Understandng MARPOL Annex VI

7/22/2019 Understandng MARPOL Annex VI

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M A R P O LUnderstanding

A Guide for Ship Owners

Annex VI


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ourM I S S I O N

quality & environmentalP O L I C Y

The mission of the American Bureau of Shipping is to serve the public

interest as well as the needs of our clients by promoting the securityof life, property and the natural environment primarily through the

development and verification of standards for the design, construction

and operational maintenance of marine-related facilities.

It is the policy of the American Bureau of Shipping to be responsive

to the individual and collective needs of our clients as well as those

of the public at large, to provide quality services in support of our

mission, and to provide our services consistent with international

standards developed to avoid, reduce or control pollution to the

environment.

All of our client commitments, supporting actions, and services

delivered must be recognized as expressions of Quality. We pledge

to monitor our performance as an on-going activity and to strive

for continuous improvement.

We commit to operate consistent with applicable environmental

legislation and regulations and to provide a framework for

establishing and reviewing environmental objectives and targets.


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M A R P O L

Understanding

A Guide for Ship Owners

Annex VI

Copyright 2005American Bureau of ShippingABS Plaza16855 Northchase DriveHouston, TX 77060 USA


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ABS Guide to Shipowners Understanding MARPOL Annex VI 1

Introduction to MARPOL Annex VI

MARPOL Annex VI, Regulations for the Prevention of Air Pollution from Ships, is included within the1997 MARPOL Protocol which was adopted by the 1997 MARPOL Conference. The Annex will enterinto force 19 May 2005 having now met the ratification requirement a minimum of 15 states which

control a combined merchant gross tonnage of not less than 50 percent of the world total. The Annexwill apply to all ships of the flag States which have ratified the 1997 MARPOL Protocol. These countries,which currently represent the flag States of 60 percent of the world tonnage, are listed on the IMOwebsite (www.imo.org). Additionally, the Annex VI requirements will also apply to ships of non-signatoryStates while operating in waters under the jurisdiction of parties to the 1997 Protocol, as highlightedby the recent Singapore Administrations Shipping Circular No. 20 2004. In the case of those flagStates which ratify the 1997 MARPOL Protocol after the entry into force date, the Annex requirementswill take effect three months from the date of their signing.

Annex VI covers a number of different pollutants and/or shipboard operations which affect air quality:

Oxides of nitrogen (NOx)

Fuel oil quality

Oxides of sulfur (SOx)

Incinerators

Ozone depleting substances

Volatile organic compounds

Fixed and floating platforms, including drilling rigs and similar structures, are considered as ships forthe purpose of this Annex, except in respect of those emissions to the atmosphere resulting directly fromoperations solely related to their drilling, production or processing functions. These controls are in addi-tion to any imposed by the government which has jurisdiction over the waters in which they operate.

From the entry into force date, compliance in terms of both the equipment and operational requirementsof Annex VI will be mandatory for ships engaged on international voyages and to which the Annexapplies. In the case of ships of 400 gross tonnage (gt) and above, compliance will be indicated by theissue of an International Air Pollution Prevention Certificate (IAPPC) following an initial survey by, oron behalf of, the responsible flag State. For ships under this tonnage limit, it is for the individualAdministrations to set up schemes appropriate to such vessels to ensure compliance.

Ships of those flag States which are not signatories to the Annex, but which intend to operate in waterscontrolled by signatories, will require Statements of Compliance with Annex VI issued by, or on behalf of,

their flag Administration.

For ships completed after the entry into force date, the IAPPC will need to be issued prior to enteringinto service. However, for ships in service at the entry into force date, the IAPPC Initial Survey is tobe undertaken no later than the first scheduled drydocking thereafter, although in all cases, it mustbe satisfactorily completed within three years of the entry into force date.

Thereafter, a system of annual (or intermediate) surveys will apply with a periodic (renewal) surveyevery five years. These statutory surveys will be undertaken by, or on behalf of, the relevant flag Stateand are to be harmonized with the other MARPOL Annex surveys. Additionally, there will be portState inspections.


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ABS Guide to Shipowners Understanding MARPOL Annex VI2

NOx Controls

The NOx controls as given within the Annex will apply to diesel engines (boilers and gas turbines arenot covered) over 130 kW which are not used solely for emergency purposes (or, in the case of fixedor floating platforms and drilling rigs engines, used solely in connection with that facilitys drilling,

production or processing functions) and which are: installed on ships built (i.e. keel laid) on or after 1 January 2000, or

subject to major conversions, as defined, on or after 1 January 2000. For the purpose of thisregulation a major conversion is where an engine:

built on or after 1 January 2000 is installed onboard

output power is increased by more than 10 percent

is substantially modified, as defined

In the case of engines installed on ships built before 1 January 2000, substantially modified means

any operational or technical modifications which are made after that date which could increase NOxemissions, as defined. Such modifications may include changes to fuel injection timing, fuel injectionequipment, the charge/scavenge air systems or combustion chamber profile. The onus would be onthe shipowner to demonstrate to the responsible Administration that any changes to such operationalor technical features did not result in an unacceptable increase in emissions.

The NOx emission limits are related to engine rated crankshaft speed:

An engines duty cycle weighed emission values (since it could be rated for more than one cycle) aregiven at reference conditions (covering such aspects as fuel type, inlet air temperature and humidityand primary coolant temperature). Consequently, these controls focus on engine design rather thanend of stack emission rates.

Engine Speed (n) rpm

Less than 130

130 1999

2000 and above

NOx Emission Limit g/kWh

17.0

45 x n-0.2 (i.e. 720 rpm 12.1)

9.8


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There are four duty cycles for marine engines:

E2 Main propulsion, constant speed (including engines driving variable pitch propellers)

E3 Main propulsion or auxiliaries operating on the propeller law speed curve

D2 Auxiliary engines, constant speed

C1 Auxiliary engines not covered by D2 or E3

It is important to recognize that, in terms of NOx certification, an engine is specifically approved onlyfor those duty cycles and rating (power and speed) which are given in its certification.

The NOx Technical Code, as a mandatory document, defines the procedures and means by which anengine is to be certified and compliance demonstrated both initially and thereafter over its service life.

The essential points in respect of those engines which will fall within the scope of Annex VI are for:

Engines, either installed on new buildings or supplied new, are to be in compliance with the NOx

Technical Code as indicated by a Statement of Compliance or similar, normally issued by, or onbehalf of, the flag State of the ship on which they are installed. It will usually be the responsibilityof the engine builder to have obtained the appropriate certification at the completion ofmanufacture.

All engines, where changes to duty, ratings, restrictions, components or settings which could affectNOx emissions are undertaken, the necessary steps are taken to demonstrate either:

that those changes do not affect the status of the subject engine relative to the Annexrequirements and any existing NOx certification; or

that the engine as modified is, and will thereafter be, demonstrably compliant with the relevantemission limit and is so certified. These changes would need to be approved by, or on behalf

of, the flag State of the ship on which the engine is installed. In the case of previously certifiedengines those changes could only be approved by the entity which issued the original Statementof Compliance with the NOx Technical Code.

An original copy of the engines Technical File (usually prepared in the first instance by the enginebuilder) as approved by, or on behalf of, the flag State of the ship on which the engine is installedis to be supplied with the engine. This is the key document in terms of demonstrating compliance.The basic requirements of the Technical File are specified by the NOx Technical Code, although inpractice there is considerable variation in content and arrangements, even between licensees of thesame design in some cases. The Technical File is to be kept with the engine throughout its servicelife. The Technical File, which is engine specific, defines the engine in terms of rating (power andspeed), duty, performance, limitations and NOx critical components and settings, the relevant

Parent Engine emission test report and the means by which that engine is to be subsequentlysurveyed in order to demonstrate compliance. Three survey options, the Onboard NOx VerificationProcedures, are given in the NOx Technical Code:

Parameter Check

Simplified Measurement

Direct NOx Monitoring


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The outlines of the first two options are defined in the NOx Technical Code. The SimplifiedMeasurement method effectively requires the full emission measurements of each engine at everysurvey, an involved, complex and costly task most unlikely to ever be adopted in practice. TheGuidelines for the Direct Monitoring Method were developed later and were finalized at MEPC 49in July 2003 as Resolution MEPC.103(49). In accordance with the NOx Technical Code the DirectMonitoring Method is not a permitted option for the Initial Survey onboard.

To date all engines have adopted the Parameter Check method. The basis of this is that emissionsare only measured in respect of the Parent Engine (as defined), all related Member Engines are thenverified as compliant on the basis of their rating, duty, NOx critical components and settings and/oroperating performance.

Engines are installed in accordance with the application and restrictions as given within the TechnicalFile. This covers such matters as rated power, speed and duty cycle. The design requirement is thatthe engine is to be compliant when operating with 25o C sea water temperature. Therefore, whereengines have intermediate, for example fresh water, cooled charge, or scavenge, air coolers, it willbe necessary that they are installed with an adequate cooling capacity to achieve charge/scavengeair temperatures no higher than the reference charge air temperatures (Tsc ref) as given in the

Technical File corresponding to operation with a sea water temperature of 25o C.


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Shipowners should also consider whether:

the implications in respect to the supply of spare parts are acceptable.

the Onboard NOx Verification Procedure as given within the Technical File is compatible withtheir operating requirements.

the given survey regime will require specialist services or personnel.While the engine builder will have developed the Engine Group/Engine Family and hence the TechnicalFile supplied with the engine as manufactured, the NOx Technical Code fully allows for other parties,such as the shipowner, with or without the cooperation of the engine builder, to also develop newEngine Groups which would of course need to be approved. Additionally, shipowners may seek to havealternative options added to existing Technical Files in order to give greater operating flexibility. Again,those amendments would need to be approved by the engine certifier. It is expected that such alterationswould primarily affect the Onboard NOx Verification procedures, either to adopt a form of the ParameterCheck Method which was not tied to the original equipment supplier or the utilization of the DirectMonitoring option

Figure 1. NOx Controls Survey Flowsheet

The NOx control requirements are not limited to the main engine and the generators. Diesel enginesdriving compressors, cranes, hydraulic power packs, etc. are also included. However, the present

understanding is that diesel engines in mobile machinery (such as crawler cranes, shovel loaders,pallet tugs etc.) carried by a ship are excluded.

ALL INSTALLED DIESEL ENGINES

Used for other than solely for:

(a) emergency purposes

(b) minerals exploitation

Engine output more than 130kW

Ship built on or after 1 January

2000

Technical File & SoC/EIAPP:

As approved

Technical File & SoC/EIAPP:

approved/issued by ABS

Engine as approved: Duty, rating,

restrictions

IAPPC issued

or endorsed

Other Annex VI aspects

complied with as necessary

Repeat from start

for next engine

Corrective

action

ABS Review Letter

obtained/signed

Engine

exempt

Engine subject to

Major Conversion

Onboard NoxVerificationprocedure shows engine

to be compliant

YES

YES

YESYES

YES

YES

YES

YES

NO

NO

NONO

NO

NO

NO

NO


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After the entry into force date any diesel engine falling within the scope of these requirements will need:

Valid engine certification. Following the entry into force date, Administrations, or organizationsacting on their behalf, will issue Engine International Air Pollution Prevention Certificates(EIAPPC) to signify the initial compliance of an engine. For engines already issued with Statementsof Compliance with the NOx Technical Code, it would be for the responsible Administration to

decide whether or not it would require those Statements to be changed to EIAPPCs a purelyadministrative task, no re-survey of the engine would be required. Statements of Compliance withthe NOx Technical Code would however continue to be issued in respect of engines to be installedon ships the flag State of which is not an Annex VI signatory.

A Technical File, as approved by, or on behalf of, the ships flag State, retained onboard. Whereamendments, additions or deletions are necessary, these will need to be approved by, or on behalfof, the relevant flag State effectively by the organization which approved that document in thefirst instance.

The diesel engine will need to be installed in accordance with the duty, rating and restrictions(including charge air/scavenge air cooling arrangements) as given in the Technical File.

The Engine Record Book (ERB), in the case where the Onboard NOx Verification procedure is tobe based on the Parameter Check method. The ERB will need to be accurately maintained. Thisdocument, as required by the NOx Technical Code, is to provide a chronological record of anychanges to NOx critical components or settings, including adjustments, part replacements andimplementation of approved modifications. As with the Technical File, this record is to be retainedwith the engine to which it refers and must be available, and complete, at the time of scheduled orunscheduled (i.e. port State) surveys. However, unlike the Technical File, the ERB will be completedby the ships staff.

To be in a demonstrably (i.e. surveyable) compliant condition.

Consequently, any engines installed between 1 January 2000 and the entry into force date, which

were modified from their initial NOx compliant condition or to which spare parts have been fitted,which do not enable the Onboard NOx Verification procedure, as given in the Technical File, to beapplied, will need to be re-instated to their as approved condition.

With the need to actually implement the Onboard NOx Verification procedures as given within theTechnical Files, it is to be expected that there will be a greater tendency for shipowners to take actionto so that such procedures can be applied without undue delay, or specialist services, while retainingthe flexibility of component supply to which the industry has been accustomed. Shipowners may alsoseek to influence the engine builders as to the nature of the verification procedures contained withinthe Technical Files as supplied, or may take a more direct form in proposing to the responsibleAdministration alternative survey schemes.


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Fuel Oil Quality

In the context of Annex VI fuel oil refers to any grade of petroleum derived fuel (gas oil, diesel oilor residual fuel oils (IFO/HFOs) together with any other alternative source liquid fuel used onboard.Although entitled fuel oil quality, the relevant requirements only cover some of the commercial

aspects which often affect supply. These requirements are essentially operational in nature. Fromthe entry into force date, it will be necessary to comply.

Marine fuel oils are to be supplied by companies registered with the appropriate authority of thecountry in which they operate. In this context, and throughout this regulation, the fuel oil supplieris the legal entity which physically delivered the fuel oil to the ship.

Bunker delivery notes from the supplier are to contain certain information about the supplier, thereceiving party and the fuel oil itself (the full scope is given in Annex VI Appendix V). One of thekey parts is the actual sulfur content essential in terms of compliance with the SOx control aspects.Additionally, the bunker delivery note must include the required composition clause in order toindicate that the fuel is free of inorganic (i.e. sulfuric or hydrofluoric) acids or added substanceswhich could harm personnel, damage machinery or add to air pollution.

For ships of 400 gt and above, the bunker delivery note is to be kept onboard for a minimumperiod of three years from the date of delivery. Individual Administrations may extend this require-ment to ships below that tonnage limit.

For those ships which are required to keep their bunker delivery notes onboard, as above, aretained sample of all fuel oils as supplied is to be drawn by the supplier, in accordance withdefined Guidelines, MEPC.96(47), at the ships receiving manifold, sealed and signed on behalfof the supplier and the Master or ships officer in charge of the bunkering operation.

This retained sample is to be kept under the ships control until the subject fuel oil has beensubstantially consumed, but in any case, for at least 12 months from the date of delivery.


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SOx Controls

In order to limit SOx emissions, Annex VI will introduce a maximum limit of 4.5 percent m/m sulfur forall marine fuel oils, irrespective of fuel grade or the type of combustion machinery in which they are tobe used. MEPC has operated a sulfur monitoring program, in conjunction with the classification society

fuel oil testing organizations (ABS, DnV and LR), since 1999. To date, this has covered nearly 300,000deliveries representing some 280 Mt of residual fuel oil. From this the number of instances of sulfurcontents in excess of 4.5 percent m/m has been negligible, the overall average sulfur value being2.6 percent/2.7 percent m/m. The overall findings of this program are shown in Figure 2.

Figure 2. Summary of MEPC Sulfur Monitoring Program, 1999-2003

As shown by the monitoring program, this 4.5 percent m/m limit does not represent any significantrestriction on current fuel supplies, however, it is lower than the maximum limit currently given formost of the residual fuel oil grades in the ISO 8217 specification. However, the real impact of theseSOx controls will be within designated SOx Emission Control Areas (SECA).

The Baltic Sea (as defined in MARPOL Annex I) was the first SECA. At MEPC 44 in March 2000, it wasfurther agreed that the North Sea (as defined in MARPOL Annex V) had met the necessary criteria to bedeclared a SECA after the entry into force of the Annex. Furthermore, there may be other areas (i.e. areasto the west of the British Isles, west of continental Europe, US coastal waters or the Mediterranean, intotal or in part) which may be expected to be proposed as SECAs.

Within a SECA, the requirement will be either a maximum limit of 1.5 percent m/m sulfur contentin respect of all fuel oils as bunkered or the use of an exhaust gas cleaning system, or equivalent, whichresults in an overall emission value of 6.0g SOx/kWh or less. In practice, it is expected that the majorityof ships will seek to comply with the SECA requirements by means of the primary control option oflimiting the sulfur content of fuel oils as delivered. Whether this will be achieved by the use of eitherlow sulfur residual fuel oils or gas oils (which inherently have sulfur contents below the limit value)will depend on such factors as ships projected operating profile, bunker tank and transfer systems andthe price differential between the various grades. In any case, the MEPC Guidelines for the approvalof exhaust gas cleaning systems, or alternative primary control options such as onboard blending, haveyet to be developed.

Residual fuel oil sulphur content, % m/m

Below

0.5

Below

4.5

0.5 - 1.0

0.5

4.0 4.0

9.0

21.0

26.0

23.0

12.0

1.00.0

1.0 - 1.5 1.5 - 2.0 2.0 - 2.5 2.5 - 3.0 3.0 - 3.5 3.5 - 4.0 4.0 - 4.5


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There will of course be those ships which will never enter, or alternatively never leave, a SECA. For thoseships, the future situation will be relatively straight forward; the respective fuel oil sulfur content limitwill apply without exception. The complication arises for ships which use residual fuel oil and operate,or may operate, for only a portion of their time within a SECA, since outside the SECA, such ships willutilize fuel oils of sulfur content typically around 2.0 - 3.5 percent m/m. In these instances, it will benecessary that those ships will have both the necessary segregated bunker capacity and the means tochange over to the lower sulfur content fuel prior to entry into a SECA.

Obviously, the effect of this change over requirement is going to differ from ship to ship, but certainly,it can be seen that some ships will require substantial segregated low sulfur fuel oil bunker capacity.In those instances, shipowners will need to consider their options prior to the entry into force of theserequirements and take the necessary steps at forthcoming dockings or other opportunities to arrangefor the necessary sub-division or addition and segregation of bunker, settling and service tanks andassociated transfer and service piping systems. Ships using residual fuel oil which intend to enter aSECA, but which do not have the capability for two segregated fuel oil grades, will therefore need tooperate continuously on the lower sulfur fuel oil.

Additionally, where ships are to operate on fuel oils of substantially different sulfur contents, i.e. withinand without SECAs, the possible need to change over the engine lubricants, particularly cylinder lubri-cants, will need to be considered. Apart from requiring a further subdivision of the lubricant storagecapacity, duplicate service tank systems may also be required.

All fuel oils for use onboard will need to be ordered, and verified from the specified bunker deliverynote on receipt, as having a maximum sulfur content of 4.5 percent m/m. The exception to this is whereships are to operate within a SECA with compliance through primary, rather than secondary controls.In those instances, the fuel oils to be used within a SECA are to be ordered, and verified, to have amaximum sulfur content of 1.5 percent m/m. Consequently, shipowners bunker specifications tosuppliers and charterers will need to be duly amended.

Those responsible for bunker purchases and chartering will need to ensure that ships have adequatequantities of fuels of the appropriate sulfur content for the intended voyages since, prior to entering aSECA, a ship will need to ensure that all fuel oil service systems in use are fully changed over andflushed of all fuel oils exceeding 1.5 percent m/m sulfur.

This requirement will not be applied to vessels operating in a SECA during the first year after theAnnex VI entry into force date or, where such areas are declared after that date, the first year aftertheir designation. Therefore, based on the Annex VI entry into force date of 19 May 2005, the BalticSECA will take effect from 19 May 2006. On the expectation that the North Sea SECA is formallyaccepted by MEPC 53 in July 2005 then that would take effect from around October 2007.

The accurate completion of the mandatory (MARPOL Annex I) Oil Record Book will be an essentialelement in keeping track of the different fuel oil grades (in terms of sulfur content) onboard.Annex VI requires that prior to entry into a SECA that the date, time and position when this changeover was completed is recorded in log-books as prescribed by the relevant Administration, whichmay well be the Oil Record Book in most cases. Although departure from a SECA is not specificallymentioned within the Annex, these requirements should be considered to be equally applicable onexit from a SECA. Consequently, the date, time and position at which that change over process backto a higher sulfur fuel oil (4.5 percent m/m maximum) was commenced, of course after exiting aSECA, will therefore also need to be recorded. Additionally, on both entry and exit from a SECA, it isrequired that the quantities of low sulfur fuels in each tank (storage, settling or service) be recorded.


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ABS Guide to Shipowners Understanding MARPOL Annex VI1 0

Incinerators

As with the NOx controls, the incinerator design requirements of Annex VI are independent of theentry into force date. Annex VI requires that all incinerators installed on, or after, 1 January 2000 areto be certified to the MEPC 76(40) specification. The only exception to this is for ships solely operating

in their flag States waters, in these cases the MEPC 76(40) specification requirement is effective fromthe entry into force date.

In addition to retaining the incinerators Type Approval certification onboard, those units which fallwithin the scope of these requirements are to be provided with an operating manual giving how theincinerator is to be properly operated.

From the entry into force date, the disposal of wastes by combustion is only to be undertaken usingincinerators except for the disposal, outside ports, harbors and estuaries, of a ships sewage sludgeand machinery sludges in main or auxiliary power plant or boilers.

Incinerators installed on, or after, 1 January 2000 (except in the case of ships operating only in theirflag States waters, in which case from the entry into force date) are to have been certified by the shipsAdministration as conforming to the MEPC 76(40) specification. It is therefore to be ensured thatsuch incinerators are adequately maintained and not subject to modifications which could affecttheir certification status. These incinerators are also required to be supplied with an operatingmanual which is to be retained onboard together with their Type Approval certification.

Incinerators installed prior to 1 January 2000 can continue to be used. However, it is prohibitedto incinerate:

Oil or chemical cargo residues or associated contaminated packaging.

Polychlorinated biphenyls (PCBs) an older form of stabilized transformer oil.

Garbage containing more than trace quantities of heavy metals (these include mercury, cadmium,lead as, for example, found in some cell type batteries).

Refined petroleum products containing halogen (fluorine, chlorine, bromine etc.) compounds.

Polyvinyl chlorides (PVC) except in incinerators certified to either MEPC 76(40) or MEPC 59(33).

Operators must be trained as to how to correctly operate incinerators.

Flue gas outlet temperature is to be monitored together with fed/start up controls.


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ABS Guide to Shipowners Understanding MARPOL Annex VI 1 1

Ozone Depleting Substances (ODS)

These are man-made chemicals which degrade the ozone layer in the upper atmosphere and which arebeing phased out, both in terms of manufacture and use, in accordance with the requirements of theMontreal Protocol. Within the marine context, these are essentially the halons, as used in some older

firefighting systems and equipment, and the chlorofluorocarbons (CFC) used as refrigerants and ininsulation material.

From the entry into force date of the Annex, 19 May 2005, it is prohibited to install any new systemor equipment containing ODS although new systems using hydro-chlorofluorocarbons (HCFC, witha much reduced ozone depleting potential as compared to CFCs) are permitted to be installed up to1 January 2020.

Existing halon and CFC systems and equipment can however continue to be used and recharged asnecessary. However, the deliberate venting of ODS is prohibited.

Annex VI also provides that Administrations may establish limits on the permitted leakage from ODScontaining systems effectively consumption controls. To date, there are no known requirements in thisrespect.

Administrations are to provide appropriate facilities for receiving ODS and equipment containing samewhen removed from either ships in service or prior to scrapping. These facilities must be used and anyshortfall in their provision reported through the usual channels.


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Volatile Organic Compounds (VOCs)

VOCs are the vaporized hydrocarbons (excepting any methane component) given off from tankervent systems when handling either crude oil or petroleum products which are a factor in theformation of low level photo-chemical pollution smog.

In order to avoid a proliferation of local requirements, where vapor emission recovery systemsare required by an Administration, these are to conform to the MSC Circ. 585 specification. TheAdministration is to advise IMO which tankers, berths and cargoes are to be covered by theserequirements and are to ensure that the necessary shore-side facilities exist to receive the returnedvapors. IMO will publish that listing, but at present this has not commenced.

1 2 ABS Guide to Shipowners Understanding MARPOL Annex VI


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ABS Guide to Shipowners Understanding MARPOL Annex VI 1 3

ISM Procedures

Apart from the specific Annex VI machinery and arrangement requirements, shipowners will also needto implement and verify that the various operational requirements of the Annex are met. Consequently,those ISM procedures covering aspects which will fall within the scope of the Annex VI will need to be

developed, or existing procedures duly amended. Depending on the status of the ship and its equipmentas regards to Annex VI these procedures could include:

NOx controls Engine operation Engine maintenance Engine spare part supply Record keeping

SOx controls Fuel oil ordering and supply Fuel oil storage, handling and usage Oil Record Book

Fuel oil Fuel oil supplier selection Fuel oil bunkering Oil Record Book Retention of documentation and samples

Incineration Operator training Material screening Operations

ODS

Equipment maintenance and servicing Disposal arrangements

VOCs VECS system

Although the review of these various procedures, and their effective implementation, would remainpart of the ISM certification process, demonstrating compliance at the in-service Annex VI surveyswill depend, and be greatly facilitated, by the correct functioning of these procedures.


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ABS WORLD HEADQUARTERSABS Plaza16855 Northchase DriveHouston, TX 77060 USATel: 1-281-877-5800Fax: 1-281-877-5803Email: [email protected]

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Understandng MARPOL Annex VI

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