Revised MARPOL Annex VI- Guidance Notes

7/17/2019 Revised MARPOL Annex VI- Guidance Notes

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Guidance notes

Revised MARPOL Annex VIRegulation 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 therequirements of MARPOL 73/78, Annex VI, Regulation 12 (hereafter referred to as RevisedMARPOL Annex VI).

1.1.1. These guidance notes are divided into sections covering; the application, survey, reportingand certification of equipment under Revised MARPOL Annex VI.

1.2. Revised MARPOL Annex VI will enter into force on 01 July 2010. The original MARPOLAnnex VI entered into force on 19 May 2005. Ship Owners have already undertakenverification surveys and International Air Pollution Prevention (IAPP) Certificates should bein place.

1.3. Revised MARPOL Annex VI covers air pollution from ships caused by emission of ozonedepleting substances. Whilst new fire-extinguishing installations containing ozonedepleting halons had been prohibited as from 1 October 1994, existing system may stillcontain halons. Therefore, fire-fighting aspects continue to be included in these guidancenotes.

1.4. Revised MARPOL Annex VI, Regulation 12 applies to all ships and to fixed and floatingdrilling rigs and other platforms. Ships of 400 gross tons and above must be surveyed andissued with an IAPP Certificate before the ship is put into service. For existing ships of 400gross tons and above, engaged in international voyages, the next renewal survey shall besuch as to ensure that equipment, systems, fittings, arrangements and material comply fullywith applicable requirements of the Revised MARPOL Annex VI.

2. Surveys



2.1.2 Revised MARPOL Annex VI surveys will normally be dealt with in their entirety and not aspart 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 surveychecklist 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 id d th t ll bl ti h b t k ft th f th



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 surveyin 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 underthe jurisdiction of other Parties; and

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

3.3 Regulation 12 (Full)

Ozone Depleting Substances

1 This regulation does not apply to permanently sealed equipment where there are no refrigerant chargingconnections or potentially removable components containing ozone depleting substances.

2 Subject to the provisions of regulation 3.1, any deliberate emissions of ozone depleting substances shallbe 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 minimalreleases 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 byParties.

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 theequipment 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:



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

5 Each ship subject to regulation 6.1 shall maintain a list of equipment containing ozone depletingsubstances. 2

6 Each ship subject to regulation 6.1 which has rechargeable systems that contain ozone depletingsubstances 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) ofsubstance 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



2 If a particular port or terminal of a Party is – taking into account the guidelines to be developed by theOrganization – remotely located from, or lacking in, the industrial infrastructure necessary to manageand 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 thisinformation may be circulated to all Parties and Member States of the Organization for their informationand any appropriate action. Each Party that has provided the Organization with such information shallalso notify the Organization of its ports and terminals where reception facilities are available to manageand 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 tocompliance. 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 usedwhen appropriate. There will always be exceptions to allow compliance. Novelarrangements 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 depletingsubstances. If deemed necessary by the attending surveyor, details of the refrigerant leakmonitoring system and a plan showing the location of all detector sensor heads may besubmitted, 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 depletingsubstances and the removal of these substances from the ship. It does not cover the operationof systems which utilize these refrigerants or halons onboard existing ships. Whilst still notspecifically stipulating that a leak detection regime needs to be undertaken, the statement thatemissions arising from leaks of an ozone-depleting substance, whether or not the leaks are deliberate, maybe regulated by Parties is perceived to indicate that a form of leak prevention and leak detection



4.2.2 The statement now made in Regulation 12, paragraph 3.2 is for installations which containhydrochlorofluorocarbon (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 MontrealProtocol has been tightened. The Nineteenth Meeting of the Parties decided in December2007 to accelerate the phase-out of HCFCs. Now, by 2020 the global consumption of HCFCsin 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 requirementswill be overtaken by national and global legislation, especially if the requirements of theMontreal 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 topermanently sealed equipment where there are no refrigerant charging connections orpotentially removable components containing ozone depleting substances. Domesticrefrigerators, domestic freezers, ice makers, water coolers and self contained air-conditionersare 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 arrangementsare considered to fall within Regulation 12. For air conditioning systems and refrigerationinstallations guidance on what equipment is considered to be subject to Regulation 12 stemsfrom 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; thecompressor, 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 isconsidered to be a sealed or ‘retail’ unit and not considered under Regulation 12. Examples ofthis are; domestic refrigerators and freezers, small self contained (free standing) airconditioning units, drinking water fountains and self contained service air dryers.



4.3.5 All centrally located accommodation air conditioning system packaged units are consideredsubject to Regulation 12. If the air conditioning unit is of integral construction, where onlycooling 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 tofall within the requirements of Regulation 12. It is normally obvious from looking at therefrigeration pipework and components that the system has been constructed from separateitems of equipment. The tell-tail signs being; equipment mounted on bulkheads, multiple

bedplates, de-mountable (flare) couplings and flange connections on the major items ofequipment. Examples of this type of unit are; domestic provision rooms with thecompressors remotely located, split air conditioning units with the condenser mountedexternally away from the evaporator/compressor set (often referred to as “splits”) and airconditioning 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 standard50/50 mix or 80/20 polyisocyanurate mix, is the most widely used insulation especially forpre-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 stageother components are added. The main one, termed the ‘blowing agent’, is a chemical with asuitably low boiling point which is added in smaller quantities. As the heat of reactionvolatilises the blowing agent, numerous small bubbles of blowing agent vapour, known ascells, 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 theearly 1990’s, HCFC R-141b, with a boiling point of 32°C, was near universally introduced forblowing polyurethane foam. As both of these gases are ozone depleting, thus affected byRegulation 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



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 landmarkwas passed on 01 January 2010, when the production and consumption of CFCs, even in thedeveloping (Article 5) countries, was banned. Thus, the use of these refrigerants to maintainexisting 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 beonly 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 arecurrently going through a transitional period of legislation. Regulation 12 makes anexception 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 newrefrigeration and air-conditioning installations effective from 01 January 2001. In accordancewith the European Commission, if the ship’s Flag Administration is a member of theEuropean Community, this legislation applies. America, Australia and Japan all have HCFCspecific 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 hasprohibited 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 byinternational, national or other legislation or requirements. The release of halon can still beundertaken in accordance with the requirements of Regulation 3. Where there is any concernregarding the acceptability of the fire fighting media being used, advice should be obtainedfrom 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 HFCR-227ea (FM-200) were originally developed as alternatives to CFC refrigerants and halons.



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 isalso not applicable to these refrigerants.

4.6.3 The various HFC gases and fluorinated ketone which are being marketed as direct or neardirect drop in replacements for halon 1301 are all considered ozone benign substances. A listof these substances is shown in Appendix 2. Other alternatives to halon 1301 such asnitrogen, argon and carbon dioxide are all ozone benign substances and need not beconsidered.

4.7 Maintenance equipment

4.7.1 Compliance with the statement in paragraph 32 of Regulation 12, that deliberate emissionsoccurring in the course of maintaining, servicing, repairing of the equipment shall beprohibited will require specialist servicing equipment. If maintenance of the refrigerationand air-conditioning equipment is to be undertaken by ship’s staff, then this specialistequipment 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 toprovide all necessary equipment.

4.7.2 Before maintenance of the refrigeration equipment can be undertaken, the refrigerant needsto be removed or reclaimed from the section or item of equipment to be worked on. Thisrequires the section or item of equipment to be ‘pumped down’ (put under a partial vacuumusing 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 recoverysystem 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 aresupplied in various colours, the colour may indicate which refrigerant it contains, but itshould, in every case, have a yellow band or section around the cylinder neck to indicatethat it contains recovered refrigerant.



4.7.6 Minimal releases of refrigerant, such as will occur when the recovery unit pipework isdisconnected from the system, can not be readily prevented and as such is acceptable inaccordance 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 arecovery unit, complete with a specialist container or external cylinder, or cylinders if morethan one type of refrigerant is used, is not provided, then paragraph 2 of Regulation 12 isconsidered 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, oroperator, requests the Refrigerating Machinery Certificate (RMC) notation to be assign tothe ship, is the refrigeration system approved. If the Environmental Protection (EP) notationis to be assigned, the applicable refrigerant systems are also considered but do not requireplan approval. When the RMC or EP notation is assigned, compliance with RevisedMARPOL 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 arebeing used. It is a requirement of most refrigeration and air conditioning design codes thatthe refrigeration plant is clearly labelled with the refrigerant used. The quantity ofrefrigerant 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 chargecalculator can be provided, if required contact; [email protected].

4.8.3 Refrigerants and refrigerant blends have been formulated to operate at their most efficientunder certain evaporating and condensing temperatures. Thus it is normal to have onerefrigerant in an air-conditioning system which has a high evaporating temperature andanother 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 refrigerationsystem is known, this information and the locations of the main items of equipment shouldbe recorded under paragraph 2.1.2 of the Supplement to the International Air Pollution



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 therequirements 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 andextinguishing media on board are in keeping with the approved fire control plans andsuitable for use.

5.1.2 It should be confirmed that no fire fighting system on board, including secondary systemssuch 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 andthe 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 isavailable.

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 theship was constructed on or after 19 May 2005. Some countries, foe example Denmark, triedto 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:



It is therefore considered that a refrigerant leak monitoring system is required but only if anozone depleting substance is being used, such as HCFC R-22, and the Flag Administrationof 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 refrigerantrecovery unit and associated cylinders need to be provided. The special cylinders used forrecovery should be specially marked and labelled, e.g. “HCFC R-22 – Recovered”. Themarkings 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 recoverycylinder(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 aspossible and equipped with valves or self-closing connections to minimise any unavoidableloss 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 leakdetection method uses a solution of soap in water. This is painted onto all joints andconnections which are then inspected for the formation of bubbles. A more effective methodis 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 drawnover the element using the venturi effect. If fluorine atoms are present they decompose andthe colour of the flame changes to blue. The shade of blue gives an indication of the severityof the leak. If a halide torch is used, toxic fumes are produced (phosgene gas) when HCFCsare 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 ionisationof decomposed refrigerants between two oppositely charged platinum electrodes. This typeof detector is suitable for HCFC and HFC refrigerants. They are extremely effective at



5.3.4 A further system of leak detecting involves adding a small amount of fluorescent dye to therefrigerant 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 byilluminating the area with an infrared lamp.

5.3.5 The periodicity of leak detection is at the discretion of the owner/operator. The quantity ofrefrigerant in each system is one way to establish the time interval between leak detection.For guidance purposes, the following NVKL recommendations are considered acceptableand 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 Yearly3 ≤ 30 kg Control room A/C, small provision chambers Quarterly30 ≤ 300 kg Cargo ship accommodation A/C, provision rooms Monthly300 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 systemis completely sealed, with no breakable connections, then leak testing may be waived at thediscretion of the owner/operator.

5.3.7 Any detected leakage should be repaired as soon as possible. If the leaking system ismaintained by a third party, such as a shore-side refrigeration contractor, then the repairshould be completed in the next port. The equipment or system shall be checked for leakageafter 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 ‘logbook’ should be kept. The information it contains should comply with paragraph 7 ofRegulation 12 and that proposed by other refrigeration legislation such as Regulation (EC)No. 842/2006 and Regulation (EC) 1005/2009 for EC countries.



5.4.3 In accordance with paragraph 6 of Regulation 12, this record or log book is to be approved bythe 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 maintainedfor each system. This would allow a refrigerant usage trend to be determined and soindicate whether a system has started to leak significantly. An allowable annual leakagefigure is hard to estimate but the following may be used as an indication;

30% of initial charge for small systems10% 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 largeproportion 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 usageshould 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 recyclingor 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



5.5.2 It is not normally considered necessary for an individual provision room to be fitted with aleak detector sensor, as the number of de-mountable joints and possible leak locations, forexample 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 otherancillary valves and fittings located in a central lobby area, this space should be fitted with adetector.

5.5.3 If all refrigeration control and isolating valves, etc. are fitted in the individual rooms, then adetector should be fitted in each room. Spaces that houses only welded or braisedrefrigerant 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 themanufacturer’s recommendation is less than this figure then their requirements should beadhered to. The location of the sensor head is dependant on the type of refrigerant used andwhether the leak is most likely in the liquid or vapour phase. Where leakage is likely to be inthe 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. Dueregard is also to be taken of the expected direction of the ventilation air stream. If therefrigeration space has a dedicated ventilation system then it is good practice to place adetector 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 calibratedand 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 fromthe safety relief valves fitted to the compressors and pressure vessels in each refrigerationsystem.

5.5.7 Refrigerant detector systems normally consist of a central electronic control unit to which anumber of detector sensor heads are connected. The number of sensor heads fitted isnormally between 4 and 12 but large systems may be of modular construction and allowadditional input cards to be fitted. Some detector sensor heads need to be changed asregularly as every two years. The system manufacturer’s requirements need to be



5.5.8 The refrigerant alarm detector panel may be located on the bridge or in the engine controlroom (ECR). It is proposed that refrigerant detector alarm activation will initiate; the ship'sengine 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 refrigerationinstallations, is for all the refrigeration equipment, containing the primary refrigerant, to belocated in a designated space. In this case only this dedicated refrigerant machinery spaceneeds 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 primaryrefrigerant valve stations and demountable joints should be fitted with a fixed refrigerantdetector 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. Twotypes of refrigerant detectors are normally used with halogenated fluorocarbon refrigerants.Infrared is the most accurate but carries a significant price premium. The semi-conductortype is cheaper and less accurate. The latter type is the most commonly specified and will bemost 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 forideal 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 partialblockage of sensor heads may result in concentrations between 150 and 175 ppm beingnecessary before a leak can be detected. To allow for background contaminants and highambient temperature and humidity, a detection level of 300 ppm is considered the practicalminimum to prevent nuisance alarms.

5.5.13 This figure should be compared with the 150 to 200 ppm initial alarm and 750 to 800 ppmleakage 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 systemalarm the second level is considered redundant.



5.5.14 If the owner or operator wishes, the alarm set point may be reduced depending upon thetype of equipment provided. If however, it is found that nuisance alarms continue, when thedetector 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 thealarm set point should be recorded in the system’s operating manual and refrigerant logbook.

5.5.15 Dates of leak detection, number and severity of any leaks detected, steps taken to repairleakage and amount of refrigerant added should be included in the refrigerant log book orengine 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 eachrefrigeration system are to be available on board. The operating manual should be suitablefor the system installed. For small systems, the amount of maintenance will be limited andno 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 asdefrosting, leak detection and filter-drier replacement should also be covered.



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 EnvironmentalProtection Notation. The refrigerants that are considered ‘mainline’ and suitable for use inmarine applications for refrigerated cargo, air conditioning and provision room refrigerationsystems are shown with an asterisk thus *.

A number of refrigerants from the hydrocarbon group have been included. Specialconsideration 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 1300R-718 Water H2O 0 0R-744 * Carbon dioxide CO2 0 1R-407A * Blend of R-32/125/134a CH2F2 0 1770

CF3CHF2

CF3CHF2FR-407C * Blend of R-32/125/134a CH2F2 0 1526

CF3CHF2

CF3CHF2FR-410A * Blend of R-32/125 CH2F2 0 1725

CF3CHF2

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

R-717 * Ammonia NH3 0 0

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



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 TBCR-764 Sulphur dioxide SO2 0 TBCR-40 Methychloride CH3Cl 0 TBCR-611 Methylformate C2H4O2 0 TBCR-1130 1,2-Dichloroethylene CHCl=CHCl 0 TBC

R-1150 Ethylene CH2=CH2 0 TBCR-1270 Propylene C3H6 0 TBC

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



Appendix 1 – List of compounds used as refrigerants or refrigerant blends

Family Refrigerant No. Name Formula ODP GWP100

CFC R-11 Trichlorofluoromethane CCl3F 1 4,000CFC R-12 Dichlorodifluoromethane CCl2F2 1 8,500CFC R-13 Chlorotrifluoromethane CClF3 1 11,700CFC R-113 1,1,2-trichloro 1,2,2-trifluoroethane CCl2FCClF2 0.8 5,000CFC R-114 1,2-dichloro 1,1,2,2-tetrafluoroethane CClF2CClF2 1 9,300CFC R-115 Chloropentafluoroethane CF3CClF2 0.6 9,300

CFC R-500 Azeotropic blend of R-12 and R-152a CCl2F2 0.74 6,300CHF2CH3

CFC R-502 Azeotropic blend of R-22 and R-115 CHClF2 0.33 5,600CF3CClF2

CFC R-503 Azeotropic blend of R-23 and R-13 CHF3 0.6 11,900CClF3


HCFC R-22 Chlorodifluoromethane CHClF2 0.055 1,700HCFC R-123 2,2-dichloro 1,1,1-trifluoroethane CF3CHCl2 0.012 120HCFC 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 1,130CHF2CH3

CF3CHClFHCFC 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 2,690CH3CH2CH3 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 3,000C3F8 CH3CH2CH3

HCFC R 403B Z t i bl d R 22/R 218/R 290 CHClF 0 019 4 310




HCFC R-409A Zeotropic blend R-22/R-124/R-142b CHClF2 0.048 1,400CF3CHClF

CH3CClF2 HCFC R-411B Zeotropic blend R22/R-152a/R-1270 CHClF2 0.032 1,600

CHF2CH3 C3H6


HFC R-23 Trifluoroethane CHF3 0 12,000

HFC R-32 Difluoromethane CH2F2 0 550HFC R-125 Pentafluoroethane CF3CHF2 0 3,400HFC R-134a 1,1,1,2-Tetrafluoroethane CF3CH2F 0 1,300HFC R-143a 1,1,1-Trifluoroethane CF3CH3 0 4,300HFC R-152a 1,1-difluoroethane CHF2CH3 0 120

HFC R-404A Zeotropic blend R-125/R-143a/R-134a CF3CHF2 0 3,780CHF2CH3 CF3CH2F

HFC R-407A Zeotropic blend R-32/R-125/R-134a CH2F2 0 1,990CF3CHF2 CF3CHF2F

HFC R-407B Zeotropic blend R-32/R-125/R-134a CH2F2 0 2,700CF3CHF2 CF3CHF2F

HFC R-407C Zeotropic blend R-32/R-125/R-134a CH2F2 0 1,650CF3CHF2

CF3CH2FHFC 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 1,980CF3CHF2

HFC R-417A Zeotropic blend R-600a/R-125/R-134a CH(CH3)3 0 1,920CF3CHF2

CF3CH2FHFC R-507 Azeotropic blend R-125/R-143a CF3CHF2 0 3,850CF3CH3

HFC R-508B Azeotropic blend R-23/R-116 CHF3 0 11,950CF3CF3

Family Refrigerant No Name Formula ODP GWP




Nat Sub R-718 Water H2O 0 <1Nat 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 theserefrigerants will be considered for commercial applications.


Methane R-30 Methylene chloride CH2Cl2 0 15Methane R-40 Methyl chloride CH3Cl 0 TBCEthane R-116 Hexaflouroethane CF3CF3 0 *Propane R-218 Octofluoropropane CF3CF2 CF3 0 7,000Oxygen R-611 Methyl formate C2H4O2 0 TBCInorganic R-764 Sulphur dioxide SO2 0 TBCUnsat 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 theappropriate 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 20048. The use of CFC refrigerants is banned or severely restricted under the Montreal Protocol



Appendix 2 – Halons and Halon replacements

Halons

Trade name Formula ODP Atmosphericlifetime

Halon 1211 CF2BrCl 3.0 25Halon 1301 CF3Br 10.0 110Halon 2402 C2F4Br2 6.0 28

Halon replacements

Trade name Formula Designation GWP100 Atmos’ lifetime

FE-13 CHF3 HFC 23 11,700 264FE-125 CF3CHF2 HFC 125 2,800 33FM-200 CF3CHFCF3 HFC 227ea 2,900 37FE-36 CF3CH2CF3 HFC 236fa 6,300 209

CEA-308 (perfluoropropane) C3F8 PFC-2-1-8 7,000 2,600CEA-410 (perfluorobutane) C4F10 PFC-3-1-10 7,000 2,600Perfluorohexane C6F14 PFC-5-1-14 7,400 3,200

NN100 N2 IG-100 0 Natural substanceArgotec Ar IG-01 0 Natural substanceArgonite N2/Ar mix IG-55 0 Natural substance

Inergen N2/Ar/CO2 mix IG-541 0 Natural substance

Water mist 0Fine 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 exampleNovec 1230, a fluorinated ketone.3. Natural substances cannot be legislated against with regard to ODP or GWP; however, toxicity may be an issue.



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. Aseparate 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 plantCompany 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, kgReason for removal. What was donewith recovered refrigerant

Leak Tests

Date Engineer/CompanyTest Result (including location andcause of any leaks identified)

Follow up actions required

Follow-up Actions

Date Engineer/Company Related to test on Actions Taken



Appendix 4 – flow chart

Was the shipconstructed on or

after 19 May 2005?

Do any systemsonboard contain

ODSs?

Yes

No

Installationprohibited

Does any air-conditioning orrefrigeration system contain a

man-made refrigerant?

Complies, no furtheraction required

Does any fire suppression orinerting system contain halon? Yes Yes

No

Permitted until replaced orrequired to be removed byinternational, national or

other requirements.Complies, no further

action required No

Systems containing halonsto be listed

Does refrigeration equipmenthave charging connection or

removable components?

NoComplies, no further

action required

Yes Yes

NoComplies, no further

action required

Does any systemcontain CFCs?

Yes

Permitted until required to be removed by

international, national orother requirement.

Systems containing CFCsto be listed

NoDoes any systemcontain HCFCs?

Yes

Permitted until required to be removed by

international, national orother requirement.

Systems containingHCFCs to be listed

No

Complies, no furtheraction required

Revised MARPOL Annex VI

CFCs are prohibited from use inexisting refrigeration systems if theship was constructed on or after 19

May 2005

HCFCs will be prohibited in newinstallations after 01 January 2020

Documents

Revised MARPOL Annex VI- Guidance Notes