revised annex vi regulation 12 guidance notes marpol vi

Revised MARPOL Annex VI – Regulation 12 Guidance Notes © Lloyd’s Register February 2010

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Guidance notes Revised MARPOL Annex VI Regulation 12 – Ozone Depleting Substances 1. Introduction 1.1. These Guidance Notes have been prepared and updated for the use of Lloyd’s Register (LR)

Group Surveyors, Ship Owners and Ship Managers. They provide guidance on the requirements of MARPOL 73/78, Annex VI, Regulation 12 (hereafter referred to as Revised MARPOL Annex VI).

1.1.1. These guidance notes are divided into sections covering; the application, survey, reporting

and certification of equipment under Revised MARPOL Annex VI. 1.2. Revised MARPOL Annex VI will enter into force on 01 July 2010. The original MARPOL

Annex VI entered into force on 19 May 2005. Ship Owners have already undertaken verification surveys and International Air Pollution Prevention (IAPP) Certificates should be in place.

1.3. Revised MARPOL Annex VI covers air pollution from ships caused by emission of ozone

depleting substances. Whilst new fire-extinguishing installations containing ozone depleting halons had been prohibited as from 1 October 1994, existing system may still contain halons. Therefore, fire-fighting aspects continue to be included in these guidance notes.

1.4. Revised MARPOL Annex VI, Regulation 12 applies to all ships and to fixed and floating

drilling rigs and other platforms. Ships of 400 gross tons and above must be surveyed and issued with an IAPP Certificate before the ship is put into service. For existing ships of 400 gross tons and above, engaged in international voyages, the next renewal survey shall be such as to ensure that equipment, systems, fittings, arrangements and material comply fully with applicable requirements of the Revised MARPOL Annex VI.

2. Surveys 2.1. A survey is conducted to confirm that the arrangements and equipment will, with proper

maintenance, be expected to remain in good condition and good working order until the next survey.

2.1.1 Only on those occasions where the required reception facilities or necessary replacement

equipment is not available locally, would items be considered for deferment.


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2.1.2 Revised MARPOL Annex VI surveys will normally be dealt with in their entirety and not as part surveys.

2.2 An Annual Survey will consist of: 2.2.1 Verification that the certificate on board is in order. 2.2.2 An examination of the various items of equipment to an extent which, in the surveyor’s

judgement, indicates that no changes, additions or disposal has occurred since the last survey, that the equipment remains in a satisfactory condition and that the standard of maintenance is considered acceptable until the next due Survey.

2.3 An Intermediate Survey will consist of: 2.3.1 An Annual Survey plus: 2.3.2 A thorough examination to ensure that the equipment complies with the requirements of the

current Regulations and is in good working order, sufficient until the next Survey. 2.4 To assist in preparing for an Annual Survey or Intermediate Survey, a provisional survey

checklist has been developed. (Refer to Appendix I) 3. Applicable sections of Revised MARPOL Annex VI 3.1 Regulation 3 (Part) Exceptions and Exemptions General 1. Regulations of this Annex shall not apply to:

.1 any emission necessary for the purpose of securing the safety of a ship or saving life at sea; or

.2 any emission resulting from damage to a ship or its equipment:

.2.1 provided that all reasonable precautions have been taken after the occurrence of the damage or discovery of the emission for the purpose of preventing or minimizing the emission; and

.2.2 except if the owner or the master acted either with intent to cause damage, or recklessly

and with knowledge that damage would probably result.


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3.2 Regulation 6 (Part) Issue or endorsement of a Certificate 1 An International Air Pollution Prevention Certificate shall be issued, after an initial or renewal survey

in accordance with the provisions of regulation 5 of this Annex, to:

.1 any ship of 400 gross tonnage and above engaged in voyages to ports or offshore terminals under the jurisdiction of other Parties; and

.2 platforms and drilling rigs engaged in voyages to waters under the sovereignty or jurisdiction of

other Parties. 3.3 Regulation 12 (Full) Ozone Depleting Substances 1 This regulation does not apply to permanently sealed equipment where there are no refrigerant charging

connections or potentially removable components containing ozone depleting substances. 2 Subject to the provisions of regulation 3.1, any deliberate emissions of ozone depleting substances shall

be prohibited. Deliberate emissions include emissions occurring in the course of maintaining, servicing, repairing or disposing of systems or equipment, except that deliberate emissions do not include minimal releases associated with the recapture or recycling of an ozone depleting substance. Emissions arising from leaks of an ozone-depleting substance, whether or not the leaks are deliberate, may be regulated by Parties.

3.1 Installations which contain ozone depleting substances, other than hydro-chlorofluorocarbons, shall be

prohibited:

.1 on ships constructed on or after 19 May 2005; or

.2 in the case of ships constructed before 19 May 2005, which have a contractual delivery date of the equipment to the ship on or after 19 May 2005 or, in the absence of a contractual delivery date, the actual delivery of the equipment to the ship on or after 19 May 2005.

3.2 Installations which contain hydro-chlorofluorocarbons shall be prohibited:

.1 on ships constructed on or after 1 January 2020; or

.2 in the case of ships constructed before 1 January 2020, which have a contractual delivery date of the equipment to the ship on or after 1 January 2020 or, in the absence of a contractual delivery date, the actual delivery of the equipment to the ship on or after 1 January 2020.


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4 The substances referred to in this regulation, and equipment containing such substances, shall be delivered to appropriate reception facilities when removed from ships.

5 Each ship subject to regulation 6.1 shall maintain a list of equipment containing ozone depleting

substances.2 6 Each ship subject to regulation 6.1 which has rechargeable systems that contain ozone depleting

substances shall maintain an Ozone Depleting Substances Record Book. This Record Book may form part of an existing log-book or electronic recording system as approved by the Administration.

7 Entries in the Ozone Depleting Substances Record Book shall be recorded in terms of mass (kg) of

substance and shall be completed without delay on each occasion, in respect of the following:

.1 recharge, full or partial, of equipment containing ozone depleting substances;

.2 repair or maintenance of equipment containing ozone depleting substances;

.3 discharge of ozone depleting substances to the atmosphere:

.3.1 deliberate; and

.3.2 non-deliberate;

.4 discharge of ozone depleting substances to land-based reception facilities; and

.5 supply of ozone depleting substances to the ship. 2 See Appendix I, Supplement to International Air Pollution Prevention Certificate (IAPP Certificate),

section 2.1. 3.4 Regulation 17 (Full) Reception Facilities 1 Each Party undertakes to ensure the provision of facilities adequate to meet the:

.1 needs of ships using its repair ports for the reception of ozone depleting substances and equipment containing such substances when removed from ships;

.2 needs of ships using its ports, terminals or repair ports for the reception of exhaust gas cleaning

residues from an exhaust gas cleaning system,

without causing undue delay to ships; and


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.3 needs in ship-breaking facilities for the reception of ozone depleting substances and equipment containing such substances when removed from ships.

2 If a particular port or terminal of a Party is – taking into account the guidelines to be developed by the

Organization – remotely located from, or lacking in, the industrial infrastructure necessary to manage and process those substances referred to in paragraph 1 of this regulation and therefore cannot accept such substances, then the Party shall inform the Organization of any such port or terminal so that this information may be circulated to all Parties and Member States of the Organization for their information and any appropriate action. Each Party that has provided the Organization with such information shall also notify the Organization of its ports and terminals where reception facilities are available to manage and process such substances.

3 Each Party shall notify the Organization for transmission to the Members of the Organization of all

cases where the facilities provided under this regulation are unavailable or alleged to be inadequate. 4. Guidance for surveyors for compliance with Regulation 12 4.1 General 4.1.1 The following notes are provided to give guidance on compliance with Regulation 12 of

Revised MARPOL Annex VI and are expected to produce a more consistent approach to compliance. There is at present no section in the Marine Survey Procedures Manual (MSPM) which covers compliance with Regulation 12 and as such the following notes should be used when appropriate. There will always be exceptions to allow compliance. Novel arrangements should not be discounted but should be given special consideration.

4.1.2 It is considered that no specific plans or information are required to be submitted to allow

appraisal of the fire fighting and refrigeration systems which may utilize ozone depleting substances. If deemed necessary by the attending surveyor, details of the refrigerant leak monitoring system and a plan showing the location of all detector sensor heads may be submitted, to allow verification of its acceptability.

4.2 Changes to the legislation 4.2.1 Regulation 12 covers the recording of refrigerant use, the deliberate emission of ozone depleting

substances and the removal of these substances from the ship. It does not cover the operation of systems which utilize these refrigerants or halons onboard existing ships. Whilst still not specifically stipulating that a leak detection regime needs to be undertaken, the statement that emissions arising from leaks of an ozone-depleting substance, whether or not the leaks are deliberate, may be regulated by Parties is perceived to indicate that a form of leak prevention and leak detection need to be provided as regulated by the Parties.


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4.2.2 The statement now made in Regulation 12, paragraph 3.2 is for installations which contain hydrochlorofluorocarbon (HCFC) refrigerants to be prohibited as from the 01 January 2020. The previous statement was for new installations containing HCFCs to be banned after 01 January 2020; however, the meaning is the same.

4.2.3 Since the original MARPOL Annex VI entered into force the requirements of the Montreal

Protocol has been tightened. The Nineteenth Meeting of the Parties decided in December 2007 to accelerate the phase-out of HCFCs. Now, by 2020 the global consumption of HCFCs in developed counties is to be limited to 0.5% of the 1989 level and non-developed (Article 5) countries 65% of the 2009 level. No mention has been made of prohibiting the use of HCFCs in existing systems.

4.2.4 It is likely that compliance with the Revised Marpol Annex VI Regulation 12 requirements

will be overtaken by national and global legislation, especially if the requirements of the Montreal Protocol are again accelerated.

4.3 Applicability – circulating fluids 4.3.1 The applicability is defined in paragraph 1 of Regulation 12. The regulation does not apply to

permanently sealed equipment where there are no refrigerant charging connections or potentially removable components containing ozone depleting substances. Domestic refrigerators, domestic freezers, ice makers, water coolers and self contained air-conditioners are usually sealed systems and thus outside the scope of complying with Regulation 12.

4.3.2 There are no fixed definitions of which refrigeration systems and fire fighting arrangements

are considered to fall within Regulation 12. For air conditioning systems and refrigeration installations guidance on what equipment is considered to be subject to Regulation 12 stems from the construction practices used. The following statements may clarify this situation.

4.3.3. If all the items of refrigeration equipment which contain the primary refrigerant, such as; the

compressor, receiver, condenser and evaporator form part of a ‘stand alone’ unit which is supplied in a fully charged condition, (with the refrigerant already in the system), then it is considered to be a sealed or ‘retail’ unit and not considered under Regulation 12. Examples of this are; domestic refrigerators and freezers, small self contained (free standing) air conditioning units, drinking water fountains and self contained service air dryers.

4.3.4 Refrigerant machinery supplied loose and fabricated onboard is considered subject to the

Regulation 12. Systems manufactured or fabricated ashore where all the refrigeration equipment is installed, pressure tested and filled with a holding charge of refrigerant and supplied as part of a package unit are considered subject to Regulation 12. Any system, independent of size, which is manufacture from separate items of equipment and fitted to bedplates or skid, is also considered subject to Regulation 12.


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4.3.5 All centrally located accommodation air conditioning system packaged units are considered subject to Regulation 12. If the air conditioning unit is of integral construction, where only cooling water and electrical supplies are connected, such as a ‘through the bulkhead’ unit, then this may be exempt.

4. 3.6 Independent of the type of system, if the equipment is supplied loose and is installed,

pressure tested and charged with refrigerant on board then this type of unit is considered to fall within the requirements of Regulation 12. It is normally obvious from looking at the refrigeration pipework and components that the system has been constructed from separate items of equipment. The tell-tail signs being; equipment mounted on bulkheads, multiple bedplates, de-mountable (flare) couplings and flange connections on the major items of equipment. Examples of this type of unit are; domestic provision rooms with the compressors remotely located, split air conditioning units with the condenser mounted externally away from the evaporator/compressor set (often referred to as “splits”) and air conditioning air handling units utilising primary refrigerant.

4.4 Applicability – blowing agents use in insulation 4.4.1 The most popular insulation materials used on existing ships are; polyurethane foam,

expanded polystyrene and extruded polystyrene. Polyurethane foam, either in the standard 50/50 mix or 80/20 polyisocyanurate mix, is the most widely used insulation especially for pre-fabricated domestic provision rooms and cold chambers constructed from panels.

4.4.2 To make the rigid polyurethane foam, two components - MDI (diphenyl methane diisocyanate)

and polyol (polyether or polyether resin), are mixed together. During the initial mixing stage other components are added. The main one, termed the ‘blowing agent’, is a chemical with a suitably low boiling point which is added in smaller quantities. As the heat of reaction volatilises the blowing agent, numerous small bubbles of blowing agent vapour, known as cells, are formed in the mixture.

4.4.3 When rigid foams were first developed the blowing agent selected was chlorofluorocarbon

(CFC) R-11. When CFC R-11 started to be phased out under the Montreal Protocol in the early 1990’s, HCFC R-141b, with a boiling point of 32°C, was near universally introduced for blowing polyurethane foam. As both of these gases are ozone depleting, thus affected by Regulation 12, there is a requirement for them to be delivered to a suitable reception facility. Thus if foam is being replaced, or the ship scrapped, the removed insulation must be sent to a suitable reception facility.


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4.5 Ozone depleting substances 4.5.1 CFC (chlorofluorocarbon) refrigerants, such as R-11, R-12 and R-502 are ozone depleting

substances and as such have been banned under the Montreal Protocol. A major landmark was passed on 01 January 2010, when the production and consumption of CFCs, even in the developing (Article 5) countries, was banned. Thus, the use of these refrigerants to maintain existing installations, which is construed as being consumption, is also prohibited.

4.5.2 There may be possible essential-use exemptions for CFCs; however, these are likely to be

only for medical inhalers. In conclusion, CFC refrigerants are now prohibited from use in any refrigeration systems on all ships, independent of the Flag Administration, as from 01 January 2010.

4.5.3 HCFC (hydrochlorofluorocarbon) refrigerants, such as R-22, R-123 and various blends are

currently going through a transitional period of legislation. Regulation 12 makes an exception for HCFCs and only requires them to be prohibited by 01 January 2020. However, other legislation, such as Regulation (EC) 2037/2000 (now recast as Regulation (EC) 1005/2009) of the European Parliament, banned the use of HCFCs from use in new refrigeration and air-conditioning installations effective from 01 January 2001. In accordance with the European Commission, if the ship’s Flag Administration is a member of the European Community, this legislation applies. America, Australia and Japan all have HCFC specific legislation, however, the applicability of this legislation has not be confirmed.

4.5.4 Halons, such as 1211 or 1301, have been used as fire fighting media and as they are ozone

depleting substances they are affected by Regulation 12. SOLAS II-2 Regulation 10-4.1.3 has prohibited the installation of new systems using halon since October 1994. On existing ships, systems containing halon can remain in service until replaced or required to be removed by international, national or other legislation or requirements. The release of halon can still be undertaken in accordance with the requirements of Regulation 3. Where there is any concern regarding the acceptability of the fire fighting media being used, advice should be obtained from a local Plan Appraisal Centre or London.

4.6 Ozone benign substances 4.6.1 HFC (hydrofluorocarbon) refrigerants and fire fighting media, such as HFC R-134a and HFC

R-227ea (FM-200) were originally developed as alternatives to CFC refrigerants and halons. Subsequently, there has been a plethora of binary and ternary HFC mixtures being promoted as HFC refrigerants, such as R-410A and R-404A. Regulation 12 does not affect HFC refrigerants as these are not ozone depleting substances.


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4.6.2 Natural substances, such as ammonia (R-717), carbon dioxide (R-744) and propane (R-290), are all used as refrigerants and are not ozone depleting substances. Thus, Regulation 12 is also not applicable to these refrigerants.

4.6.3 The various HFC gases and fluorinated ketone which are being marketed as direct or near

direct drop in replacements for halon 1301 are all considered ozone benign substances. A list of these substances is shown in Appendix 2. Other alternatives to halon 1301 such as nitrogen, argon and carbon dioxide are all ozone benign substances and need not be considered.

4.7 Maintenance equipment 4.7.1 Compliance with the statement in paragraph 32 of Regulation 12, that deliberate emissions

occurring in the course of maintaining, servicing, repairing of the equipment shall be prohibited will require specialist servicing equipment. If maintenance of the refrigeration and air-conditioning equipment is to be undertaken by ship’s staff, then this specialist equipment will need to be available onboard. If maintenance is contracted out to a third party, such as a shore-side refrigeration contractor, this company and not the ship is to provide all necessary equipment.

4.7.2 Before maintenance of the refrigeration equipment can be undertaken, the refrigerant needs

to be removed or reclaimed from the section or item of equipment to be worked on. This requires the section or item of equipment to be ‘pumped down’ (put under a partial vacuum using the refrigeration system’s own compressor if possible) and then isolated. After isolation the section is to be connected to a refrigerant recovery unit.

4.7.3 If the refrigeration system utilises HCFC refrigerant, then some form of refrigerant recovery

system is essential. 4.7.4 Refrigeration recovery units contain a vacuum pump, which can work to very low vacuums

(less than 1 torr), and a condensing unit, which allows the gas to be removed, condensed to a liquid and stored. The unit has either its own (internal) recovery refrigerant container (usually 13 kg) or is connected to an external cylinder (13, 26 or 55 kg). These cylinders are supplied in various colours, the colour may indicate which refrigerant it contains, but it should, in every case, have a yellow band or section around the cylinder neck to indicate that it contains recovered refrigerant.

4.7.5 It should also be noted that it can take considerable time for the entire refrigerant charge to

be reclaimed from a system, especially to liberate all refrigerant from the oil retained in the compressor sump.


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4.7.6 Minimal releases of refrigerant, such as will occur when the recovery unit pipework is disconnected from the system, can not be readily prevented and as such is acceptable in accordance with paragraph 2 of Regulation 12.

4.7.7 If the ship’s staff are to undertake the maintenance of the refrigeration system(s) and a

recovery unit, complete with a specialist container or external cylinder, or cylinders if more than one type of refrigerant is used, is not provided, then paragraph 2 of Regulation 12 is considered to be contravened.

4.8 Plan appraisal aspects - refrigeration 4.8.1 Very few refrigeration system installed on ships are classed. Only when the owner, or

operator, requests the Refrigerating Machinery Certificate (RMC) notation to be assign to the ship, is the refrigeration system approved. If the Environmental Protection (EP) notation is to be assigned, the applicable refrigerant systems are also considered but do not require plan approval. When the RMC or EP notation is assigned, compliance with Revised MARPOL Annex VI will form part of the appraisal process. However, for the vast majority of air-conditioning and provision room systems, no plan appraisal has been undertaken.

4.8.2 Thus, on new ships it will be for the attending surveyor to investigate which refrigerants are

being used. It is a requirement of most refrigeration and air conditioning design codes that the refrigeration plant is clearly labelled with the refrigerant used. The quantity of refrigerant in a system can be difficult to determine, especially if long pipe runs are used. The amount of refrigerant in each system should be requested from the yard or when possible the specialist sub-contractor. If no information is available, a refrigerant charge calculator can be provided, if required contact; [email protected].

4.8.3 Refrigerants and refrigerant blends have been formulated to operate at their most efficient

under certain evaporating and condensing temperatures. Thus it is normal to have one refrigerant in an air-conditioning system which has a high evaporating temperature and another in a provision room system which has a lower evaporating temperature. Thus it is common to have two different refrigerants on the same ship and in use next to each other.

4.8.4 Once the type (R number) and quantity of refrigerant charge (kg) for each refrigeration

system is known, this information and the locations of the main items of equipment should be recorded under paragraph 2.1.2 of the Supplement to the International Air Pollution Prevention Certificate. The same information should be recorded in the refrigerant log book, retained on board. If replacement refrigerant is stored onboard, then the number, size and the content of each cylinder and its location should be recorded.


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4.9 Plant appraisal aspects – fire fighting media 4.9.1 As fire fighting system are always appraised for SOLAS and Class requirements it is

proposed that the fire fighting medium is also considered for compliance with the requirements of Revised MARPOL Annex VI.

5. Guidance for surveyors – Initial Survey 5.1 Fire fighting equipment and extinguishing media 5.1.1 The surveyor attending the initial SOLAS survey is to confirm that the equipment and

extinguishing media on board are in keeping with the approved fire control plans and suitable for use.

5.1.2 It should be confirmed that no fire fighting system on board, including secondary systems

such as compressor rooms on gas carriers and galley cooker hoods on passenger ships, contain halon or any other banned substance.

5.2 Refrigeration equipment and systems 5.2.1 The location of each applicable refrigeration system is to be established. 5.2.2 The type and quantity of refrigerant in each system is to be determined by inspection and

the documentation for each system. For smaller systems, such as engine room control room air conditioning, an estimate of the charge may be necessary if no documentation is available.

5.2.3 Existing equipment containing CFC refrigerants may continue in operation. However,

Revised MARPOL Annex VI bans the use of all CFCs in existing refrigeration systems if the ship was constructed on or after 19 May 2005. Some countries, foe example Denmark, tried to legislate against CFCs continuing to be ‘used’ in existing refrigeration installations but were defeated. The term ‘use’ is defined as:

The charging, topping up and removal of refrigerant from the system or equipment. 5.2.4 Paragraph 2 of Regulation 12 includes the statement: Emissions arising from leaks of an ozone depleting substance, whether or not the leaks are deliberate,

may be regulated by Parties.


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It is therefore considered that a refrigerant leak monitoring system is required but only if an ozone depleting substance is being used, such as HCFC R-22, and the Flag Administration of the ship requires compliance with other Statutory Instruments or legislation such as Regulation (EC) No. 842/2006 or Regulation (EC) 1005/2009 for EC countries.

5.2.5 If maintenance of the refrigeration equipment is carried out by ship’s staff, then a refrigerant

recovery unit and associated cylinders need to be provided. The special cylinders used for recovery should be specially marked and labelled, e.g. “HCFC R-22 – Recovered”. The markings should be clear and near the top of the cylinder.

5.2.6 Care must be taken not to overcharge the recovery unit's internal container or the recovery

cylinder(s). A method of ensuring that overcharging does not occur should be provided, normally a set of dedicated scales. Charging and recovery lines should be kept as short as possible and equipped with valves or self-closing connections to minimise any unavoidable loss of refrigerant to the atmosphere upon disconnection.

5.3 Periodic leak detection 5.3.1 To reduce the possibility of leaks occurring, periodic leak detection should be undertaken.

This is separate from the leak monitoring system required by paragraph 5.2.4. A simple leak detection method uses a solution of soap in water. This is painted onto all joints and connections which are then inspected for the formation of bubbles. A more effective method is to use an electronic leak detector which is specifically calibrated for the refrigerant in use. For refrigerants which contain a fluorine atom, such as HCFC R-22, a further method is to use a hand-held halide torch.

5.3.2 The halide torch burns propane or butane to heat a copper element; sample air is drawn

over the element using the venturi effect. If fluorine atoms are present they decompose and the colour of the flame changes to blue. The shade of blue gives an indication of the severity of the leak. If a halide torch is used, toxic fumes are produced (phosgene gas) when HCFCs are burnt. This method is no longer considered acceptable, especially in confined spaces such as refrigeration machinery spaces, and as such should not be promoted.

5.3.3 Electronic detector operates by measuring the variation in current flow caused by ionisation

of decomposed refrigerants between two oppositely charged platinum electrodes. This type of detector is suitable for HCFC and HFC refrigerants. They are extremely effective at finding leaks as small as 5 grams per year. Electronic detectors need to be periodically recalibrated. The periodicity of recalibration must be in accordance with the manufacturer’s instructions.


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5.3.4 A further system of leak detecting involves adding a small amount of fluorescent dye to the refrigerant circulating around the system. Any leaks from flanges, glands, connections, etc, will include a small amount of the dye. As this has smaller molecules than the refrigerant it is more susceptible to leaking. The location of any leaks can then be easily identified by illuminating the area with an infrared lamp.

5.3.5 The periodicity of leak detection is at the discretion of the owner/operator. The quantity of

refrigerant in each system is one way to establish the time interval between leak detection. For guidance purposes, the following NVKL recommendations are considered acceptable and are more stringent than those presently required by the European legislation:

Charge Example of System Type Periodicity

< 3 kg Bottle cooler, walk-in chambers, split A/C units Yearly 3 ≤ 30 kg Control room A/C, small provision chambers Quarterly 30 ≤ 300 kg Cargo ship accommodation A/C, provision rooms Monthly 300 kg & over Cargo refrigeration plants, passenger ship A/C Weekly *

* interval may be extended depending on the number of leaks being found. 5.3.6 It is recommended that the leak test regime as listed above is followed, however, if a system

is completely sealed, with no breakable connections, then leak testing may be waived at the discretion of the owner/operator.

5.3.7 Any detected leakage should be repaired as soon as possible. If the leaking system is

maintained by a third party, such as a shore-side refrigeration contractor, then the repair should be completed in the next port. The equipment or system shall be checked for leakage after the repair and then again within one month to ensure that the repair has been effective.

5.4 Ozone Depleting Substance Record Book 5.4.1 To comply with the need to maintain a record, it is proposed that a form of refrigerant ‘log

book’ should be kept. The information it contains should comply with paragraph 7 of Regulation 12 and that proposed by other refrigeration legislation such as Regulation (EC) No. 842/2006 and Regulation (EC) 1005/2009 for EC countries.

5.4.2 In accordance with paragraph 5 of Regulation 12, a record of the equipment containing ozone

depleting substances must be maintained. It is therefore envisaged that the refrigerant log book would also be used to record this information. In addition to the log book, it is considered that a dedicated entry should also be made in the engine room log sheet to record any refrigerant usage.


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5.4.3 In accordance with paragraph 6 of Regulation 12, this record or log book is to be approved by the Administration. An example of a suitable log sheet is shown as Appendix 3.

5.4.4 By using a log book, an annual refrigerant usage figure can be established and maintained

for each system. This would allow a refrigerant usage trend to be determined and so indicate whether a system has started to leak significantly. An allowable annual leakage figure is hard to estimate but the following may be used as an indication;

30% of initial charge for small systems 10% of initial charge for medium systems 3% of initial charge for large systems It should be noted that if a catastrophic failure occurred, such as a pipe fracture, a large

proportion of the charge may escape. In this case, the above figures would be meaningless. 5.4.5 The logs recording the refrigeration systems installed on board and their refrigerant usage

should be inspected at each survey. These logs are to include details and location of each system which is considered applicable under Revised MARPOL Annex VI Regulation 12.

The following information should be recorded:

• Refrigerant number and charge amount (kg) in each system • If any recharging, full or partial, has occurred to each system and the amount of

refrigerant added or removed • Any repair or maintenance done to a refrigeration system • The discharge of refrigerant, both deliberate and non-deliberate • The number and location of any full, or part full, cylinders of virgin refrigerant used for

maintenance and servicing. • The amount and location of any full or part full cylinders of recovered refrigerant. • The amount and date when any recovered refrigerant has been sent ashore for recycling

or disposal. • The amount and date of any refrigerants supplied to the ship

5.5 Leak monitoring system 5.5.1 For fixed refrigerant leak monitoring systems, the number and location of the proposed leak

detector sensors is at the discretion of the owner/operator/yard. For guidance, where fixed refrigerant detection system sensors are to be located Part 6, Chapter 3, Paragraph 5.1.1 of the Rules and Regulations for the Classification of Ships stated that a detector may be considered to cover an area of 36 m².


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5.5.2 It is not normally considered necessary for an individual provision room to be fitted with a leak detector sensor, as the number of de-mountable joints and possible leak locations, for example valve stem seals, is limited and is often zero. If however, the provision room system has all the thermostatic expansion valves, bypass valves, filter driers and other ancillary valves and fittings located in a central lobby area, this space should be fitted with a detector.

5.5.3 If all refrigeration control and isolating valves, etc. are fitted in the individual rooms, then a

detector should be fitted in each room. Spaces that houses only welded or braised refrigerant pipework need not be fitted with a detector, as the chance of a leak occurring is considered remote.

5.5.4 Whilst the Rules state that a detector sensor head normally covers an area of 36 m2; if the

manufacturer’s recommendation is less than this figure then their requirements should be adhered to. The location of the sensor head is dependant on the type of refrigerant used and whether the leak is most likely in the liquid or vapour phase. Where leakage is likely to be in the liquid phase (e.g. liquid pumps) the sensor heads are to be placed beneath the equipment or at deck level. Where leakage would be in the vapour phase (e.g. compressors) and the refrigerant is lighter than air, sensor heads should be placed at deckhead level. Due regard is also to be taken of the expected direction of the ventilation air stream. If the refrigeration space has a dedicated ventilation system then it is good practice to place a detector sensor head in the ventilation outlet duct.

5.5.5 A single detector sensor head may be fitted in a space. Standby sensor heads are not

considered necessary provided they are so designed as to be readily tested and calibrated and failure of the sensor head initiates an alarm.

5.5.6 It is recommended that a detector sensor head is fitted in the common discharge line from

the safety relief valves fitted to the compressors and pressure vessels in each refrigeration system.

5.5.7 Refrigerant detector systems normally consist of a central electronic control unit to which a

number of detector sensor heads are connected. The number of sensor heads fitted is normally between 4 and 12 but large systems may be of modular construction and allow additional input cards to be fitted. Some detector sensor heads need to be changed as regularly as every two years. The system manufacturer’s requirements need to be established and the date stamped on each sensor head checked. Air sampling or ‘Sniffer’ type detector systems were common but are now almost unknown for refrigeration installations.


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5.5.8 The refrigerant alarm detector panel may be located on the bridge or in the engine control room (ECR). It is proposed that refrigerant detector alarm activation will initiate; the ship's engine room alarm or dedicated audible and visual alarms on the bridge or in the event of the engine room being unmanned, the engineers’ call.

5.5.9 Current construction practice, for air conditioning and produce chamber refrigeration

installations, is for all the refrigeration equipment, containing the primary refrigerant, to be located in a designated space. In this case only this dedicated refrigerant machinery space needs to be provided with a fixed leak detection system.

5.5.10 Where air conditioning refrigeration systems are split between the machinery compartment,

housing the compressors and condensers, and air handling units, housing the evaporators, located at upper deck level in separate compartments, then each space containing primary refrigerant valve stations and demountable joints should be fitted with a fixed refrigerant detector sensor head.

5.5.11 The refrigerant concentration at which a leak monitoring system alarm is instigated is to be

an acceptable value in keeping with the system manufacturer’s recommendations. Two types of refrigerant detectors are normally used with halogenated fluorocarbon refrigerants. Infrared is the most accurate but carries a significant price premium. The semi-conductor type is cheaper and less accurate. The latter type is the most commonly specified and will be most widely found in ship applications.

5.5.12 For the semi-conductor type of detector, the minimum concentration of halogenated

fluorocarbon which can normally be detected is around 50 ppm. This value is quoted for ideal or laboratory conditions with no air flow and the sensor heads in perfect condition. Higher operating temperatures, contamination from paint fumes or oil mist and partial blockage of sensor heads may result in concentrations between 150 and 175 ppm being necessary before a leak can be detected. To allow for background contaminants and high ambient temperature and humidity, a detection level of 300 ppm is considered the practical minimum to prevent nuisance alarms.

5.5.13 This figure should be compared with the 150 to 200 ppm initial alarm and 750 to 800 ppm

leakage alarm set points claimed by a number of leak detector manufacturers as the ‘normal’ alarm levels. As qualified personnel will be available to investigate any detector system alarm the second level is considered redundant.


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5.5.14 If the owner or operator wishes, the alarm set point may be reduced depending upon the type of equipment provided. If however, it is found that nuisance alarms continue, when the detector system is set to activate below 300 ppm, then after checking for any leaks, the alarm level may be raised in small increments until nuisance alarms cease. Any variation in the alarm set point should be recorded in the system’s operating manual and refrigerant log book.

5.5.15 Dates of leak detection, number and severity of any leaks detected, steps taken to repair

leakage and amount of refrigerant added should be included in the refrigerant log book or engine log. This should be done for each refrigeration system tested.

5.6 Operation manuals 5.6.1 Suitable manuals or procedure sheets, covering the operation and maintenance of each

refrigeration system are to be available on board. The operating manual should be suitable for the system installed. For small systems, the amount of maintenance will be limited and no preventative maintenance will normally be required, thus the manual or procedure sheets will be limited in their complexity.

5.6.2 For larger systems the operation and maintenance manual should suitably cover charging,

pumping down and evacuating the system. Other simple maintenance procedures such as defrosting, leak detection and filter-drier replacement should also be covered.


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6. Refrigerants 6.1 Listed below are all the currently available refrigerants that have zero ODP and a GWP100

value below 1950 thus being suitable for the ‘R’ character associated with the Environmental Protection Notation. The refrigerants that are considered ‘mainline’ and suitable for use in marine applications for refrigerated cargo, air conditioning and provision room refrigeration systems are shown with an asterisk thus *.

A number of refrigerants from the hydrocarbon group have been included. Special consideration would need to be given to the use of these refrigerants.

Refrigerant No. Name Formula ODP GWP100

R-134a * 1,1,1,2-Tetrafluoroethane CF3CH2F 0 1300 R-718 Water H2O 0 0 R-744 * Carbon dioxide CO2 0 1 R-407A * Blend of R-32/125/134a CH2F2 0 1770 CF3CHF2

CF3CHF2F R-407C * Blend of R-32/125/134a CH2F2 0 1526 CF3CHF2

CF3CHF2F R-410A * Blend of R-32/125 CH2F2 0 1725 CF3CHF2

R-32 Difluoromethane CH2F2 0 580 R-50 Methane CH4 0 24.5 R-152a 1,1-Difluoroethane CHF2CH3 0 140 R-30 Methylene chloride CH2Cl2 0 15

R-717 * Ammonia NH3 0 0

R-170 Ethane CH3CH3 0 3 R-290 * Propane CH3CH2CH3 0 3 R-600 * Butane C4H10 0 3 R-600a * Isobutane CH(CH3)3 0 3


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The GWP100 figure for each of the following refrigerants has yet to be confirmed. However, it is unlikely that any of these refrigerants will be considered for commercial applications.

Refrigerant No. Name Formula ODP GWP100

R-160 Ethyl chloride CH3CH2Cl 0 TBC

R-764 Sulphur dioxide SO2 0 TBC R-40 Methychloride CH3Cl 0 TBC R-611 Methylformate C2H4O2 0 TBC R-1130 1,2-Dichloroethylene CHCl=CHCl 0 TBC R-1150 Ethylene CH2=CH2 0 TBC R-1270 Propylene C3H6 0 TBC

The above tables are not a complete list of substances which might be used. If other blends are produced that meet the appropriate ODP and GWP limits, they should also be included.


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Appendix 1 – List of compounds used as refrigerants or refrigerant blends Family Refrigerant No. Name Formula ODP GWP100 CFC R-11 Trichlorofluoromethane CCl3F 1 4,000 CFC R-12 Dichlorodifluoromethane CCl2F2 1 8,500 CFC R-13 Chlorotrifluoromethane CClF3 1 11,700 CFC R-113 1,1,2-trichloro 1,2,2-trifluoroethane CCl2FCClF2 0.8 5,000 CFC R-114 1,2-dichloro 1,1,2,2-tetrafluoroethane CClF2CClF2 1 9,300 CFC R-115 Chloropentafluoroethane CF3CClF2 0.6 9,300 CFC R-500 Azeotropic blend of R-12 and R-152a CCl2F2 0.74 6,300 CHF2CH3 CFC R-502 Azeotropic blend of R-22 and R-115 CHClF2 0.33 5,600 CF3CClF2 CFC R-503 Azeotropic blend of R-23 and R-13 CHF3 0.6 11,900 CClF3 Family Refrigerant No. Name Formula ODP GWP100 HCFC R-22 Chlorodifluoromethane CHClF2 0.055 1,700 HCFC R-123 2,2-dichloro 1,1,1-trifluoroethane CF3CHCl2 0.012 120 HCFC R-124 2-Chloro-1,1,1,2-tetrafluoroethane CF3CHClF 0.026 620 HCFC R-401A Zeotropic blend R-22/R-152a/R-124 CHClF2 0.027 1,130 CHF2CH3 CF3CHClF HCFC R-401B Zeotropic blend R-22/R-152a/R-124 CHClF2 0.028 1,220 CHF2CH3 CF3CHClF HCFC R-402A Zeotropic blend R-125/R-290/R-22 CF3CHF2 0.013 2,690 CH3CH2CH3 CHClF2 HCFC R-402B Zeotropic blend R-125/R-290/R-22 CF3CHF2 0.02 2,310 CH3CH2CH3 CHClF2 HCFC R-403A Zeotropic blend R-22/R-218/R-290 CHClF2 0.026 3,000 C3F8 CH3CH2CH3 HCFC R-403B Zeotropic blend R-22/R-218/R-290 CHClF2 0.019 4,310 C3F8 CH3CH2CH3 HCFC R-408A Zeotropic blend R-125/R-143a/R-22 CF3CHF2 0.026 3,100 CF3CH3 CHClF2


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Family Refrigerant No. Name Formula ODP GWP100 HCFC R-409A Zeotropic blend R-22/R-124/R-142b CHClF2 0.048 1,400 CF3CHClF CH3CClF2 HCFC R-411B Zeotropic blend R22/R-152a/R-1270 CHClF2 0.032 1,600 CHF2CH3 C3H6 Family Refrigerant No. Name Formula ODP GWP100 HFC R-23 Trifluoroethane CHF3 0 12,000 HFC R-32 Difluoromethane CH2F2 0 550 HFC R-125 Pentafluoroethane CF3CHF2 0 3,400 HFC R-134a 1,1,1,2-Tetrafluoroethane CF3CH2F 0 1,300 HFC R-143a 1,1,1-Trifluoroethane CF3CH3 0 4,300 HFC R-152a 1,1-difluoroethane CHF2CH3 0 120 HFC R-404A Zeotropic blend R-125/R-143a/R-134a CF3CHF2 0 3,780 CHF2CH3 CF3CH2F HFC R-407A Zeotropic blend R-32/R-125/R-134a CH2F2 0 1,990 CF3CHF2 CF3CHF2F HFC R-407B Zeotropic blend R-32/R-125/R-134a CH2F2 0 2,700 CF3CHF2 CF3CHF2F HFC R-407C Zeotropic blend R-32/R-125/R-134a CH2F2 0 1,650 CF3CHF2 CF3CH2F HFC R-407D Zeotropic blend R-32/R-125/R-134a CH2F2 0 1,500 CF3CHF2 CF3CH2F HFC R-410A Zeotropic blend R-32/R-125 CH2F2 0 1,980 CF3CHF2 HFC R-417A Zeotropic blend R-600a/R-125/R-134a CH(CH3)3 0 1,920 CF3CHF2 CF3CH2F HFC R-507 Azeotropic blend R-125/R-143a CF3CHF2 0 3,850 CF3CH3 HFC R-508B Azeotropic blend R-23/R-116 CHF3 0 11,950 CF3CF3 Family Refrigerant No. Name Formula ODP GWP100 HC R-50 Methane CH4 0 24.5 HC R-170 Ethane CH3CH3 0 20 HC R-290 Propane CH3CH2CH3 0 20 HC R-600 Butane C4H10 0 20 HC R-600a Isobutane CH(CH3)3 0 20 HC R-1150 Ethylene CH2=CH2 0 * HC R-1270 Propylene C3H6 0 *


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Family Refrigerant No. Name Formula ODP GWP100

Nat Sub R-718 Water H2O 0 <1 Nat Sub R-744 Carbon dioxide CO2 0 1 Nat Sub R-717 Ammonia NH3 0 <1 Other refrigerants from different families The GWP100 figures for the following refrigerants have yet to be confirmed. However, it is unlikely that any of these refrigerants will be considered for commercial applications. Family Refrigerant No. Name Formula ODP GWP100 Methane R-30 Methylene chloride CH2Cl2 0 15 Methane R-40 Methyl chloride CH3Cl 0 TBC Ethane R-116 Hexaflouroethane CF3CF3 0 * Propane R-218 Octofluoropropane CF3CF2 CF3 0 7,000 Oxygen R-611 Methyl formate C2H4O2 0 TBC Inorganic R-764 Sulphur dioxide SO2 0 TBC Unsat organic R-1130 1,2-Dichloroethylene CHCl=CHCl 0 TBC The above tables are not a complete list of substances which may be used, if other blends are produced meeting the appropriate ODP and GWP limits, they should also be considered. Notes 1. Refrigerant numbers in bold are, or were, the most commonly used. 2. Not all HCFC blends have been included – many were developed but not marketed. 3. * - signifies not known 4. Nat Sub – natural substances (not legislated against with regard to ODP or GWP) 5. TBC – signifies to be confirmed 6. GWP values are taken from Intergovernmental Panel on Climate Change (IPCC), 2001 ‘Climate Change 2001: The Scientific Basis’. 7. Current as of October 2004 8. The use of CFC refrigerants is banned or severely restricted under the Montreal Protocol Lloyd's Register, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as the ‘Lloyd's Register Group’. The Lloyd's Register Group assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd's Register Group entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.


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Appendix 2 – Halons and Halon replacements Halons Trade name Formula ODP Atmospheric lifetime

Halon 1211 CF2BrCl 3.0 25 Halon 1301 CF3Br 10.0 110 Halon 2402 C2F4Br2 6.0 28 Halon replacements Trade name Formula Designation GWP100 Atmos’ lifetime FE-13 CHF3 HFC 23 11,700 264 FE-125 CF3CHF2 HFC 125 2,800 33 FM-200 CF3CHFCF3 HFC 227ea 2,900 37 FE-36 CF3CH2CF3 HFC 236fa 6,300 209 CEA-308 (perfluoropropane) C3F8 PFC-2-1-8 7,000 2,600 CEA-410 (perfluorobutane) C4F10 PFC-3-1-10 7,000 2,600 Perfluorohexane C6F14 PFC-5-1-14 7,400 3,200 NN100 N2 IG-100 0 Natural substance Argotec Ar IG-01 0 Natural substance Argonite N2/Ar mix IG-55 0 Natural substance Inergen N2/Ar/CO2 mix IG-541 0 Natural substance Water mist 0 Fine particulate aerosol 0 Notes 1. The PFC family of replacements is banned by IMO, SOLAS Chapter II-2, Reg 10, 4.1.3 refers. 2. Not all replacement blends have been included – many have been developed but no information is available, for example

Novec 1230, a fluorinated ketone. 3. Natural substances cannot be legislated against with regard to ODP or GWP; however, toxicity may be an issue.


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Appendix 3 – sample log sheet

Log Sheet for Record Keeping Obligation, RAC Equipment

This record sheet allows compliance with Revised MARPOL Annex VI, Reg 12, 1005/2009 & 842/2006. A separate sheet must be kept for each refrigeration system that contains 3 kg or more of refrigerant.

RECORD SHEET FOR MARPOL ANNEX VI & EUROPEAN REGULATION COMPLIANCE General Information

Ships Name IMO No.

Plant Name Reference No.

Location of plant

Company and operator’s name

Cooling loads served

Refrigerant Type Refrigerant Quantity (kg)

Plant manufacturer Year of installation

Refrigerant Additions

Date Engineer/Company Amount Added, kg Reason for addition

Refrigerant Removals

Date Engineer/Company Amount Removed, kg Reason for removal. What was done with recovered refrigerant

Leak Tests

Date Engineer/Company Test Result (including location and cause of any leaks identified) Follow up actions required

Follow-up Actions

Date Engineer/Company Related to test on Actions Taken

Testing of Automatic Leak Detection System (if fitted)

Date Engineer/Company Test Result Comments

Appendix 4 – flow chart

Does any system onboard contain an

ODS?


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No

Yes

Is it a new installation? No

Does any fire suppression

system contain halon?

Does any A/C or refrigeration system

contain a man-made refrigerant?

Yes

Permitted until replaced or required

to be removed by international, national or other requirements

No

Yes

Does the system contain

HCFCs? No

Does any system contain CFCs?

Complies with

Regulation 12

Yes

Complies with Regulation 12

Complies with

Regulation 12

Yes

Yes

Does any fire suppression

system contain halon?

No

Yes

No

Complies with

Regulation 12

Complies, HCFCs to be listed on the

IAPP Certificate

Complies, CFCs to be listed on the IAPP Certificate

No

Complies with

Regulation 12

No

Does any system contain CFCs?

Yes

Yes

Complies, CFCs to be listed on the IAPP Certificate

No

Does the system contain

HCFCs? No

Yes

Complies with

Regulation 12

Does any A/C or refrigeration system

contain a man-made refrigerant?

Complies, Halons to be listed before 19 May 2005

Complies, HCFCs to be listed on the

IAPP Certificate

revised annex vi regulation 12 guidance notes marpol vi

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