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Euroshore is an international association of PRF’s with representatives in most European countries. In Europe, Euroshore represents ca 70% of the waste collected from seagoing vessels.

Euroshore is in favour of a zero discharge of ships and promotes sustainable solutions on board of ships as on the landside. We support initiatives in waste prevention, waste segregation and try to re-use as much the materials. We operate in a strict professional environment with respect to all relevant certification standards such as the ISO standards, Quality and EMAS certification etc.

From this perspective, Euroshore participated in an initiative to sample the effluent of scrubbers in order to offer, if needed, a sustainable solution for the potential waste streams.

EGCSA and EUROSHORE have found each other in an attempt to clarify the situation. Up till now the contribution of Euroshore was limited to the payment of the transport cost of the samples and the cost of the SGS laboratory in Germany. But since we had no input in the draft evaluation report provide by MR Gregory, it looks me fair to point out our position without knowing all details at this moment.

I would like to sum up some remarks:

1. PH STANDARDS.

IMO has provided the 2009 Guidelines for Exhaust Gas Cleaning Systems (MEPC 184 (59)) which includes effluent limits for pH, PAH, nitrates, turbidity and temperature.

Currently the Guidelines allow pH to meet a limit of 6,5pH, at a point 4 metres from the discharge pipe. This 4 metres distance means that an open loop scrubber might actually be discharging was water with a pH as low as 3,0 before being diluted in the receiving water.

MEPC took up the dilution discussion in order to ease the measuring.

USA Federal effluent requirements with respect to scrubbers.

Discharges into US waters, within the three nautical miles of the coastline, must comply with the EPA Vessel General Permit (VGP), last updated in 2013. The VGP regulates in addition to 26 discharges incidental to marine vessels, exhaust gas scrubber wash water.

In the EPA pH requirements, the pH of the effluent may as low as 6,0pH at the discharge pipe. However, the EPA does not accept dilution trials or models at any distance from the discharge pipe. In practise this makes the EPA limit extremely more restrictive. As a result, it is almost impractical to use open loop scrubbers within the 3 nautical miles of the US Coastline.

NOTE: the samples taken by EUROSHORE before the common sampling programme showed pH below 3 pH (even sometime below 2pH).

Conclusion on pH: to avoid further acidification of the seas with a loss of biodiversity another negative effects as result, an additive should be used to neutralise the wash water (or a kind of after treatment which I believe is optional in certain exhaust gas cleaning systems).

2. METALS

The HFO supplied to ships contains all kind of impurities and heavy metals, as part of natural crude oil and as a result of the refining process these heavy metals and impurities are found in HFO.

The scrubber washes out the sulphur but also other pollutants such as the heavy metals. So that is the one of the reasons why nickel, vanadium and some other metals are find in the wash water.

3. PORT RECEPTION FACILITIES.

Being present with several PRF’s in the ports located in the ECA’s, we haven’t seen a demand for the collection of wash waters. Up till now the demand was extremely limited to 1 or a few requests in 2014 and 2015. Which probably means that most wash water is discharged in the sea.

We also noticed that the quality of wash water varies a lot in function of the scrubber that is installed on board. It seems that some are equipped with pre- and after treatment devices. I am afraid that such a conclusion, will not contribute to a one fit all conclusion.

With this statement we hope to clarify our position. We have different interests in this topic but we will support further the investigation of the sampling of wash waters, but like the remarks from others, we would like to get more clarifications.

In case the final conclusion would be that certain wash waters need to be disposed to a port reception facility, we will be ready and by way of transparency we will share sustainable treatment solutions with others.