owners’ Annex VI Checklist
The following table is a proposed checklist for Owners preparing for the
implementation of Annex VI of MARPOL 73/78 and the initial survey to obtain the
required International Air Pollution Prevention (IAPP) Certificate.
- Appendix 2-
MARPOL 73/78 Annex VI Technical and Operational Implications
- Appendix 2-
MARPOL 73/78 Annex VI Technical and Operational Implications
Appendix 3
Ratification status, MARPOL 73/78, Annex VI
Azerbaijan
Bahamas
Bangladesh
Barbados
Bulgaria
Cyprus
Denmark
Germany
Greece
Liberia
Marshall Islands
Norway
Panama
Samoa
Singapore
Spain
Sweden
United Kingdom
Vanuatu
The updated list showing state of ratification can be found on IMO’s web
pages (www.imo.org/home.asp) under ‘conventions’ and ‘status of
conventions by country’.
- Appendix 3-
MARPOL 73/78 Annex VI
Issued
21 February 2005
Annex VI in general:
DNV, Cargo Handling, Piping Systems, Marpol and Gas Carriers
Design and production: DNVE Graphic Services 0502-029
(MTPNO880@dnv.com)