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					Hellenic Forum

    Athens

  6 March 2007



  Peter M. Swift
 Hellenic Forum

  REVISION of
MARPOL ANNEX VI

  Air Emissions
   Peter M. Swift
         Governing Regulations
• MARPOL Annex VI entered into effect in 2005
• Baltic Sea - SECA from May 2006
• North Sea - SECA in November 2007
• Europe Sulphur Directive (1999 & Rev) governs
  inter alia emissions in port (0.1% S at berth)
• California (CARB) new regulations which took
  effect Jan 2007
• Various ports
  - local regulations on Ship Emissions, which are
  inhibiting future expansion/development
  - introducing differentiated port fees

    Of particular concern to tramp sectors, trading
    internationally, lifting bunkers in ports worldwide
         SECAs & CHANGE OVER AREAS
                             Source: http://maps.google.com/




Changeover
   Area
                           MAY
                           2006

             AUGUST 2007
                    IMO & UNILATERAL LEGISLATION
                    ON LOW SULPHUR MARINE FUELS
DATE         SHIP TYPE                    WHERE                           max. % S   REG.
19.05.2005   All                          Everywhere                         4.5     IMO
19.05.2006   All                          Baltic Sea                         1.5     IMO & EU
11.08.2006   All                          All EU Ports                               EU
                                          MGO (DMA and DMX)                  0.2
                                          MDO (DMB and DMC)                  1.5
11.08.2006   Passenger ships              EU                                 1.5     EU
1.01.2007    All aux. & diesel-electric   24 miles off California shore              CARB
             main engines on all ships    MGO (DMA grade)                     -
                                          MDO (DMB grade)                    0.5
11.08.2007   All                          North Sea & English Channel        1.5     EU

22.11.2007   All                          North Sea & English Channel        1.5     IMO

1.01.2010    All                          All EU ports                       0.1     EU
1.01.2010    Inland waterway ships        All EU inland waterways            0.1     EU
1.01.2010    All aux. & diesel-electric   24 miles off California shore              CARB
             main engines on all ships    MGO (DMA grade)                    0.1
1.01.2012    16 Greek ferries             Greek ports                        0.1     EU
             MARPOL Annex VI
        PROPOSALS FOR AMENDMENTS
• Lower limits for SOx & NOx emissions
• SECAs with lower S cap (1.0% or 0.5%)
• NOx emission limitation on existing
    engines
•   NECAs – NOx controlled areas
•   Restriction on Particulate Matters (PM)
    emissions
•   Further controls on VOC emissions
    from cargo oil tanks
                   INTERTANKO Process (1/2)
•   2005       Revision Process for Annex VI initiated
•   2005/6     INTERTANKO initiates committee review of Annex VI
•   2005/6     INTERTANKO Council discusses CARB, cold ironing et al

•   Apr/May    Intersessional Meeting called for November 2006
    „06        (Date clash with Nov ‟06 Council)

•   May ‟06    HKSOA announces (LS) Global SECA proposal

•   June ‟06   ExCom support principle of assessing a distillate only option,
               but refer to ISTEC

•   June ‟06   INTERTANKO “thinking” discussed with ICS and
               INTERCARGO

•   Jul ‟06    ICS invite INTERTANKO to Strategy Committee.
               INTERTANKO accepts highlighting current thinking re
               distillates, Subsequently INTERTANKO expresses same to
               RT Members et al. (Committee now scheduled for first
               meeting May 2007)
                INTERTANKO Process (2/2)
•   Sept ‟06   Draft INTERTANKO paper to intersessional passed to
               ICS, BIMCO et al

•   Sept ‟06   Joint meeting of ISTEC and INTERCARGO‟s CASTEC
               support case for distillates being tabled at IMO
               intersessional

•   Sept ‟06   ExCom agree to tabling of submission FOR
               DISCUSSION of distillate option. Copy of DRAFT
               submission passed immediately to RT colleagues, inviting
               comments and support.

•   Oct ‟06    INTERTANKO secures extension on filing and submits
               revised paper aimed at removing any ambiguities and to
               clarify purpose of submission; in particular stressing
               “suggestion” i.e. merits discussion

•   Nov ‟06    IMO Intersessional WG develops 4 options to be sent to
               MEPC
     INTERTANKO : Guiding Principles

Executive Committee (June 2006) – Principles for an
  INTERTANKO position:

   – ensure a solid platform of requirements
   – be realistic and feasible
   – seek a long term and positive reduction of air
     emissions from ships, and
   – contribute to a long term and a predictable
     regulatory regime
        Alternative Approaches
ITEMS FOR DISCUSSION include:
• Future production of low sulphur fuels & time
  frame
• Proving of / reliability of SCR and scrubber
  technologies
• Costs of extra bunker tanks & associated systems
• Costs of manifold modifications / sampling
• Costs of additional maintenance
• Means of disposing of wash water and scrubbed
  by-products
• Suitability of blended fuels
• Net benefits
• Future costs of low sulphur HFO/IFOs
         REVISION OF MARPOL ANNEX VI
           INTERTANKO SUGGESTION
FOR DISCUSSION
• Distillate fuels & 2-tiered S cap program:
  – from [2010], a maximum of 1.00% S content
  – for ships’ engines installed on and after [2015], a
    maximum [0.50]% S content


• A Global Sulphur Emission Control Area

• A New Fuel specification in Annex VI

• Simpler monitoring of compliance
              MDO – ADVANTAGES
                AIR EMISSIONS
• Applies to ALL existing ships/engines
• With no other measure, immediately
  reduces:
  – SOx emissions by 80% to 90%
  – PM emissions by 90%
  – NOx emissions by 10% to 15%
• Reduces fuel consumption with some 4%
  from ALL ships and thus CO2 emissions
• Facilitates further NOx reductions by in-
  engine modifications for IMO’s Tier II & III
           MDO – ADVANTAGES
             AIR EMISSIONS


• Engines designed for use of MDO only
  will accommodate further emission
  reductions over their entire life time

• Further regulatory reduction of air
  emissions from ships will be a function
  of better quality fuels and not limited
  by engine’s functional parameters
          MDO - ADDITIONAL BENEFITS

• ENVIRONMENTAL:
  – Reduces onboard fuel generated waste
  – No fuel heating/treatment = energy saving
  – ALL ships become “greener”
  – “Cleaner” waste & free of hazardous elements
    contained in residual fuels
  – Avoiding use of abatement technologies = no further
    additional waste & no need of further waste disposal
  – Potential bunker spills significantly less harmful
• SAFETY:
  – Less incidents with engine breakdowns caused by
    poorer quality fuels
  – No need of complex fuel change-over operations
  – No risk of incompatibility of blended fuels
  – Safer working environment for crews
           BLG Working Group Options: SOx

• A. Status Quo - No change
• B. Sulphur Emissions Control Area (SECA):
   – A global sulphur cap (unchanged or lower value)
   – SECA sulphur cap lowered in two tiers:
      • 1.0% in [2010]
      • 0.5% in [2015]
• C1. Change to distillate fuels (no SECA) :
   – Use of distillate fuels for all ships
   – A global sulphur cap in two tiers:
      • 1.0% in [2012]
      • 0.5% in [2015]
   – Include in MARPOL Annex VI the specification for
     the distillate fuel to be used by ships
• C2. Global cap – As C1 but allows use of residual fuel +
  scrubbers
          Challenges for IMO
  Reduce air emissions from ships

• What emissions
  - SOx, NOx, PM, VOCs ?
  - Later CO2 ?

• Where
  - Globally, Coastal regions ?

• Timing:
  - Phased, where/when/how ?
                   OPTIONS ?
 Reduce air emissions from ships
 AT WHAT COST AND WHO TAKES RESPONSIBILTY ?

• High sulphur residual with scrubbers

• Low sulphur residual

• Combination HS/LS residual

• MDO (Low sulphur)

• Other combination
                CO2 Emissions –
           Net Environmental Benefit
• High refinery CO2 emissions from de-
  sulphurisation of residuals
• High refinery CO2 emissions from MDO
  production/distillation
• Ship CO2 emissions lower with MDO due
  to lower fuel consumption
• Ship CO2 emissions lower with MDO
  since no need to heat residual fuels prior
  treatment & injection
• High CO2 emissions in manufacturing &
  operating scrubbers
               USA Proposal to BLG11

• SOx & PM – emission limits at [200]
  nm from shore as from 2011 [0.1% S
  cap]
• NOx standards for existing (pre-2000)
  engines - 20% reduction
• NOx for new engines:
  – Tier II       - 15% – 25% as from 2011
  – Tier III      - 80% only in defined areas
                       (NECAs) as from 2016
       Norwegian proposal to BLG11

• SOx: MDO 0.5% sulphur content in all
  ships by 2015
• NOx - slow speed engines (n < 130 rpm)
  and intermediate speed engines
  (130rpm < n < 1000 rpm) - in engine
  technology
  – a) Tier II: 20%
  – b) Tier III: 40%
• NOx on existing (pre 2000) slow speed
  engines – as by Tier I standard (17
  g/kWh)
           Other Propsals to BLG11

Japan

• No suggestions for measures related to SOx
  and PM emissions.
• NOx emissions - reduction by 80% by a
  combination of fuel quality, in engine
  technology and after treatment technology.

Sweden

• SOx & PM emissions - use of MDO with a lower
  sulphur content, most likely in a two tier step
  at dates to be established by IMO.
                What next?

• BLG : 16 -20 April 2007
• MEPC 56: 9-13 July 2007
• EU Commission to take stock of
  progress
  – Review of Sulphur Directive – 2008
  – Scope for Community measures to
    reduce ship emissions pursuant to
    Council’s conclusions - 2008
• US considers own legislation if IMO
  does not deliver
               What next?

• Annex VII – Scrubber / Catalytic
  Converter toxic waste handling

• Biomass – 20% reduction target for
  CO2

• Emissions trading – extended to
  shipping

• Sequestration of CO2
                Current position
• INTERTANKO encourages open debate on the options
  available to reduce damaging air emissions from ships
  and has sought to provide for discussion comprehensive
  solutions that are applicable on a global basis.
• We remain anxious that the current reviews around the
  world do not result in a mix of local and regional
  requirements that impose an onerous burden on
  international shipping, especially those engaged in
  tramp shipping - bunkering in and trading to ports around
  the world.
• We continue to stress the importance that any new
  requirements should take full account of all the
  operational and safety considerations, and should be
  assessed on the same basis - this latter should involve
  the cost and environmental implications of all the
  production, manufacturing, operating and waste
  handling aspects of the proposed system, as well as
  other practicalities with respect to introduction,
  fitting/retrofitting, etc.
           INTERTANKO
Encourages further discussion at Panel
   Meetings, Seminars and Council
              pre BLG

             NOTE:
 NO INTERTANKO submission to BLG

				
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