IMO Tier III Nitrogen Oxide (NOx) Emission Compliance

28.05.
2023, 10:35 IMO Tier III Nitrogen Oxide (NOx) emission compliance
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IMO Tier III Nitrogen Oxide (NOx) emissions

compliance
IMO Tier III NOx compliance is now mandatory for new vessels entering certain
emission control areas. This article summarises the regulations surrounding NOx
emissions and discusses means of control, financials and the associated industry
issues.
Nitrogen is a natural element in the atmosphere and also occurs in the chemical
structure of residual fuels. In the combustion process of an internal combustion engine,
most of the engine intake air consists of nitrogen (N2) and oxygen (O2). NOx is
produced by the reaction between atmospheric nitrogen and oxygen at high
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28.05.2023, 10:35 IMO Tier III Nitrogen Oxide (NOx) emission compliance
temperatures in the engine combustion chamber and, to a lesser extent, during the
reaction between nitrogen in the fuel and oxygen.
As a hazardous engine emission, NOx is of concern for several reasons. It is

responsible for acid deposition, respiratory illness in humans and the formation of
greenhouse gases, contributing to the problem of global warming.
Regulations
NOx emissions are regulated by the International Convention for the Prevention of
Pollution from Ships (MARPOL Annex VI). Under Regulation 13 of MARPOL Annex VI,
3 tiers of nitrogen oxide emission limits have been established for engines, namely IMO
Tier I, Tier II and Tier III. Each tier limits NOx emissions to a specific value. The different
tiers are based on the date the ship's keel was laid. The Tier I NOx limit applies to
engines on ships with keels laid on or after 1 January 2000 and Tier II on ships with
keels laid on or after 1 January 2011. Tier I and Tier II apply globally, and Tier III
standards apply to engines installed on ships with keels laid:
On or after 1 January 2016, which operate in an existing NOx Emission Control Area
(NECA), and;
On ships constructed and operating on or after the date of adoption of a new NECA.
Based on the above, vessels with keels laid on or after 1 January 2016, operating in
North America and the U.S. Caribbean must comply with Tier III (as these NECA areas
were adopted on 1 January 2016). From 1 January 2021, the Baltic and the North Sea
are also NECA areas. So, vessels with keels laid on or after 1 January 2021, operating
in the Baltic Sea or North Sea NECA, must also be equipped with Tier III engines.
Means of NOx control

Tier 1 and Tier II compliance has been achieved through targeted fuel optimization and
pre-combustion control technologies, thereby lowering the peak combustion
temperature of the engine. However, to meet IMO Tier III requirements, secondary
methods must also be used to reduce NOx in the exhaust gas through downstream
treatments. These secondary methods include Selective Catalytic Reduction (SCR) and
Exhaust Gas Recirculation (EGR) technology. Recently, MAN energy solutions' two-
stroke engine business announced that it had received more than 2,000 orders for IMO
Tier III-compliant engines using SCR and EGR technologies.
Tier III NOx-Abatement Engine Orders Pass 2,000 Mark (man-es.com)
SCR is a popular choice for meeting Tier III requirements because it can reduce NOx
emissions by more than 90%. In an SCR system, the exhaust gas is mixed with
ammonia, usually in the form of a solution of urea in water. This introduces atomic
nitrogen (N) before passing the exhaust through a particular catalyst. The NOx is
reduced to harmless gaseous stable nitrogen (N2) and water. In the SCR system, Urea
consumption is an operating expense.
Exhaust gas recirculation (EGR) is a method of modifying the intake air to reduce NOx
emissions. A portion of the exhaust gas is cooled and cleaned using water before being
returned to the scavenge air side. As a result, peak combustion temperatures are
reduced significantly. On the negative side, installing an EGR system reduces the
combustion efficiency of an engine and therefore increases fuel consumption. Further,
in addition to the various other system configurations, a water treatment system and
sodium hydroxide (NaOH) dosing arrangement are required to neutralize the water
used in the EGR unit before discharging. The discharge of the effluent water must
always meet the requirements of IMO MEPC 307(73), 2018 Guidelines for the
Discharge of Exhaust Gas Recirculation (EGR) bleed-off water and has similar
requirements for SOX scrubber wash water discharge requirements.
Another combination that meets Tier III requirements and is popular in the dual-fuel
segment is Otto cycle engines using gas as fuel. An Otto cycle engine, e.g. Low-
Pressure Dual Fuel engine, is characterized by low peak combustion temperatures
leading to significantly lower NOx emissions. Thus, the Otto cycle combustion process
satisfies IMO NOx Tier III limit requirements without requiring emissions abatement
equipment (such as SCR or EGR). Note that Tier III compliance without any after-
treatment is for the gas mode only. If the vessel needs to switch to fuel oil mode due to
operational issues or breakdowns, the ship will no longer be Tier III compliant. Also, the
Otto cycle is prone to cause engine knocking at specific conditions and inherent higher
Methane Slip.
Each of the above systems have advantages and disadvantages and need careful
consideration.
Financials and who bears the cost?

The options for compliance with the NOx Tier III have different financial implications for
shipowners and the charterers of these vessels. While the capital expenditure (CAPEX)
for dual fuel engines is significant, the EGR has additional operating costs primarily due
to the fuel penalty, the additional electricity required to operate ancillary equipment
(e.g., EGR blowers and water treatment), disposal of the sludge generated during EGR
and NaOH consumption. The SCR system is efficient for both diesel fuel and DF
engines to meet Tier III requirements, but there are operational considerations in
addition to CAPEX. The operating costs for SCR systems are mainly related to urea
consumption and catalyst replacement after certain hours of operation.
Recently, Intertanko published a model clause on urea consumption for time charter
contracts. Intertanko's model clause provides that the charterer is responsible for all
consumption of urea or equivalent chemicals if the vessel is ordered to trade or transit
through a NECA. Therefore, vessel operators must provide accurate information on
urea consumption and keep records of the change from Tier II to Tier III. This will also
be part of statutory records required to be kept by the ship when entering or leaving an
NECA or when there is a change of status within such area, along with the vessel's
position.
Topics/Issues - INTERTANKO
As with all new equipment and technology, appropriate crew training is essential to
prevent incidents and accidents. Also, charter party negotiations for ships trading or
transiting NOx emission control areas might be required to avoid future disputes.
Further reading on the technical aspects: ABS Advisory on NOx Tier III Compliance
(eagle.org)
Ansuman Ghosh
Director of Risk Assessment
22/08/2022
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IMO Tier III Nitrogen Oxide (NOx) Emission Compliance

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28.05.

IMO Tier III Nitrogen Oxide (NOx) emissions

As a hazardous engine emission, NOx is of concern for several reasons. It is

Means of NOx control

Tier III NOx-Abatement Engine Orders Pass 2,000 Mark (man-es.com)

Financials and who bears the cost?

You may also be interested in:

Green Shipping - Transitional Fuels

UK MRV reporting requirements delayed to 2025

IMO Regulatory Update - A Boost for Biofuels!

VPS Circular: High Cloud Point Distillates in ARA

On 28 September, VPS released an important alert regarding distillate fuels

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