Term Paper on "Marpol Annex (VI) Requirements on Sulfur Content"

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Figure 2. Average Sulfur Content of HFO Bunker Production (in MT)

Figure 3. Potential Low Sulphur HFO Bunker Production by Re-Blending (in MT)

An Analysis of the Implications of MARPOL Annex VI Requirements on Sulfur Content of Fuel Oil

Introduction

While marine pollution problems have become more acute and signs of deterioration have appeared more frequently in the marine environmental system, the need for new international roles to protect the marine environment has emerged as a major concern for the world community of nations (Wang 334). One of the principal guiding measures in this regard is the 1973 International Convention for the Prevention of Pollution from Ships, (MARPOL) and the 1978 Protocol, which superseded the 1954 Convention for the Prevention of Pollution of the Sea by Oil and its amendments (Wang 291). This protocol was promulgated by the International Maritime Consultative Organization (named changed to International Maritime Organization, or IMO, in 1982) upon the recommendation of the United States for an expanded role, not only in maritime safety, but in marine environmental protection as well. According to Chasek, the Marine Environmental Protection Committee (MEPC) adopted a "quasi-legislative" approach by making technical changes to the 1973 International Convention for the Prevention of Pollution from Ships (MARPOL) (302).

Regarded by many observers today as being "too little, too late," MARPOL nevertheless represents the culmination of several years' worth of efforts by the international community to address the problems associated with ozone emissions from both land- and sea-based sources. The 1978 MARPOL Protocol is aimed at improving or implementing the existing conventions, the 1973 Convention for the Prevention of Pollution from Ships and the 1975 Vienna Convention for the Protection of the Ozone Layer (Chasek 56).

Annex VI of MARPOL 73/78, Regulations for prevention of Air Pollution from Ships was adopted in 1997 and finally ratified in 2004. The regulations entered into force on May 19, 2005. MARPOL Annex VI covers the following general areas:

ozone depleting substances;

nitrogen oxides (NOx);

sulphur oxides (SOx);

volatile organic compounds (VOC);

reduction in maximum sulphur content in ISO 8217 RM grade fuels specifications;

the creation of Sulphur Emission Control Areas where the maximum sulphur content is 1.5% (Brewer 7).

These regulations are mandatory for vessels of 400 tons and above in gross weight; as a result, the MARPOL Annex VI regulations have been making their impact felt throughout the maritime industry, with ship operators among those being most directly affected (Brewer 8). One of the major requirements in MARPOL Annex VI concerns the sulphur content in marine fuels. Because of the enormous costs involved, this issue has long-term ramifications for ship operations; in addition, because of its profound environmental implications, this issue also has long-term ramifications for everyone on earth. In order to meet the new requirements, both existing vessels and newly constructed craft will therefore be faced with a wide range of challenges and obstacles in ensuring that their onboard fuel treatment plants can accommodate low-sulfur bunkers, particularly during the switchover from low- to high-sulphur fuel use (and vice-versa), whenever the ship enters or leaves areas with specific fuel sulphur content specifications. Furthermore, marine fuel experts have been cautioning the maritime industry about a list of possible engine problems resulting from the prolonged consumption of low-sulphur marine fuels. In this study, the focus will be on operational challenges faced by operators and impact on the refining industry in meeting the MARPOL Annex VI requirements on sulphur contents of fuel oil.

Statement of Problem. For the past half century, the development of global marine environmental principles has assumed an increasing importance in the evolution of the law of the world's oceans. According to Murphy, McCaffrey, Patton and Allard, "Marine shipping, the largest unregulated source of oxides of nitrogen (NOx) emissions, represents a significant long-term obstacle to achieving ozone standards in coastal areas" (1). There is a growing awareness among the international community concerning the significance of shipping emissions because ships are increasing in number, size, carrying capacity and speed and fuel use is increasing proportionally.

Furthermore, the most common fuel used in large ship engines is residual heavy fuel oil; this type of fuel continues to decrease in quality, while a greater number of engines are being designed to use this lower-quality fuel. Sulphur is naturally present in fuel oil and is released as sulphur dioxide when oil is burned in engines (Consultation Paper regarding the European Commission's proposal for a Directive amending Directive 1999/32/EC as regards the sulphur content of marine fuels 3). Consequently, there is an increasing awareness of the impacts of shipping emissions on onshore air quality. Today, an estimated 85% of international shipping traffic occurs in the northern hemisphere, and 70% of that is within 400 km (240 miles) of land. Much of the shipping activity and associated emissions occur near major urban areas, many of which are already struggling with air quality problems.

Research Questions.

The following research questions will guide this study:

1. What is MARPOL and what effect has it had on emission standards to date?

2. What are the issues involved in developing more environmentally friendly marine fuels given the trends toward lower sulfur content?

3. What steps can be taken to mitigate the impact of these lower-quality marine fuels?

Research Methodology.

The proposed research methodology will be a critical review of the peer-reviewed and scholarly literature to identify answers to the above-stated research questions. Issues to be considered include:

Operational aspects of a sulphur limit on marine fuels. Low sulphur fuel oil might involve re-blending of current high sulphur fuel oil or other products. This option presents a risk for producing unstable low sulphur bunkers. The design of fuel systems and their design to handle different fuels will be considered.

Because of drastically different change-over periods, depending on fuel oil system layout and vessel trading pattern, some engines will have to operate almost entirely on low-sulphur fuel while others may actually benefit from a dual fuel system. According to Reeds, "Today's marine diesel engine is remarkably robust. It will run on almost anything, even crude oil at a pinch. In the 1980s a few unscrupulous owners were caught fuelling tankers with crude bled off from the cargo. Even the usual bunker fuel is a mucky blend of heavy oils that no-one else wants because it's so filthy" (100). These trends and the others discussed below could result in a relative distortion of vessel operating costs, with unscrupulous or "flag of convenience" carriers being able to unfairly compete with more environmentally responsible carriers, all at the detriment of the global environment. Depending on the vessel type and trading pattern (in and outside the SECA zones), this might/might not induce a requirement for multiple (dual) fuel and lube oil systems. The major issues involved are:

a. Fuel oil incompatibility;

b. Fuel change-over issues;

c. Base number - sulphur balance: Acid/Alkalinity;

d. Duration of fuel change-over - the 'Sulphur Battery.'

2.

The availability of low sulphur fuel in the future.

Review of the Literature

Background and Overview.

According to Wang, the 1973 MARPOL Convention was the result of efforts by 71 member nations of the International Conference on Marine Pollution. This protocol came into force after 15 nations ratified it on October 2, 1983, a decade after its adoption; the merchant fleets of the 15 original contracting parties, though, represented fully 50% of the world's total tonnage. These countries were: Colombia, Italy, Tunisia, Denmark, Liberia, United Kingdom, France, Norway, United States, Federal Republic of Germany, Peru, Uruguay, Greece, Sweden, and Yugoslavia (Wang 334).

The 1973 MARPOL Convention was the maritime industry's response to the new realities that existed in the global transport of oil… READ MORE