SCRUBBER

TRAINING
2020

1
Contents:
1 INTRODUCTION 4
1.1 REGULATORY BACKGROUND 4-6
1.2 DEFINITIONS AND REQUIRED DOCUMENTS 7
1.3 SAFETY NOTE 8
2 RULES & REGULATIONS 9
2.1 REGIONAL AND LOCAL REGULATIONS 9-16
2.2 IMO EXHAUST GAS CLEANING SYSTEM (EGCS) GUIDELINES 17-21
2.3 REQUIRED EGC SYSTEM DOCUMENTATION 22-23
2.4 EMISSIONS MONITORING 24-25
2.5 WASHWATER DISCHARGE CRITERIA AND MONITORING 26-31
2.6 DATA MONITORING 32
2.7 WASH WATER RESIDUES 33
2
Contents:
2.8 PSC CHECKLIST 34
3 EGC SYSTEM CONCEPTS 35

3.1 GENERAL 35-36

4 SHIP IMPLEMENTATION PLAN 37-39
5 TECHNICAL AND OPERATIONAL RISKS 40-51
6 FAQ 52-60
7 APPENDICES 61
Appendix 1 - FORM OF SOX EMISSION COMPLIANCE CERTIFICATE
Appendix 2 - PROOF OF THE SO2/CO2 RATIO METHOD
Appendix 3 - WASHWATER DATA COLLECTION

8 TRAINING VIDEO 62 3
 1 - INTRODUCTION
1.1 - REGULATORY BACKGROUND

The marine industry is facing the challenge of adopting new technologies and/or operational practices to comply with
stricter international, regional, national and local regulations introduced to reduce air emissions from ships. The adverse
effects of exhaust emissions from internal combustion engines and boiler exhaust gases on human beings and sensitive
ecosystems have been well documented by the scientific community. The objective of regulations introduced by the
International Maritime Organization (IMO), the European Union (EU), the U.S. Environmental Protection Agency (EPA),
the People’s Republic of China (PRC), the Government of the Hong Kong Special Administrative region of the PRC and the
California Air Resources Board (CARB) is to reduce the negative impact shipping makes on global and local air quality.
Critical amongst these regulations are the measures to reduce sulfur oxide (SOx) emissions inherent to the relatively high
sulfur content of marine fuels. Ship designers, owners and operators have a number of different routes to achieve SOx
regulatory compliance: • Use low-sulfur marine fuels in existing machinery
• Install new machinery (or convert existing machinery where possible) designed to operate on a low sulfur alternative
fuel, such as liquefied natural gas (LNG)
• Install an Exhaust Gas Cleaning System (EGCS) as an after treatment device

4
 1.1 - REGULATORY BACKGROUND

Marine air pollution regulations typically require the use of low-sulfur fuel in order to reduce SOx gaseous emissions and
the sulfate portion of the particulate matter (PM) emissions. However, the use of EGCS technology is generally permitted
as an alternative means of compliance. While EGCS have limited commercial marine references, they are proven
technologies with numerous land-based installations and applications as part of the inert gas systems on tankers.
Scrubbers can be effective in complying with regulations that require the use of 0.1 percent sulfur fuel.
With regard to meeting the regulatory requirements for emissions of nitrogen oxides (NOx), a typical EGCS provides only
negligible reduction in NOx emissions and is not an effective method for obtaining compliance with NOx emission
requirements. A number of primary (engine) and secondary (after treatment) techniques for reducing NOx emissions
exist. One primary engine technique is the use of exhaust gas recirculation (EGR), which involves the recirculation of a
portion of the exhaust gas, typically 20 to 40 percent, back into the combustion chamber. For marine applications, this
technique may include an EGCS to prevent engine fouling, corrosion and wear issues because of the relatively high sulfur
content in the fuel. IMO is currently in the process of developing guidelines applicable to the bleed off water from EGR
systems. Selective catalytic reduction (SCR) after treatment systems may be used as a means of reducing NOx emissions,
which have the potential to reduce emissions by up to 95 percent.

5
 1.1 - REGULATORY BACKGROUND

While scrubbers offer the potential for lower operating costs by permitting the use of less expensive high-sulfur fuels,
capital, installation and operational costs associated with scrubbers must be considered on a vessel-specific basis. These
costs need to be assessed against the alternatives of operating a ship on low-sulfur fuel or an alternative low-sulfur fuel,
such as LNG. Fuel switching, an operational practice in which higher sulfur fuel is used where permitted and lower sulfur
fuel is burned where mandated, has its own complications and risks but need to also be considered during an evaluation
of fuel compliance options. The operating profile of the ship will often dictate which compliance option offers the best
capital expenditure versus operational benefit.

6
1.2 - DEFINATIONS AND REQUIRED DOCUMENTS

Fuel oil combustion unit Any engine, boiler, gas turbine, or other fuel oil fired equipment, excluding shipboard incinerators
EGC Exhaust gas cleaning
SOX Sulphur oxides
SO2 Sulphur dioxide
CO2 Carbon dioxide
UTC Universal Time Co-ordinated
Certified Value The SO2/CO2 ratio specified by the manufacturer that the EGC unit is certified as meeting when operating on a continuous basis on
the manufacturers specified maximum fuel Sulphur content

In situ Sampling directly within an exhaust gas stream

MCR Maximum Continuous Rating
Load range Maximum rated power of diesel engine or maximum steaming rate of the boiler
SECP SOX Emissions Compliance Plan
SECC SOX Emissions Compliance Certificate
ETM-A EGC system – Technical Manual for Scheme A
ETM-B EGC system – Technical Manual for Scheme B
OMM Onboard Monitoring Manual
EGC Record Book A record of the EGC unit in-service operating parameters, component adjustments, maintenance and service records as appropriate

7
1.3 - SAFETY NOTE

Due attention is to be given to the safety implications related to the handling and proximity of exhaust gases, the
measurement equipment and the storage and use of pressurized containers of pure and calibration gases. Sampling
positions and permanent access platforms need to be such that this monitoring may be performed safely. In locating
discharge outlet of wash water used in the EGC unit, due consideration need to be given to the location of the ship's
seawater inlet. In all operating conditions the pH need to be maintained at a level that avoids damage to the vessel’s anti-
fouling system, the propeller, rudder and other components that may be vulnerable to acidic discharges, potentially
causing accelerated corrosion of critical metal components.

8
 2 - RULES & REGULATIONS
2.1 - REGIONAL AND LOCAL REGULATIONS

The IMO considers exhaust gas scrubbers to be an acceptable means of reducing vessels’ Sulphur emissions and
ensuring compliance with MARPOL Annex VI. A separate guideline, Resolution MEPC.259(68), specifies the
requirements for the verification, testing, survey and certification of scrubber systems and sets out the criteria for
discharging scrubber wash water into the sea.

However, some coastal states and ports have implemented local regulations with more stringent requirements that
restrict or completely prohibit the discharge of wash water from open loop scrubbers or prohibit the use of scrubbers.
We are currently aware of the following regions/states/ports with local regulations that have an effect on the discharge
of exhaust gas scrubber wash water, although the list need to not be considered as complete.

9
2.1 - REGIONAL AND LOCAL REGULATIONS

ASIA

China
China’s Ministry of Transport (MOT) issued its ‘Notice on Regulating the Implementation of Supervision and
Management of Ship Air Pollutant Emission Control Areas’ which states that from 1 January 2019 discharge of wash
water from scrubbers is prohibited in the county’s inland emission control areas (ECAs), port water areas of coastal
domestic ECAs and Bohai Bay waters. The document also states that a ban in the entire coastal domestic ECA will be
announced in due course. Our local correspondent, Huatai, has published a useful circular on China’s ban on scrubber
wash water discharge, which can be accessed here. China MOT recently circulated a draft recommending that the ban
on the discharge of wash water be extended to within 12nm of all coastal areas and regions near the southern island
province of Hainan.

Hong Kong
If a ship intends to use scrubbers in Hong Kong waters, to meet the Sulphur cap requirements, application must be
made to the Hong Kong authorities requesting for an exemption from using compliant fuel. The exemption application
must be made at least 14 days prior to a ship’s first visit to Hong Kong after 1st January 2019. For details of the
exemption application process, please refer to Sections 7 to 11 of the new ‘Air Pollution Control (Fuel for Vessels)
Regulation’.
10
2.1 - REGIONAL AND LOCAL REGULATIONS

Singapore
According to the Maritime and Port Authority of Singapore (MPA), discharge is prohibited in Singapore port waters from
1 January 2020. MPA has published useful guidance on IMO’s 2020 Sulphur limits which can be accessed here. The
document advises ships fitted with open loop scrubbers to ‘carry out the switch to either closed-loop mode or to
compliant fuel well in advance of the vessel’s arrival at the port waters’. Residues from scrubbers have been classified as
toxic industrial waste under Singapore’s Environmental Public Health (Toxic Industrial Waste) Regulations. It can only be
collected by licensed Toxic Industrial Waste Collectors.

India
In DG Engineering Circular 05 of 2018, India seems to indicate that scrubber wash water discharges are allowed if the
criteria set out in MEPC.259(68) are met. However, this is qualified with a requirement that local regulations need to
also be followed. As of now, it is not clear if local restrictions will be imposed in some areas.

UAE
Abu Dhabi: In 2013 Abu Dhabi authorities issued ‘Vessel Discharge and Maintenance Guidelines For Owners, Masters
And Agents’. It states that scrubber wash water can be discharged in port waters if free form pollutants whilst scrubber
sludge need to be discharged from the vessel to an Abu Dhabi Ports Company (ADPC) licensed waste disposal
contractor.
11
2.1 - REGIONAL AND LOCAL REGULATIONS

Fujairah: As per notice to mariners no. 252, Harbour Master of Fujairah has announced that use of open loop scrubbers
will be banned in port waters. The circular can be found here.

EUROPE

Belgium
The European Commission’s 2016 note on discharge of scrubber wash water, bans the discharge in ports and inland
waters.

Germany
Discharge is not allowed in inland waterways and the Rhine, pursuant to Articles 1 and 3 of the CDNI Convention
(Convention on the Collection, Deposit and Reception of Waste Produced during Navigation on the Rhine and Inland
Waterways).

12
2.1 - REGIONAL AND LOCAL REGULATIONS

Lithuania
The authorities are currently studying the impact of scrubber wash water on the marine environment and will provide
its conclusions upon completion of the study. Meanwhile, the current position seems to be that discharge is not allowed
in port waters, according to port rules and conditions of use approved by the Ministry of Transport. Reference is made
to the European Commission’s 2016 note on discharge of scrubber wash water.

Latvia
General position, as mentioned in the European Commission’s 2016 note, is that discharge is not allowed in territorial
and port waters. Discussions are currently ongoing within the European Commission, on improving the regulations and
to provide more clarity.

Ireland

Dublin
The Irish authorities’ Notice No. 37 of 2018 ‘Prohibition on the Discharge of Exhaust Gas Scrubber Wash Water’
stipulates that discharge of wash water is prohibited in waters under Dublin port jurisdiction. Dublin port jurisdiction
includes waters from the Matt Talbot Memorial Bridge eastwards to a line from the Baily Lighthouse through the North
and South Burford buoys and through Sorrento Point.
13
2.1 - REGIONAL AND LOCAL REGULATIONS

Waterford:
As per Port of Waterford’s marine notice ‘Prohibition on the Discharge of Exhaust Gas Scrubber Wash Water’, discharge
of scrubber wash water is prohibited in port limits from the start of January 2019.

Cork:
Port notice No. 15 of 2018 states that given the potential for impact on sensitive ecosystems, and the abundance of
Natura 2000 sites within the jurisdiction of the port company, discharge of scrubber wash water is prohibited in port
waters.

Norway
Under the amendments of 1 March 2019 to Regulation No.488 on the environmental safety of ships and mobile
offshore units, use of open loop scrubbers is prohibited in the Norwegian fjords. Also, for ships using closed or hybrid
type scrubbers, a device for reducing visible emissions to air is required.

14
2.1 - REGIONAL AND LOCAL REGULATIONS

AMERICAS

Hawaii, USA
Conditional section 401 WQC (Water Quality Certification) as mentioned in section 6.7 of 2013 VGP allows for discharge
of wash water subject to certain requirements being fulfilled. These requirements can be found in the same section.

Connecticut, USA
Connecticut has laid down specific conditions as part of the 2013 Vessel General Permit (VGP) requirements. In
accordance with section 6.5.9[UK1] of the 2013 VGP, discharge of exhaust gas scrubber wash water into Connecticut
waters from any vessel covered under the VGP is prohibited. Please see CGS section 22a-427, and Connecticut Water
Quality Standards (CT WQS).

California, USA
The CARB OGV (California Air Resource Board for Ocean Going Vessels) regulations do not permit the use of abatement
technologies such as scrubbers, hence their use as well as any discharge of wash water is prohibited. Vessel discharge
regulations for Port of Long Beach also state that it is prohibited to discharge wash water from scrubbers in port waters.
However, pursuant to CARB’s Marine Notice 2017-1 discharge is permitted if the vessel has an experimental or
temporary research permit.
15
2.1 - REGIONAL AND LOCAL REGULATIONS

Australia
As of today, bans on the discharge of wash water from open loop scrubbers have not been imposed by any state. This is
indicated in the summary of the 6th roundtable discussion hosted by AMSA and MIAL. It is stated that authorities are
currently looking at the impact of scrubber discharges.

South Africa
In marine notice no. 08 of 2019 South Africa has indicated that it accepts all types of approved scrubbers including open
loop scrubbers as long as the IMO discharge criteria set out in Resolution MEPC.259(68) is met. However, recent
reports indicate that South Africa may reconsider its position on the acceptance of open loop scrubbers. A decision is
expected in September 2019.

16
 2.2 - IMO EXHAUST GAS CLEANING SYSTEM (EGCS) GUIDELINES

The development of EGCS for use on-board ships has been driven by the aforementioned IMO, national and local
regulations. These EGCS were envisaged by the original Regulation 14.4 (b) to MARPOL Annex VI, whereby SOx emissions
were limited to 6.0g/kWh for systems that met the requirements in the subsequently developed guidelines of IMO
Resolutions MEPC.130 (53), MEPC.170 (57), MEPC.184 (59) 2009 and MEPC.259 (68) 2015 Guidelines for Exhaust Gas
Cleaning Systems (adopted on May 15, 2015, and hereafter referred to as the ‘2015 Guidelines’). These guidelines
provide guidance for the monitoring of the SO2/CO2 content of the exhaust gases for varying sulfur contents of the fuel
(see Table 3) to provide equivalency to the prescribed specific SOx emission limits as stipulated in Regulations 14.1 and
14.4.
The 2008 revision to MARPOL Annex VI removed the specific reference to EGCS from Regulation 14 and approval of an
EGCS is now undertaken in accordance with the requirements under Regulation 4 of the Annex as an ‘equivalent’. Flag
Administrations must take into account any relevant guidelines developed by IMO when assessing the equipment and
notify IMO (for circulation to all Administration parties) of the details of that assessment. It is important to note that the
2015 Guidelines are not regulations. However, it is understood that EGCS installations meeting these guidelines will be
accepted as equivalent by the Administrations. This equivalence would need to be confirmed by the flag Administration
of each vessel onto which the equipment is to be installed on a case-by-case basis.
The 2015 Guidelines identify the method of determination of the pH value from the discharge wash water. The pH can be
determined either by direct measurement or by using a calculation-based methodology (computational fluid dynamics or
other equally scientifically established empirical formulae) to be left to the approval by the Administration.
17
 2.2 - IMO EXHAUST GAS CLEANING SYSTEM (EGCS) GUIDELINES

Among other sections, the following provisions were retained:

The recommendation to IMO Administrations to collect data on wash water discharges in accordance with Appendix 3 of
the guidelines enables this criterion to be subsequently reviewed by the IMO, taking into account any advice from the
Joint Group of Experts on the Scientific Aspects of Marine Environmental Pollution (GESAMP).
Provision of two basic Schemes for compliance to be used for EGCS approval, Scheme A or Scheme B, at the choice of
the equipment manufacturer. Approval is to be undertaken in accordance with the initial and ongoing survey
requirements of the guidelines by, or on behalf of, a flag Administration, typically by a class society recognized by the
Administration (as a Recognized Organization or RO).
The approval regimes being similar to those applied to diesel engines under the IMO NOx Technical Code (NTC), whereby
technical manuals are approved, certification issued (Scheme A) and continuing compliance verified through parameter
checks and continuous monitoring.
The two EGCS schemes apply the following concepts:
• Scheme A based on initial emission performance unit certification together with a continuous check of operating
parameters and daily exhaust emission monitoring
• Scheme B based on continuous exhaust emission monitoring together with a daily check of operating parameters
In both cases, the condition of discharged wash water used in the scrubbing process is to be monitored and recorded.

18
 2.2 - IMO EXHAUST GAS CLEANING SYSTEM (EGCS) GUIDELINES – SCHEME A -
EGC SYSTEM APPROVAL, SURVEY AND CERTIFICATION USING PARAMETER AND
EMISSION CHECKS

SCHEME A
For Scheme A approvals, the EGCS must be certified as meeting the emission limit value specified by the manufacturer
(the ‘certified value’) for continual operation with fuel oils of the manufacturer’s specified maximum sulfur content over
the range of declared exhaust gas mass flow rates. Mechanisms are in place within the guidelines for the emissions
testing to be reduced for ‘serially manufactured units’ of nominally similar designs where an agreed ‘conformity of
production’ arrangement is in place.
Alternatively, it is possible for the manufacturer to obtain a ‘product range approval’ for the same scrubber design by
undertaking emissions testing at the highest, intermediate and lowest capacity ratings. This certification can be
undertaken prior to or after installation on board and is approved by the issue of a serial number-based SOx Emissions
Compliance Certificate (SECC) on behalf of the vessel’s flag Administration. The basis of the approval and the EGCS
operating and maintenance parameters, together with survey procedures, are to be contained within the EGCS -
Technical Manual for Scheme A (ETM-A), which is also to be approved by the Administration, or RO acting on its behalf.
The EGCS is to be surveyed after installation to confirm that the scrubber is installed in accordance with the ETM-A, and
has the relevant SECC. This would enable the ship’s MARPOL Annex VI International Air Pollution Prevention (IAPP)
Certificate to be amended and re-issued to reflect the EGCS installation. Subsequent surveys will be undertaken at the
usual MARPOL Annex VI annual, intermediate and renewal survey intervals.

19
2.2 - IMO EXHAUST GAS CLEANING SYSTEM (EGCS) GUIDELINES – SCHEME A
- EGC SYSTEM APPROVAL, SURVEY AND CERTIFICATION USING PARAMETER
AND EMISSION CHECKS

Continual compliance is verified by continuous monitoring of EGCS operating parameters, daily checks of the exhaust
emissions and continual monitoring of the wash water discharge.
The shipowner is required to maintain an EGCS Record Book, in which the maintenance and service of the EGCS is to be
recorded and made available for inspection at EGCS surveys. The form of this record book is to be approved by the
Administration and may form part of the vessels planned maintenance record system.

20
2.2 - IMO EXHAUST GAS CLEANING SYSTEM (EGCS) GUIDELINES – SCHEME B -
EGC SYSTEM APPROVAL, SURVEY AND CERTIFICATION USING CONTINUOUS
MONITORING OF SOX EMISSION

SCHEME B
The Scheme B EGCS does not need to be pre-certified as meeting the emission limit value but must demonstrate
compliance with the required equivalent emission values to the fuel sulfur content requirements 14.1 and 14.4 of
MARPOL Annex VI Regulation 14 at any load point, including during transient operation, by verification of the SO2/CO2
ratio after the scrubber is in accordance with Table 3. This must be undertaken on a continual basis by the use of a
continuous exhaust gas monitoring system that is approved by the Administration, and which records data at a rate not
less than 0.0035 Hz.
Similar to Scheme A, Scheme B EGCS units are to be supplied with an approved EGC Technical Manual -B (ETM-B)
detailing the EGCS operating parameters and limits. The EGCS is to be surveyed after installation and at the usual
MARPOL Annex VI Annual, Intermediate and Renewal Survey intervals, in the same manner as Scheme A is surveyed for
issue of the IAPP Certificate. Continual compliance is verified by continuous monitoring of the exhaust emissions, daily
spot checks of the EGCS operating parameters and by continual monitoring of the wash water discharge. Scheme B
shipowners should be supplied with an EGCS Record Book in the same manner as Scheme A

21
 2.3 - REQUIRED EGC SYSTEM DOCUMENTATION

For ships intending to use an EGCS in part, or in full, to comply with Regulation 14 of MARPOL Annex VI, a SOx Emissions
Compliance Plan (SECP) must be approved on behalf of the Administration and is required to detail the method of
compliance for all fuel oil combustion machinery installed on board.
Furthermore, an approved Onboard Monitoring Manual (OMM) is also to be retained on board the vessel for each installed
EGCS.
The OMM need to be approved by the flag State of the vessel and is to include the following parameters:
• Data on the sensors used in the EGCS emissions and wash water monitoring system, including service, maintenance and
calibration
• Positions where the exhaust and wash water measurements are to be taken, together with any necessary supporting
services or systems
• Data on the analyzers to be used in the emissions and wash water systems, including operation, service and maintenance
requirements
• Procedures for analyzer zero and span checks
• Other information and data needed to properly operate and maintain the monitoring systems
• Details on how the monitoring systems are to be surveyed

22
2.3 - REQUIRED EGC SYSTEM DOCUMENTATION

23
 2.4 - EMISSIONS MONITORING

For EGCS operating on distillate and residual fuel oils, exhaust emission compliance with the equivalent fuel oil sulfur
content is verified from the measured SO2/CO2 concentration ratio. Table 3 below from the Guidelines shows the required
SO2/CO2 ratio in a diesel engine’s exhaust and the equivalent sulfur concentration in the fuel.
If the exhaust from the scrubber has the same or lower SO2/CO2 ratio as that tabulated, for example less than 4.3 for a
vessel operating in an ECA where fuel of a maximum of 0.1 percent sulfur is applicable, then the scrubber is considered to
be providing equivalent effectiveness.
The verification through the SO2/CO2 ratio enables a much simpler verification of exhaust emissions. The derivation of this
ratio and its applicability to typical marine fuels is given in Appendix II to the Guidelines and demonstrates the
correspondence between the 6.0g/kWh prescribed by the original MARPOL Annex VI requirements based on a brake-
specific fuel consumption of 200g/kWh.
For those scrubbers where the exhaust gas cleaning process may affect the amount of CO2 in the exhaust gases, the CO2
concentration is to be measured before the scrubber, and the SO2 concentration after it, to calculate the ratio correctly.

24
2.4 - EMISSIONS MONITORING

25
 2.5 - WASHWATER DISCHARGE CRITERIA AND MONITORING

The IMO Guidelines specify the discharge wash water quality criteria and monitoring requirements for a number of
parameters. Additional wash water limitations may be set by regional, federal or state regulations. Shipowners and vessel
managers are encouraged to verify the requirements for each of the intended ports in a vessel’s voyage.
PH CRITERIA The pH of the wash water discharged from the scrubbing process at the overboard discharge should be no
lower than 6.5 except during maneuvering or transit where the pH difference between the ship’s inlet and overboard
discharge can be up to 2 pH units measured at the ship’s inlet and overboard discharge.
The pH is to be continuously monitored with a pH electrode and meter having a resolution of 0.1 pH units and temperature
compensation, with both electrode and meter meeting the standards referenced by the Guidelines.
The wash water discharge may be diluted by mixing with other sources of sea water, such as cooling water discharges, to
achieve the required pH level. Furthermore, the pH at the wash water discharge may be adjusted by controlling the flow of
reactive water to the EGC unit. For those EGC units using chemicals or additives to meet the pH, or any other wash water
criteria, the wash water is required to be further assessed for those agents, taking into account IMO guidance for ballast
water management systems that make use of active substances (G9 under MEPC.169 (57)).

26
 2.5 - WASHWATER DISCHARGE CRITERIA AND MONITORING

During commissioning of EGCS, the overboard pH discharge limit applicable to the overboard discharge monitoring position
can be determined either by means of direct measurement or by using a calculation based methodology (computational
fluid dynamics or other equally scientifically established empirical formulae) subject to the approval of the Administration,
and in accordance with the following conditions to be recorded in the ETM-A or ETM-B:
1. EGC units connected to the same outlets are operating at their full loads (or highest practicable load) and with the fuel
oil of a maximum sulfur content for which the units are to be certified (Scheme A) or used with (Scheme B)
2. If a lower sulfur content test fuel, and/or test load lower than maximum, sufficient for demonstrating the behavior of the
wash water plume is used, the plume’s mixing ratio must be established based on the titration curve of seawater. The
mixing ratio would be used to demonstrate the behavior of the wash water plume and that the overboard pH discharge
limit has been met if the EGCS is operated at the highest fuel sulfur content and load for which the EGC system is certified
(Scheme A) or used with (Scheme B)
3. Where the wash water flow rate is varied in accordance with the EGC system gas flow rate, the implications of this for the
part load performance should also be evaluated to confirm that the overboard pH discharge limit is met under any load
4. Reference should be made to a seawater alkalinity of 2,200 mol/litre and pH 8.2; an amended titration curve should be
applied where the testing conditions differ from the reference seawater, as agreed by the Administration
5. If a calculation-based methodology is to be used, details to allow its verification such as, but not limited to, supporting
scientific formulae, discharge point specification, wash water discharge flow rates, designed pH values at both the discharge
and 4 m location, titration and dilution data should be submitted
27
 2.5 - WASHWATER DISCHARGE CRITERIA AND MONITORING

POLYCYCLIC AROMATIC HYDROCARBONS

The wash water discharge is also to be monitored for polycyclic aromatic hydrocarbons (PAH), whereby the maximum
continuous PAH concentration is not to be greater than 50μg/L PAHphe (phenanthrene equivalence) above the inlet water
PAH concentration. The PAH concentration should be measured downstream of the water treatment equipment (i.e. after
any water treatment equipment), but upstream of any wash water dilution or other reactant dosing unit, if used, prior to
discharge. This limit value is applicable to EGCS wash water flow rates normalized to 45t/MWh. MWh refers to the
maximum continuous rating (MCR) or 80 percent of the power rating of the fuel oil combustion unit. This limit may be
adjusted up or down in accordance with Table 5 for different flow rates.

28
2.5 - WASHWATER DISCHARGE CRITERIA AND MONITORING

Flow rate (t/MWh) Discharge concentration limit

(µg/L PAHphe equivalents) Measurement technology

0-1 2250 Ultraviolet light

2.5 900 –"–

5 450 Fluorescence3

11.25 200 –"–

22.5 100 –"–

45 50 –"–
90 25 –"–

The Guidelines permit a 15-minute deviation of up to 100 percent of this limit value, in any 12-hour period, to account for
EGCS startup. The PAH discharge is to be continuously monitored and the monitoring equipment must be capable of
monitoring PAH in a range twice that given to the applicable limit value as shown in Table, using either the permitted
ultraviolet or fluorescence measuring techniques. The monitoring equipment must not deviate by more than 5 percent
within the working range of the application.

29
 2.5 - WASHWATER DISCHARGE CRITERIA AND MONITORING

TURBIDITY/SUSPENDED PARTICLE MATTER

The turbidity of the EGCS wash water should not exceed 25 FNU (formazin nephlometric units) or 25 NTU (nephlometric
turbidity units) above the inlet water turbidity. This should be measured continuously using equipment meeting the
requirements of the standards referenced by the Guideline. During periods of high turbidity, the time lapse between inlet
and outlet measurements may be such that the acceptable limiting difference may be unreliable. Therefore all turbidity
readings must be a rolling average over a 15-minute period to a maximum of 25 FNU.
The turbidity in the wash water must be measured downstream of any water treatment equipment, but upstream of wash
water dilution (or other reactant dosing) prior to discharge. The treatment system should be designed to minimize
suspended particle matter such as ash and heavy metals. Similar to the criteria for PAH, the Guidelines permit a 15-minute
deviation of up to 20 percent in any 12-hour period.

30
 2.5 - WASHWATER DISCHARGE CRITERIA AND MONITORING

NITRATES

Wash water discharge samples are to be taken within three months of an EGC unit renewal survey and analyzed for nitrate
discharge data. The analysis certificate is to be retained as part of the EGC Record Book for the purpose of verifying that
the wash water treatment system prevents the discharge of nitrates beyond a level equivalent to 12 percent removal of
NOx from the exhaust, or 60 mg/l normalized for a discharge flow rate 45t/MWh.
The Guidelines require that all EGCS are tested for nitrates in the discharge water and, if typical levels are above 80 percent
of the upper limit, they should be recorded in the ETM-A or ETM-B.

31
2.6 - DATA MONITORING

The Guidelines require that data recording devices are provided as part of any EGCS installation. The following details
some of the basic system data that is to be continuously monitored and recorded automatically.
• When the system is in use, time against Universal Coordinated Time (UTC) and vessel position by Global Navigational
Satellite System (GNSS) position
• Wash water pressure and flow rate at the inlet connection
• Exhaust gas pressure before and pressure drop across the scrubber
• Engine and/or boiler load(s)
• Exhaust temperature before and after the scrubber
• Exhaust gas SO2 and CO2 content
• Wash water pH, PAH and turbidity
The data recording device need to be robust, tamper-proof, read-only and able to record at a rate not less than 0.0035
Hz. It need to be capable of preparing reports over specified time periods and the data need to be retained for a period
of not less than 18 months from the date of recording. If the unit is changed during that time period, the shipowner
need to ensure that the required data is retained on board and available as may be required. The device need to be
able to download a copy of the recorded data and reports in a readily usable format. The copy of the data and reports
need to be made available to the flag Administration or Port State Control (PSC) authorities upon request .

32
2.7 - WASHWATER RESIDUES

Residues from the EGCS wash water are to be collected on board and delivered ashore at suitable reception
facilities that administrations are required to provide under Regulation 17 to MARPOL Annex VI. Discharging
these residues at sea or incinerating them on board is not permitted. It is also mandated by the Guidelines
that storage and disposal of such residues are to be recorded in the EGC Record Book, inclusive of the date,
time and location of delivery. The EGC Record Book may form a part of an existing logbook or electronic
recording system as approved by the Administration.

33
2.8 – PSC CHECKLIST

PSC Checklist -
Inspection of a ship using an abatement method (EGCS):
• Type Approval documents of Continuous Exhaust Gas Monitoring System;
• Approved documentation –
SOx Emission Compliance Certificate (SECC),
EGCS Technical Manual for Scheme B (ETM-B),
Onboard Monitoring Manual (OMM),
SOx Emission Compliance Plan (SECP);
• There are continuous-monitoring systems with tamper-proof data recording and processing devices and the
records demonstrate the necessary compliance when set against the limits given in the approved
documentation and applies to relevant fuel combustion units on board.
• Checking can include but is not limited to:
• emissions ratio, pH, PAH, turbidity readings as limit values given in ETM-B and operation parameters as listed
in the system documentation – EGCS Record Book.

34
 3 - EGC SYSTEM CONCEPTS
3.1 - GENERAL

A scrubber is a device installed in the exhaust system after the engine or boiler that treats exhaust gas with a variety
of substances, which may include seawater, chemically treated fresh water or dry substances, with the goal of
removing most of the SOx from the exhaust and reducing PM. After passing through the scrubber system, the
compliant exhaust is emitted to the atmosphere.
All scrubber technologies create a waste stream containing the substance used for the cleaning process plus the SOx
and PM removed from the exhaust.
SOx (SO2 plus SO3) gases are water soluble. Once dissolved, these gases form strong acids that react with the
natural alkalinity of the seawater, or the alkalinity derived from the added substances (normally sodium hydroxide),
forming soluble sodium sulfate salt, which is a natural salt in the seas. In addition, the PM in the exhaust will
become entrapped in the wash water, adding to the sludge generated by a scrubber. With dry scrubbers, calcium
hydroxide (Ca(OH)2), or hydrated lime as it is more commonly known, reacts with the SOx. The reaction produces
solid calcium sulfate (CaSO4), also known as gypsum. The waste stream and generated sludge has to be processed as
per the IMO guidelines before discharge overboard, where allowed, or stored and discharged to a shore reception
facility as a waste substance.

35
3.1 - GENERAL

Engine Exhaust Gas Chemistry:

S + O2 → SO2 ~ 95% SO2 + ½O2 → SO3 ~ 5%
SOx Reactions in a Scrubber: SO2 + H2O → H2SO3 (Sulfurous Acid)
SO3 + H2O→ H2SO4 (Sulfuric Acid)

Sulfurous gases in water are in a state of rapid oxidation; sulfur dioxide (SO2) oxidizes to sulfur trioxide (SO3), which
dissolves in water to form sulfuric acid (H2SO4). Also, upon dissolution in water, SO2 forms the hydrate SO2 + H2O or
sulfurous acid H2SO3, which dissociates rapidly to form the bisulfate ion HSO3, which in turn is oxidized to sulfate.
There are two basic concepts commonly proposed for shipboard application of EGCS: the dry scrubber-type and the wet
scrubber-type. The basic principles for the dry and wet scrubbing concept are described further in this section.

36
 4 - Ship Implementation Plan

Our 7 vessels are already lined up for fitment of EGCS (sys type open loop + hybrid ready).
Soon we will have 2 more vessels with similar system i.e. type open loop + hybrid ready fitted on-board.
The average cost of equipment + Fitment and commissioning comes to around USD 3Mi.
We have chosen a leading company from Norway for the purpose who are offering quality products for the
marine industry.
It is a compact multi-streaming EGCS solution
As the system works independently of the combustion units and the automatic NaOH feed governs the
cleaning efficiency, the operation is simple and robust.
The NaOH feed also limits the pH reduction caused by the neutralisation process, which makes demands on
the materials less severe and provides a longer system lifetime at a lower cost.

37
Ship Implementation Plan

This EGC unit has a high-speed cyclone (advanced vortex chamber – AVC) incorporated in the design,
providing considerably high PM and liquid droplet trapping.
A fan and gas recirculation feature allows one EGC unit to serve all combustion units simultaneously. This
feature ensures that the backpressure in the exhaust pipes, and therefore the efficiency of the combustion
units, is undisturbed. With zero backpressure requirements, the single scrubber also serves the boiler in
addition to the main and auxiliary engines.
Except for the fans and pumps there are few moving parts, which makes maintenance tasks rare and
inexpensive.
To use this EGCS, the operator will use a laptop, or it can be integrated to an existing system or to a marine
energy management system.

38
Ship Implementation Plan

A push button menu will adapt the EGCS for seagoing full-speed operation or for stay in port. During sea trials,
the system is tuned; for example, the fan speed and NaOH dosing are controlled automatically with the use of
variable frequency drives and PLC. This system can be remotely surveyed via the ship’s LAN, and satellite
communication system if available. Download of compliance logs is also possible if connected to the system.
System works equally well in open and closed (fluid recirculation) modes. According to IMO Annex VI there is
no restriction on discharge of water containing sulphate as long as PAH, turbidity, pH and nitrate levels are
within certain levels.
When selecting an EGCS unit, identify the highest practical amount of exhaust gas produced by all exhaust
sources connected to the unit during normal operation mode. Makers also include a margin, which will ensure
gas recirculation through the BDR.
When retrofitting an EGC unit this may be done adjacent to an existing funnel or inside an enlarged funnel.
We have selected a Greek Company for naval architect assistance and class-approved drawings needed for the
EGCS placement and any required structural changes on-board.
The installation work is planned to be carried out in some economical ship repair yards, in the vicinity.
Maker will provide installation specification and personnel will survey the installation and carry out
commissioning.
39
 5 -TECHNICAL AND OPERATIONAL RISKS

TECHNICAL AND OPERATIONAL RISKS FOR OPEN-LOOP SCRUBBERS

SUB-SYSTEM RISK/HAZARD CAUSE CONSEQUENCE

Seawater intake and Loss of seawater supply ■Marine growth in sea chest ■Shutdown of scrubber
supply due to clogging of sea ■Clogged sea chest from
chest sand/debris

Reduced performance of ■Pipe bends in front of ■Reduced reliability of

seawater pump due to pump inlet pump
poor flow at inlet
Loss of seawater supply due ■Mechanical failure ■Shutdown of scrubber
to failure of seawater ■Electrical failure
pump(s)
External leakage before ■Burst/crack/break of ■Flooding of engine room
scrubber tower seawater piping
■Over-pressure
■Closed valves
■Corrosion/erosion 40
SUB-SYSTEM RISK/HAZARD CAUSE CONSEQUENCE
Wash water discharge Discharge water is not ■Design does not include ■Use of MGO/compliant
Systems selection compliant with US VGP pH solution for in- creasing fuel when in US water
limit (no less than 6) wash water pH prior to
discharge
Corrosion of overboard ■Poor coating or installation ■Shutdown of scrubber
discharge pipe quality ■Repair of discharge
pipe in-service
Corrosion of valves in ■Corrosion due to low pH ■Downtime of scrubber
wash water discharge line wash water
■Improper material
properties
■Handling and installation

External leakage after ■Burst/crack/break of wash ■Flooding of engine room

scrubber tower water piping
■Over-pressure
■Closed valves
■Corrosion/erosion

Turbulence creating gas in ■Lack of degassing ■Visible gas bubbles and

wash water function in the drain line possibly sheening
41
■Possible non-compliance
SUB-SYSTEM RISK/HAZARD CAUSE CONSEQUENCE

Scrubber tower Soot and scrubber water on ■Soot accumulation during

Systems selection
deck operation, blowout during
quick change in engine load

Back-pressure in exhaust ■System design and capacity is ■Thermal overload on engines

line exceeds limit under dimensioned ■Reduced output
■Additional fuel consumption

Flooding of scrubber tower ■Clogged piping ■Flooding of engine room,

■Erroneous valve operation worst case flooding of
■Failure of high-level alarm engine

Cracks or deformation of ■Corrosion ■Flooding of engine room

scrubber tower ■Incorrect welding
■Incorrect installation
■Mechanical stress between
scrubber parts (tower and
42
venturi)
SUB-SYSTEM RISK/HAZARD CAUSE CONSEQUENCE

Scrubber tower Clogging of scrubber ■Insufficient cleaning of demister ■Increased back-pressure

Systems selection
tower demister ■Spray nozzles does not cover ■Soot on deck
the whole area

Corrosion/erosion of ■Lower spraying efficiency

scrubber nozzles ■Damaged piping or
pump due to increased
pressure
■Blocked/damaged valves
down- stream
Insufficient scrubber ■Tower design/size not suitable ■Non-compliant air
efficiency for exhaust flow and retention emissions
time
■Droplet size and water volume
not optimal
Exhaust gas flow ■Shutdown of seawater pump ■Melting of plastic/low-
through tower without (false or actual alarm) heat- resistant
seawater pumps ■Exhaust valves in wrong components in tower
running position when starting engine
■Air sealing function of
exhaust valves not effective 43
SUB-SYSTEM RISK/HAZARD CAUSE CONSEQUENCE

Exhaust piping Leaking bellows at ■Thermal expansion / heat ■Shutdown of scrubber

Systems selection
scrubber tower inlet and transfer of piping and
outlet related components at
tower

Corrosion of exhaust ■Acid environment ■Wet exhaust line leak

pipe after scrubber ■Material degradation due to ■Flow disturbances
corrosion ■Downtime of scrubber

Internal leakage in exhaust ■Failure to fully close ■Internal leakage to bypass line
gas bypass valves ■Air seal fan failure ■Exhaust flow through both scrub-
ber and bypass
■Non-compliance requiring
changeover to MGO

Burst explosion of exhaust ■Main valve and bypass ■Off-hire

line valve both in closed ■Damaged exhaust pipe
position during start-up of ■Structural damage
main or auxiliary engine
44
SUB-SYSTEM RISK/HAZARD CAUSE CONSEQUENCE

Emissions Low reliability of ■Clogged sample line due to soot build-up ■Wrong or no reading
Systems selection
monitoring the Continuous ■Clogged filter ■Non-compliance
Emission Monitoring ■Crystallization in sample line requiring changeover to
System (CEMS) ■Electrical failure MGO
■Failure of pump
■Exhaust gas not sufficiently conditioned
Automation and Unreliable ■Internal undetected sensor failure ■Wrong operation
control automation and ■Undetected cable failure ■Unintentional shutdown
control system ■Input failure of the controller of system
■Delayed emergency
response

Hull and structure Corrosion at hull ■Low pH discharge water ■Structural degradation
in wash water
discharge area

45
Scrubbers are technical feasible solution while good system design and material selection is critical to
minimize downtime

 Scrubber efficiency and compliance

 Corrosion challenges

 System reliability

 Monitoring equipment calibration and maintenance

 Closed / hybrid systems

46
Scrubber efficiency and compliance

FO Sulphur 0.5% = 21,7 Scrubber efficiency

FO Sulphur 0.1% = 4,3
 Most scrubbers in operation are able to meet the air emission
requirement with some margin
 Spray nozzle design and location, droplet size, retention time
combined with water flow are the main parameters to consider

Engine backpressure
 Scrubbers increase the back pressure with about 1000 –
1500 Pa which may affect the performance of the ME
 It must be verified that the exhaust back pressure limits
are not exceeded (NOx rating)
 Exhaust gas fans are generally not recommended

Wash water discharge compliance

 Methodology for documenting pH compliance using CFD is
established
 Key factor is size and number of discharge outlets, diffusers
need to be avoided
pH >
6.5 at 4m
 New suppliers still require some direction on design solutions

47
Corrosion challenges

Corrosion of exhaust pipe

 The exhaust line after the scrubber tower must be corrosion
resistant
 For in-line design the existing exhaust piping need to be
replaced

Corrosion of wash water piping, bellows and valves

 Wash water has low pH and is highly corrosive!
 GRE/GRP piping is frequently applied due to their
corrosive resistant properties
 Design need to aim to minimize penetration of existing
structures (bulkheads, deck) to avoid steel penetrations

Corrosion of discharge pipe and side shell

 Class rules require replacement of overboard
valves every 5 years
 Discharge pipe must be UT tested every year
(recommended every 6m)
 Appropriate coating must be applied to side shell
48
System reliability

Sea water supply

 The scrubber system can be supplied by existing sea
chests if there are sufficient capacity
 Most systems are only connected to one sea chests
which introduce a single-point of failure
 It is recommended to install redundant sea water pumps

By-pass valves and sealing air fans (multi-inlet)

 Failure of by-pass valves or sealing air fans can result in-non
compliant air emissions
 The interlock functionality of by-pass valves are critical to
ensure that the valves are in correct position when starting DE’s
 It is recommended to install redundant sealing air fans
Automation system
 A robust automation system is key to ensure reliable operation of
scrubber systems
 The automation systems incorporate a range of shut-down alarms,
and poor automation systems can impact the availability
49
Monitoring equipment calibration and maintenance

Analyzer reliability
 Reliable monitoring equipment is key since they are the
basis to show compliance of the system
 The analyzers requires proper maintenance to function
correctly
 Crew training is important to minimize downtime of
analyzers
Calibration and maintenance
 Calibration methods and interval vary between
manufactures, general intervals can be summarized as:

Factory calibration /
Sensors Onboard calibration
maintenance
CEMS ~ 1 month ~ 1 year

Turbidity ~ 3 month ~ 2 year

PAH ~ 6 month ~ 2 year

pH ~ 2 - 3 month

50
Closed / hybrid systems

Process reliability
 Hybrid / closed loop systems are significantly more complex
 Robust automation system and good installation quality of
sensors are required to minimize downtime from “false alarms”
Wash water treatment
 Various types of wash water treatment systems are available;
centrifugal, chemical and membrane types
 Performance vary significantly and thorough technology
assessment is recommended
Sludge storage and discharge
 Sludge from treatment units are hazardous waste and must be
treated accordingly
 Major ports have facilities / companies for accepting sludge
Alkali bunkering and handling
 Common alkalis are caustic soda (NaOH) and magnesium hydroxide
 NaOH has very strict requirements, and it will be reclassified in the
IBC code to toxic from 2020 51
 6 - FAQ

When transiting an ECA, what would be required of a vessel if a failure occurs on its installed scrubber system?
MARPOL Annex VI Regulation 3.1 considers exemptions and exceptions for vessels that experience noncompliance with
the emission standards set forth in MARPOL Annex VI Regulation 14 as a result of damage to a ship or its equipment.
The acceptance or non-acceptance of an exemption would be in the realm of the concerned flag Administrations. For
the exemption to be granted, the owner would need to exhibit that due diligence had been exercised in both design
and operation, i.e. sufficient redundancy, has been incorporated into the system.
Continuous operation of the fuel combustion units and scrubber systems is achievable to maintain the vessel’s
propulsion and manoeuvring capability, together with continual compliance with MARPOL Annex VI Regulation 14.

52
 FAQ

Are scrubber systems acceptable for use in the state of California in lieu of low-sulphur fuel?
California Air Resources Board (CARB) does not currently accept SOx scrubbers as an alternative means for using low-
sulphur distillate fuel, but it has temporarily authorized, through CARB Marine Notice 2014-1, August 2014, the use of
the EGCS as a ‘Research Exemption’ for the duration of the sunset review process for the vessels that are in compliance
with the ECA. The sunset review is a study that is being conducted by CARB staff in order to evaluate the emissions
reductions achieved by the ECA Regulation and compare them to the emissions reductions achieved by the California
Ocean Going Vessel (OGV) Fuel Regulation.
The EPA has issued an “Interim Guidance on the Non-Availability of Compliant Fuel Oil for the North American Emission
Control Area” dated June 26, 2012, which states that vessels may either use MARPOL Annex VI ECA-compliant fuel oil
when operating within the designated North American ECA or install and use an equivalent method as approved and
allowed under MARPOL Annex VI Regulation 4, and 40 CFR. § 1043.55 (e.g., exhaust gas cleaning device).

53
 FAQ

How will Port State Control verify the cleaning rate of the scrubbers?
Guidelines for PSC associated with MARPOL Annex VI are described in IMO Res. MEPC.181 (59), where it is stated that
the PSC officer need to examine the “approved documentation relating to any installed exhaust gas cleaning systems,
or equivalent means, to reduce SOx emissions (Reg. VI/4).” Furthermore, as per 4.2.3.2 and 5.3.2 of the Annex to Res.
MEPC.259 (68), EGCS and their monitoring systems may also be subject to inspection by Port State Control. Section 7.5
also requires that a copy of the recorded data and reports need to be made available to the Administration or Port
State Authority as requested.
With regard to nitrates, according to 10.1.5.2 of the Resolution “at each renewal survey nitrate discharge data is to be
available in respect of sample overboard discharge drawn from each EGC system within the previous three months
prior to the survey.” However, the Administration may require an additional sample to be drawn and analyzed at their
discretion. The nitrate discharge data and analysis certificate is to be retained on board the ship as part of the EGC
Record Book and is to be made available for inspection as required by Port State Control or other parties.

54
 FAQ

Which monitoring devices are needed for an EGCS and what is the marine service experience of these devices?
The requirements for monitoring are described in MEPC.259(68) and there are installations that have substantial
marine experience. In general, the monitoring devices required have been in use for several years on onshore
installations. The type and extent of monitoring depends on the certification Scheme (A or B) of Resolution
MEPC.259(68), and the details of these monitoring devices are required to be specified in the Onboard Monitoring
Manual (OMM).
Scheme A – MEPC.259(68) recommends that, where a continuous exhaust monitoring system is not fitted, a daily spot
check of exhaust emissions plus a continuous monitoring of certain prescribed parameters is required. If continuous
monitoring is installed then only spot checks of the prescribed parameters may be carried out. Scheme B requires
continuous monitoring of exhaust emissions using an approved monitoring system together with daily spot checks of
certain prescribed parameters. In both cases the wash water is required to be continuously monitored for pH, PAH and
turbidity. The pH electrode and pH meter need to have a resolution of 0.1 pH units and temperature compensation.
The electrode need to comply with the requirements defined in BS 2586 or of equivalent or better performance, and
the meter need to meet or exceed BS EN ISO 60746-2:2003. The PAH monitoring equipment need to be capable of
monitoring PAH in water in a range to at least twice the applicable discharge concentration limit. The equipment need
to be demonstrated to operate correctly and not deviate more than 5 percent in wash water with turbidity within the
working range of the application. The turbidity monitoring equipment need to meet requirements defined in ISO
7027:1999 or USEPA 180.1.
55
.
 FAQ

Are there any requirements on particulate matter (PM) monitoring by the IMO, U.S. EPA or other such
organizations?
IMO does not specifically limit PM but regulates the sulfate portion of PM formation through the fuel sulfur content
requirements of Regulation 14 to MARPOL Annex VI. The U.S. EPA defines PM limits for Category 1 and 2 marine
engines (below 30 liters displacement/cylinder). The EPA emission measurement requirements for Category 3 engines
(30 liters and over displacement/cylinder) require test bed monitoring of PM. In response to a query put forth
regarding the requirements for PM limits, the EPA advised that at this point in time that there is no official guidance
regarding the PM limits by substitution with exhaust gas scrubbers in lieu of using low-sulfur fuel. However, as specified
in the EPA’s Final Rule for Control of Emissions From New Marine Compression Ignition Engines at or Above 30 Liters
per Cylinder, significant PM emissions control will be achieved through the ECA fuel sulfur requirements.
During its 68th session, the MEPC approved the definition of Black Carbon, which was agreed and proposed by the PPR
2. The committee was aware of the need for Black Carbon measurement studies, to gain knowledge with the
application of the definition and the methods of measurement. The Committee agreed to the need for a protocol for
any voluntary measurement studies to collect data, focusing on using the agreed definition of Black Carbon to support
data collection; to identify the most appropriate measurement method(s) of Black Carbon emissions from international
shipping, and inviting interested Member Governments and international organizations to submit additional relevant
proposals/information to PPR 3.
56
 FAQ

What are the IMO and regional regulations governing discharge water?
Wash water criteria limits for pH, PAH, turbidity/suspended PM and nitrates are defined in 10.1 of Resolution
MEPC.259(68). The U.S. EPA wash water discharge limits are consistent with the IMO requirements in the VGP for 2013.
However, the EPA has added some additional requirements for wash water sampling and analytical monitoring for all
16 PAHs, while the IMO requires monitoring by measuring the most common phenanthrene equivalents;
shipowners/operators must submit all monitoring data to the U.S. EPA’s e-reporting system unless specifically
exempted from electronic reporting. Monitoring data must be submitted at least once per calendar year, no later than
February 28 of the following year, on the vessel’s annual report. In addition to those requirements, the EPA is in the
process of drafting a water quality certification to the VGP that would be adding other conditions related to vessels in
general.

57
 FAQ

Please elaborate on the wash water discharge criteria in the final 2013 VGP.
As per 2.2.26.2.2 of the proposed 2013 VGP, in addition to the continuous monitoring found in Part 2.2.26.2.1 of this
permit, vessel owner/operators must collect and analyze two samples in the first year of permit coverage or system
operation, whichever is first, for each of the constituents analyzed in Part 2.2.26.2.3 to demonstrate treatment
equipment maintenance, probe accuracy and compliance with this permit. Samples must not be collected within 14
days of each other. Samples must be collected from inlet water (for background), water after the scrubber (but before
any treatment system) and discharge water. For all vessels, one of those samples may be conducted as part of vessel’s
annual or other survey, and during the first year, one of those sampling events may be conducted as part of the
installation of the system to ensure it is functioning properly.
After the first year, samples must be collected at least once per calendar year from inlet water (for background), water
after the scrubber (but before any treatment system) and discharge water, and may be collected as part of the vessel’s
annual survey as appropriate. Records of the sampling and testing results must be retained onboard for a period of 3
years in the vessel’s recordkeeping documentation, consistent with Part 4.2.

58
 FAQ

Are SOx scrubbers compatible with selective catalytic reduction (SCR) systems for NOx removal, considering post-
2016 Tier III requirements?
Vessels built after January 1, 2016, will need to consider how the vessel arrangements meet both NOx and SOx
requirements, but the degree of impact would appear to depend on the NOx reduction method being utilized. EGR
arrangements would typically also involve the use of scrubbers and would not be in conflict. However, SCR systems
need high exhaust inlet temperatures to work and hence must be deployed upstream of the scrubber. This in turn
means the SCR needs to deal with the fuel sulfur content, which may be a problem for some SCRs. Most SCR
manufacturers have catalyst technologies that can operate at a higher SOx content. The shipowner is well advised to
inquire about catalyst cost, and service life expectancy at higher SOx exhaust levels, and what the upper sulfur limit is
for the specific SCR. The use of an SCR in addition to a scrubber in the exhaust stream will increase back pressure,
which has to be considered.
Will the scrubber function as designed at all loads?
Scrubbers are to be designed to reduce emissions to equal, or less than, the required fuel S equivalence at any load
point when operating within the range of operational limits for which the unit is approved. The maximum HFO sulfur
content for which this is achievable is to be stated by the manufacturer.

59
 FAQ

Are there any particular sludge disposal restrictions in place? Can the sludge produced be incinerated on board?
The residues from the exhaust scrubbing processes may not be incinerated on board and must be disposed of ashore in
accordance with MARPOL Annex VI Regulation 16, Paragraph 2.6, which prohibits incineration of sludge generated from
a scrubber. Even if all major ports were expected to have approximate capacities by 2015, the shipowner is well advised
to investigate sludge reception facilities where the ship will trade to avoid deviations. Where reception facilities are
found to be inadequate, the Administration is to notify the IMO (as per document MEPC/Circ.469 Rev.1, which contains
an entry for exhaust gas cleaning residues) based on information sent by a ship having encountered difficulties in
discharging waste to reception facilities – see MARPOL Regulation VI/17.2 and 17.3.

60
Thankyou
Link for the Test

61