Beware of local restrictions before discharging wash water from exhaust gas scrubbing

Euroshore, as stated in its Position Paper regarding the use of Scrubbers (….insert link with the website) is against the discharge of wash waters from open loop scrubbers, and fully support any initiative from ports authorities or states to ban that practice.

We are currently aware of the following regions/states/ports with local regulations that have an effect on exhaust gas scrubber wash water discharge, although the list should not be considered as complete.

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. A ban in the entire coastal domestic ECA will be announced in due course.

Singapore

The Maritime and Port Authority of Singapore (MPA) prohibits discharge in Singapore port waters from 1 January 2020. It published useful guidance on IMO 2020 sulphur limits:  ships fitted with open loop scrubbers are advised 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’.

India

In 2018 DG Engineering Circular 05, India seems to indicate that scrubber wash water discharges are allowed, if the criteria set out in MEPC.259(68) are met and provided local regulations are followed. However, it is not clear if local restrictions will be imposed in some areas.

Abu Dhabi, UAE

In 2013, Abu Dhabi authorities issued ‘Vessel discharge and maintenance guidelines for owners, masters and agents’ stating scrubber wash water can be discharged in port waters if free form pollutants whilst scrubber sludge should be discharged from the vessel to an Abu Dhabi Ports Company (ADPC) licensed waste disposal contractor.

Europe

Belgium

The European Commission (EC) 2016 Note on discharge of scrubber wash water, bans the discharge in ports and inland waters. Relevant Belgian legislation is the law on the protection of  surface water against pollution(Flemish Region, Law of 26 March 1971).

Germany

Discharge is not allowed in inland waterways and the Rhine (Art. 1 & 3 of the CDNI Convention (Convention on the collection, deposit and reception of waste produced during navigation on the Rhine and inland waterways).

Lithuania

The port rules and conditions of use approved by the Ministry of Transport forbids discharge in. port waters, hereby referring to Reference is made to the above mentioned EC 2016 Note. Authorities are currently studying the impact of scrubber wash water on the marine environment and will provide conclusions upon its completion.

Latvia

Discharge is not allowed in territorial and port waters, again referring to the above mentioned EC 2016 Note.  Discussions are ongoing within the EC on improving regulations in order to provide more clarity.

Dublin, Ireland

The Irish authorities’ Notice No. 37 of 2018 ‘Prohibition on the discharge of exhaust gas scrubber wash water’ stipulates wash water discharge is prohibited in waters under Dublin port jurisdiction (including 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).

Norway

The Norwegian Maritime Directorate (NMD) bans the use of all types of scrubbers, including closed loop and hybrid systems, and also proposes prohibiting waste incineration on board in the country’s heritage fjords. Implementation is expected to start in the first half of 2019.

Americas

Hawaii, USA

Conditional section 401 Water Quality Certification (WQC), as mentioned in section 6.7 of the 2013 Vessel General Permit (VGP), allows for discharge of wash water subject to certain requirements (mentioned in same section) being fulfilled.

Connecticut, USA

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. See CGS section 22a-427 and Connecticut Water Quality Standards (CT WQS).

California, USA

The California Air Resources Board for Ocean-Going Vessels (CARB OGV) regulations permit the use of abatement technologies such as scrubbers, hence their use as well as any discharge of wash water is prohibited. However, pursuant to CARB’s Marine Notice 2017-1 discharge is permitted, if the vessel has an experimental or temporary research permit.

Recommendations

Various other coastal states and ports are discussing enforcing similar bans citing the adverse effects of scrubber wash water on the marine environment. It is therefore likely that the above list of states/ports currently regulating/banning open-loop scrubber discharges in their waters will grow over time

In those areas where the discharge of wash water is not permitted, vessel operators have two options to choose from to ensure compliance with sulphur limits:

• use compliant fuel instead of open-loop scrubbers; or,
• switch to closed-loop operation mode, necessating to convert currently installed open-loop systems to closed-loop or hybrid systems, if not already done.

Any change-over should be carried out well in advance of the vessel entering the areas with prohibition or restrictions in place. This will help in identifying operational issues, if any, after  change-over and will allow for sufficient time to rectify such before the vessel enters the area.

We advise members and clients to monitor the situation closely and ensure that crews onboard vessels fitted with open-loop scrubbers are made aware of any relevant local discharge requirements in force. As a precautionary measure, we advise owners of vessels with open-loop scrubbers installed to approach local agents for detailed actual requirements on scrubber wash water discharge as part of a vessel’s voyage planning.  

_{Source: GARD (http://www.gard.no/web/updates/content/26939066/beware-of-local-restrictions-before-discharging-washwater-from-exhaust-gas-scrubbing) -  Marine Insurance P&I Club News,Shipping: Emission Possible 16/01/2019}