Current Environmental Issues

Information for Owners

Our Mission
The mission of ABS is to serve the public interest as well as the
needs of our clients by promoting the security of 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.

Quality & Environmental Policy

It is the policy of ABS 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.
 TABLE OF CONTENTS

Extended Drydocking Periods Build on Eco Advantages

of New Antifouling Coatings 2

Cold Ironing Offers Hope, Challenges 4

Annex VI Sets International Standards 6

Air Pollution Remains High on IMO’s Agenda 8

Marine Fuel Oil Sulfur Controls - the Situation to Date 10

Guidance for the Management of Ballast Water 12

Entry into Force of the BWM Convention 14

Developers Seek a Safe and Successful Method for

Treating Ballast Water 16

Managing the Change from High Sulfur to

Low Sulfur Fuel Oil 18

Designers Adapt to New MARPOL Regs for Fuel Oil Tanks 20

Dual Fuel LNGs Intended for Baltic, North Sea Trading

Will Need to Demonstrate SECA Compliance 22

IMO Considers Clarifying the Handling of Oil Residues 24

Slow Progress on Ship Recycling Draft Convention 25

CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 1

 Extended Drydocking Periods Build on
Eco Advantages of New Antifouling Coatings
I
f successful, a recently launched trial
program to evaluate the effectiveness of
silicone antifouling coatings could see
the number of drydockings for high speed
containerships cut from four to two over the
vessel’s first 20 years of service. The program
is the latest step in the rapid evolution
of antifouling technology in the
period since the IMO adopted
the International
Convention on
the Control
2 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS
of Harmful Antifouling Systems on Ships in
late 2001.
Although it will not enter into force until
17 November 2008, the Convention
recognized the harmful ecological effects
of organotin tributylin (TBT) biocide laced
antifouling paints that had been used since
the 1960s and put an end to their continued
application.
Under the terms of the Convention, ships
will be required to have either removed all
TBT based coatings from their hulls or apply
an effective protective coating that prevents
any leaching of the harmful biocides from the
remaining paint.
In the period since the adoption of the
Convention the coatings industry has
developed several, effective, first generation,
self-polishing, non-TBT applications such as
those containing zinc carboxylate or copper
acrylate. The most recent developments have
focused on emerging technology such as
nanocapsule acrylate approaches and non-
stick silicone based release coatings. The
former are more suited to ships with a service
speed of less than 15 knots and the latter to
the smaller cluster of higher speed vessels
such as containerships, passenger ferries and
LNG carriers. The higher speed is needed for
the self-polishing action to be effective.
Of all the various approaches, the silicone
based fouling release is, at present, considered
the most ecologically friendly as it is the only
alternative that does not release biocides into
the marine environment. Other environmental
advantages accrue from the reduced fuel and
powering requirements to maintain service
speed which in turn reduce the amounts of
SOx, NOx and CO2 that are released into the
atmosphere.
The latest initiative has been instigated by
AP Möller, the world’s largest container carrier,
working with ABS and its other classification
societies and the flag Administrations of
Denmark, the UK and Singapore. Other
container lines have subsequently approached
ABS about adopting a similar trial program.
Flag State involvement stems
from the IMO Resolution
A.948 (23) that contains
recommendations to flag States
for carrying out SOLAS surveys.
It allows for inspections of the
ship’s hull to be carried out,
alternately, underwater or in
dry dock with any deviations
from these recommendations
requiring sanction from the
relevant flag State.

This means that, with the

flag State’s concurrence,
conformance with the Surface tension determines spreading of glue from fouling organisms.
SOLAS requirements can be
demonstrated by conducting appropriate
in-water surveys at the Intermediate and
First Special Surveys followed by an
inspection in drydock of the outer hull and
the condition of the coatings at the Second
Intermediate Survey at seven and one half
years. The net effect is that over a 15 year
life span, the number of required drydockings
can be reduced from three to two and,
depending upon subsequent in-service
performance and coating condition, it is
possible that the third drydocking may not
be required until the vessel is more than
22 years old.
It should be stressed that, under the terms
of the trial program as agreed with ABS, if
an in-water survey should indicate deteriora-
tion of the coatings or damage to the hull
plating or raise concerns with elements such
as cathodic protection, rudders and stern
bearing arrangements, thrusters, sea chests
and other items, a drydocked inspection
may be required to assess the condition
that has broached the concern. It is also a
requirement of the program that the coatings
of all ballast spaces must be maintained in
a “good” condition throughout.
The scheme is ship specific and is to be
reviewed annually and re-assessed after
five years. However, since no in-service
experience currently exists on the
performance characteristics and longevity
of the specified silicone-based antifouling
coating, it is hoped that the information and
knowledge gained from this pilot project
will allow ABS to determine the suitability of
permitting an extended drydocking interval
under specified conditions to be included in
future versions of the ABS Rules for selected
vessel types.

Antifouling Convention Takes Effect

T
he 2007 ratification of the Antifouling System (AFS) Convention (Inter-
national Convention on the Control of Harmful Antifouling Systems on
Ships) by Solvenia and Panama meant that the IMO conditions for entry into
force (25 States with 25 percent gt) have been met. The Convention will enter
into force on 17 November 2008.

AFS applies to ships (excluding fixed or floating platforms, FSUs and FPSOs) of 400
gt and above engaged on international voyages. Annex 1 of the AFS Convention
prohibits certain types of antifouling systems and requires removal or application
of a sealer coat using an uncontrolled AFS (one that does not appear in Annex 1).
It is however noted that in the event a vessel is registered in a EU Member State
or intends to trade within EU waters, compliance with the AFS Convention was
required on 1 January 2008.

CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 3

REDUCING EMISSIONS IN PORT
Cold Ironing Offers Hope, Challenges
I
t is estimated that a modern, post-panamax
containership, using ship’s power, will
generate about one ton of Nitrogen Oxide
(NOx) and almost 100 pounds of particulate
matter (PM) each day that it is alongside
a berth in port. For large ports in densely
populated areas, the cumulative effect on
air quality can be significant. According to
a report commissioned by the Port of Long
Beach California, ships at berth in the twin
ports of Los Angeles and Long Beach generate
more than 4,000 tons of smog forming NOx
on an annualized basis.
With increased emphasis being placed on
environmental issues, it is understandable
that the issue is now before the IMO’s Marine
Environment Protection Committee with
Sweden and Germany jointly submitting a
proposal to initiate a standardization process
(involving the International Standards
Organization (ISO) if appropriate) for the
provision of on-shore power, or cold ironing,
for ships in port. The Committee agreed that
standardized power connections could benefit
the industry but noted that more detailed
studies were needed. Subsequently the
International Association of Ports and Harbors
(IAPH) has also undertaken research into this
area and ISO has published ISO/PAS 29501
(E) Ships & Marine Technology – Environmental
Protection - Onshore Power Supply (Cold Ironing).
Cold ironing is neither a new concept nor
widespread. It has been used for many years
4 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS
in a limited number of locations by ships on
regular trades and, more recently, in a growing
number of environmentally sensitive areas such
as by cruise ships in Alaska, containerships in
southern California and ferries in Scandinavia.
Requirements from local governments call
for the reduction of emissions of diesel
particulate matter, nitrogen oxides, sulfur
oxides (SOx), and reactive organic gases
(ROG). These requirements include goals to
reduce emissions. For example, the statewide
emission reduction goal for the State of
California for 2010 is to reduce the projected
2010 emission levels to the 2001 levels or
below. It is expected that the need for cold
ironing systems will increase regionally and
globally as the requirements become more
stringent.
The MEPC submission by Sweden and
Germany recognizes that cold ironing may not
be a universal panacea. It acknowledges that
shore power will often be more expensive;
that the CO2 emissions from shore-side power
generation may be greater than those of an
efficient on-board generator, particularly if the
shore utility is coal-fired; that the loss of power
during the changeover may be detrimental to
the modern electronic equipment and systems
on board the vessel; and that the technical
standards associated with on-board electricity
vary widely, posing significant difficulties
in matching ship requirements with shore
supplies. It is for this reason in particular
that the submission urges the creation of
international standards that will promote the
widespread use of cold ironing.
There would be no limit to the type of vessel
that can be considered for changeover to shore
power connections although it is estimated that
modification costs could run as high as $1m
for some vessels. Particular ship types such
as passenger ships, large containerships and
reefers may require loads in the order of several
megawatts, much larger than what could be
supplied through a typical low voltage “shore
power connection.”
Currently there are no published standards ad-
dressing the connections of marine vessels to
shoreside electrical power systems when
the connection voltages are 6.6 kV or 11 kV.
There are some industry standards, class
society rules (including ABS requirements)
and regulations addressing typical low voltage
shore power connection (usually 480 V).
electric generators. At least one diesel
engine should be designated as a standby
generator and provided with the necessary
arrangements so that it could be started
quickly to achieve the emergency departure.

International standards will need to be • The auxiliary boiler may be needed to

developed to establish requirements
specifically for cold ironing systems if the
issue is to be effectively and efficiently
addressed. Some elements that would require
particular attention include:
• Standardization of the connectors and
interconnecting power cables as well as
system voltages and frequencies.
• Safe paralleling of the vessel’s main
generators to the shore power to avoid
disruption of power when connecting and
disconnecting from shore power.
• Methods to limit or prevent the possibly
large levels of available short circuit
current from the shore power system from
damaging the vessel’s power system and
equipment, since the typical vessel power
system would not be rated to handle these
possibly large levels.
• Cable management systems at the berths
to accommodate different sized vessels and
environmental factors, such as large tidal
fluctuations.
• Control signals from the vessel to shore
and from shore to the vessel would need
to be made available whenever the safety
of the vessel or the safety of the port may
be affected. For example, during offloading
operations for an LNG vessel, the port
may issue an Emergency Shutdown (ESD)
signal to the vessel to stop the offloading
operations. Whenever possible, it would
be advantageous to transfer back to vessel
power prior to actually losing the shore
power. If shore power is lost before transfer
back to vessel power, the flag State may
consider this to be a reportable incident.
maintain the temperature of heavy fuel oil
(HFO) and jacket water for diesel engines.
If the port authority requires the auxiliary
boiler to be shut down, then an electric
heating system may be needed. Use of other
fuels that do not require heating, instead
of HFO, should also be considered. As
regulations grow more stringent, shutdown
of the auxiliary boiler will be looked at as
another way to further reduce emissions.
Other practical issues that an owner should
consider include the means for on-board
storing and handling of the necessary
electrical cables. Owners may also consider
using an interim container-based solution
where a container fitted with the necessary
connection panel/switching gear, transformer
and cable can be stored at a port and loaded
aboard the vessel on arrival by a contractor.
ABS is able to provide comprehensive
guidance to owners for both the design of
the electrical system of new ships and the
retrofitting of existing ships to prepare them
for cold ironing to meet the needs of specific
trades and to position them for the expected
increased mandate to use shore power in the
principal urban ports around the world.

• Consideration of the need for a vessel to

make an emergency departure from a port
in response to a perceived threat. Vessels
with steam turbine propulsion would
not be able to shutdown their propulsion
boilers. Diesel driven vessels with electric
propulsion would be able to shut down
most of the diesel engines driving the

CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 5

controlling emissions imposes costly burden on owners

Annex VI Sets International Standards

T
he principal Both NOx and SOx have human health
means of implications and are contributors to acid
regulating deposition which can have severe effects in
emissions to sensitive areas of the natural environment
atmosphere such as the northern latitudes and the polar
from ships is the regions. Additionally NOx, in combination
International Maritime with certain hydrocarbon emissions, will
Organization’s (IMO) result in the formation of photochemical
MARPOL Annex VI, pollutants, including smog in the lower
‘Regulations for the atmosphere, which again can have further
Prevention of Air detrimental effects on both health and the
Pollution from Ships’. environment.
Annex VI entered
into force in May In the case of the NOx controls, these typically
2005 and, to date, apply to diesel engines over 130 kW, not used
some 48 countries solely for emergency purposes, either installed
representing over 74.7 on ships built on or after 1 January 2000 or
percent of the world’s those engines which have undergone ‘major
tonnage are Parties to conversion’ (as defined) on or after that date.
the 1997 MARPOL These controls require applicable engines to
Convention by which be certified in accordance with the mandatory
that Annex was NOx Technical Code and to be operated,
introduced. A major fitted, maintained and adjusted within
revision to Annex VI approved bounds.
is in progress at IMO
and is expected to be In contrast, the SOx controls apply to all
finalized in October grades of fuel oils used at sea for combustion
2008. purposes. These controls apply to two levels;
worldwide the sulfur content of all marine fuel
The requirements of oils is limited to 4.5 percent maximum. The
Annex VI apply both current average level is around 2.7 percent.
to ships registered in
those countries which Additionally, in areas accepted by IMO,
are Parties to the referred to as ‘SOx Emission Control Areas’
Convention and also (SECA), as being particularly sensitive to
to ships of other flag acid deposition, a tighter level of control
States while operating within waters under the applies which limits the sulfur content
control of a Party State. of all fuel oils used in those defined areas
to a maximum of 1.5 percent or requires
The Annex VI controls cover nitrogen oxide equivalent primary or secondary control
(NOx) and sulfur oxide (SOx) emissions and measures to be applied. The Baltic Sea
certain fuel oil quality matters, together with SECA entered into effect in May 2006; the
restrictions on the use and release of ozone North Sea SECA applied from November
depleting substances, the specification of vapor 2007. There is no additional SECA under
emission control systems where mandated and consideration. However, it must be fully
onboard incineration. expected that other proposals will be
forthcoming which could include such
NOx is formed by oxidation of a minor part of areas as the polar regions.
the charge air nitrogen under high temperature
combustion conditions while SOx is formed With regard to fuel oil quality matters, one
by the combustion of fuels containing sulfur. aspect of Annex VI is to prohibit the addition
These emissions can have effects both close of materials, such as waste chemicals, which
to the point of discharge and over wider areas could be harmful to personnel, adversely affect
due to their transport and distribution by the machinery performance or result in increased
prevailing airstreams. air pollution.

6 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS

Despite the level of ratification to date and,
in view of its wider application to ship’s of
non-Party States when operating in Party State
waters, Annex VI, together with its associated
NOx Technical Code and various Guidelines,
is currently subject to widespread review
within IMO. This process has only recently
commenced and there is no clear idea as to
what the outcome will be, except that controls
generally will be extended and tightened.
The Annex VI controls are, however,
international in their application, albeit with
regional variations such as the SECA.
More Rigorous Regional Controls
For an industry that relies on uniformity
of standards, regional emission control
regulations pose particular headaches for
ship operators. The approach adopted by
the European Union (EU) with regard to
SOx controls is illustrative of how these
regional restrictions can have far reaching
implications.
The EU Directive covering SOx emissions
from combustion machinery was revised
in 2005. It introduced a number of aspects
which will have appreciable effects on
the marine industry, one of which is the
requirement that all ships, irrespective of
flag State, will be required to operate within
the EU on fuel oils of sulfur content not more
than 0.1 percent while alongside at berth,
moored or at anchor except those with a
timetabled turnaround of under 2 hours. This
requirement commences 1 January 2010 and
will effectively mandate the use of distillate
grade fuel oils or the use of cold ironing
(shore power).
The other prominent example of the unilateral
application of SOx emission controls can be
taken from the US where the California Air
Resources Board has approved new regulations
to reduce emissions from auxiliary diesel
engines and diesel-electric engines operated
on commercial oceangoing vessels of all flags,
not only while in Californian ports but also
within 24 miles of the California coast.
Under the regulations, vessel owner/operators
are required the meet an emissions limit based
on the use of marine distillate fuels. Effective
1 January 2007, vessels were required to either
use marine gas oil (DMA as defined in Table
1 of the ISO 8217 standard) or marine diesel
oil (DMB) at or below 0.5 percent sulfur for
diesel electric main engines and auxiliary
generators. On 1 January 2010 the standards
will be further tightened to restrict fuels to
marine gas oils with sulfur conent at or below
0.1 percent.
Compliance can also be achieved through
the use of shore side power (cold ironing)
or exhaust emission controls that have
been demonstrated as having equivalent
effectiveness to the use of the specified fuels.
In circumstances when a vessel has made an
unplanned entry into Californian waters or
has inadvertently been supplied with defective
fuel, the owner will be required to pay a
noncompliance fee which increases with the
number of ports called.
As with other designated emission control
areas, the vessel operator must keep records
noting the date, local time and location when
the ship enters and leaves regulated Californ-
ian waters, when fuels are switched and which
fuels are burned while in Californian waters,
in addition to the common requirement
to maintain a record of the types of fuel
purchased and their sulfur content.
The above examples are given to illustrate
how certain geographic areas which are
deemed to be sensitive to particular issues may
enact requirements both substantially more
restrictive and with a different timeline, to the
general, worldwide, case.
However, SOx controls are somewhat unique
in that these can, through limiting the fuel
oil’s sulfur content, be restricted simply
by operational controls. Controls on NOx
emissions, together with aspects such as
hydrocarbon particulate emissions, are more
related to the actual combustion machinery
itself, its maintenance and operation and
hence are not amenable to that type of
regulation.
Consequently, where it is required to
impose more restrictive controls on these
emission species, such controls will need
to frame the ship design and engine choice
options from the initial construction stage.
Typically, this will involve the requirement
for low emission engines that still retain
reliability and good operating characteristics,
together with the addition of primary (i.e.,
fuel oil emulsification/charge air
humidification) and or secondary (i.e.,
selective catalytic reduction) emission
control systems which can be switched
in as necessary in order to achieve the
targets.
CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 7
Air Pollution Remains High on IMO’s Agenda
W
ith climate change
the subject of
widespread
public concern, it was not
surprising that the 56th
meeting of the IMO Marine
Environment Protection
Committee (MEPC)
revisited its intention to
update the 2000 IMO Green
House Gas (GHG) Study.
The Committee is looking
for a better foundation for
future decisions that takes
into account significant
changes in the world’s
shipping industry and
global climate and technical
developments that have
taken place since the 2000
Study. It agreed that the
update should be carried
out with completion no
later than 2010.
The study will entail an updating of the current
inventories and future scenarios of emissions
of GHGs and other relevant substances from
international shipping in order to assess climate
change and future emission reduction potential.
Although carbon dioxide (CO2) is the most
significant GHG emitted by ships, the study will
8 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS
also assess methane (CH4), nitrous oxide (N2O),
hydrofluorocarbons (HFCs), perfluorocarbons
(PFCs) and sulfur hexafluoride (SF6). Other rel-
evant substances include nitrogen oxides (NOx),
non-methane volatile organic compounds
(NMVOC), carbon monoxide (CO), particulate
matter (PM) and sulfur oxides (SOx).
In the meantime the MEPC and the Bulk Liquids
and Gases (BLG) Subcommittee continue their
evaluation of air pollution issues. The principal
focus is on:
• NOx emission limits for new engines
• Reduction of SOx emissions
• Reduction of Volatile Organic Compounds
(VOCs)
• Emission of Particulate Matter (PM)
• NOx and PM limits for existing engines.
However, progress has been slow and numerous
options for each of the above areas have been
identified as ways of trying to substantially
minimize air pollution from all possible marine
sources. To facilitate the Committee’s goal to
develop practicable, workable and affordable
solutions, IMO’s Secretary General proposed
that an informal cross government/industry
scientific group of experts be convened under
the chairmanship of the UK. Subsequently a
report was submitted to the BLG Subcommittee
meeting in February 2008.
The study was not aimed at promoting any
particular position, but gathered, evaluated and
presented facts to specifically address the effects
of the proposed fuel options to reduce SOx and
PM emissions generated by shipping, as well
as assess the consequential impact such emis-
sion reductions may have on other pollutants
(e.g. CO2).
Additionally, MEPC 56 extended the schedule
to complete the revision of MARPOL Annex
VI by one year and agreed to the holding of
an intersessional meeting of the Bulk Liquids
and Gases (BLG) Air Pollution Working Group
which is to be hosted by Germany. The work
of this intersessional meeting was sent to the
BLG Subcommittee meeting (February 2008)
for review, together with the results from the
informal cross government/industry scientific
group of experts.
If approved by the BLG Subcommittee, the
proposed revisions would be sent to MEPC 57
(31 March - 4 April 2008) for consideration
and approval thereby allowing for the adoption
of any new or revised regulation to occur at
MEPC 58 (6 - 10 October 2008).
The more substantial tasks are:
• Finalize the draft proposals for Tier II and
Tier III NOx regulations for new engines.
The current MARPOL VI Regulation 13
comprises Tier I. Tier II represents the
best available in-engine technology, with
potential reductions of 15 percent to
25 percent depending on engine type and
has a tentative implementation date of
1 January 2011. Tier III, with a tentative
implementation date of 2015 or 2016,
would introduce more stringent limits
requiring further engine development or
the use of different after-treatment tech-
niques. A geographically based approach is
also under consideration for Tier III.
• Examine the feasibility of establishing NOx
regulations for existing (pre-2000) engines
and develop a draft simplified certification
scheme for existing engines as a new chapter to
the NOx Technical Code. In this regard, the
Committee was informed that the Swedish
shipping industry has gained substantial
experience in successfully retrofitting after-
treatment technologies to existing engines
and achieved significant NOx reduction.
• Consider definition and measurement methods
of possible emission limits for PM and imple-
mentation of possible PM limits for new and
existing engines. Substantial work remains,
particularly in examining the feasibility
to introduce retrospective regulations for
existing engines.
• Review and finalize, if possible, draft
washwater criteria for Exhaust Gas-SOx
Cleaning Systems (EGCS-SOx). Recognizing
that this is new technology under
development for marine applications,
relatively simple criteria were developed
to protect the marine environment while
also allowing progress in development
of this new technology. A draft set
of washwater criteria was developed
addressing oil (using polycyclic aromatic
hydrocarbons as an indicator), pH, heavy
metals, and nitrates. Separate criteria for
pH are proposed for operation in ports,
harbors, and estuaries – where the greatest
concern has been placed – and while
underway recognizing that damage to the
ship’s antifouling system could occur as a
result of highly acidic discharges along the
ship’s hull.
• Review the draft amendments to the
Guidelines for On-board Exhaust Gas-SOx
Cleaning Systems (MEPC.130(53)) and
finalize the draft amended Guidelines. The
draft guidelines represent a significant
improvement in organization and format
over the current guidelines and were
considered close to finalization.
ISM CODE TO BE TIGHTENED
A t the next
n meeting of
the IM
IMO’s Maritime
Safety Committee
Com (MSC)
Recognizing that a key role
in implementing the ISM
Code is played by the
two Circul
Circulars which aim to Designated Person Ashore,
strengthen the operational DPA, a second Circular
implementation of the ISM provides qualifications,
Code will be presented for training and experience
approval. These Circulars for the DPA. The Circular
place greater emphasis on recommends formal educa-
performing internal annual tion from a tertiary institu-
audits and internal system tion within a relevant field
reviews by qualified persons. of management, engineering
Greater focus is also placed or physical sciences.
on the SMS review/assess- Alternatively, seagoing
ment by the company and experience as a certified
the master who should take ship’s officer or formal
into account reporting and education with three years
analysis of non-conformities, practical experience at a
accidents and hazardous senior ship management
occurrences. level are also acceptable.
CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 9
Marine Fuel Oil Sulfur Controls – the Situation to Date
nnex VI to MARPOL entered into force
A 19 May 2005. It applies to ships either
flagged in, or operating within the waters
of the signatory States (currently 48 representing
74.7 percent of the world’s gross tonnage).
Regulation 14 of the Annex limits the maximum
sulfur content of all marine fuel oils to 4.5
percent m/m (percent by weight). The latest
data from the IMO’s sulfur monitoring scheme,
which has been running since 1999, gives the
average residual fuel oil sulfur content for the
year as 2.6 percent m/m with over 62 percent of
the fuel samples tested (in total 86,117 samples
representing over 86 million tonnes) in the
range 2.0-3.5 percent m/m. This represents a
slight reduction from the previous year’s average
of 2.7 percent. For the period 2001 to 2006
the annual average and the three year rolling
average have been consistently within the 2.6
to 2.7 percent range which is within the IMO’s
Guidelines.
In addition to the 4.5 percent m/m global
fuel oil sulfur limit, within areas termed SOx
Emission Control Areas (SECA) the fuel oil
sulfur content is further limited to 1.5 percent
m/m maximum or alternatively SOx emissions
New stricter controls will not be uniform
worldwide and, depending on trading routes,
may require machinery systems, fuel storage
and handling arrangements together with
related ancillary equipment that are adaptable
to comply with the controls in place.
10 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS
to 6.0 g/kWh. This latter limit may be achieved
either by exhaust gas cleaning systems (the
Guidelines for their certification are given
by MEPC.130(53) and a number of such
systems are currently under development) or
other equivalent technological means. These
equivalent means would cover arrangements
such as onboard fuel oil blending or the use
of dual fuel (residual fuel oil/gas) systems.
However no work has yet been undertaken
on the required certification Guidelines. SECA
compliance is required from the point of
entry into the area through to exit and is to be
documented as required.
Currently there are two SECAs. The Baltic (as
defined by MARPOL Annex I) SECA entered
into effect 19 May 2006. The entry into effect of
the North Sea (as defined by MARPOL Annex
V) SECA has been complicated by overlapping
MARPOL and European Union (EU) derived
legislation. In accordance with MARPOL
implementation procedures, the North Sea
SECA commenced 22 November 2007, but the
latest amendment to the EU Sulfur Directive
(2005/33) effectively brought this date forward
to 11 August 2007. Although there are currently
no applications to IMO for other areas to be
considered as a SECA, the growth in their
number and their wider dispersion worldwide
must be anticipated.
Revision of MARPOL Annex VI
As agreed at MEPC 53 in July 2005, MARPOL
Annex VI is currently under revision in order to
take into account the widespread
pressure that the emissions to
atmosphere from ships be further
reduced. The detailed aspects of
this work are being undertaken
by the IMO’s Bulk Liquids and
Gases (BLG) Subcommittee. With
regard to SOx emissions, Regula-
tion 14, this has been subject to
considerable debate which is
far from concluded, even as
to the basic structure of future
regulations.
Following BLG 11 (April 2007)
the range of options currently
tabled divide into two main
groups, the first involving
retention of the global/SECA
arrangement but with revised
limits and a second group
proposing a global only approach. On the basis
of the debate to date, it is unrealistic to expect
the baseline, the current Regulation 14, to be
retained unchanged.

With regard to the global/SECA approach, the

options proposed would retain or lower the
global sulfur limit in stages (possibly down
eventually to 1.5 percent m/m) and lower
the SECA limit, also in stages, for example 1
percent m/m in 2010 then 0.5 percent in 2015.
Additionally, estuarial and port areas could be
automatically considered as SECAs.

As to the global only options, these center on

the proposal that all marine fuels should be
distillates (gas/diesel oils) with sulfur limits
again progressively decreased with 1.0 percent
m/m in 2012 and 0.5 percent m/m in 2015
being suggested. A variant of this approach
would be that fuel oils with sulfur contents up
to 4.5 percent m/m could also continue to be
used but would require exhaust gas cleaning
systems to be installed which would reduce the
overall SOx emissions to those equivalent to the
‘distillate only’ option.
A further complication has been added by the
possibility that SOx emission trading could be
used as part of the overall compliance program
whereby, within a controlled sea area, those
emitting above the limit would have to buy SOx
emission credits from those which are below the
set limit.
At present, it is far from clear what the outcome
of this debate will be and the relative influence
of economic, environmental, political, supply
chain, technical or non-scientific factors.
Additionally, at BLG 11 the IMO Secretary
General announced his proposal to set up
a cross government/industry scientific group
to evaluate the various control options with
regard to limiting SOx and other emissions.
Further consideration of this was undertaken
at MEPC 56 in July 2007.
Currently, it is envisaged that completion
will be MEPC 58 (October 2008). However,
in view of the amount of basic work which
remains outstanding, together with the possible
implications on completion resulting from the
work of the cross government/industry scientific
group, it remains to be seen whether this will
be achieved.
Other SOx Emission Control Regimes
With regard to limiting SOx emissions from
ships it is important to note that IMO is not the
only source of controls which affect the marine
industry. Shipowners and others will also need
to address specific regulatory requirements
covering the waters or ports in which they in-
tend their ships to operate, in particular the EU
Sulfur Directive.
In the case of the EU, the previously mentioned
2005/33 amendment to the Directive also
requires that from 11 August 2006 all passenger
ships operating within EU waters are to use a
fuel oil not exceeding 1.5 percent m/m sulfur
and that from 1 January 2010 all ships while
‘at berth’ (which includes at anchor) are to use
fuel oils with a maximum sulfur content of
0.1 percent m/m. Alternatively ships may use
cold ironing when the berth is so equipped.
In addition to these regulations which directly
affect ship operations, other related regulations
from, for example, the EU or the US Environ-
mental Protection Agency (EPA) will also restrict
the actual sulfur content of fuel oils sold in the
areas under their control. In the case of the
EPA, from 1 June 2007 the sulfur limit of ISO
8217 DMA type grade products has been set at
500ppm (0.05 percent m/m) and will further
reduce in January 2012 to 15ppm (0.0015
percent m/m which is equivalent to the current
on-road diesel fuel limit).
Outlook
Consequently, the outlook for marine fuel oil
sulfur limits is that of significant reductions.
What is clear is that these new controls will
not be uniform worldwide and, depending on
trading routes, may require machinery systems,
fuel storage and handling arrangements together
with related ancillary equipment that are adapt-
able to comply with the controls in place.

CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 11

 Guidance for the
Management of Ballast Water
I
n an initiative aimed at bringing
international consistency to the problem of
the transfer of harmful aquatic organisms
between geographic areas in the ballast
water of ships, the International Maritime
Organization adopted the International
Convention for the Control and Management
of Ships’ Ballast Water and Sediments in 2004.
The Convention calls for ships to meet a
concentration-based ballast water discharge
standard in accordance with a gradually
implemented schedule linked to the build
date and the amount of ballast carried on
board the ship.
Acceptance of the Convention has been
slow. Entry into force will occur 12 months
after ratification by 30 States, representing
35 percent of world merchant shipping
tonnage. However as of yet, only 12 countries
accounting for 3.46 percent of world tonnage
have signed the Convention.
Until such time as the Convention is ratified,
action to address the issue of invasive foreign
aquatic species is increasingly occurring on
a national, regional and local level. More
than a dozen individual nations, in addition
to regions as diverse as northwest Europe,
the Great Lakes and Antarctica,
have introduced specific
regulations addressing
the discharge
12 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS
of ballast in their waters. Further compli-
cating the issue, individual States such as
California and ports within the US (and
the State of Victoria in Australia) have
introduced local ballast water management
requirements.
A small number of these jurisdictions
may prohibit the discharge of ballast water
entirely (Panama within the Panama Canal)
or require chlorination (Buenos Aires) or
restrict in-port discharge to an approved
on-shore reception facility.
However, until active ballast water treatment
systems are developed, approved and
fitted, most of these jurisdictions require
arriving vessels to have exchanged the
ballast water on passage in conformance
with specified criteria. Such criteria may
specify the minimum distance from the
coast, the minimum depth of water and the
necessary documentation which may include
an approved Ballast Water Management
Plan (BWMP), log book entries, pre-arrival
notification requirements and signed ballast
water reporting forms.
Canadian requirements relating to the
Ballast Water Management Plan are typical:
the plan must be ship specific, it should
follow IMO Resolution A.868(20) and be
reviewed by the flag Administration or
Recognized Organization. Brazil requires
that, if the vessel is registered in a flag State
that has not ratified the IMO Ballast Water
Management Convention, the BWMP
must be approved by a Letter of
Compliance issued by a
classification society.
ABS has been
authorized by
various flag State
Administrations
to conduct
such review
and approvals
against the IMO
and flag State
requirements.
The review will
assess longitudinal strength, stability, propeller and hull girder
immersion, bridge visibility and sloshing strength are the
among other issues. principal elements
affecting sequential
Owners are encouraged to contact their ballast exchange
relevant flag State or shipowner association for that should be
the latest specific information on national or addressed during
regional requirements as new and additional the design process.
requirements are being mandated on a regular When sequential
basis. A comprehensive master list of existing exchange is
and proposed ballast water legislation is also impractical, the
maintained by the International Chamber of tank overflow
Shipping. system should be
arranged so that
Since the issue of mid-ocean ballast water the flow through
exchange is of recent origin, the majority approach can be
of ships currently engaged in international carried out without
trade has been designed with little or no the risk of over-
consideration to the ability to efficiently and pressurizing the
safely exchange ballast. As a consequence, tanks.
exchange sequences can be quite complex
if stability, hull girder strength, resonant To assist both
sloshing, slamming and propeller immersion designers and
criteria are to be maintained within acceptable owners, ABS is
limits. issuing a comprehensive update of its
Advisory Notes on Ballast Water Exchange
Detailed technical studies undertaken by ABS Procedures. Currently in development, the
have highlighted the complexity of exchange new ABS Guide for Ballast Water Exchange
sequences on certain vessels and the attendant takes account of the relevant IMO, national
safety concerns. Human error and equipment and regional requirements and provides
failures could potentially endanger the vessel detailed criteria intended to assist designers
such that appropriate training of shipboard and operators to meet those requirements
personnel and system reliability should be effectively, efficiently and safely.
subject to particular attention.
The ABS Guide recognizes the three
As a rule, recent designs have been developed methods accepted by IMO: sequential,
with due consideration being given to ballast flow through, and dilution. The text of
water exchange procedures. At least one the Guide details specific considerations
prototype design, developed by the Ship- for each of these methods to support the
building Research Center of Japan, takes safe operation of the ships when conducting
a radical approach to the hull geometry of ballast water exchanges at sea. The optional
tankers and bulk carriers, such that the need class notation ÀBWE will be awarded to
for ballast is largely eliminated. those ships which have been designed,
built, installed and commissioned in
For conventional designs, the ballast system accordance with the requirements of the
layout, ballast capacity, tankage configuration ABS Guide.

CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 13

Ballast Water Management
Entry into Force of the BWM Convention

O
ne of the primary tasks before the 56th
session of the IMO Marine Environment
Protection Committee (MEPC) was to
complete an assessment of the Ballast Water
Management (BWM) Convention to determine
if there were any impediments to the entry
into force provisions. These provisions require
approximately 540 ships (with a ballast capacity
< 5,000 m3 that are estimated to be constructed
in 2009) to treat ballast water to comply with
the biological standard contained in Regulation
D-2.
As noted during earlier sessions of the MEPC,
the most significant impediment has been the
lack of availability of BW treatment systems that
have been tested (ashore and onboard) and type
approved in accordance with the G8 Guidelines
contained in resolution MEPC.125(53). This
concern is thought to have been the cause of
why only 12 States, representing 3.46 percent of
the world merchant fleet tonnage, have ratified
the BWM Convention to date. This is far less
than the required 30 States representing 35 per-
cent of the world merchant fleet tonnage needed
for the Convention to enter into force.
Figure 1 - PureBallast BWT System
The one problem that the Committee agreed on
is that ships built on/after 1 January 2009 would
be required to comply with the Convention
when traveling to, or within the jurisdictional
waters of States that have ratified the Conven-
tion. The extent of retroactivity of the 1 January
2009 compliance date for ships flying the flag of
non-signatory States remains unknown at this
time.
The IMO Legal Division advised that if the
conditions for entry into force were not met by
31 December 2007, then the Convention would
only enter into force after 1 January 2009 which
would shift the first application date of the D-2
standard (1 January 2009) to the date of entry
into force of the Convention. Consequently,
ships constructed between 1 January 2009
and the date of entry into force would not be
required to meet the Regulation D-2 standard
until 2014 or 2016 according to their ballast
water capacity as specified in the Convention.
Several States (including Norway, Germany,
Japan and the USA) disagreed with the above
view. With no agreed position on the extent
of retroactivity and
without any approved
technologies available,
the proper course of
action for industry to
take is not clear at all.

Progress towards the

development of an
approved treatment
system was made,
however. Under the
provisions of the
G9 Procedures for
Approval of Systems
which use Active
Substances adopted
by MEPC.126(53),
the Committee agreed
with the assessment
carried out by the GE-
SAMP BW Working
Group and granted
both Basic Approval
and Final Approval
to the PureBallast
system.

14 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS

This system, which makes use
of active substances, will now
undergo further testing including
an assessment of ship and crew
safety before the Norwegian
Administration grants Type
Approval under the provisions
of the G8 Guidelines. Two other
systems that were submitted for
review were found deficient at this
point in time and were not granted
either Basic or Final Approval.

The PureBallast system (see

Figure 1) is comprised of a
50 µm filter (with automatic
back flushing capability) for removing larger
particles and organisms, thereby reducing the
level of sediments in the ballast water tanks,
and a Wallenius AOT (Advanced Oxidation
Technology) Unit. This unit introduces UV-
energy together with catalysts in order to
produce short-lived free radicals which react
with and destroy microorganisms.
The system requires no chemicals to be added
and there are no chemicals formed which can
enter the ballast tanks. Full scale testing for
type approval is set to be performed with
a flow rate 250 m3/h and with a power
consumption of 64 kW.
Guideline for Requiring
Additional Measures
The Committee also adopted a new resolution
which contains the G13 Guideline that
provides the basis for a State, after consulting
with adjacent States, to implement additional
measures regarding ballast water management,
including measures for emergency situations,
to prevent, reduce or eliminate the transfer
of harmful aquatic organisms and pathogens
under the provisions of Regulation C-1 of the
BWM Convention. In so doing, the State should
endeavor to make available all appropriate
services for ships to facilitate their compliance.

Due to the uncertainty that arose in the review
of the PureBallast system with respect to “active
substances” produced during the treatment
process, interim measures were agreed until
the G8 Guidelines can be revised. These request
Administrations to require that manufacturers
developing BWT systems that only use physical
processes which may produce chemical by-
products, to utilize the relevant guidance and
testing provisions for eco-toxicology, human
health and ship and crew safety that are
included in the G9 Procedure as part of the
G8 Guidelines for Type Approval.
The locations affected by the additional
measures are to be defined by precise
coordinates. Any operational and/or technical
requirements applicable to the ship to
achieve compliance with, and the duration
of, the additional measures are to be defined.
Regulation C-1 contains two procedures for
introducing additional measures: one requires
IMO approval prior to implementation, and
the other requires IMO notification six months
prior to implementation except in the case
of an emergency (e.g., harmful algal blooms)
which can be implemented without delay.

UPDATE
Delayed Application of Ballast Water Management Convention
The Ballast Water Management Convention requires ships with an aggregate ballast
capacity less than 5000 m3, constructed in or after 2009, to comply with the biological
standard contained in Regulation D2 on delivery from the shipyard. However, due to a
lack of type-approved equipment, the IMO Assembly at its 25th session agreed to delay
the compliance date for these ships until the second annual survey, but no later than 31
December 2011.

CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 15

Developers Seek a Safe and
Successful Method for Treating Ballast Water
E
xchanging ballast water while on
passage is an obligation that no seafarer
worth his salt should feel entirely
comfortable doing. Depending upon the type
of ship, its voyage routing, its draft, trim and
stability, open ocean ballast water exchange
can be fraught with danger unless the
appropriate Ballast Water Management Plan
is explicitly followed.
For seafarers, the preferred alternative is the
development of a ballast treatment system
that mechanically, physically, chemically or
biologically kills off or renders harmless any
aquatic organisms and pathogens that may
be lurking in the ballast that was taken aboard
at the last port of call.
16 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS
The challenge for the growing number
of companies and creative technical
entrepreneurs wrestling with this issue is to
develop a system that does exactly that but at
an acceptable cost and in an efficient manner
within the space available. It should not render
the ballast water toxic such that, on discharge,
the danger of unwanted organisms has merely
been supplanted by a comparable or worse
danger from pumping acutely toxic water into
a benign port environment.
To date just six proposals have received Basic
Approval by the IMO’s Marine Environmental
Protection Committee (MEPC). These are
the biocide-based Peraclean Ocean system
from Degussa GmbH of Germany; the electro-
chemical disinfecting system of
Electro-Clean marketed by Techross
Ltd and the Korea Ocean Research
and Development Institute; the
Special Pipe and Ozone treatment
system from the Japan Association
of Marine Safety (JAMS); the electro-
chemical EctoSys system originally
developed by Permascand AB of
Sweden and subsequently acquired
by RWO GmbH of Germany; the
PureBallast System from Alfa Laval/
Wallenius Water AB; and the NK
Ballast Water Treatment System from
NK Co. Ltd of Korea. In addition
the NEI Venturi Oxygen Stripping
(VOS) ballast water treatment system
was issued a type approval certificate
by the Liberian Administration in
late 2007.
The approval of these systems
means that the respective flag State
Administrations can authorize on-
board testing subject to the IMO
Guidelines for the Approval and
Oversight of Prototype Ballast Water
Treatment Technology Programmes
that were adopted by the MEPC at
the meeting. The Guidelines provide
a detailed framework for assessing
the effectiveness of proposed systems
but also make it clear that any ships
fitted with the test equipment must
ensure that existing applicable
international and national ballast
water management requirements are
not compromised.
ABS has been approached by a significant
number of companies developing ballast water
treatment processes requesting a review of
their proposed systems. These include the use
of filtration, pressurization within a specially
designed pipe, magnetic separation, heat
treatment, chlorination and various hybrids
of these. ABS Type Approval is expected to be
extended to those systems that are approved
by the MEPC.
As a Recognized Organization for more than
100 countries, ABS is also able to survey the
installation of treatment prototypes and to
issue the Installation Survey Statement of
Compliance in conformance with the IMO
Guidelines if so requested by the relevant flag
Administration.
Particular issues to which ABS recommends
attention be paid by developers include
on-board storage arrangements for the
active substances, the piping and electrical
cabling system layouts and material selection
(stainless steel tanks for certain chemicals)
or hull protection (special coatings or
mechanical barriers) which may fall
outside the scope of the approval by the
flag Administration.
To assist designers and operators, ABS is
developing a comprehensive Guide for
Ballast Water Treatment Systems. Given the
rapidly changing nature of this issue as new
treatment methodologies are proposed and
tested, final release of the Guide will be
coordinated with the ongoing efforts within
the MEPC at IMO.
CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 17
 Managing the Change from
High Sulfur to Low Sulfur Fuel Oil

S
hips entering SOx Emission Control
Areas (SECA) that normally operate
on high sulfur bunker fuels need to
orchestrate the change to the specified low
sulfur fuels in advance so that the vessel
is burning clean on entry into the area.
Operators must also be able to demonstrate
to the relevant authorities through appropriate
documentation and records that they have
complied with the low sulfur limits.
IMO designated SECAs limit the sulfur
content of all fuel oils used in those defined
areas to a maximum of 1.5 percent or requires
equivalent primary or secondary control
measures to be applied. The Baltic Sea
SECA entered into effect in May 2006 and
the North Sea SECA applies from November
2007. Regional controls apply in areas such
as Californian waters where, from 1 January
2007 defined auxiliary diesel engines and
noncompliance fee. The vessel must also
maintain records showing when it entered
and departed California waters and when
it switched fuels. Records must also be
kept regarding fuel purchases and sulfur
content. The restriction will be further
tightened on 1 January 2010 by restricting
usage solely to marine gas oil at or below
0.1 percent sulfur.
Vessels constructed on or after 1 July 1998
are provided with at least two fuel oil service
tanks having a capacity of at least eight hours
at MCR of the propulsion plant and normal
operating load at sea of the generator plant.
(Chapter II-1/Reg.26.11 of SOLAS 74 as
amended.)
In this case, one service tank is available
for low sulfur fuel oil and could be designated
as a service tank in which only low sulfur
fuel oil is used. To
achieve compliant
changeover from the
high to low sulfur
fuels, the following
procedure could be
considered:

• The high sulfur

fuel oil in a settling
tank is discharged
to the overflow tank
through a valve at
the tank’s bottom by
gravity at a loading
or unloading port
outside the SECA.

• The high sulfur fuel

oil in a service tank
to be used for the
low sulfur fuel oil
is shifted to another
service tank and/or
the overflow tank.

diesel-electric engines must use either
marine gas oil or marine diesel oil at or
below 0.5 percent sulfur. Alternatively,
the vessel may use control measures to
reduce its emissions to the same level or,
in certain situations, the vessel may pay a
• Upon completion of the fuel oil shifting/
transference, a low sulfur fuel oil is
transferred to the settling tank from a
low sulfur fuel oil bunker tank and then
is supplied to the service tank through fuel
oil purifiers.

18 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS

Where the MDO service tank also has a
capacity of at least eight hours operation at
MCR of the propulsion plant and normal
operating load at sea of the generator plant,
the change from high to low sulfur fuels
should follow one of the following two
procedures.
If using MDO during the change:
• The fuel oil in both a settling tank and
a service tank is completely discharged
to the overflow tank through a valve at
the tank’s bottom by gravity after the
fuel oil to the main engine and the
auxiliary engines has been switched
to MDO.
• Low sulfur fuel oil is transferred to the
settling tank from a low sulfur fuel oil
bunker tank.
• The low sulfur fuel oil is supplied to the
service tank through fuel oil purifiers.
• After the service tank level has reached the
minimum feasible level for the intended
operation, the fuel oil is switched from
MDO to the low sulfur fuel oil.
If not using MDO during the change, the
following switching procedure should be
carried out prior to entering the SECA, taking
into account the time needed for the change
to complete:
• The high sulfur fuel oil in the settling
tank is completely discharged into an
overflow tank under the condition that
the service tank has been fully filled with
a high sulfur fuel.
• The low sulfur fuel oil is transferred to
the settling tank from a low sulfur fuel
oil bunker tank.
• Once the temperature of the fuel oil in the
settling tank has reached the temperature
necessary for its purification, the high
sulfur fuel oil in the service tank is
discharged to an overflow tank up to the
minimum feasible level for the intended
operation.
• The low sulfur fuel oil in the settling tank
is immediately supplied to the service tank
through fuel oil purifiers.
Containerships constructed before 1 July
1998, normally have additional settling and
service tanks for low sulfur fuel oil, with
each tank usually having a capacity of
about 100 m3. However bulk carriers,
product carriers or oil carriers are not
provided with such tanks. For owners/
operators who decide not to make the
necessary structural modifications to install
additional settling and/or service tanks on
such existing vessels, it is still possible to
effect an acceptable changeover from high to
low sulfur fuels by considering the following:
Since there was no specific requirement for the
capacity of HFO settling and service tanks in
SOLAS, their capacity was usually less than is
provided on post 1998 vessels. In this case, the
fuel oil management procedures for switching
from high to low sulfur fuels should be
developed taking into account the ship’s crews’
knowledge and skill level.
If, as a consequence, it is not possible to
follow the previously outlined procedures,
the changeover can be achieved without
discharging the high sulfur fuel oil in both
the settling and the service tanks. Taking into
account the risks to the safety of the vessel
this procedure is performed by switching
valves at the suction of the transfer pump.
The low sulfur fuel oil is transferred to
the settling tank, mixing with the retained
high sulfur fuel oil. The low sulfur fuel oil
is then supplied to the service tank with
the high sulfur fuel being separated by the
purifiers.
Once again, this changeover should be
carried out well prior to entering the SECA,
taking into account the time required for
the transition to low sulfur fuel.
If a shipowner does not intend to modify
an existing vessel by adding the required
additional settling and service tanks, a fuel
oil management plan is to be prepared that
takes into account the time required to
complete the changeover from a high sulfur
oil to a low sulfur oil prior to entering the
SECA.
ABS is able to assist owners in developing
the fuel management plan for specific ships
within a fleet. The specific plans take into
account the relative sulfur contents of the
fuels, the capacity of each of the fuel oil
settling and service tanks, the main and
auxiliary engine outputs, the capacity of the
fuel oil purifiers, the fuel service system and
relevant safety issues.
CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 19
Protecting Against Bunker Spills
Designers Adapt to New MARPOL Regs for Fuel Oil Tanks
C
oncerned about the potential for
pollution from a ruptured bunker
space, IMO’s Marine Environment
Protection Committee (MEPC) has adopted
an amendment to the revised MARPOL Annex
I that includes a new regulation (12A) on oil
fuel tank protection. It applies to all new ships
and major conversions with an aggregate oil
fuel capacity of 600 m3 (about 570 tons of
MFO) and above for which either the contract
is placed on or after 1 August 2007 or, if no
contract, the keel is laid on or after 1 February
2008 or the vessel is delivered on or after
1 August 2010.
New purpose built FPSOs and FSUs are also
subject to the new requirements with minor
exceptions. The Committee recognized the
technical difficulties of subjecting column
stabilized units to the regulations and
approved a Unified Interpretation to govern
their application to these units. Self-elevating
drilling units are exempt from the new
standards.
The regulations apply to tanks greater than
30 m3 in capacity in which oil fuel is carried
but excludes those tanks which would not
contain bunkers in normal operation such
as overflow and sludge tanks. In addition to
requiring that the tanks be located so as to
have both double side and double bottom
protection, a maximum individual tank
capacity of 2,500 m3 is imposed.
Designers and owners are given two
alternative approaches to comply with the
new requirements. It is expected that most
owners of most ship types will opt for
protectively locating the bunker tanks
(see sidebar for details). The alternative
is based upon specified accidental oil fuel
outflow performance standards in the event
20 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS
of a collision or grounding. Specific
assumptions are given for the calculation of
the mean oil outflow parameter for each tank
subject to bottom damage and side damage
given the probability that the compartment
will be breached.
The probabilistic approach takes into account
the density of the fuel oil, the location of the
tank relative to the side shell and the tank size.
These are used to determine mean oil outflow
considering 40 percent outflow due to side
damage and 60 percent outflow due to bottom
damage and a percentage of oil entrapped by
tanks bounding the bottom shell plating. In
the event that a double bottom or double side
is fitted, providing partial protection with the
intent of reducing the mean oil outflow, the
dimensions of those spaces are to be not less
than those required under the prescriptive
requirements.
It is inherent in the new regulations that
the fuel oil piping shall also be located in
protected positions. Where the piping must
be placed closer to the ships bottom or
side than specified, MARPOL Annex I.12A
requires the fitting of valves or similar closing
devices within, or immediately adjacent to
the protected fuel tank. The valves must be
capable of being operated remotely from either
the bridge or machinery control position, they
must fail in a closed position in the event of
a remote system failure and they are to be
maintained in a closed position at sea except
during the transfer of bunkers.
To encourage owners to consider incorpor-
ating protectively located bunker spaces into
new ship designs, ABS introduced the optional
class notation POT (Protection of Fuel and
Lubricating Oil Tanks) effective 1 July 2003.
With the adoption of the formal requirements
by the MEPC in
March 2006, the
ABS criteria were
updated effective
1 July 2006 to
conform fully
to the final IMO
standards. Since
the ABS POT
notation criteria
exceed MARPOL
requirements by
also addressing the protection of lube oil
tanks, the notation will continue to be
offered after the IMO requirements take
effect on 1 August 2007.
ABS has been working closely with the
leading shipyards to verify that proposed
design modifications that are being
developed are in compliance with the
new regulations. The most commonly
adopted approach for tanker designs is
to provide protected locations in the
engine room and in way of the pump
room. Bulk carrier designers are largely
choosing to locate the bunker spaces in
the engine room, in protected locations
in topside tanks and in protected spaces
between the engine room and the
aftermost cargo hold.
LNG carrier designers are tending towards
providing protected space in the engine
room or in protected locations between
the collision bulkhead and the cofferdam
bulkhead of the No. 1 cargo tank.
Large containerships pose a particular
challenge given the very large quantity of
bunkers that must be carried to maintain
the preferred high service speeds.
Whatever location is selected results in
a loss of cargo space. The most common
arrangement to date is to use protectively
located deep tanks between the transverse
bulkheads between the cargo holds.
For the ultra large containerships, these
locations may not provide sufficient space
for the quantity of bunkers required and
designers are also evaluating encroaching
on cargo spaces by including bunker tanks
above the double bottom in one or more
cargo holds.
For all ship types, incorporating the
required protectively located spaces will
incur additional bulkheads and associated
structural costs. With the exception of
containerships, cargo lifting capacity
should not be materially affected.
ABS has garnered considerable practical
experience on this issue since first
issuing its POT notation in 2003. Assist-
ance can be provided to owners and
designers seeking clarification of either
the protective location or probabilistic oil
outflow options and proposed arrange-
ments can be reviewed by all ABS
engineering offices to verify conformance
with MARPOL Annex I.12A.
PROTECTIVE LOCATION OF FUEL OIL TANKS
Applicable criteria can be found in the ABS
Steel Vessel Rules Part 4, Chapter 6, Section
4 (for piping arrangements) and Section
4-6-4 (for ship piping systems and tanks).
Relevant sections are extracted below.
All applicable tanks are to be located away
from the vessel’s side or bottom shell plating
for a distance as specified in 4-6-4/17.3.2
below. Small suction wells may extend below
fuel oil tank bottoms, if they are as small as possible
and the distance between the vessel’s bottom plate
and the suction well bottom is not reduced by more
than half of the distance required by 4-6-4/17.3.2.
Fuel oil tanks of any volume are not to be used for
ballast water.
Protective Location of Tanks
The protective locations for the tanks specified in
4-6-4/17.3.1 above are to be as follows:
i) For vessels having an aggregate oil fuel capacity
of 600 m3 and above, all tanks are to be
arranged within an inner bottom above vessel’s
molded line of bottom shell plating at least of
the distance h as specified below:
h = B/20 m or
h = 2.0 m (6.6 ft), whichever is smaller
where B is the breadth of the vessel, as defined
in 3-1-1/5, in m (ft).
h is in no case to be less than 0.76 m (2.5 ft).
ii) For vessels having an aggregate oil fuel capacity
greater than or equal to 600 m3 (21190 ft3) but
less than 5,000 m3 (176,570 ft3), tanks are to
be arranged inboard of the molded line of side
plating not less than the distance w as specified
below:
w = 0.4+2.4C/20000 m
w = 1.31+7.87C/706290 ft
where C = vessel’s total volume of oil fuel in m3
(ft3) at 98% tank filling;
w = at least 0.76 m (2.5 ft) for individual tanks
smaller than 500 m3 and at least 1.0 m (3.3 ft)
for individual tanks greater than or equal to
500 m3
iii) For vessels having an aggregate oil fuel capacity
of 5,000 m3 (176,570 ft3) and above, tanks are
to be arranged inboard of the molded line of
side plating not less than the distance w as
specified below:
w = 0.5 + C/20000 m
w = 1.64+C/706290 ft or
w = 2.0 m (6.6 ft), whichever is smaller
where C is the vessel’s total volume of oil fuel
in m3 (ft3) at 98% tank filling.
The minimum value of w=1.0 m (3.3 ft).
CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 21
Dual Fuel LNGs Intended for Baltic, North Sea
Trading Will Need to Demonstrate SECA Compliance
A
n interesting question has arisen with
respect to the use of dual fuel LNG
carriers on projected future trades
into the Baltic for Russian export gas cargos
and into other SOx Emission Control Areas
(SECAs) including North Sea destinations.
Current indications are that, within these
areas, the use by LNG carriers of fuel oils
with a sulfur content above 1.5 percent in
conjunction with the burning of boil-off gas
(BOG) with effectively zero sulfur content,
would be considered as potentially acceptable
under MARPOL Annex VI Reg 14(4)(c).
However final determination will lie with the
relevant Administrations – both the flag State
and the interested port States within the SECA.
The Guidelines referred to in Reg 14(4)(c)
which the Administration should take into
account when approving such arrangements
have not yet been finalized. Work within
IMO to substantially revise Annex VI and the
NOx Technical Code has meant deferment
of specific consideration of this issue.
The question has been raised whether the
Guidelines required by Reg 14(4)(c) will still
be required and current indications appear to
suggest they will be, both to cover boil off gas
and residual fuel usage and to address those
situations in which a ship may use an on-board
blender to produce a SECA compliant fuel.
With dual fuel diesel engines, where the fuel
oil used is a diesel oil or gas oil grade product
(i.e. ISO 8217 specification DMB or DMC
grade), that fuel would normally be under the
1.5 percent sulfur limit as documented by the
bunker delivery note as required under Annex
VI Reg 18. In these cases operation within a
SECA would be in accordance with the Reg
14(4)(a) option. The same would apply when
using a residual fuel oil with sulfur content
limited to 1.5 percent maximum.
Where dual fuel diesel engines use a residual
fuel oil with sulfur content in excess of 1.5
percent (but below the global limit value
applicable in all instances of 4.5 percent) it
would be necessary to have approval of the
Administration. In the absence of the Reg
14(4)(c) Guidelines it would be necessary for
the owner to approach the relevant Admini-
stration and request approval on the merits of
22 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS
the arrangement presented. It is likely that this
could be demonstrated through calculation
and would not require engine emission testing.
For dual fuel diesel engines where the fuel
oil acts only as a pilot and hence is limited
to 1 percent of the total fuel rate, it should
be possible to make the necessary case to the
Administration that even if operating with
a 4.5 percent sulfur fuel oil, the total SOx
emission rate across the engine load range
(at which gas is used) would still be below
6.0 g/kWh.
In such instances where it is normal to
manuever or operate under low load on fuel
oil, only then would that fuel oil need to
comply with the Reg 14(4)(a) requirements
– i.e. 1.5 percent maximum sulfur content.
However, if when operating on a fuel oil with
a sulfur content above 1.5 percent within a
SECA and a problem occurred with the gas
supply system or other cause which resulted in
the emergency tripping of the engine main gas
supply valve, then that would be expected to
be considered an ‘allowable exemption’ under
Annex VI Reg 3 – but only until the situation
was brought under control.
It should be also noted that receiving terminals
may not allow a ship to burn gas during
discharge since they are returning gas to the
ship, especially where the sales are based on an
ex-ship (CIF) basis. In effect the buyer would
be paying for the ship fuel for several hours
while the ship is alongside discharging. This
is a commercial issue and not related to safety
but it should be considered as it impacts the
SOx emission issue. In such cases, where LNG
is discharged to a receiving terminal located
within SECA, the ship will have to carry a fuel
oil with a sulfur content not exceeding 1.5
percent unless commercial agreements could
be agreed to so that the ship could operate in
the gas mode during discharge.
In all cases where dual fuel diesel engines are
to use a residual fuel oil with sulfur content
in excess of 1.5 percent it would be expected
that a SECA Compliance Plan (similar to
that required in the case of the use of SOx
emission control equipment under Reg
14(4)(b) would need to be developed by the
shipowner (directly or by a consulting party)
and approved by the Administration. This
would detail the procedures to be followed for
compliance while within a SECA and hence
be available to Port State Control inspectors as
required.
The position is more problematic if the vessel
is fitted with a conventional steam turbine
plant capable of burning both BOG and fuel
oil. While, in principle, the same approach as
outlined for dual fuel diesel plants apply to
boilers using a mix of BOG and fuel oil with
sulfur content above 1.5 percent, due to the
much wider range of potential BOG/fuel oils
ratios the demonstration of compliance could
be much more complicated. Whereas with
the pilot fuel oil of the dual fuel diesel engine
there is no ability to increase the fuel oil flow
rate above that as limited by the pilot injector
capacity. This is not the case for the dual
fuelled boilers where wide variations could be
possible.
Such variations could result, for example, in
the 50/50 use of BOG and 3.8 percent sulfur
fuel oil – this could represent an overall
SOx emission rate in excess of 8.0 g/kWh
– particularly when taking into account the
fuel efficiency of boiler plant. In any case the
application of the 6.0 g/kWh limit is extremely
problematic in the case of combustion
machinery (such as boilers) which does not
have a brake power output.
For this reason it is thought that the
Reg 14(4)(c) Guidelines, as yet to be
developed to cover duel fuel engines and
boilers (together with the option
of on-board blending), should,
in the case of dual fuel boilers in
particular, cross refer to the now
adopted Guidelines for Reg 14(4)
(b) – MEPC 130(53) – especially
the Scheme B option by which
continuous monitoring of SO2 and
CO2 is required to demonstrate
compliance with the accepted
alternative compliance limit of
65 SO2 (ppm)/CO2 (percent).
However, due to the nature
of those Guidelines, it will be
necessary to leave scope for other
alternative approaches as may
be proposed and subsequently
approved by, or on behalf of, the
ship’s Administration.
Regardless, any boiler plant will
need to comply when operating
within a SECA. Even for dual fuel boilers there
will be the case where there is no or minimal
amounts of BOG available (or BOG use is not
permitted). Under these circumstances the use
of a 1.5 percent sulfur maximum fuel would
be the only available option in the absence of
a SOx exhaust gas cleaning system. This may
well require the division of existing bunker
tank capacity to retain onboard two (sulfur)
grades of fuel oils and the modification of
existing fuel oil transfer and service systems
to enable the two grades to be handled and
changed over as required.
If operation with BOG only is proposed it
would be outside the scope of Annex VI
Reg 14 (or Reg 18) since these are both related
to the use of fuel oils. There would of course
be no problem in a general environmental
sense since the sulfur content of BOG is
minimal and any post combustion emissions
would hence be well below 6.0 g SOx/kWh.
As such, if there is a system problem or fault
with the BOG supply system (which fell
within the bounds of Reg 3) it is thought that
it would probably be accepted as an allowable
temporary exception.
Where the concern occurs with this approach
would be at terminals or other such points
(such as maneuvering) where BOG only
fuelled operation is not possible and hence
fuel oils (of whatever grade) needed to be used
in part or in full to supply the ship’s power
requirements. Those fuel oils would need to
be sulfur limited to 1.5 percent maximum in
the absence of other control devices.
CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 23
Sludge Creates Problems for Owners
IMO Considers Clarifying the Handling of Oil Residues
A
n increasing number of national
Administrations have adopted a zero
tolerance attitude towards oil based
pollution of the marine environment from ship
operations. Shipowners and their crews face
heavy fines and possible criminal prosecutions
in several jurisdictions, most notably France
and the US.
Yet some of the applicable international
regulations, contained in Annex I to MARPOL
73/78, are considered by many owners to be
either unrealistic or too ambiguous to provide
sufficiently clear, achievable instructions to
adequately protect them and their crews from
potentially damaging legal penalties.
Those concerns have been forcefully expressed
by owners who are seeking technical assistance
in developing proposals to amend Annex I for
submittal to their national Administrations.
The proposals seek to clarify the operational
and documentation requirements related
to the handling of oil residues (sludge) and
bilge water. The national Administration
would then have the option of submitting
suggested amendments and interpretations
of the relevant sections of Annex I to the
24 • CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS
IMO’s Marine Environment Protection
Committee. Denmark has been the leading
advocate in this area.
The issue now appears to be firmly on the
MEPC agenda. Although some owners are
wary that the IMO process may take too
long, given their current exposure to possible
liabilities, there appears to be a growing
consensus that the subject needs to be
addressed and a fairly wide agreement on the
steps that need to be taken.
The focus is on more clearly defining a sludge
tank, determining the appropriate size for such
tanks as current requirements do not provide
realistic guidance and are routinely exceeded
in new designs, and more clearly identifying
the incineration criteria since owners can find
themselves in the position of contravening
elements of MARPOL Annex VI when
attempting to comply with Annex 1.
The other major issue that has yet to be
addressed is which, if any, changes that may
be adopted will apply to existing ships and
which, if any, solely to new construction.
Some owners’ associations, while supporting
the need to reconsider the
design, installation and
the effective and proper
operation of the waste
management system, believe
that any such changes
should only apply to new
ships.
ABS is currently seeking
input from owners on a
wide range of detailed
questions on the manner
in which sludge wastes are
handled on board ships of
different types and sizes
on a day-to-day basis. The
information obtained,
together with developments
at the IMO, will be used to
develop specific guidance
and accompanying notations
for owners seeking to
demonstrate rigorous
compliance with superior
environmental standards.
Slow Progress on
Ship Recycling Draft Convention
A
draft of the proposed IMO Ship
Recycling Convention is now scheduled
for completion for a diplomatic
conference tentatively set for April 2009.
There remain several significant unresolved
issues that resulted in slow progress being
reported on the issue at the 56th Marine
Environment Protection Committee (MEPC)
meeting.
Principal among the unresolved issues are:
• the potential for or the extent to which
the Convention will allow a coastal State
to impose more stringent requirements on
foreign flag ships than that contained in
the draft Convention.
• the development of text to ensure that a new
IMO Convention would not inadvertently
place governments in a position where they
must deal with inconsistent international
obligations between applicable ILO and
IMO Convention requirements.
• the application of the Convention to ships
which have operated exclusively within
the waters of a State and which are recycled
within that same State. While the majority
of those in attendance agreed that such
ships are to be exempted, there were
concerns expressed that possible loopholes
were being introduced in the proposed
text which could circumvent the
requirements.
• a proposed compliance mechanism to assist
implementation by Parties that are recycling
States but whose facilities might not be in
compliance with the requirements of the
Convention remains to be resolved. Addi-
tionally concerns also focused on the ability
to recycle ships in facilities located in non-
Party States.
• agreement was not achieved on the need
for the Convention to require a contract or
agreement between the shipowner and Ship
Recycling Facility.
A small, but notable, bit of progress was that
the Committee agreed to use the word “marine”
in lieu of “aquatic” in the definition of vessel
operation and thereby exclude inland waterway
vessels from the application of the new
Convention.
An intersessional
working group
was hosted by
France in January
2008 to continue
discussion of the
above issues and
concerns.
Convention
Guidelines for
Implementation
With priority given
to completing the
draft Convention, the six identified guidelines
addressing the following issues were not further
developed during MEPC 56 from their draft
condition which has led to some inconsistency
relative to the Convention:
• Developing an Inventory of Hazardous
Materials
• Survey and Certification
• Inspection of Ships
• Authorization of Ship Recycling Facilities
• Safe and Environmentally Sound Ship
Recycling
• Development of the Ship Recycling Plan
IACS continues to be particularly keen on
progressing developments of the Guidelines
for Survey and Certification. The current draft
of the Guidelines calls for a slightly different
approach to be used for existing ships than for
new ships.
Developing the Inventory List of Hazardous
Materials for new ships is primarily dependent
on material declarations from the ship, vendors
and equipment manufacturers whereas existing
ships require hazardous material experts to
carry out documentation review, visual checks
and, where confirmation is not achieved, a
sampling of material.
For new and existing vessels, the Administration
or Recognized Class Society will need to carry
out visual inspections to prepare the ship for
recycling and to facilitate the development of a
Ship Recycling Plan which is to be prepared by
the recycling facility.
CURRENT ENVIRONMENTAL ISSUES - INFORMATION FOR OWNERS • 25
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