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Contents
1. Introduction .............................................................................................................................. 3
2. Purpose of this document ......................................................................................................... 3
3. Important notes ........................................................................................................................ 4
4. Quick guide ............................................................................................................................... 5
5. Points of contact ....................................................................................................................... 6
6. First actions ............................................................................................................................... 7
6.1 Sample point identification ............................................................................................... 7
6.2 Power measurement ......................................................................................................... 7
6.3 Ship information ............................................................................................................... 7
6.4 Ship’s code and sampling data forms ................................................................................ 7
7. Sampling kits ............................................................................................................................. 8
7.1 Sample box contents ......................................................................................................... 8
7.2 Ordering sample kits ....................................................................................................... 10
7.3 Action on receipt of sample box...................................................................................... 10
8. Sampling ................................................................................................................................. 11
8.1 Equipment ....................................................................................................................... 11
8.2 Timing ............................................................................................................................. 11
8.3 Data recording immediately before all sampling ............................................................ 11
8.4 Sample labels .................................................................................................................. 12
8.5 Sample point preparation ............................................................................................... 12
8.6 Filling sample bottles ...................................................................................................... 13
8.7 Data recording immediately after completion of all sampling ........................................ 13
8.8 Filled sample bottles ....................................................................................................... 14
9. Data requirements .................................................................................................................. 15
10. Sample despatch ................................................................................................................. 16
APPENDIX 1 ......................................................................................................................................... 18
Sampling Points .............................................................................................................................. 18
A1.1.1 Open Loop Systems ............................................................................................................. 19
A1.1.2 Closed Loop Systems ........................................................................................................... 20
A1.1.3 Hybrid Systems .................................................................................................................... 21
APPENDIX 2 ......................................................................................................................................... 23
Forms & Examples .......................................................................................................................... 23
APPENDIX 3 ......................................................................................................................................... 32
Other Documents ........................................................................................................................... 32
1. Introduction
There have been concerns expressed that there is not enough information on the composition of
scrubber wash water discharges. This has led to perhaps unfounded concerns about the operation of
marine exhaust gas cleaning systems in some ports in the European Union.
Following a meeting of the EC’s European Sustainable Shipping Forum (ESSF) scrubber working group
on the 2nd July 2014, it was agreed between the Exhaust Gas Cleaning Systems Association, EGCSA
and the Association of Port Reception Facility Providers, Euroshore to run a joint campaign of wash
water sampling to establish a better understanding of the possibility of harmful components in open
and closed loop wash water discharges and to determine the likely concentrations.
During 2015, EGCSA and Euroshore worked with ship operators and scrubber manufacturers to
sample the wash water in the exhaust gas cleaning systems of 10 ships and the seawater receiving
the wash water discharges.
Following review of the analytical data from this first sampling, it has been agreed that a second
round of sampling will be undertaken during 2016/17, which will focus on the concentration of
Polycyclic Aromatic Hydrocarbons (PAH) and metals in the wash water discharges and seawater
surrounding the ship.
This programme is also aligned with IMO’s requirements in MEPC. 259 (68) – 2015 Guidelines for
Exhaust Gas Cleaning Systems, which requests that ship-owners undertake sampling and testing of
at least 2 samples over a 24-month period after scrubber system commissioning.
3. Important notes
• Ship-owners will be offered complete anonymity with respect to the sample source
• The management of sampling will be by EGCSA
• It is intended that ship’s crew take the majority of samples this time
• Ship names will be replaced by a code. The ship’s identity will be held by the EGCSA
secretariat and will not be released
• Ship operators will be provided with analysis results for their ship
• The sharing of anonymised sample analysis results from all ships and reporting of the data to
ESSF will be undertaken jointly between Euroshore and EGCSA and no information will be
released without mutual agreement
• The costs of supplying sample boxes to the ship’s agent and all analyses will be for EGCSA
and Euroshore.
• The ship operator will be responsible for the cost of returning the samples in the sample
bottle box to the laboratory by courier.
4. Quick guide
SHIP OPERATOR: Nominate vessel for scrubber water sampling
*Supply and despatch of sample box to be in mainland Europe unless in USA by special arrangement
5. Points of contact
EGCSA will be the sole point of contact for the sample analysis programme. The following persons
will manage all enquiries, including those regarding:
• Sample kit orders
• Sampling points and procedure
• Data from engine, boiler and scrubber systems
• Transport of samples to the laboratory; and
• Analytical data
6. First actions
6.1 Sample point identification
Following agreement to participate in the programme, EGCSA will need to discuss the ship’s
scrubbing system in detail with the vessel’s Technical Manager and Chief Engineer in order to
identify sample points and ensure representative sampling.
A screen shot from the scrubber system computer display, system schematic, pipeline drawing or
photographs will be required.
Wherever possible sampling should be from a point immediately adjacent to the full flow of the
process water. The diagrams in Appendix A1.1 should be used to help identify the sample points. It
is recognised that these may not be fully applicable on all ships. Some typical variations from the
standard arrangement of scrubbers are also listed in Appendix A1.2, together with
recommendations for sampling of these systems.
On many ships a direct reading of power is not available and so how it is to be determined must be
agreed before sampling can be undertaken.
These forms must be used to record data before and after sampling. See sections 8 and 9 for
further information.
7. Sampling kits
7.1 Sample box contents
It is recognised that scrubber systems vary in configuration and arrangement, however, a baseline
sample kit will typically comprise an outer carton/box (which should be kept and used for returning
the samples) an inner insulated box which contains ice packs and 6 bottles to enable 2 samples to be
taken from each of the 3 positions shown in the diagrams in Appendix A1.1**:
1. Seawater inlet for open loop scrubbing (or seawater surrounding the ship for closed loop
scrubbing)
2. Wash water after scrubber, but before wash water treatment
3. Wash water overboard discharge, after wash water treatment, but before any dilution or
chemical pH adjustment
**Please note: the exact number of sample bottles supplied will depend upon initial discussions
about the scrubber system configuration and the number of sample points identified (see section 6).
*** For a small number of selected vessels only visiting or trading in the North America ECA, it may
be possible to arrange to supply sample kits and undertake laboratory analysis in USA. This will be by
separate arrangement.
8. Sampling
The sample points agreed with EGCSA must be used. These are given on data forms 1 and 2 (see
Appendix 2 for examples)
Correct sampling and repeatable/reproducible laboratory analyses are critical to the success and
validity of this analysis programme. Planning and preparation are therefore vital.
8.1 Equipment
AS THE TESTS FOR PAH HAVE VERY LOW LIMITS OF DETECTION (PARTS PER BILLION) IT IS
IMPORTANT THAT ALL EQUIPMENT USED DURING THE TAKING OF SAMPLES IS THOROUGHLY
CLEAN.
THE USE OF ANY HYDROCARBON BASED CLEANING AGENTS OF THE SAMPLING POINT MUST BE
AVOIDED.
HOSES THAT ARE ALREADY IN-SITU MUST NOT BE USED FOR FILLING OF SAMPLE BOTTLES
BECAUSE OF THE RISK OF SAMPLE CONTAMINATION. IN GENERAL, THE USE OF HOSES, FUNNELS
AND SECONDARY CONTAINERS SHOULD BE AVOIDED.
See further information below at 8.5 and 8.6 regarding filling of sample bottles.
8.2 Timing
Samples should be taken no more than 24 hours before berthing. (see section 10 regarding the
maximum allowable sample preservation time of 7 days before PAH analysis at the laboratory, which
may be factor to consider if the vessel is to be held for an extended time at anchor).
The ship should be moving at steady speed throughout the sampling exercise at as high a power as
is operationally practical. (It is recognised that the need to meet schedules on regular routes, the
uncertainties of spot market operation, weather and sea conditions and the need to save fuel can all
effect the power level that can be practically achieved or is operationally allowable.)
Should auxiliary engines be fitted with exhaust gas scrubbers, samples may be taken while the vessel
is at sea or at berth, and should be operated at the highest practical load.
After filling the sample bottle take a note of the date and time of sampling. This will be required for
the data forms.
While the instrumentation stations at scrubber seawater inlet and overboard discharge typically
have a valve from which samples can be taken, this is not always the case. For example, it may be
necessary to take before wash water treatment samples from gauge connections after each
scrubber unit. Vent valves on sea chests may also be in quite inaccessible places at lower floor
plate/bilge level when taking some seawater samples
THE SAMPLE POINT MUST BE THOROUGHLY FLUSHED TO REMOVE ANY POSSIBLE DEBRIS,
UNREPRESENTATIVE MATERIAL AND PRODUCTS OF CORROSION FROM AREAS OF STATIC WATER
OR LOW FLOW.
AT LEAST 10 LITRES OF WATER SHOULD BE RELEASED PRIOR TO TAKING THE SAMPLE AND THE
WATER FLUSHED THROUGH THE SAMPLE POINT SHOULD HAVE REACHED A STABLE LEVEL OF
CLARITY. ANY DIRTY HOSES AND BUCKETS USED FOR CLEANING OR TO COLLECT WATER FLUSHED
THROUGH THE SAMPLE POINT MUST NOT BE USED FOR SAMPLE COLLECTION.
HOSES THAT ARE ALREADY IN-SITU MUST NOT BE USED FOR FILLING OF SAMPLE BOTTLES
BECAUSE OF THE RISK OF SAMPLE CONTAMINATION. IN GENERAL, THE USE OF HOSES, FUNNELS
AND SECONDARY CONTAINERS SHOULD BE AVOIDED.
IF THIS IS UNAVOIDABLE BECAUSE OF THE LOCATION OF THE SAMPLING POINT ALL EQUIPMENT
MUST BE AS NEW AND THOROUGHLY CLEAN.
The sample bottles are supplied pre-cleaned and prepared ready for immediate sampling. Note that
the sample bottle should only remain unsealed for the few seconds it takes to fill the bottle
completely and without air gap. The seal and cap should be fitted immediately after filling. As the
sample bottles for metals analysis contain small amounts of acid preservative it is essential that
appropriate safety wear be used.
After filling the sample bottle take a note of the date and time of sampling. This will be required for
the data forms.
NOTE: This section of the guide is also included in the sample box. If a copy of the full guide is
required, please contact:
9. Data requirements
Before sampling, dedicated forms based on discussions with the ship’s Technical Manager and Chief
Engineer will be sent to the ship by EGCSA. Examples are shown at Appendix 2.
Note: the sample box contains a copy of the sampling instructions - section 8 from this guide, pre-
printed address and URGENT delivery labels. Copies of the labels (and a customs declaration form
should it be needed) are shown at Appendix 3.
• Form 1 should be completed and sent to EGCSA only and not the laboratory. The following
data are required. To supplement the form, it is recommended that photographs or screen
shots from the scrubber system control & reporting computers at the time of sampling are
also sent.
o Latitude and longitude (before and after sampling)
o Engine power (or % of MCR) (before and after sampling)
o Daily fuel consumption rate at time of sampling (t/day)
o Fuel analysis (a copy of the analysis report, if available); or
o Fuel viscosity; and
o Fuel sulphur content
o Hybrid scrubber operating mode during sampling (open or closed loop)
o Open loop wash water flow rate through scrubber (before and after sampling); or
o Closed loop discharge flow rate before dilution (before and after sampling)
▪ This may need prior discussion with the scrubber manufacturer if no flow
meter is fitted
o Closed loop discharge: intermediate or continuous
o Seawater inlet (if applicable) & overboard pH reading (before and after sampling)
o Seawater inlet (if applicable) & overboard PAH reading before dilution/chemical
addition for pH correction, (before and after sampling)
o Seawater inlet (if applicable) & overboard turbidity reading before dilution/chemical
addition for pH correction, (before and after sampling)
o Dilution water flow rate (if applicable)
o Sampling date and time (at each sampling point)
o If the system uses chemicals a record of the chemical name and dosage rate during
sampling
o Any other relevant information
The ship should arrange with its agent shipment of the sample box by courier to the following
laboratory address:
The samples should be despatched as soon as possible after arrival at the berth.
Between sampling and arrival, the samples should be kept in the box in a cool place, but not a
freezer.
Immediately before handing over the samples to the agent, the ice packs should be put into the box
along with chain of custody form 2 (REMEMBER: form 2 must be included for the laboratory to
undertake analysis. It must also be anonymised with the vessel code rather than vessel name). The
insulated box should be placed inside the cardboard outer box and taped closed. Attach the address
and URGENT labels to the outer box.
Usually it is not necessary to include a customs declaration as these are water samples of zero
commercial value and to preserve anonymity it is recommended it is not included unless requested.
However, should it be required a letter that can be used is shown at Appendix 3.
A standard courier service can be used and a special overnight service is not required. However,
the agent must instruct the courier that the sample box is to be delivered to the laboratory within
48 hours of collection.
As such it is recommended that samples are only taken before ports from where this can be
achieved i.e. from main European ports (Baltic, North Sea, Atlantic, western Mediterranean)
Experience from the first round of sampling has shown that there can be delays in collection and
delivery by couriers. Typically, standard couriers do not collect after 17:00, which does not fit well
with ships’ schedules. The laboratory is also not open to receive samples or undertake analyses at
weekends or after 17:00 hours. If, for example, the delivery will coincide with a weekend, then
under most circumstances courier collection on a Monday morning should still allow PAH analysis
within the 7-day maximum preservation time:
• Sampling: maximum 24 hours before berth
• Agent: collection of samples from ship as soon as possible after berthing
• Courier: collection of samples from agent as soon as possible (if vessel berths at 17:00, then
there can be up to a 15-hour delay before the courier collects from the agent)
• Courier: maximum delivery time of 48 hours
The agent should be instructed not to pass the samples to the courier if they cannot be delivered
before a weekend. Should this situation arise the agent should hold the samples and pass to the
courier at opening of business on Monday morning. Samples should be stored in a cool place but
not a freezer while waiting for courier collection
The ship should advise EGCSA (see section 5 - points of contact) when the samples have been
taken and collected, and provide contact details for the agent:
• Agent company name
• Contact name
• Email address
• Telephone number
This will enable EGCSA to track progress of the sampling and delivery – any samples received by
the laboratory outside of the 7-day maximum preservation time will not be analysed for PAH
AN IMPORTANT PART OF EACH SHIP SAMPLING IS PRE-PLANNING TO TAKE INTO ACCOUNT THE
SHIP’S SCHEDULE AND ORGANISING THE MEANS BY WHICH SAMPLES WILL BE COLLECTED AND
DELIVERED TO THE LABORATORY, WITH A CONTINGENCY PLAN FOR SHIP DELAYS.
APPENDIX 1
Sampling Points
✓
2
✓
3
✓
1
Figure A1.1.1: Open loop system sampling points
1. Seawater inlet
2. Wash water after scrubber, but before wash water treatment
3. Wash water overboard discharge, after wash water treatment, but before any dilution or
chemical pH adjustment
✓
2
✓
✓ 3
1
2 ✓
3
✓
1
✓
Figure A1.1.3a: Hybrid system open loop mode sampling points
1. Seawater inlet
2. Wash water after scrubber, but before wash water treatment
3. Wash water overboard discharge, after wash water treatment, but before any dilution or
chemical pH adjustment
2
✓
3
✓
1
✓
Figure A1.1.3b: Hybrid system closed loop mode sampling points
1. Seawater (see A1.2 point 3, regarding sampling seawater and closed loop scrubbing)
2. Wash water after scrubber, but before wash water treatment
3. Wash water overboard discharge, after wash water treatment, but before any dilution or
chemical pH adjustment
2. Multiple scrubber units – one wash water treatment system, one overboard discharge
a. Take seawater samples as per Appendix A1.1 or points 1 or 3 in this section.
b. Take one set of samples* after each of the scrubber units before the wash water
pipework is joined into the common wash water treatment system.
c. Take one set of samples* from the combined overboard discharge before any
dilution or chemical addition to correct discharge pH
3. Closed loop system or hybrid system in closed loop mode – no seawater inlet
a. Take one set of samples* from a sea chest or seawater cooling pump forward of the
scrubber overboard discharge. (This could be the seawater pump supplying the
scrubber system coolers)
b. Take other samples as per Appendix A1.1 or point 2 in this section.
*One set of samples from a sampling point = 2 bottles (one for PAH and one for metals analysis) – see Figure 1
APPENDIX 2
Forms & Examples - replace as required.
Note:
• Forms 1 & 2 will be sent to the ship by EGCSA
• EGCSA will pre-fill the grey cells in the forms with information shown in section 6.3
• Yellow cells in the forms must be completed by the ship before and/or after sampling
• Examples are included in this Appendix
APPENDIX 3
Other Documents – update as required