15-09-2021

Nox Osx

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  1. Nox Os X
  2. Nox Oxides Of Nitrogen
The control of diesel engine NOx emissions is achieved through the survey and certification requirements leading to the issue of an Engine International Air Pollution Prevention (EIAPP) Certificate and the subsequent demonstration of in service compliance in accordance with the requirements of the mandatory, regulations 13.8 and 5.3.2 respectively, NOx Technical Code 2008 (resolution MEPC.177(58) as amended by resolution MEPC.251.(66)).
The NOx control requirements of Annex VI apply to installed marine diesel engine of over 130 kW output power other than those used solely for emergency purposes irrespective of the tonnage of the ship onto which such engines are installed. Definitions of ‘installed’ and ‘marine diesel engine’ are given in regulations 2.12 and 2.14 respectively. Different levels (Tiers) of control apply based on the ship construction date, a term defined in regulations 2.19 and hence 2.2, and within any particular Tier the actual limit value is determined from the engine’s rated speed:
Ship construction date on or after
n = engine’s rated speed (rpm)
n = 130 - 1999
I
17.0
e.g., 720 rpm – 12.1
II
14.4
e.g., 720 rpm – 9.7
III
3.4
e.g., 720 rpm – 2.4
TheTier III controls apply only to the specified ships while operating in EmissionControl Areas (ECA) established to limit NOx emissions, outside such areas theTier II controls apply. In accordancewith regulation 13.5.2, certain small ships would not be required to installTier III engines.

A marine diesel engine that is installed on a ship constructed on or after the following dates and operating in the following ECAs shall comply with the Tier III NOx standard:

.1 1 January 2016 and operating in the North American ECA and the United States Caribbean Sea ECA; or

.2 1 January 2021 and operating in the Baltic Sea ECA or the North Sea ECA.

The emission value for a diesel engine is to be determined in accordance with the NOx Technical Code 2008 in the case of Tier II and Tier III limits. Most Tier I engines have been certified to the earlier, 1997, version of the NOx Technical Code which, in accordance with MEPC.1/Circ.679, may continue to be used in certain cases until 1 January 2011. Certification issued in accordance with the 1997 NOx Technical Code would still remain valid over the service life of such engines.
An engine may be certified on an individual, Engine Family or Engine Group basis in accordance with one or more of the four duty test cycles as given in appendix II of the Annex. In the case of Engine Family or Engine Group engines it is the Parent Engine which is actually emissions tested, this is the engine which has the combination of rating (power and speed) and NOx critical components, settings and operating values which results in the highest NOx emission value or, where more than one test cycle is to be certified, values which, to be acceptable, each of which must be no higher than the applicable Tier limit value. Subsequent series engines, Member Engines, are thereafter constructed with a rating, components, settings and operating values within the bounds established for the respective Engine Family or Engine Group. Generally all new engine certification leading to the issue of an EIAPP Certificate is undertaken at the engine builder’s works where the necessary pre-certification survey takes place.
Consequently a diesel engine having an EIAPP Certificate is approved, by, or on behalf of (since almost all engine certification work is delegated to Recognized Organizations), the flag State of the ship onto which it is to be installed, to a stated Tier for one or more duty test cycles, for a particular rating or rating range, and with defined NOx critical components, settings and operating values including options if applicable. Any amendments to these aspects are to be duly approved and documented.
For each NOx certified diesel engine there must be onboard an approved Technical File, NOx Technical Code 2008, regulation 2.3.4, which both defines the engine as approved and provides the applicable survey regime together with any relevant approved amendment documentation. As of October 2010 virtually all engines are surveyed using the Parameter Check method, NOx Technical Code 2008, regulation 2.4.3.1, whereby the actual duty, rating and NOx critical components, settings and operating values are checked against the given data in the Technical File. A key document in the Parameter Check procedure is the Record Book of Engine Parameters, NOx Technical Code 2008, regulation 6.2.2.8, which is maintained to record all replacements and changes to NOx critical components, settings and operating values. Engine surveys are undertaken on completion of manufacture and subsequently as part of the overall ship survey process; flowcharts illustrating the aspects checked at the various survey stages are given in NOx Technical Code 2008 appendix II.
In addition, there is the case where a diesel engine is subject to “major conversion”, regulation 13.2. Of the three routes given, “substantial modification” and uprating, both as defined, involve changes to an existing installed engine and under these circumstances the relevant Tier is that applicable to the construction date of the ship onto which the engine is installed except, in the case of ships constructed before 1 January 2000, where Tier I is applied. In the third route, that of the installation of a replacement, non-identical, or additional engine then the Tier appropriate to the date of installation applies although, subject to acceptance by the Administration taking into account guidelines, in some circumstances it would permitted to install a Tier II replacement engine as opposed to one certified to Tier III, regulation 13.2.2. In the case of an identical replacement engine the Tier appropriate to the ship construction date applies.
The revised Annex VI has also introduced the prospect of retrospective NOx certification, regulation 13.7, in the case of diesel engines of more than 5000 kW power output and a per cylinder displacement of 90 litres and above installed on ships constructed between 1 January 1990 and 31 December 1999. This will generally therefore affect only the main engines on such ships, the 90 litre/cylinder criteria represents, for example in current medium speed engine designs, engines with a bore of 460 mm and above. For these engines if a Party, not necessarily the ship’s flag State, has certified an 'Approved Method' which results in an emission value no higher than the relevant Tier I level and has advised of that certification to IMO then that Approved Method must be applied no later than the first renewal survey which occurs more than 12 months after deposition of the advice to IMO. However, if the ship owner can demonstrate that the Approved Method is not commercially available at that time then it is to be installed no later than the next annual survey after which it has become available. Given within regulation 13.7 are constraints on the Approved Method that limit its cost and detrimental effects on engine power and fuel consumption. Notifications of Approved Method from Parties are available through GISIS.
Further requirements are given in chapter 7 of the NOx Technical Code 2008 which includes an outline of the Approved Method File which must be retained with the engine. To date several notifications of Approved Methods have been advised to the Organization. It is not clear the extent to which others will become available however it is expected that, if so developed, these will be limited to involving aspects such as changing the engine’s fuel injection nozzles. Consequently, in the case of engines potentially subject to the requirement to install an Approved Method it will be necessary for ship owners (and also surveyors and port State inspectors) to remain vigilant over the service life of those engines as to the availability of such arrangements and to ensure that they are duly fitted and thereafter retained as required. For those engines where an Approved Method exists there is the alternative option, regulation 13.7.1.2, whereby the engine is instead certified in accordance with the conventional NOx Technical Code requirements.

Background

International Maritime Organization (IMO) is an agency of the United Nations which has been formed to promote maritime safety. It was formally established by an international conference in Geneva in 1948, and became active in 1958 when the IMO Convention entered into force (the original name was the Inter-Governmental Maritime Consultative Organization, or IMCO, but the name was changed in 1982 to IMO). IMO currently groups 167 Member States and 3 Associate Members.

IMO ship pollution rules are contained in the “International Convention on the Prevention of Pollution from Ships”, known as MARPOL 73/78. On 27 September 1997, the MARPOL Convention has been amended by the “1997 Protocol”, which includes Annex VI titled “Regulations for the Prevention of Air Pollution from Ships”. MARPOL Annex VI sets limits on NOx and SOx emissions from ship exhausts, and prohibits deliberate emissions of ozone depleting substances from ships of 400 gross tonnage and above engaged in voyages to ports or offshore terminals under the jurisdiction of states that have ratified Annex VI.

The IMO emission standards are commonly referred to as Tier I...III standards. The Tier I standards were defined in the 1997 version of Annex VI, while the Tier II/III standards were introduced by Annex VI amendments adopted in 2008, as follows:

  • 1997 Protocol (Tier I)—The “1997 Protocol” to MARPOL, which includes Annex VI, becomes effective 12 months after being accepted by 15 States with not less than 50% of world merchant shipping tonnage. On 18 May 2004, Samoa deposited its ratification as the 15th State (joining Bahamas, Bangladesh, Barbados, Denmark, Germany, Greece, Liberia, Marshal Islands, Norway, Panama, Singapore, Spain, Sweden, and Vanuatu). At that date, Annex VI was ratified by States with 54.57% of world merchant shipping tonnage.

    Accordingly, Annex VI entered into force on 19 May 2005. It applies retroactively to new engines greater than 130 kW installed on vessels constructed on or after January 1, 2000, or which undergo a major conversion after that date. The regulation also applies to fixed and floating rigs and to drilling platforms (except for emissions associated directly with exploration and/or handling of sea-bed minerals). In anticipation of the Annex VI ratification, most marine engine manufacturers have been building engines compliant with the above standards since 2000.

  • 2008 Amendments (Tier II/III)—Annex VI amendments adopted in October 2008 introduced (1) new fuel quality requirements beginning from July 2010, (2) Tier II and III NOx emission standards for new engines, and (3) Tier I NOx requirements for existing pre-2000 engines.

    The revised Annex VI entered into force on 1 July 2010. By October 2008, Annex VI was ratified by 53 countries (including the Unites States), representing 81.88% of tonnage.

Emission Control Areas. Two sets of emission and fuel quality requirements are defined by Annex VI: (1) global requirements, and (2) more stringent requirements applicable to ships in Emission Control Areas (ECA). An Emission Control Area can be designated for SOx and PM, or NOx, or all three types of emissions from ships, subject to a proposal from a Party to Annex VI.

Definition

Existing Emission Control Areas include:

  • Baltic Sea (SOx: adopted 1997 / entered into force 2005; NOx: 2016/2021)
  • North Sea (SOx: 2005/2006; NOx: 2016/2021)
  • North American ECA, including most of US and Canadian coast (NOx & SOx: 2010/2012).
  • US Caribbean ECA, including Puerto Rico and the US Virgin Islands (NOx & SOx: 2011/2014).

Greenhouse Gas Emissions. 2011 Amendments to MARPOL Annex VI introduced mandatory measures to reduce emissions of greenhouse gases (GHG). The Amendments added a new Chapter 4 to Annex VI on “Regulations on energy efficiency for ships”.

NOx Emission Standards

The NOx emission limits of Regulation 13 of MARPOL Annex VI apply to each marine diesel engine with a power output of more than 130 kW installed on a ship. A marine diesel engine is defined as any reciprocating internal combustion engine operating on liquid or dual fuel. There are two exceptions: engines used solely for emergencies and engines on a ships operating solely within the waters of the state in which they are flagged. The later exception only applies if these engines are subject to an alternative NOx control measure.

NOx emission limits are set for diesel engines depending on the engine maximum operating speed (n, rpm), as shown in Table 1 and presented graphically in Figure 1. Tier I and Tier II limits are global, while the Tier III standards apply only in NOx Emission Control Areas.

Table 1. MARPOL Annex VI NOx emission limits
TierDateNOx Limit, g/kWh
n < 130130 ≤ n < 2000n ≥ 2000
Tier I200017.045 · n-0.29.8
Tier II201114.444 · n-0.237.7
Tier III2016†3.49 · n-0.21.96
† In NOx Emission Control Areas (Tier II standards apply outside ECAs).

Tier II standards are expected to be met by combustion process optimization. The parameters examined by engine manufacturers include fuel injection timing, pressure, and rate (rate shaping), fuel nozzle flow area, exhaust valve timing, and cylinder compression volume.

Tier III standards are expected to require dedicated NOx emission control technologies such as various forms of water induction into the combustion process (with fuel, scavenging air, or in-cylinder), exhaust gas recirculation, or selective catalytic reduction.

Pre-2000 Engines. Under the 2008 Annex VI amendments, Tier I standards become applicable to existing engines installed on ships built between 1st January 1990 to 31st December 1999, with a displacement ≥ 90 liters per cylinder and rated output ≥ 5000 kW, subject to availability of approved engine upgrade kit.

Testing. Engine emissions are tested on various ISO 8178 cycles (E2, E3 cycles for various types of propulsion engines, D2 for constant speed auxiliary engines, C1 for variable speed and load auxiliary engines).

Addition of not-to-exceed (NTE) testing requirements to the Tier III standards is being debated. NTE limits with a multiplier of 1.5 would be applicable to NOx emissions at any individual load point in the E2/E3 cycle.

Engines are tested using distillate diesel fuels, even though residual fuels are usually used in real life operation.

Further technical details pertaining to NOx emissions, such as emission control methods, are included in the mandatory “NOx Technical Code”, which has been adopted under the cover of “Resolution 2”.

Sulfur Content of Fuel

Annex VI regulations include caps on sulfur content of fuel oil as a measure to control SOx emissions and, indirectly, PM emissions (there are no explicit PM emission limits). Special fuel quality provisions exist for SOx Emission Control Areas (SOx ECA or SECA). The sulfur limits and implementation dates are listed in Table 2 and illustrated in Figure 2.

Table 2. MARPOL Annex VI fuel sulfur limits
DateSulfur Limit in Fuel (% m/m)
SOx ECAGlobal
20001.5%4.5%
2010.071.0%
20123.5%
20150.1%
20200.5%

Heavy fuel oil (HFO) is allowed provided it meets the applicable sulfur limit (i.e., there is no mandate to use distillate fuels).

Alternative measures are also allowed (in the SOx ECAs and globally) to reduce sulfur emissions, such as through the use exhaust gas cleaning systems (EGCS), aka scrubbers. For example, in lieu of using the 0.5% S fuel (2020), ships can fit an exhaust gas cleaning system or use any other technological method to limit SOx emissions to ≤ 6 g/kWh (as SO2).

Greenhouse Gas Emissions

Nox Os X

MARPOL Annex VI, Chapter 4 introduces two mandatory mechanisms intended to ensure an energy efficiency standard for ships: (1) the Energy Efficiency Design Index (EEDI), for new ships, and (2) the Ship Energy Efficiency Management Plan (SEEMP) for all ships.

  • The EEDI is a performance-based mechanism that requires a certain minimum energy efficiency in new ships. Ship designers and builders are free to choose the technologies to satisfy the EEDI requirements in a specific ship design.
  • The SEEMP establishes a mechanism for operators to improve the energy efficiency of ships.

The regulations apply to all ships of 400 gross tonnage and above and enter into force from 1 January 2013. Flexibilities exist in the initial period of up to six and a half years after the entry into force, when the IMO may waive the requirement to comply with the EEDI for certain new ships, such as those that are already under construction.

In April 2018, the IMO adopted an Initial Strategy on the reduction of GHG emissions from ships [3949], with a target to reduce the total annual GHG emissions by at least 50% by 2050 compared to 2008. The strategy calls for strenghtening the EEDI requirements and a number of other measures to reduce emissions, such as operational efficiency measures, further speed reductions, measures to address CH4 and VOC emissions, alternative low-carbon and zero carbon fuels, as well as market-based measures (MBM).

Other Provisions

Ozone Depleting Substances. Annex VI prohibits deliberate emissions of ozone depleting substances, which include halons and chlorofluorocarbons (CFCs). New installations containing ozone-depleting substances are prohibited on all ships. But new installations containing hydro-chlorofluorocarbons (HCFCs) are permitted until 1 January 2020.

Annex VI also prohibits the incineration on board ships of certain products, such as contaminated packaging materials and polychlorinated biphenyls (PCBs).

Nox Oxides Of Nitrogen

Compliance. Compliance with the provisions of Annex VI is determined by periodic inspections and surveys. Upon passing the surveys, the ship is issued an “International Air Pollution Prevention Certificate”, which is valid for up to 5 years. Under the “NOx Technical Code”, the ship operator (not the engine manufacturer) is responsible for in-use compliance.