MARINE ENVIRONMENT MEPC

4/1
PROTECTION COMMITTEE 23 July
2022
1st session Original:ENGLISH
Agenda item 4 Pre-session public
release:☒

REDUCTION OF GHG EMISSION FORM SHIPS

Proposed amendment to MARPOL ANNEX VI, REGULATION 12 AND

RELEVANT GUIDELINES
MEPC.1/Circular.589 – Greenhouse Gas Module in the Global Integrated
Shipping Information System – (17 March 2008)

Submitted by THE REPUBLIC OF INDONESIA

SUMMARY
Executive This paper draws the attention of the Marine Environment Protection
summary: Committee towards the need of requirement for GHG emission owing to the
damages to the environment.

Refer to my comments on the earlier paper

The meeting is invited to discuss the document and decide on further actions with
regard to the reduction of GHG emissions during transportation of cargo, emitted by
main engine and other auxiliary machineries.
MEPC Circulars

1. The Marine Environment Protection Committee, at its fifty-sixth session (July 2007),agreed
to the format for a greenhouse gas (GHG) module in the Global Integrated Shipping
Information System (GISIS) based on the Interim Guidelines for Voluntary Ship CO2
Emission Indexing for Use in Trials (MEPC/Circ.471).
2. IMO Assembly resolution A.963(23) on “IMO Policies and Practices Related to the
Reduction of Greenhouse Gas Emissions from Ships” urged the Marine Environment
Protection Committee (MEPC) to identify and develop the mechanism or mechanisms needed
to achieve the limitation or reduction of Greenhouse Gas (GHG) emissions from international
shipping and, in doing so, to give priority to the establishment of a GHG baseline; and the
development of a methodology to describe the GHG efficiency of a ship in terms of GHG
emission index for that ship. In developing the methodology for the GHG emission indexing
scheme, MEPC should recognize that CO2 is the main greenhouse gas emitted by ships.
3. As urged by the Assembly, MEPC 53 (July 2005) approved Interim Guidelines for Voluntary
Ship CO2 Emission Indexing for Use in Trials (MEPC/Circ.471).
4. The Interim Guidelines should be used to establish a common approach for trials on
voluntary CO2 emission indexing, which will enable shipowners to evaluate the performance
of their fleet with regard to CO2 emissions. As the amount of CO2 emitted from a ship is
directly related to the consumption of bunker fuel oil, the CO2 indexing will also provide
useful information on a ship's performance with regard to fuel efficiency.
5. The Committee invites Members States to input CO2 indexing data from voluntary trials into
the GHG module in GISIS. The procedures for inputting the data is available at the IMO
website (http://gisis.imo.org/Members/GHG).
6. The CO2 Index is used as an interim monitoring index for energy efficiency of a ship in
operation, limited to efficiency expressed as CO2 emitted per unit of transport work.
7. The format for a GHG module in GISIS is based on the Interim Guidelines for Voluntary
Ship CO2 Emission Indexing for Use in Trials and is attached as annex to this circular.

DEVELOPMENT IN IMO

1. Annex VI to the MARPOL 73/78 Convention entered into force 19 May 2005. The current
Annex VI covers ozone-depleting substances, nitrogen oxides (NOx), sulphur oxides (SOx)
and volatile organic compounds (VOC). Annex VI does not limit VOC emissions but it
accepts the right of a Party to the Protocol of 1997 to regulate VOC emissions in its ports or
terminals.
2. New installations which containing Ozone-depleting substances shall be prohibited on all
ships, except new installations containing HCFCs, which are permitted until 1 January 2020.

3.  With respect to the completion of the IAPP certificate supplement items 2.1.2 and 2.1.3,
permanently sealed refrigeration equipment should not be included. Permanently sealed
refrigeration equipment are equipment where there is no refrigerant charging connections or
potentially removable components
Challenges related to GHG emissions
1. The marine sector has a significant challenge from decarbonization, which is raising concerns
about how to meet the IMO’s initial strategy for reducing GHG emission form ships. The
IMO committed in to achieve maximum GHG emission from shipping as soon as possible
and to reduce the total amount of GHG emission by at least 50% by 2050. GHG reduction
can be defined as one of the key challenges in shipping, leading to significant environmental
changes that subsequently affect all industry participants (DNVGL 2017, p. 55; Wartsila n.d.-
a).

2. IMO has obligatory measures to diminish the outflows of GHG from international shipping,
beneath IMO’s pollution prevention treaty (MARPOL)- the Energy Efficiency Design Index
(EEDI) mandatory for the new ships, and the Ship Energy Efficiency Management Plan
(SEEMP).
Current practice
During unloading and loading, most tanker vessels use the safety device (Pressure-vacuum valve/PV
Valve) to protect the cargo tank against unacceptable negative internal pressure and over pressure.
Through this valve atmospheric air is sucked into the cargo tank and excess vapour is emitted out
from the cargo tank to bring the internal pressure back to an acceptable level. If the pressure-vacuum
valve fails, the instrument for measuring the pressure of the vapour phase inside the cargo tanks will
be activated.
This practice raises many questions about safety:
 Is it desirable that a safety device like the pressure-vacuum valve (PV Valve) is used during
normal operations?
 Is it desirable that atmospheric air is sucked into the cargo tank which could create an
explosive mixture with the vapours of the unloaded cargo?
 Is it desirable that vapours are emitted out into the atmosphere which could be catastrophic to
the environment while loading?
These safety questions could easily be solved by prescribing the use of the vapour return line during
unloading and loading, with which the vessel receives the vapours back of the substance which it is
currently unloading or loading.
The Republic of Indonesia recognizes and strongly supports the need to improve the global
environment and address local health and environmental concerns by reducing VOCs emissions
from tankers engaged in international trade. However it must also be recognized that Annex VI has
only entered into force but the improvements generated have yet to be measured.
The Republic of Indonesia has always advocated a holistic approach to reducing air emissions from
shipping andbelieves that it is essential to undertake a scientific assessment of the critical emissions
to becontrolled and create a situation where specified local environmental vulnerabilities can benoted
and justified.
Volatile Organic Compounds (VOC). The Republic of Indonesia also welcomes the intention to
include a VOCmanagement plan in the revised Annex VI. It should be recognized that the carriageof
VOC equipment on board tankers is only half of the solution and implies that shore returnfacilities
will be available in the terminals.
The Republic of Indonesia recommends that provision should be made now for a further review of
air emission achievements five years after the entry into force of the revised Annex VI.
The Model IMO is requested to take the above comments into accountduring its deliberations.
Introduction
These oil vapours are technically called Volatile Organic Compounds (VOC). Volatile Organic
Compounds (VOCs) are any organic compounds with an initial boiling point less than or equal to
250°C (482°F) when measured at a standard atmospheric pressure of 101.3 kPa. VOCs are a mixture
of light end hydrocarbons (such as methane, ethane, propane or butane) that evaporate within the
range of typical atmospheric conditions. VOCs are generated when cargo flashes in the piping
system from the source to the cargo tanks, and evaporation from the oil surface inside the cargo oil
tanks during and after loading. VOCs may be released to the atmosphere together with the inert gas
during loading of crude oil tankers and subsequent vessel transit.
Volatile Organic Compounds (VOC) are organic chemicals that vaporize under normal conditions
and contribute to the greenhouse effect as well as to air pollution. VOC emissions from the
fuel/petroleum industry sources occur during regulartanker vessels operation, such as loading and
transporting petroleum oil.
The cargo tank atmosphere initially contains nitrogen, Carbon Dioxide (CO2), other non-methane
compounds, and traces of VOCs from previous cargo. During loading, hydrocarbon gases (methane-
pentane and heavier components) are also released from the cargo. The release of these compounds,
combined with the rising cargo level, results in a pressure increase of the cargo tank that is
eventually vented to the atmosphere. The reasons for reducing VOC emissions are twofold:
environmental protection and to minimize light end product losses.
TIME TO CURB SEABORNE CARGO VOC EMISSIONS
Oil majors, operators and transporters all together face a unique window of opportunity. By
minimizing Volatile Organic Compounds (VOCs) losses during crude oil loading and transport, you
can benefit the environment whilst saving billions of dollars.
Around 70 million barrels of hydrocarbons are lost yearly due tothe emission of Volatile Organic
Compounds (VOC) during loading, storage and transportation of crude oil on ships. This is an
environmental problem as well as a high economic cost.
The lost amount represents a value of 3.0 to 3.5 billion USD annually. For a standard ship such as an
Aframax tanker, the economic loss during a single voyage with full tank amounts to more than
40,000 USD.
VOCs’ annual losses by evaporation from oil tankers are more than 3.2m tonnes of oil (equivalent to
15-20 VLCCs).
The total loaded cargo of crude oil in the global seaborne trade in 2014 was 1.81 billion tons.
The United Kingdom Offshore Operators Association (UKOOA) suggests that during loading, 1kg of
VOC is emitted per metric ton of crude oil loaded. Consequently 1.81 million tons of VOC were
emitted from tanker loading operations within 2014. In financial terms and assuming a global
average of 7.3 barrels for each metric ton of crude oil and a price of 35 USD per ton, it translates into
$462 million USD of lost cargo.
WHY VOC EMISSIONS SHOULD BE REDUCED
VOCs are a large group of organic compounds. Several light hydrocarbons, such as methane, ethane
and propane, are VOCs. Due to high vapour pressure, VOCs can quickly evaporate. To the oil
industry, evaporation of hydrocarbons equals economic loss.
VOC can also cause oil spills on a ship’s deck, as severe VOC generation can cause oil entrainment
into the mixture of inert gas and VOC.
Further, VOC emissions can harm the environment and human health. Especially methane is a potent
greenhouse gas, contributing to climate change. Several other VOCs including ethane, propane,
butane, pentane, and hexane react with NOx to form ground level ozone which has harmful effects
on human health and plants.
TINY LOSSES ADD UP TO BIG MONEY
The study by Bhatia and Dinwoodiedemonstrated how the continuous emissions of VOC would
amount to significant total losses.
Consequently, several countries and organizations began to look into the problem as a consequence
of this and other studies. For instance, the Norwegian Marine Technology Research Institute
(MARINTEK) concluded that the unloading and loading of crude oil on ships was responsible for
more than 50 % of Norway’s non-methane VOC emissions.
The studies estimated that as much as 9 million tons of VOCs were emitted annually from global
crude oil loading, unloading and transport. The figure corresponds to about 70 million barrels of light
end hydrocarbons representing a value between 3.0 and 3.5 billion USD annually.
Tanker transportation is mainly responsible for the global maritime trade in petroleum and
refined oil. The maritime crude oil trade depends on the structure of supply and demand, so tanker
transportation has a direct and close relationship with crude oil export and consumption. Port
conditions in many oil importing countries do not meet the ultra large crude carrier (ULCC), so
crudeoil transportation requires transit hub ports and then is shipped to import destinations by
smallvessels. Comparing the changes of oil tanker cargo flow before and after the oil price slumped,
wefind that the shipping situation of importing countries and transshipment hub ports are
concentratedrapidly. For example, the share of tanker transportation in the East Asia region rise from
93.7% to 95.6%,and that in the Southeast Asian region increased from 88.5% to 93.9%. Therefore,
the oil importing country’s transit port and hub port playsan important role in maritime crude oil
trade.
EFFECTS
Emission generated by the international merchant fleet has been suggested torepresent a significant
contribution to global anthropogenic emissions.
The environmental impact of these emissions is significant as the emitted gas consists of a range of
hydrocarbons from methane to higher (typically C6+). Methane is a greenhouse gas with a global
warming potential (GWP) of 21 (GWP for CO2 is 1). The non-methane fractions, known as
NMVOC, react in the presence of sunlight with nitrous oxides and create a toxic ground level ozone
and smog layer, which has detrimental environmental effects on vegetation and on human health,
particularly on the eyes and lungs.
Vapour exhausted while loading crude oil has become a serious problem in large-
volume transportation of crude oil by tankers. As a significant source of volatile
organic compound (VOC) emissions, this tanker vapour has become a significant
cause of environmental pollution, and it is known that the United States
Environmental Protection Agency (EPA) has issued warnings about ground-level
ozone originating from VOC pollution1). Particularly in the case of crude oils with
high sulfur contents, bad odour caused by tanker vapour has an adverse effect on
personnel working at shipping terminals. Moreover, gas also is also a waste of energy
resources, as the released VOC includes components that are equivalent to liquefied
petroleum gas (LPG) and gasoline.

VOC emissions from crude oil transport [Fearnleys, 1997, United Nations, 1998].
The VOC emissions during transport and cargo handling of 1300 Mt crude oil is
estimated to be close to 2 Mt, and corresponds well with estimates-; the VOC
emissions are distributed as 70% during loading, 27% at voyage, and 3% during
unloading.
EXISTING RULES & REGULATIONS.
1. The Maritime Safety Committee, at its sixtieth session, recognized the necessity
ofthe international standards for vapour emission control systems and approved the
standards developed by the BCH Sub-Committee at its twenty-first session for use by
administrations, as contained in the annexe.
2. Member Governments are invited to note this development.
There are two aspects of VOC control within this IMO regulation. In the first,
regulations 15.1 - 15.5 and 15.7, control on VOC emitted to the atmosphere in respect
of specific ports or terminals is achieved by a requirement to utilize a vapour emission
control system (VECS). Where so required, both the shipboard and shore arrangements
are to be in accordance with MSC/Circ.585“Standards for vapour emission control
systems”. The second aspect of this regulation, regulation 15.6, requires that all
tankers carrying crude oil have an approved and effectively implemented ship specific
VOC Management Plan covering at least the points given in the regulation. Guidelines
regarding the development of these plans are given by resolution MEPC.185 (59) and
related technical information on systems and operation of such arrangements is given
by circular MEPC.1/Circ.680.
GENERAL
1.1 These standards have been developed to design, construct and operate vapour
collection systems on tankers and vapour emission control systems at terminals. The
standards are intended to apply to vapour emission control systems which collect
vapours of flammable cargoes from tanker cargo tanks during cargo loading or
ballasting operations. Vapour emission control systems that collect vapour of cargoes
having characteristics that may pose hazards in addition to or other than flammability
should be subject to special consideration by the Administration. These standards are
notintended to require vapour emission control systems but rather to
recommendsafety standards when such systems are utilized. The requirement to collect
vapours will stem from a port Administration or terminal regulation. These standards
are intended to promote the safety of terminals, tankers, and personnel, recognizing
these systems’ unique design features and characteristics.
Effects of VOCs on human health
The health effects of VOCs emitted from crude oil into the atmospherehave been well
documented:
It is also noted that VOCs can cause major global-scale contributions toproduce
photochemical ozone (O3) and other harmful oxidants whichadversely affect the air
quality and human health. In addition to methane, some VOCs emitted from crude oil
such as ethane,propane, butane, pentane, and hexane, can also interact with NOxin the
air forming ground-level ozone named the troposphericozone. Hence, crude oil
emissions are alsoconsidered as “ozone precursors” and “global warming agents.”
The scale of the adverse impact of VOC emission on public health is significantin
many areas and countries in the world. Niger Delta (Nigeria) isan example and one of
the most affected places regarding thescale and severity of air contamination by crude
oil VOCs. It hasbeen reported that children born within 10 km of that site inthe Niger
Delta were twice as likely to die in their first month, which hasbeen linked mainly to
the exposure of pregnant women to the VOCssuch as benzene and toluene.
 Major impacts of VOCs on human health.

Emissions are a function of the physical and chemical characteristics of both previous
and new cargos. Emissions are also a function of the vessel size. Many U.S. harbours
are tooshallow to receive large tankers. Instead, these tankers must remain outside the
harbour area andoff-load their cargo to smaller vessels in a process known as
lightering. Since most lighteringoccurs offshore, emissions from these operations are
well prone to reach the land.
VOC emissions are also a function of the method of vessel loading. In splash loading,
the fill pipe dispensing the cargo is lowered only partway into the cargo tank, resulting
in higherturbulence during loading and subsequent high levels of vapour generation
and loss.
MEASURES THAT CAN BE IMPLEMENTED
One way to prevent emissions of these light hydrocarbonvapors and yield significant
economic savings is to installvapour recovery units (VRUs) on tanker terminals
storage tanks. VRUs arerelatively simple systems that can capture about 95 percent of
the vaporus for sale or use onsite asfuel. Between 7,000 and 9,000 VVRUs are
currently installed in the oil production sector, with an average offour tanks connected
to each VRU.
Natural Gas STAR partners have generated significant savings from recovering and
marketing these vaporus while at the same time substantially reducing methane and
hazardous air pollutants (HAP) emissions. Partners have found that when the volume
of vapours is sufficient, installing a VRU on one or multiplestorage tanks can save up
to $606,800 per year and payback in as little as two months. This Lessons Learned
study describes how partners can identify when and where VRUs should be installed
to realize these economic and environmental benefits.

Economic and Environmental Benefits

Determining the cost of a VRU project.

 Number of LPG terminals

THE REPUBLIC OF INDONESIA IN MARITIME

First, Indonesia as an archipelago with an island number of 17,508 and a coastline
of81,000 km , is the largest archipelagic country globally and has a vast natural
resource wealth of the sea and has not been utilized optimally.
Indonesia is ranked 11th in global gas production, with proven reserves of 96trillion
cubic feet (TCF) in 2018. On a reserve basis, Indonesia ranks 13th in the world and
the second in the Asia-Pacific region (following China). Indonesia’s relevance in
seaborne Liquefied Natural Gas (LNG) is more critical.
Maritime resources include fisheries, wave power, the attraction of coral reefs, and the
myriad species that live there and the geologicalresources under the sea bed. This
includes oil and gas and this has been ofgreat importance to the Indonesian economy
over many years. In addition to these, Indonesia is still home to a huge array of
biological species and has great culture and linguistic diversity. Indonesia’s land area
is approximately 1.3% of the earth’s land, but it contains 17% of the world’s flora and
fauna. If you consider the species living in its seas, then Indonesia can be considered
the most significant areaof mega biodiversity in the world.
Arun LNG, which was one of the world’s first LNG facilities and one of the biggest
LNG exporters in the 1990s, has been converted into a storage and re-gasification
terminal due to declining gas reserves.
Indonesia has 60 sedimentary basins, including 36 in Western Indonesia that has
already been thoroughly explored. Fourteen of these are producing oil and gas. In
under-explored areas of Eastern Indonesia, 39 tertiary and pre-tertiary basins show
rich promise in hydrocarbons.
Indonesia’s crude oil production was about 1250 thousand barrels of oil per day.
Further demonstrating the importance of gas, Indonesia’s gas production represents
60% of total oil and gas production. This portion is estimated to increase to 70% in
2020 and 86% in 2050.
EFFECT ON CLIMATE CHANGE
One of the most alarming global concerns in today’s world is CLIMATE CHANGE.
Many human-driven factors lead to tremendous climate changes, including melting of
glaciers, rising sea levels, tidal floods, storms, and whatnot. Shockingly, experts fear
that some of the most gorgeous cities and natural wonders might be completely sunk
and depleted in the next three to four decades.
1. Jakarta, Indonesia
The Indonesian capital of Jakarta is home to 10 million people but itis also the world’s
fastest sinking city. Jakarta is also the 2nd densely populated city of the world. North
Jakarta had already sunk by 2.5m in 10 years and was continuing to sink by 25cm a
year in some places. The average sinking rate of Jakarta is around 1 to 15 cm in a year.
Nearly 50 percent of the city has gone below sea level. 

Note: 2025 and 2050 predictions are based on research by Dr. Heri Andreas.
2. Lagos, Nigeria
3. Houston, Texas
4. Dhaka, Bangladesh
5. Venice, Italy
6. Virginia Beach, Virginia
7. Bangkok, Thailand
8. New Orleans, Louisiana
9. Rotterdam, The Netherlands
10. Alexandria, Egypt
11. Miami, Florida
In a report by the Organization for Econimic Corporation and Development (OECD),
“Kolkata,Mumbai most vulnerable to coastel flood by 2070”.
These all are important cities, and they are sinking due to the rise in sea level, a
consequence of the uncontrolled emission of VOCs. They act as greenhouse gases and
hence there is global warming, climate change, sea- level rise, extreme weather,
flooding, salination, population displacement, agriculture in coastal areas
consequences.
TRANS-SHIPMENT’S CONTRIBUTION TO DOUBLE THE VOCs EMISSION
Many ports and tanker terminals around the world are too shallow to receive large
tankers. Instead, these tankers must remain outside the harbour area and off-load their
cargo to smaller vessels in a process known as Lightering/Trans-shipment. As the
loading and unloading of volatile liquid cargos increases proportionally to the amount
of vapour emission is also increased.
Volatile Organic Compound emission control methods, systems and procedures
There are two generic approaches to VOC recovery, known as Active and Passive
VOC recovery technology. Active VOC emission systems typically include a
compression step followed by condensation, absorption and/or adsorption. Passive
VOC systems use vapour-balanced loading/unloading with VOC as blanket gas.
This section lists the VOC emission control methods, systems, procedures and
associated technologies that are available for treating or limiting VOC emissions from
oil tankers while loading and during vessel transit.
 Examples of Active and Passive VOC Recovery Methods.
The Republic of Indonesia noted various technical solutions available that allow
significant reductions of VOC emissions during loading-unloading operations and
transportation.
The Model IMO is requested to take the above comments into account during its
deliberations and requesting amendments to the current rules and regulations.

Paper written in the above format will never get through the Committee. Please
remember that the Committee will only consider arguments related to safety and
protection of the environment.
Furthermore, the paper also needs to be reformatted as per the norns. You can refer to
the paper under agenda item 2