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The flow chart above is meant as a general guidance indicating the necessary stepsfor you to consider regarding the NOx requirements of Annex VI. Please note that theflow chart is only concerning the NOx requirements to the diesel engines, and this isalso what the EIAPP certificate is covering.If you find that your engines are required to carry an EIAPP certificate, but for somereason they don’t have this, our advice is for you to approach the enginemanufacturer for further assistance.The certification process includes an emission test for compliance with the NOxrequirements on the manufacturer’s test bed, and approval of the Technical File.All certified engines are delivered with an individual Technical File that contains theengine’s specifications for compliance with the NOx regulation, and the applicableonboard verification procedure.The NOx Technical Code opens for 3 different onboard verification procedures:- Engine parameter check method- Simplified measurement method- Direct measurement and monitoring methodThe applicable onboard verification procedure is initially decided by the enginemanufacturer, and is usually a specific chapter in the engine’s Technical File. The byfar most common method is the Engine parameter check method, but the ship owneris free to use the method they prefer. If they wish to change to another method thanthe one specified in the Technical File, the new onboard verification procedure mustbe submitted to the Administration (or DNV on behalf of the Administration whenauthorised) for approval before taken into use.4.2.1 Engine parameter check methodFor the purpose of assessing compliance with Regulation 13 of Annex VI, it is notalways necessary to measure the NOx level to know that an engine is likely tocomply with the NOx emission limits. It will be sufficient to know that the present stateof the engine corresponds to the specified components, calibration or parameteradjustment state at the time of initial certification.The engine’s Technical File is identifying its components, settings and operatingvalues that influences the exhaust emissions and these must be checked to ensurecompliance during surveys and inspections.Ship owners or people responsible for vessels equipped with diesel engines requiredto undergo an engine parameter check method shall ensure that the followingdocumentation is kept onboard and updated as applicable:- Technical File including the onboard verification procedure.- Record book of engine parameters for recording all of the changes maderelative to an engine’s components and settings. Also to include technicaldocumentation in case of modification of any of the engine’s designatedcomponents.- EIAPP certificate (Statement of Compliance) for each applicable engine.6

The NOx-influencing components and settings depend on the design of the particularengine, and shall be listed in the engine’s Technical File. The below list shows typicalNOx-influencing parameters:- Injection timing- Injection system components (nozzle, injector, fuel pump)- Injection pressure- Camshaft components (fuel cam, inlet- and exhaust cam)- Valve timing- Combustion chamber (piston, cylinder head, cylinder liner)- Compression ratio (connecting rod, piston rod, shim, gaskets)- Turbocharger type and build (internal components)- Charge air cooler/charge air pre-heater- Auxiliary blower- NOx reducing equipment “water injection”- NOx reducing equipment “emulsified fuel” (fuel/water emulsion)- NOx reducing equipment “exhaust gas recirculation”- NOx reducing equipment “selective catalytic reduction”The actual Technical File of an engine may include less components and/orparameters other than the list above, depending on the particular engine and thespecific engine design.4.2.2 Simplified measurement methodFor onboard verification tests during periodical and intermediate surveys, the NOxTechnical Code opens for a simplified measurement method. Note that every firstengine test for certification shall be performed on the engine maker’s test-bed.The simplified measurement method is to be performed more or less like the parenttesting on the test-bed, but simplifications according to the NOx Technical Code 6.3are accepted.However, the testing shall be performed in accordance with the applicable test cycleas specified in the engine’s Technical File. This involves full load running of theengine for about 20 minutes, and will in most cases require a test trial.Due to the possible deviations when applying the simplified measurement method, anallowance of 10% of the applicable limit value is accepted for confirmation tests andduring periodical and intermediate surveys.4.2.3 Direct measurement and monitoring methodThe ship-owner will have the option of direct measurement of the NOx emissionsduring the engine operation. Such data can either take the form of spot checkslogged with other engine operating data on a regular basis and over the full range ofengine operation, or they can result from continuous monitoring and date storage.Data must be taken within the last 30 days, and must have been acquired using thetest procedures given in the NOx Technical Code. These monitoring records are to7

be kept onboard for at least three months for verification purposes. We wouldhowever recommend maintaining the documents, on board or in shore office, for alonger period of time.To demonstrate the compliance by the direct measurement method, sufficient datashall be collected to calculate the weighed average NOx emissions in accordancewith the NOx Technical Code.It should be noted that the two methods that involve measuring of the exhaustemissions do not include any kind of identification markings of the NOx-influencingcomponents.4.3 Spare parts and spare parts policyOne of the main consequences of MARPOL Annex VI is that the onboard verificationprocedure “Engine parameter check method” requires identification markings on theNOx influencing components. These components are typically those specified inabove list.All the components listed are to be fitted with identification markings according to theTechnical File. Please note that these markings may not be the same as the articleno’s usually found on the engine components.DNV, on behalf of the Flag Administration, can not accept any other markings thanthose stated in the Technical File. Manufacturer’s producing engines on licenseefrom an engine designer usually have their own Id Numbers on the enginecomponents. Since these numbers may differ from the designer’s Id Numbers, it maybe advisable to ask the licensee to also include the designer’s Id No’s in theTechnical Files.In order to make the purchasing easier, it could be an idea to keep a copy of theTechnical Files in the purchasing section.There may be situations where the engine maker comes up with a new design forone of the NOx-influencing components, with a different Id No from what’s stated inthe Technical File. The new design should then be approved by the Administration(or DNV on behalf of a Flag Administration when authorised) and the change is to bedocumented in the “Record book of engine parameters”. The same is applicable forall other changes the engine may be approved for during its lifetime.4.4 Surveys and inspectionsFollowing the regime of the IAPP certificate, the diesel engines will also be subject forthe following surveys:- An initial survey before the ship is put into service or before the IAPPCertificate is issued for the first time.- Periodical surveys at intervals specified by the Administration, but notexceeding five years,- A minimum of one intermediate survey during the period of validity of thecertificate.8

-Annual Surveys (or a Flag Administration may instead implementunscheduled inspections as an alternative to Annual surveys)If the “Engine Parameter Check Method” is the selected onboard verificationprocedure, the surveyor will typically want to see:- EIAPP Certificates for all applicable diesel engines onboard- Approved Technical Files including “Onboard verification procedure” for allthe applicable diesel engines onboard- Record Book of Engine parameters for all the applicable diesel enginesonboard- One or all of the identified components, settings or operating valuesspecified in the engines’ Technical FileIf the “Simplified Measurement Method” is the selected onboard verificationprocedure, the surveyor will witness the testing in addition to review the followingdocumentation:- EIAPP Certificates for all applicable diesel engines onboard- Approved Technical Files including “Onboard verification procedure” for allthe applicable diesel engines onboard- All recommendations from engine manufacturer and approvals from theAdministration concerning the “Simplified Measurement Method”- Test resultsIf the “Direct Monitoring and Measurement Method” is the selected onboardverification procedure, the surveyor will typically want to see:- EIAPP Certificates for all applicable diesel engines onboard- Approved Technical Files including “Onboard verification procedure” for allthe applicable diesel engines onboard- Documentation/Approval of the installed measuring equipment- Logged measurement results in order to verify that the engines comply withthe NOx Technical Code.Regardless of what onboard verification procedure the Ship-Owner chooses, theIAPP Certificate for the vessel will be issued if all other requirements are found tocomply with the applicable requirements.4.5 Engines with EIAPP certificates issued by another companyThere are a number of different companies that are certifying diesel engines withregard to NOx-emissions. DNV, on behalf of the Flag Administration, can only acceptcertification from companies that are authorised by the applicable flag to performcertification on their behalf. This procedure will be based on a case-by-case approval.The certificates and Technical Files, including all possible upgrades, are to besubmitted to DNV for review.9

5. Regulation 14 - Sulphur Oxides (SOx)5.1 GeneralUpon entry into force of Annex VI to MARPOL on the 19 May 2005, the sulphur oxide(SOx) emissions from ships will be controlled by setting a limit of 4.5% on the sulphurcontent of marine fuel oils.Further, a limit of 1.5% on the sulphur content of marine fuel oil will apply indesignated SOx Emission Control Areas (SECAs). IMO has currently agreed on thedesignation of two SECA’s as per below. The first designated SECA is the Baltic SeaArea which has been agreed that will enter into force on the 19 May 2006.The second area, the North Sea Area and the English Channel has also beenagreed, but due to the amendment process in IMO, it has been indicated that it willnot enter into force as a SECA until 19 November 2007. It is expected that furtherSECA’s will be designated in the future and IMO has set forth certain criteria fordesignating such SECA’s. It should however be noted that the amendment processwithin IMO may take considerable time.For the sake of good order, it should be noted that the limitations in sulphur contentapplies to all fuel oils (heavy fuel oils, marine diesel oils and gas oils) and regardlessof use on board (i.e. in combustion engines, boilers, gas turbines etc.).Indication of SECA’sCurrently, the average sulphur content in fuel oils is in the region of 2.7%. Results ofthe comprehensive number of fuel samples tested by DNV Petroleum Servicesindicate that only 0.2% of the fuel oils tested have a sulphur content exceeding therequired 4.5%. However, it also indicates that only 4% of the fuel oils supplied todayhave a sulphur content of 1.5% or less.It has been estimated that the low sulphur fuel oil demand in the SECA’s will be in theregion of 14-20 million tons per year, of which approximately 0.7 million tons per yearis available in North West Europe today.10

While certain owners with a high environmental profile currently have a sulphur limitof 1.5% in their fuel specifications, the sulphur content of the fuel is generallydependent on the composition of the crude oil from which it is refined. Increasing theoutput of low sulphur fuel oil can be obtained through the following:- Refining of naturally occurring low sulphur crude oils.- Re-direct/blend inland grade fuel to the marine fuel market.- Re-blending of residual fuel oils down to the required specification.- Residue de-sulphurisation (Note that large scale investments in residue desulphurisation units are not expected to be made until a substantial pricedifference between high and low sulphur fuels are achieved).It is generally acknowledged that the above will lead to increased prices for lowsulphur fuel oils and a price hike from 25 to 100 USD/ton has been indicateddepending on method of production and market availability/demand.Although it has been indicated that the total world wide availability of low sulphur fuelis adequate with the current SECA’s and associated low sulphur limit (1.5%), it ishighly uncertain as to whether the availability will be adequate in world wide ports. Itshould further be noted that currently, low sulphur fuel is in general only available tooperators with contract agreements with Oil Majors. Future spot availability is thusdependent on the developments in market demand and price after entry into force ofSECA’s.5.1.1 Exhaust Gas Cleaning systemsAs an alternative to using marine fuel oil with a 1.5% sulphur content in SECA’s, anexhaust gas cleaning system or other equivalent system may be used (abatementtechnologies). The emission criteria for such systems are 6 g SOx/kWh.Overboard Discharge of cleanedwaterScrubbed & re-heated exhaust gasesScrubbed gas re-heat sectionIntimate mixing of exhaustgas and sea waterSeparation and Filtration PlantSea WaterS.W. to cyclone separator& heat exchangerS.W. InletExhaust GasesSludge ashore to authorisedcontractorExhaust gas cleaning system11

Development of a type approval standard for such systems is ongoing in IMO. Thecurrent available abatement technology is based on seawater scrubbing principles.There is however a few concerns related to these types of scrubber type systems:----Annex VI states that port states may prohibit discharge of scrubber effluentoverboard in ports within SECA’s unless it can be documented that the effluentcomplies with criteria set by that port state. A mitigating measure is installationof filtration/treatment systems.It has been indicated that conventional scrubber technology may be strugglingto meet the emission criteria at high exhaust gas discharge flows.It has been indicated that there is a risk of blue-sheen originating from thescrubber overboard discharge. Although, not necessarily constituting anenvironmental hazard, the mere risk of such occurrences is to some operatorsunacceptable.There are space considerations in the engine room and more specifically thefunnel. Although it has been indicated that the more advanced scrubber typescan replace standard silencers, the associated piping systems may representa challenge. Pressure drop in scrubbers has also been indicated as alimitation, particular in way of main engines uptakes.Tanker owners have had mixed experiences with corrosion of inert gasscrubbers and associated piping systems.The EU has been reluctant to accept scrubbers. However, in the latestproposed amendments to the EU directive, they have opened for “trials of shipemission abatement technologies”. Based on such trials they have indicatedthat they may accept abatement technology as an equivalent to low sulphurfuel. Note that EU has indicated that it will develop criteria for resulting wastestreams in their ports.Regrettably, the number of development projects related to new scrubber technologyappears to be limited. However, some projects currently in the prototype phase showpromising results in terms of overcoming the above indicated constraints. It shouldalso be taken into account that exhaust gas cleaning alternatives will reduce theemission of particulate matter (PM). Particulate matter is considered to be the nextfocal point of IMO and this increases the future relevance of exhaust gas cleaningsystems.Despite the indicated installation costs of 1-2 mill USD, future legislation, andelimination of the problems associated with low sulphur fuel bunker management andoperation, may lead to exhaust gas cleaning systems becoming a cost-beneficialalternative worthwhile exploring.12

5.2 EU Directive 1999/32/EC with proposed amendmentsIn connection with MARPOL Annex V

The certification process includes an emission test for compliance with the NOx requirements on the manufacturer's test bed, and approval of the Technical File. All certified engines are delivered with an individual Technical File that contains the engine's specifications for compliance with the NOx regulation, and the applicable