Exhaust Gas Cleaning Scrubber Management Plan

Document ID: HSE-07.
24
Exhaust Gas Cleaning Scrubber Management Plan
Effective Date: 15-DEC-2019 Revision: 7.0
EXHAUST GAS
CLEANING
SCRUBBER
MANAGEMENT
PLAN
Ship’s Name : Golden Anastasia
Ship Type : Bulk carrier
IMO Number : 9696046

OSM SAFETY COMMITMENTS
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Document ID: HSE-07.24

VESSEL PARTICULARS
Flag MARSHAL ISLANDS, MAJURO
Length BP 283.5 M
Breadth 45.0 M
Draft (Summer) 18.3 M
Displacement 206518.7
Call Sign V7HJ2
Year Built 2014
Shipyard SUNGDONG DOCKYARD
Number of Crew / Passengers 25
GT 93464
NT 59492
Maker: Alfa Laval Nijmegen B.V.Model: Open Loop, U‐Type S/N:
Equipment Make/Model 182.30.1.5382
Type of Scrubber Open Loop

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EXHAUST GAS CLEANING SCRUBBER

MANAGEMENT PLAN

Master is responsible for maintaining ship specific exhaust gas cleaning scrubber management plan
and arrange crew training for general awareness at interval not more than 6 months. Master along
with the chief engineer must review the manual every year to ensure it is ship specific and complying
with all the latest amendments and meeting the latest regulations. The annual revision must be
carried out not later than 30 October of every calendar year. The Chief Engineer to ensure no crew is
getting engaged in EGCS operation or maintenance work without having basic familiarization training
as guided in the maker’s manual.
Upon taking over, or retrofitting’s or new delivery any ship under management the Master must start
the process and collect all the required information and to insert in this template to make a Ship
specific EGCS Management Plan within one month. Once all ship specific information is recorded the
Master must send the document to the vessel manager for review and approval. The Master must
maintain the office approval document along with this manual for internal audit verification.
1. PURPOSE
The objectives of this manual are to provide practical guidance to ship staff and any other interested
parties, on measures to minimize the risk of air pollution or water pollution from ships' exhaust and
wash water discharge. It is important that exhaust gas scrubber management procedures be effective
as well as environmentally safe & practical, designed to minimize costs and delays to the ship.
2. SCOPE
This Exhaust Gas Cleaning Scrubber Management Plan is specific and unique for this vessel. The plan
is following the outline given in the IMO guideline, MEPC.176(58),259(68), dated 15 May 2015 and
revised MARPOL 73/78 annex VI into force. Along with Polar Code.
The European Commission has published Directive 2012/33/EU amending Council Directive 1999 / 32
/ EC as regards the sulphur content of marine fuels.
Other regulations on emissions reduction include EC Directive 2005(33), California Air Resources
Board (CARB), the US EPA, and local jurisdictions such as port administrations.
This guideline must be read and followed along with manufacturer’s manuals;
 Operation manual  Functional Block Diagram  Spare parts list.
 Local port regulations including
 General arrangement of applicable wash water discharge
 Technical Manual.
Scrubber plan criteria.
 Troubleshooting manual  Electrical drawings.  Technical circulars.
Regulation 14 of Annex VI requires ships to use fuel oil with a sulphur content not exceeding that
stipulated in regulations 14.1 or 14.4. Regulation 4 allows, with the approval of the Administration, the
use of an alternative compliance method at least as effective in terms of emission reductions as that
required by the Annex, including the standards set forth in regulation 14.
Hence it is important to maintain all the valid Class Certification on behalf of the administration issued
for this purpose and to carry out survey required by the regulation.
These guidelines have been developed with the intention of being objective and performance oriented.
Furthermore, use of the SO2(ppm)/CO2 (%) ratio method will simplify the monitoring of SOX emission
and facilitate approval of an EGC unit.

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3. ACKNOWLEDGEMENT:
This Exhaust Gas Cleaning Scrubber Management Manual has been developed for the vessel
and is valid until further revision.
Master
Place Date Name Signature
Master to first make xerox of this page and then fill it up.

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4. REVIEW RECORDS:
Date of Review Remarks Reviewed By
Master to first make xerox of this page and then fill it up.

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5. TRAINING RECORDS:
Date of Name of Candidate and Signature Instructor: Signature
Training
Master to first make xerox of this page and then fill it up. No person should work in the exhaust gas
cleaning scrubber system until and unless a proper familiarization training has been conducted to the
satisfaction of the Chief Engineer. A new joining Chief Engineer must obtain the familiarization training
from the existing Chief Engineer upon joining, except in case of an emergency or undue circumstance on
board second engineer and electrical officer who is familiar with the system may provide training to the
new joining chief engineer with office approval. Training guideline is available under Appendix III.

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6. TABLE OF CONTENTS.
Section Title Pages
0 Vessel Particulars 2
1 Purpose 3
2 Scope 3
3 Acknowledgement 4
4 Review Records 5
5 Training Records 6
6 Table of content 7
7 Definition 9
8 Applicable Regulation 11
9 Options 12
10 IMO exhaust gas cleaning system (EGCS) guidelines 12
11 Ship compliance and documentation 20
12 Monitoring 21
13 Residue tanks are to satisfy the following requirements 27
14 Sodium hydroxide tank 27
15 Scrubber automation and monitoring requirements 28
16 Protective equipment 30
17 Requirements for MC (notation) ships 30
18 Backpressure 30
19 Electrical systems 31
20 Piping systems in engine room associated with scrubber 31
21 Flooding 32
22 Vessel stability 32
23 Redundancy 33
24 Equipment type approval flow diagram 34
25 EGCS classification concepts 35
26 Poster for discharge criteria 36

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Section Title Pages
27 Dry scrubbers 37
28 Wet Scrubbers 37
29 Exhaust gas bypass 42
30 Contingency measures 44
31 Responsibility 45
ANNEX I: REGIONAL AND LOCAL REGULATIONS 46
LIST OF COUNTRIES AND PORT PROHIBITS WASH WATER

ANNEX II DISCHARGE FROM EXHAUST GAS CLEANING SCRUBBERS OPEN 52
LOOP SYSTEM:
ANNEX III WASHWATER DISCHARGE POSTER 57
ANNEX IV FREQUENTLY ASKED QUESTIONS 58
ANNEX V ALKALINITY LEVELS TABLE 62
SHIP SPECIFIC SECTION

APPENDIX I SHIP SPECIFIC INFORMATION TABLE 63
APPENDIX II SHIP BOARD DOCUMENT CONFIRMATION LIST 65
APPENDIX III TRAINING CHECKLIST 66

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7. DEFINITION
Defeat Device Means a device that measures, senses, or responds to operating variables (e.g.,
engine speed, temperature, intake pressure or any other parameter) for the purpose of activating,
modulating, delaying or deactivating the operation of any component or the function of the emission
control system, such that the effectiveness of the emission control system is reduced under conditions
encountered during normal operation, unless the use of such a device is substantially included in the
applied emission certification test procedures.
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.
CO2 Carbon dioxide.
COD Chemical Oxygen Demand, which is a measure of the theoretical oxygen consumption of a water
sample. The oxidization of bisulfite and sulfite to sulfate increases the COD, which could potentially
have an adverse impact on aquatic systems.
EGC Exhaust gas cleaning.
EGCS Record Book This record would include the date, time, location and quantity of residues
delivered ashore from the EGCS water treatment system. Alternatively, electronics recording is
allowed provided approved by administration.
Emission Means any release of substances, subject to control by this Annex, from ships into the
atmosphere or sea.
Emission Control Area Means an area where the adoption of special mandatory measures
for emissions from ships is required to prevent, reduce and control air pollution from NOx or SOx
and particulate matter or all three types of emissions and their attendant adverse impacts on
human health and the environment. Emission control areas shall include those listed in, or
designated under, regulations 13 and 14 of this Annex.
ESSF: European Sustainable Shipping Forum.

ETM-A EGC system – Technical Manual for Scheme A.
ETM-B EGC system – Technical Manual for Scheme B.
Fuel Oil Combustion Unit Any engine, boiler, gas turbine, or other fuel oil fired equipment,
excluding shipboard incinerators.
FNU stands for Formazin Nephelometric Units and signifies that the instrument is measuring scattered
light from the sample at a 90-degree angle from the incident light. FNU is most often used when
referencing the ISO 7027 (European) turbidity method.
GESAMP Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection
IN SITU: Sampling directly within an exhaust gas stream
Irrational Emission Control Strategy Means any strategy or measure that, when the ship is
operated under normal conditions of use, reduces the effectiveness of an emission control system to a
level below that expected on the applicable emission test procedures.
Load Range Maximum rated power of diesel engine or maximum steaming rate of the boiler.
MCR Maximum Continuous Rating.
Metals Metals are a diverse group of pollutants, many of which are toxic to aquatic life and humans.
While some metals, including copper, nickel and zinc, are known to be essential to organism function,
many others, including thallium and arsenic, are non-essential and/or are known to have only adverse
impacts. Even essential metals can do serious damage to organism function in sufficiently elevated
concentrations.
NaOH Sodium Hydroxide (Caustic Soda)
NDIR Non-Dispersive Infrared

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Nitrate a salt or ester of nitric acid, containing the anion NO3− or the group —NO3.
NTU stands for Nephelometric Turbidity Unit and signifies that the instrument is measuring scattered
light from the sample at a 90-degree angle from the incident light. The unit used to measure the
turbidity of a fluid or the presence of suspended particles in water. ... NTU units are most commonly
used by purification plants.
OMM: Onboard Monitoring Manual.
PPM Means "parts per million". It is assumed that ppm is measured by gas analysers on a molar
basis, assuming ideal gas behavior. The technically correct units are micro-moles of substance per
mole of total amount ( mol/mol), but ppm is used in order to be consistent with units in the NOx
Technical Code.
Polycyclic aromatic hydrocarbons (PAHs) are a large group of organic compounds with two or
more fused aromatic rings. PAHs occur naturally in petroleum and are also produced as by-products of
fuel combustion. PAHs are an important class of environmental contaminants, which are known to
accumulate in ecosystems. The US EPA has identified 16 PAH compounds as priority pollutants. Some
of these compounds are carcinogenic and/or mutagenic to mammals; in addition, they have both
acute toxicity and sub-lethal effects on some aquatic organisms. PAHs may also bio-accumulate in
edible shellfish, which gives them a pathway to humans. A source of PAHs is the incomplete
combustion of fuel oils and although engines and boilers are designed to optimise the combustion of
fuel, exhaust gases will always contain a proportion of incompletely combusted material. This results
in gaseous hydrocarbon and particulate emissions that range from methane to very large complex
molecules; a proportion of which will include polycyclic aromatic hydrocarbons. Whilst low molecular
weight PAHs are mainly found unbound in the gaseous phase of the exhaust stream, heavier molecular
weight PAHs constitute a group of the substances that are bound onto soot created during combustion.
pH In Chemistry a figure expressing the acidity or alkalinity of a solution on a logarithmic scale on
which 7 is neutral, lower values are more acid and higher values more alkaline. The pH is equal to
−log10 c, where c is the hydrogen ion concentration in moles per litre.
PM stands for particulate matter (also called particle pollution): the term for a mixture of solid
particles and liquid droplets found in the air. Some particles, such as dust, dirt, soot, or smoke, are
large or dark enough to be seen with the naked eye. Others are so small they can only be detected
using an electron microscope. Particle pollution includes:
 PM10 : inhalable particles, with diameters that are generally 10 micrometers and smaller; and
 PM2.5 : fine inhalable particles, with diameters that are generally 2.5 micrometers and smaller.
 How small is 2.5 micrometers? Think about a single hair from your head. The average human
hair is about 70 micrometers in diameter – making it 30 times larger than the largest fine
particle.
SCHEME A EGC system approval, survey and certification using parameter and emission checks.
SCHEME B EGC system approval, survey and certification using continuous monitoring of SOx
emissions.
SECP SOX Emissions Compliance Plan.
SECC SOX Emissions Compliance Certificate.
Ships Constructed Means ships the keels of which are laid or that are at a similar stage of
construction.
SOX Sulphur oxides.
SO2 Sulphur dioxide.
Turbidity the quality of being cloudy, opaque, or thick with suspended matter. Turbidity is a measure
of the degree to which the water loses its transparency due to the presence of suspended particulates.
The more total suspended solids in the water, the murkier it seems and the higher the turbidity.

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8. APPLICABLE REGULATION:
8.1: MARPOL Annex VI- Regulation 14 - Sulphur Oxides (SOx) and Particulate Matter states:
General Requirements
1. The sulphur content of any fuel oil used on board ships shall not exceed the following limits:
 4.50% m/m prior to 1 January 2012;
 3.50% m/m on and after 1 January 2012; and
 0.50% m/m on and after 1 January 2020.
2. The worldwide average sulphur content of residual fuel oil supplied for use on board ships shall be
monitored taking into account guidelines developed by the Organization. (MEPC.82(43),)
Requirements within Emission Control Areas
3. For the purpose of this regulation, emission control areas shall include:
 the Baltic Sea area as defined in regulation 1.11.2 of Annex I and the North Sea area as
defined in regulation 1.14.6 of Annex V;
 the North American area as described by the coordinates provided in Appendix VII to this
Annex;
 the United States Caribbean Sea area as described by the coordinates provided in Appendix VII
to this Annex; and
 any other sea area, including any port area, designated by the Organization in accordance with
the criteria and procedures set forth in Appendix III to this Annex.
4. While ships are operating within an Emission Control Area, the sulphur content of fuel oil used on
board ships shall not exceed the following limits:
 1.50% m/m prior to 1 July 2010;
 1.00% m/m on and after 1 July 2010; and
 0.10% m/m on and after 1 January 2015.
 Prior to 1 January 2020, the sulphur content of fuel oil referred to in paragraph 4 of this
regulation shall not apply to ships operating in the North American area or the United States
Caribbean Sea area defined in paragraph 3, built on or before 1 August 2011 that are powered
by propulsion boilers that were not originally designed for continued operation on marine
distillate fuel or natural gas.
5. The sulphur content of fuel oil referred to in paragraph 1 and paragraph 4 of this regulation shall be
documented by its supplier as required by regulation 18 of this Annex.
6. Those ships using separate fuel oils to comply with paragraph 4 of this regulation and entering or
leaving an Emission Control Area set forth in paragraph 3 of this regulation shall carry a written
procedure showing how the fuel oil change-over is to be done, allowing sufficient time for the fuel oil
service system to be fully flushed of all fuel oils exceeding the applicable sulphur content specified in
paragraph 4 of this regulation prior to entry into an Emission Control Area. The volume of low sulphur
fuel oils in each tank as well as the date, time, and position of the ship when any fuel-oil-change-over
operation is completed prior to the entry into an Emission Control Area or commenced after exit from
such an area, shall be recorded in such log-book as prescribed by the Administration.
7. During the first twelve months immediately following entry into force of an amendment designating
a specific emission control area under paragraph 3 of this regulation, ships operating in that emission
control area are exempt from the requirements in paragraphs 4 and 6 of this regulation and from the
requirements of paragraph 5 of this regulation insofar as they relate to paragraph 4 of this regulation.
8.2: As per MEPC\74\MEPC 74-18-Add.1.docx
Interpretation:
Regulation 14.1 of MARPOL Annex VI for the prohibition on carriage of non-compliant fuel oil should be
applied to the fuel oil of emergency equipment.

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8.3: Regulation 4 – Equivalents
1. The Administration of a Party may allow any fitting, material, appliance or apparatus to be fitted in
a ship or other procedures, alternative fuel oils, or compliance methods used as an alternative to that
required by this Annex if such fitting, material, appliance or apparatus or other procedures, alternative
fuel oils, or compliance methods are at least as effective in terms of emissions reductions as that
required by this Annex, including any of the standards set forth in regulations 13 and 14.
2. The Administration of a Party which allows a fitting, material, appliance or apparatus or other
procedures, alternative fuel oils, or compliance methods used as an alternative to that required by this
Annex shall communicate to the Organization for circulation to the Parties particulars thereof, for their
information and appropriate action, if any.
3. The Administration of a Party should take into account any relevant guidelines developed by the
Organization pertaining to the equivalents provided for in this regulation.
4. The Administration of a Party which allows the use of an equivalent as set forth in paragraph 1 of
this regulation shall endeavor not to impair or damage its environment, human health, property, or
resources or those of other States.
9. OPTIONS
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 under regulation 4.
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.
10. IMO EXHAUST GAS CLEANING SYSTEM (EGCS) GUIDELINES

The development of EGCS for use on-board ships has been driven by the 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 6.0 g/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 consider 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
washwater.
The pH can be determined either by direct measurement or by using a calculation-based methodology

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(computational fluid dynamics or other equally scientifically established empirical formulae) to be left
to the approval by the Administration.
Among other sections, the following provisions were retained:

The recommendation to IMO Administrations to collect data on washwater discharges in accordance
with Appendix 3 of the guidelines enables this criterion to be subsequently reviewed by the IMO,
considering 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 like 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 washwater used in the scrubbing process is to be monitored
and recorded.
10.1: 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. Continual compliance is verified by continuous monitoring
of EGCS operating parameters, daily checks of the exhaust emissions and continual monitoring of the
washwater discharge.
The ship 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

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book is to be approved by the Administration and may form part of the vessels planned maintenance
record system.
10.1.1: EGCS Technical Manual for Scheme A (ETM-A)
Ships installed with an EGCS approved under Scheme A should be equipped with an ETM-A provided
by the manufacturer and approved by the Flag Administration. This ETM-A should, at a minimum,
contain the information listed in the following.
1. Unit identification information (e.g., manufacturer, model/type, serial number and other details
as necessary) including a description of the unit and any required ancillary systems.
2. Certified unit operating limits, or operating value ranges. These should, at a minimum, include
the following:
a) Maximum and, if applicable, the minimum mass flow rate of exhaust gas.
b) Power, type and other relevant parameters of the fuel oil combustion unit for which the EGC
unit is to be fitted. In the case of boilers, the maximum air/fuel ratio at 100% load should
also be given. In the case of diesel engines, it should be indicated whether the engine is
two-stroke or four-stroke cycle.
c) Maximum and minimum washwater flow rates, the inlet pressure and the minimum inlet
water alkalinity (refer to ISO 9963-1-2: “Water quality - Determination of alkalinity”)
d) Exhaust gas inlet temperature ranges as well as the maximum and minimum exhaust gas
outlet temperatures when the EGC unit is in operation.
e) Exhaust gas differential pressure range and the maximum exhaust gas inlet pressure when
the fuel oil combustion unit is operating at MCR or an 80% power rating.
f) Salinity levels or fresh water elements necessary to provide adequate neutralizing agents.
g) Other factors concerning the design and operation of the EGC unit relevant to achieving a
maximum emission value no higher than its Certified Value
3. Any requirements or restrictions applicable to the EGC unit or associated equipment necessary
to enable the unit to achieve a maximum emission value no higher than the Certified Value.
4. Maintenance, service or adjustment requirements in order that the EGC unit can continue to
achieve a maximum emission value no higher than the Certified Value. The maintenance,
service and adjustments should be recorded in the EGC Record Book.
5. Corrective actions to be taken in cases where the applicable maximum allowable SO2/CO2 ratio
or the washwater discharge criteria are exceeded.
6. Verification procedure to be used at surveys to ensure that the EGC unit’s performance is
maintained and that it is being used as required.
7. Through range performance variation in washwater characteristics.
8. Design requirements for the washwater system.
9. The SECC.
Changes made to the ETM-A which reflect any modifications made to the EGC unit which affect
performance with respect to air or water emissions should be approved by the Flag Administration.
When documents related to additions, deletions or corrections made to the ETM-A are provided

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separately from the initially approved ETM-A, they should be kept together with the ETM-A and should
be part of the ETM-A.
Prior to use, EGCS should be issued with an SECC by the Flag Administration. Following the installation
survey, “Section 2.6 Equivalents (regulation 4)” of the ship’s Supplement to the International Air
Pollution Prevention (IAPP) Certificate should be completed.
Operating limits, or range of operating values which should be included in ETM-A
10.1.2: The ETM-A should include a verification procedure for demonstrating EGCS
compliance
This procedure should not require specialized equipment or an in-depth knowledge of the system.
Where devices are required, they should be provided and maintained as part of the system. The EGC
unit should be designed in such a way as to facilitate inspection as required. With respect to the
verification procedure, it is specified that if all the relevant components and operating values or
settings are within approved ranges, the performance of the EGCS is, in principle, deemed to satisfy
the requirements without the need for actual exhaust emission measurements.
It is necessary to ensure that the EGC unit is fitted to a fuel oil combustion unit for which it is rated –
this forms part of the SECP. In cases where information about the exhaust gas (e.g. gas flow rate,
etc.) of fuel oil combustion units connected to the EGCS is required by the Flag Administration or PSC
surveyor etc., either the relevant EIAPP certificate, relevant Technical File, or an Exhaust Gas
Declaration issued by the engine maker, the designer or another competent party may be submitted.
In addition, a Flue Gas Declaration issued by the boiler maker, the designer or another competent
party is considered to serve this purpose to the satisfaction of the Flag Administration.
Onboard verification procedures should be in accordance with following:

1. Verification of all components and operating values or settings which may affect the operation
of the EGC unit and its ability to satisfy Certified Values should be included.
2. An ETM-A which includes the verification procedure should be submitted by the EGCS
manufacturer and approved by the Flag Administration.
3. Both a documentation check and an on-site verification of the EGC unit should be covered.
4. Surveyors should verify that each EGC unit is installed in accordance with the ETM-A and has
an SECC as required.

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To demonstrate compliance when an EGCS is in use, at least the following should be automatically
recorded at a rate which should not be less than 0.0035 Hz (35 times per 10000 sec. where once per
285.7 sec. is equal to once every 4 min. 45.7 sec.).
(1) Washwater pressure and flow rate at the EGC unit’s inlet connection.
(2) Exhaust gas pressure before and pressure drop across the EGC unit.
(3) Fuel oil combustion equipment load.
(4) Exhaust gas temperature before and after the EGC unit.
Under scheme A, if a continuous exhaust gas monitoring system is not fitted, daily spot checks
of the SO2/CO2 ratio are recommended in order to confirm the proper operation of EGCS. If a
continuous exhaust gas monitoring system is fitted, only daily spot checks of the above parameters
would be required to verify proper operation of the EGC unit.
If the EGCS manufacturer is unable to provide assurance that the EGC unit will satisfy the Certified
Value or below between surveys by means of the verification procedure shown, or if this requires
specialized equipment or in-depth knowledge, it is recommended that Scheme B, the continuous
exhaust gas monitoring of each EGC unit, be used to assure continuous compliance with requirements
related to fuel oil sulphur content.
10.1.3: Emission Limits
Section 4.3 of Chapter 4 of the IMO EGCS Guidelines requires that EGCS should be capable
of reducing SOx emission to less than the Certified Value. In addition, it specifies the load point
where emission measurement testing should be performed to confirm this. A summary of these
requirements is given below.
EGC units should be capable of reducing emissions to equal to or less than Certified Values within the
following load ranges according to the type of fuel oil combustion unit as per ETM-A scheme.
1) Emission Limits:
Sl No Subject Limit range

1 For main propulsion purposes 25–100%
2 For auxiliary purposes 10–100%
For both main propulsion and
3 10–100%
auxiliary purposes
10–100% of the load range (steaming rate) or, if the turn
4 For boilers down ratio is smaller, over the actual load ranges of the
boilers
2) Emission Measurement Testing:

In order to demonstrate performance, emission measurements, as agreed upon by the Flag, should be
carried out at a minimum of four load points as shown in
Sl No Subject Limit range

1 Load point 1 at 95–100% of the maximum exhaust gas mass flow rate
2 Load point 2 within ± 5% of the minimum exhaust gas mass flow rate
two load points which are equally spaced between the
3 Load points 3 and 4 maximum and
minimum exhaust gas mass flow rates
For loads below those specified in 1, the EGC unit should continue to operate. In cases where the fuel
oil combustion equipment may be required to operate under idling conditions, the SO2 emission
concentration (ppm) at the standardized O2 concentration (15.0 % diesel engines, 3.0 % boilers)
should not exceed 50 ppm.

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10.2: 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 using 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.
Like 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 washwater discharge. Scheme B shipowners should be
supplied with an EGCS Record Book in the same manner as Scheme A.
In addition, among the documents required to retain on board, approval by the Flag Administration is
required for the ETM-B, OMM and SECP.
Furthermore, either an installation or an initial survey is required when the EGCS is installed to verify
initial compliance and a periodical survey is required after installation to verify continued compliance.
The EGC unit approval required under Scheme A is not required under this scheme.
IMO EGCS Guidelines specifies requirements related to the measuring and recording of SO2/CO2 ratios
under Scheme B.
A summary of these requirements is given below.
Exhaust gas composition in terms of SO2 (ppm) and CO2 (%) should be measured at an appropriate
position downstream of the EGC unit and such measurement should be in accordance with the
requirements of emission testing specified. SO2 and CO2 should be continuously monitored and
recorded by a data recording and processing device at a rate which should not be less than 0.0035 Hz
(35 times per 10000 sec. where once per 285.7 sec. is equal to once every 4 min. 45.7 sec.). If more
than one analyser is to be used to determine the SO2/CO2 ratio, these should be tuned to have similar
sampling and measurement times and the data outputs aligned so that the SO2/CO2 ratio is fully
representative of the exhaust gas composition.
Onboard Procedures for Demonstrating Compliance with Emission Limits.

The IMO EGCS Guidelines specifies that data recording systems should comply with the requirements
for data recording and processing device specified. As well as relevant requirements for onboard
monitoring manuals (OMM) specified. It also specifies that daily spot checks of the parameters listed in
are needed to verify proper operation of the EGC unit and that the results of these checks should be
recorded in either the EGC Record Book or in the engine-room logger system.
10.2.1: EGCS Technical Manual – Scheme B (ETM-B)
The IMO EGCS Guidelines specifies the following requirements for ETM-B:
Ships which would be installed with an EGCS based upon Scheme B should be equipped with an ETM-B
provided by the manufacturer and approved by the Flag Administration. This ETM-B should, at a
minimum, contain the information listed in the following:
1. Unit identification information (e.g., manufacturer, model/type, serial number and other details
as necessary) including a description of the unit and any required ancillary systems.

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2. The operating limits or range of operating values for which the unit is certified. These should,
as a minimum, include the following:
a) Maximum and, if applicable, minimum mass flow rate of exhaust gas.
b) The power, type and other relevant parameters of the fuel oil combustion unit for which the
EGC unit is to be fitted. In the case of boilers, the maximum air/fuel ratio at 100% load
should also be given. In the case of diesel engines, it should be indicated whether the
engine is two-stroke or four-stroke cycle.
c) Maximum and minimum washwater flow rate, inlet pressures and minimum inlet water
alkalinity (refer to ISO 9963-1-2: “Water quality - Determination of alkalinity”)
d) Exhaust gas inlet temperature ranges as well as the maximum and minimum exhaust gas
outlet temperature when the EGC unit is in operation.
e) Exhaust gas differential pressure range and the maximum exhaust gas inlet pressure when
the fuel oil combustion unit operating at MCR or an 80% power rating, whichever is
appropriate.
f) Salinity levels or fresh water elements necessary to provide adequate neutralizing agents.
g) Other parameters as necessary concerning the operation of the EGC unit.
3. Any requirements or restrictions applicable to the EGC unit or its associated equipment.
4. Corrective actions in the case of exceedances of the applicable maximum allowable SO2/CO2
ratio, or the washwater discharge criteria.
5. Through range performance variation in washwater characteristics.
6. Design requirements of the washwater system.
10.2.2: Emission Testing
The IMO EGCS Guidelines specifies requirements related to exhaust gas measurements during
emission testing. Such requirements and other relevant requirements related to exhaust gas
measurement specified in the IMO EGCS Guidelines are listed below. In addition to the requirements
in this Guidelines, compliance with the requirements in Chapter 5 of the NOx Technical Code 2008
(NTC 2008) and associated appendices is also required.
EGCS Guidelines requirements related to exhaust gas measurements.
EGCS
Items Requirements Guidelines
references
To be measured at an appropriate position downstream of the EGC unit.
In cases where CO2 concentration is reduced by the EGC unit, CO2
concentration can be measured at the EGC unit inlet, provided that the
correctness of such a methodology can be clearly demonstrated. In such
cases, the SO2 and CO2 values should be compared on a dry basis. If
Measurement CO2 Measurement 5.4.1,6.9
measured on a wet basis, the water content in the exhaust gas stream at
position
those points should also be determined in order to correct the readings to dry
basis values. For calculation of the CO2 value on a dry basis, the dry/wet
correction factor may be calculated in accordance with paragraph 5.12.3.2.2
of the NTC 2008
SO2 measurement To be measured at an appropriate position downstream of the EGC unit 5.4.1, 6.4

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To be continuously monitored and recorded onto a data recording and
Measurement frequency 5.4.2
processing device at a rate which should not be less than 0.0035 Hz.
To be measured using an analyzer operating on Other systems or
non-dispersive infra-red (NDIR) principle with analyzer
CO2 measurement
additional equipment such as dryers as principles may be
necessary. accepted, subject to the
6.2
Measurement To be measured using analyzers operating on Flag Administration
method non-dispersive infra-red (NDIR) or non-dispersive approval, provided they
SO2 measurement
ultra-violet (NDUV) principles with additional yield equivalent or
equipment such as dryers as necessary. better results.
CO2 measurement
In-situ or extractive sample systems 6.5
SO2 measurement
Extractive exhaust gas samples should be maintained at a sufficient
temperature to avoid condensed water in the sampling system and hence the 6.6
Measures to prevent the loss of SO2 for
loss of SO2.
extractive sample
If an extractive exhaust gas sample for determination needs to be dried prior
systems
to analysis, it should be done in a manner that does not result in the loss of 6.7
SO2.
Consideration of the water The SO2 and CO2 should be compared on the basis of the same residual
6.8
content water content (e.g. dry or with the same wetness fraction).
In accordance with the requirements in sections 1.6 to 1.10 of appendix III of the NOx Technical
6.3
Code 2008. These requirements are given below.
An analyzer should not deviate from the nominal calibration point by more
Section 1.6 of
than ± 2% of the reading over the entire measurement range except for zero
Accuracy Appendix III of
or
the NTC
± 0.3% of the full-scale value, whichever is larger.
Precision, defined as 2.5 times the standard deviation of 10 repetitive
responses to a given calibration or span gas, should satisfy the following:
Section 1.7 of
(1) For concentrations above 100 ppm (or ppmC):
Precision Appendix III of
not greater than ± 1% of full-scale concentration for each range
the NTC
(2) For concentration below 100 ppm (or ppmC): not greater than ± 2% of
Analyzer each range
specifications The analyzer peak-to-peak response to zero and the calibration or span
Section 1.8 of
gases over any 10-second period should not exceed 2% of the full-scale
Noise Appendix III of
value of all
the NTC
ranges used.
Zero response is defined as the mean response, including noise, to a zero
Section 1.9 of
gas during a 30-second time interval. The drift of the zero response during a
Zero drift Appendix III of
one-hour period should be less than 2% of the full-scale value of the lowest
the NTC
range used.
Span response is defined as the mean response, including noise, to a span
Section 1.10 of
gas during a 30-second time interval. The drift of the span response during a
Span drift Appendix III of
one-hour period should be less than 2% of the full-scale value of the lowest
the NTC
range used.
10.2.3: Data Recording and Processing Device
The IMO EGCS Guidelines specifies requirements related to data recording and processing device as
given below.
1. It should be of a robust, tamper-proof design with read-only capability.
2. It should record the monitoring and recording data required by 2.4.4.4, 2.5.4 and 2.10.1 in
Universal Coordinated Time (UCT) for ship positions based upon Global Navigational Satellite
System (GNSS).
3. It should be capable of preparing reports over specified time periods.

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4. Recorded data should be retained for a period of not less than 18 months from the date of
recording. If the unit is replaced during that period, the shipowner should ensure that the
required data is retained on board and available as required.
5. It should be capable of downloading a copy of the recorded data and reports in a readily
useable format. Such copies of data and reports should be available to the Flag Administration
or port state authority as required.
10.2.4: Onboard Monitoring Manual (OMM)
The IMO EGCS Guidelines specifies requirements for OMM as given below.
1. An OMM should be prepared to cover each EGC unit provided for fuel oil combustion
equipment, so that each unit can be identified, and its compliance verified.
2. The OMM should, at a minimum, include the following:

a) The sensors to be used in evaluating EGC system performance and washwater
monitoring, their service, maintenance and calibration requirements.
b) The positions from which exhaust emission measurements and washwater monitoring are
to be taken together with details of any necessary ancillary services such as sample
transfer lines and sample treatment units and any related service or maintenance
requirements.
c) The analyzers to be used, their service, maintenance, and calibration requirements.
d) Analyzer zero and span check procedures.
e) Other information or data relevant to the correct functioning of the monitoring system or
its use in demonstrating compliance.
3. The OMM should specify how the monitoring system should be surveyed.
4. The OMM should be approved by the Flag Administration
11. SHIP COMPLIANCE AND DOCUMENTATION
The IMO EGCS Guidelines specifies requirements related to SOx Emission Compliance Plans (SECP).
An SECP is required to be retained onboard so that it can be used to demonstrate that an EGCS
satisfies the requirements for alternative methods of fuel oil Sulphur content compliance. A summary
of these requirements is given below.
1. An SECP approved by the Flag Administration is required for each ship using an EGCS in part or
in total.
2. The SECP should list each item of fuel oil combustion equipment which needs to satisfy
requirements related to fuel oil sulphur content.
3. An SECP under Scheme A should be in accordance with the following:

a) It should indicate the procedures for verifying through continuous monitoring that the
parameters listed are maintained within manufacturer recommended specifications.
b) The following documents should be included as reference:

 ETM-A,
 EGC Record Book or Engine-Room Logger System, and
 OMM.

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c) The procedure to verify that the EGC unit’s rating and restrictions, as approved,
complies with regulation, should be provided for all of the fuel oil combustion equipment
specified.
4. An SECP under Scheme B should be in accordance with the following:

a) It should indicate the procedures for verifying through continuous exhaust gas emission
monitoring that the SO2/CO2 ratio satisfies the requirements related to fuel oil Sulphur content.
b) The following documents should be included as reference:

 ETM-B,
 EGC Record Book or Engine-Room Logger System, and
 OMM.
11.1: The approved EGCS documentation that needs to be on board a ship utilizing EGCS
Under Scheme A Or B of the 2015 guidelines.
Scheme A – Parameter Scheme B –

Document
Check Continuous Monitoring
SOx Emissions Compliance Plan
X X
(SECP)
SOx Emissions Compliance
X -
Certificate (SECC)
EGCS Technical Manual, Scheme A (ETM-A) X -
EGCS Technical Manual, Scheme B (ETM-B) - X
Onboard Monitoring Manual (OMM) X X

EGC Record Book or Electronic
X X
Logging System (Flag Approved)
12. MONITORING
12.1 Emissions
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
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 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 6.0 g/kWh prescribed by the original
MARPOL Annex VI requirements based on a brake-specific fuel consumption of 200 g/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.

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12.1.1: TABLE 3: EGCS sulfur content emission equivalence
Ratio Emission
Fuel Oil Sulfur Content (% m/m)
SO2 (ppm)/CO2 (% v/v)
4.5 195.0
3.5 151.7
1.5 65.0
1.0 43.3
0.5 21.7
0.1 4.3
12.2: Washwater
The IMO Guidelines specify the discharge washwater quality criteria and monitoring requirements for a
number of parameters. Additional washwater limitations may be set by regional, federal or state
regulations. Shipstaff are encouraged to verify the requirements for each of the intended ports
in a vessel’s voyage.
Washwater discharge criteria and requirements related to washwater monitoring and recording:
A summary of these requirements is given below.

When an EGCS is operated in ports, harbors or estuaries and washwater is discharged overboard, the
discharge washwater is to be continuously monitored by washwater monitoring systems and recorded
by a data recording and processing device. The values monitored and recorded should include pH,
PAH, turbidity and temperature. In other areas, the continuous monitoring and recording equipment
should also be in operation, whenever the EGCS is in operation, except for short periods of
maintenance and cleaning. The discharge criteria and monitoring criteria are given below.
Warning:
 The Master must send a mail to each port agent prior commencement of the voyage to obtain
written local requirements of the port she is calling. The passage plans to incorporate the change of
compliant fuel requirements and wash water discharge criteria for open loop scrubber, basis agent’s
guidelines to meet the local regulation to be adopted immediately. A notification to be made to the
vessel manager, Charterer and Owner.
12.2.1: pH Criteria
pH criteria should comply with the following (a) or (b) Which requirements are applied should be
stated in the ETM-A or ETM-B.
a) Discharge washwater should have a pH of no less than 6.5 measured at the ship’s overboard
discharge. During maneuvering and transit, however, a maximum difference of 2 pH units
between the inlet and outlet is allowed measured at the ship’s inlet and overboard discharge.
b) The pH discharge limit, at the overboard monitoring position, is the value that will achieve as a
minimum pH 6.5 at 4 m from the overboard discharge point with the ship stationary, and which
is to be recorded as the overboard pH discharge limit in the ETM-A or ETM-B. The overboard pH
discharge limit can be determined either by means of direct measurement, or by using a
calculation-based methodology (computational fluid dynamics or other equally scientifically

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established empirical formulae) to be left to the approval by the Flag Administration, and in
accordance with the following conditions to be recorded in the ETM-A or ETM-B.
I. All EGC units connected to the same outlets are operating at their full loads (or highest
practicable load) and with the fuel oil of the maximum sulphur content.
II. If a test fuel with lower sulphur content, and/or test load lower than maximum, sufficient
for demonstrating the behavior of the washwater 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 behaviour of the washwater plume and that the overboard pH
discharge limit has been met if the EGC system is operated at the highest fuel sulphur
content and load.
III. Where the washwater 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
ensure that the overboard pH discharge limit is met under any load.
IV. Reference should be made to a sea-water alkalinity of 2,200 μmol/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 Flag Administration.
V. 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, washwater
discharge flow rates, designed pH values at both the discharge and 4 m location, titration
and dilution data should be submitted.
12.2.1.a: pH monitoring
pH should be continuously monitored by pH monitoring equipment which has a resolution of 0.1 pH

units and temperature compensation. pH electrodes should comply with the requirements defined in
BS 2586 (Specification for glass and reference electrodes for the measurement of pH) or have an
equivalent or better performance. The pH meter should meet or exceed BS EN ISO 60746-2:2003
(Expression of performance of electrochemical analyzers. pH value).

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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 washwater 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 washwater 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 washwater criteria, the washwater is required to
be further assessed for those agents, considering IMO guidance for ballast water management
systems that make use of active substances (G9 under MEPC.169 (57)).
Hazards:
 Requirements related to the pH of washwater discharge. For example, zinc used for sacrificial
anodes has a corrosion resistance area of near neutral (pH 6 to 12.5) and has a corrosion area of
both acidic (less than pH 6) and alkaline (above pH 12.5). Therefore, the pH of the discharge and
the arrangement of the discharge outlets need to be carefully considered to prevent excessive
consumption of the sacrificial anode.
 Regarding anti-fouling coating, elution behavior of coating components may largely vary
depending on pH. Moreover, the degree of influence may show markedly different tendencies
depending upon coating. For some hydrolysable coatings, care needs to be taken since the pH
dependence of initial elution of the anti-fouling coating is prominent and as the pH get lower, the
elution rate increases
12.2.2: Polycyclic Aromatic Hydrocarbons (PAH)
Polycyclic aromatic hydrocarbons are a large group of organic compounds with two or more fused
aromatic rings. PAHs occur naturally in petroleum and are also produced by-products of fuel
combustion. A source of PAHs is the incomplete combustion of fuel oils and although engines and
boilers are designed to optimize the combustion of fuel, exhaust gases will always contain a proportion
of incompletely combusted material.
Phenanthrene C14H10
12.2.2.a PAH criteria
PAH criteria should comply with the following. The discharge limit should be stated in the ETM-A or
ETM-B.
a) The PAH concentration in the water should not be greater than 50 μg/L PAHphe (phenanthrene
equivalence) compared to the inlet water PAH concentration with 45 t/MWh of washwater flow
rate. The PAH concentration should be measured downstream of the water treatment
equipment, but upstream of any washwater dilution or other reactant dosing unit.
b) The discharge limit specified in (a) above is the limit which is normalized for a washwater flow
rate through the EGC unit of 45 t/MWh where the MW refers to the MCR or an 80% power

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rating of the fuel oil combustion unit. Where the washwater flow rate is varied, the limit should
be adjusted in accordance with Table below.
c) In consideration of starting up of the EGCS, etc., the continuous PAHphe concentration limit
may exceed the limit described above by up to 100% (100μg/L PAHphe at 45 t/MWh of
washwater flow rate) within a 15-minute period during any 12-hour period.
12.2.2.b PAH monitoring
PAH monitoring equipment should be capable of monitoring PAH in water in a range to at least twice
the discharge concentration limit specified in Table below. Ultraviolet light or fluorescent light should
be used to measure according to flow rate. All equipment should be verified to operate correctly and
not deviate more than 5% in washwater with turbidity within its working range.
PAH Discharge Concentration Limits
Discharge Concentration
Flow Rate (t/MWh) limit Measurement Technology
(μg/L PAHphe equivalents)
0-1 2,250 Ultraviolet Light
2.5 900 Ultraviolet Light
5 450 Fluorescence*
11.25 200 Fluorescence
22.5 100 Fluorescence
45 50 Fluorescence
90 25 Fluorescence
* For any flow rate greater than 2.5 t/MWh fluorescence technology should be used.
For PAH monitoring equipment, excitation wavelength and fluorescent wavelength are fixed to 254 mm and 360 mm respectively, which are the
maximum absorption and the maximum emission wavelength of phenanthrene.
12.2.3 Turbidity/Suspended Particle Matter (SPM)
The turbidity and SPM should comply with the following. The discharge limit of turbidity should be
stated in the ETM-A or ETM-B.
12.2.3.a Turbidity / SPM criteria
The washwater treatment system should be designed to minimize SPM, including any heavy metals
and ash.
a) The maximum continuous turbidity in washwater should not be greater than 25 FNU (formazin
nephlometric units) or 25 NTU (nephlometric turbidity units) or equivalent units, above the
inlet water turbidity. However, during periods of high inlet turbidity, the precision of the
measurement device and the time lapse between inlet measurement and outlet measurement
are such that the use of a difference limit is unreliable. Therefore, all turbidity difference
readings should be a rolling average over a 15-minute period to a maximum of 25 FNU. For the
purposes of this criteria, the turbidity in the washwater should be measured downstream of the
water treatment equipment but upstream of
b) washwater dilution (or other reactant dosing) prior to discharge.
c) As for the PAH criteria, the continuous turbidity discharge limit may be exceeded by 20% within
a 15-minute period in any 12-hour period.
12.2.3.b. Turbidity / SPM monitoring

Turbidity should be continuously monitored, and the monitoring equipment should meet requirements
defined in either ISO 7027:1999 (“Water quality - Determination of turbidity”) or USEPA 180.1
(“Determination of Turbidity by Nephelometry”).

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12.2.4 Nitrates
In an engine combustion chamber a series of reactions occur that oxidise a small part of the nitrogen
in the charge air and most of the nitrogen in the fuel oil so that nitric oxide (NO) is formed. In the
cooler exhaust after the combustion chamber approximately 5% to 10% of the NO is then converted
to nitrogen dioxide (NO2) in the presence of excess oxygen. Collectively NO and NO2 are often referred
to as NOx. When NO2 is dissolved in water a series of reactions occur which finally result in the
formation of nitrate
12.2.4.a. Nitrates criteria
I. The washwater treatment system should prevent the discharge of nitrates beyond that
associated with a 12% removal of NOx from the exhaust, or beyond 60 mg/l normalized for a
washwater discharge rate of 45 tons/MWh (see Table below), whichever is greater.
II. A sample of discharge water drawn from each EGCS should be analyzed for nitrate content and
nitrate discharge data should be available at installation survey and each renewal survey. At
each renewal survey, the data of sample drawn within the three months prior to the survey
should be available. However, the Flag Administration may require an additional sample to be
drawn and analyzed at their discretion. The nitrate discharge data and analysis certificate
should be retained on board the ship as part of the EGC Record Book. Requirements related to
sampling, storage, handling and analysis should be detailed in the ETM-A or ETM-B as
applicable. The test method for the analysis of nitrates should be according to standard
seawater analysis as described in Grasshoff et al.
III. The discharge water from all EGCS should be tested for nitrates. If typical nitrate amounts are
above 80% of the upper limit, it should be recorded in the ETM-A or ETM-B.
Nitrate concentration limit in discharge water
Flow Rate (t/MWh) Nitrate Concentration Limit (mg/L nitrates)

1 2,700
2.5 1,080
5 540
11.25 240
22.5 120
45 60
90 30
12.2.5. Washwater additives and other substances
A washwater assessment of influence for environment etc. is required for an EGCS which makes use of
chemicals, additives, preparations and create relevant chemicals. This assessment should be carried
out in consideration of relevant IMO Guidelines such as the “Procedure for approval of ballast water
management systems that make use of Active Substances (G9)” (Resolution MEPC.169(57)), etc.
Furthermore, additional washwater discharge criteria should be established as necessary.
12.3 Treatment of Residue
The IMO EGCS Guidelines specifies the treatment of residue removed from washwater. Such residue is
required to be delivered ashore to adequate reception facilities and should not be discharged into the
sea or incinerated on board. Moreover, the date, time and location of said storage and disposal is
required to be recorded. It is specified that such records may be entered into either an existing log
book or electronic recording system approved by the Flag Administration.

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13. RESIDUE TANKS ARE TO SATISFY THE FOLLOWING REQUIREMENTS
1. Residues removed from washwater used in scrubber chambers are to be stored in tanks
independent of the oil residue (sludge) tanks fitted in accordance with Chapter 2, Part 3 of the
Rules for Marine Pollution Prevention Systems. In addition, such residues are to be discharged
to appropriate reception facilities.
2. Manholes or access holes in a sufficient size are to be provided at such locations that each part
of the tank can be cleaned without difficulties.
3. Tank capacities are to be decided in consideration of the number and kinds of installed EGCS as
well as the maximum number of days between ports where residue can be discharged ashore.
14. SODIUM HYDROXIDE TANK
Where sodium hydroxide solution is stored in integral tanks, the following are to be considered during
the design and construction:
1. These tanks may be designed and constructed as integral part of the hull, (e.g. double bottom,
wing tanks).
2. These tanks are to be coated with appropriate anti-corrosion coating.
3. These tanks are to be designed and constructed as per the structural requirements applicable
to hull and primary support members for deep tank construction after taking into account the
specific gravity of sodium hydroxide solution.
4. These tanks are to be fitted with but not limited to level gauge, temperature gauge, high
temperature alarm, high- and low-level alarm, etc.
5. These tanks are to be segregated by cofferdams, void spaces, pump rooms, empty tanks or
other similar spaces so as to not be located adjacent to accommodation, service or machinery
spaces, cargo spaces containing cargoes which react with sodium hydroxide solutions in a
hazardous manner as well as any food stores, fuel oil tanks and fresh water tanks.
6. These tanks are to be included in the ship’s stability calculation. The tanks are to be so
arranged to prevent liquids containing sodium hydroxide solutions escaping or leaked from the
tanks from encountering high temperature equipment surfaces. Such tanks are especially not
to be located immediately above or near equipment such as boilers, steam pipes or exhaust
gas pipes.
7. In cases where shore connections with standard couplings are fitted onto filling-up pipe lines
proper protection against any spraying of sodium hydroxide solutions, such as effective
enclosures, is to be provided in consideration of the sodium hydroxide solution spraying out
during filling-up operations.
Piping systems for liquids containing sodium hydroxide solutions are not to pass through or to extend
into accommodation, service spaces, or control stations.
Piping systems for liquids containing sodium hydroxide solutions are not to pass through or to extend
into any storage tanks for other liquids, except where deemed appropriate by Class.
Piping systems for liquids containing sodium hydroxide solutions, excluding those near nozzles
spraying washwater, are to be so arranged to prevent any outflows or leakage from the piping system
from encountering any high temperature equipment surfaces. Such piping systems are especially not
to be located immediately above or near equipment such as boilers, steam pipes or exhaust gas pipes.
Discharge pipes from storage tanks for liquids containing sodium hydroxide solutions are to be fitted
with stop valves directly on the tank.

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Piping systems for sodium hydroxide solutions which, if damaged, would allow the solution to escape
from storage tanks are to be fitted with cocks or valves directly onto the tank. Such cocks or valves
are to be capable of being closed from accessible positions even in the event of solution leakages.
In cases where sodium hydroxide solutions are stored within tanks which form part of the ship’s hull,
enclosed compartments normally entered by ship personnel which are located adjacent to such tanks
are to be provided with mechanical exhaust ventilation systems. These ventilation systems are to be
capable of giving at least 20 air changes per hour and of being operated from outside the
compartment.
15. SCRUBBER AUTOMATION AND MONITORING REQUIREMENTS
15.1 Safety Devices and Alarm Devices
EGCS is to be provided safety devices which are capable of automatically stopping exhaust gas
washwater supply pumps and sodium hydroxide solution pumps in the event of any of the following
failures:
1. Abnormal rise of the liquid level in the scrubber.
2. Abnormal increase of the pressure at scrubber chamber inlet or differential pressure across the
scrubber chamber (in cases where changeover devices for exhaust gas pipes are not fitted)
In cases where changeover devices for exhaust gas pipes are fitted, devices capable of automatically
operating changeover devices to bypass sides in the event of any of the following failures are to be
fitted.
1. Abnormal rise of the liquid level in the scrubber
2. Abnormal increase of the exhaust gas pressure at the scrubber chamber inlet or the differential
pressure across the scrubber chamber.
3. Abnormal increase of the exhaust gas temperature at the scrubber chamber outlet
Alarm devices, to be activated in the event of any of the abnormal conditions given in Table below, are
to be provided at control stations.
Alarm points for EGCS
Monitored Variables
Liquid level in scrubber chamber *1 H
Temperature of washwater supply (in cases where the washwater includes sodium
H
hydroxide solutions) *2
Liquid levels in tank for sodium hydroxide solution *3 HL
Temperature in tank for sodium hydroxide solution *4 HL
Exhaust gas pressure at scrubber chamber inlet or differential pressure across scrubber
H
chamber *5
Exhaust gas temperature at scrubber chamber outlet *6 H
Power loss of control, alarm, monitoring or safety devices O
Note: “H” and “L” mean “high” and “low”. “〇” means that abnormal condition occurred.
*1: To prevent flow of washwater into fuel oil combustion units connected to EGCS as a result of rising liquid levels in scrubber chambers due
to poor washwater drainage.
*2: To detect high washwater temperature due to any abnormal condition of heat exchangers. Alarms need not be fitted in cases where heat
exchangers are not used.
*3: To prevent overflow and unanticipated leak of sodium hydroxide solution.
*4: To store sodium hydroxide solution at an appropriate temperature to prevent substantial corrosion in the tanks due to excessively high
temperature and deposition due to low temperature. It does not depend on whether the temperature control device is installed or not.

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*5: To prevent adverse effects on fuel oil combustion units due to backflow or clogging of exhaust gas.
*6: For reasons that problems such as decreases of material strength may be caused when scrubber chamber temperature is higher than
expected in cases where washwater is not injected due to clogging of nozzles, etc.
EGCS is to be fitted with monitoring devices at control stations, and these devices are to indicate the
information listed.
1. Liquid levels in scrubber chambers.
2. Liquid levels in tanks for sodium hydroxide solutions.
3. Temperatures in tanks for sodium hydroxide solutions.
4. Exhaust gas temperatures at scrubber chamber outlets.
5. Pressures at scrubber chamber inlets or differential pressures across scrubber chambers
Level switches which activate High-High level alarms and stop washwater supply pumps are
recommended to be provided to bilge wells, etc., in spaces where washwater and sea water may be
in preparation for leakage of washwater and sea water.
Function Control Mechanism Remarks

Water flow rate &
Number of pumps or pump Necessary to reduce water flow rate at low
pressure varied by
speeds engine power
engine load
Alkalinity of water Control of dosing rate Applies to closed loop scrubber
Washwater
Control of seawater cooler Applies to closed loop scrubber
temperature
For scrubbers certified under Scheme
A, exhaust emissions monitoring is to
Monitor SO2/CO2 ratio
Monitor exhaust be undertaken on a periodic basis. For
(ppm/%) with specialized
emissions scrubbers certified under Scheme B, the
analyzers
SO2/CO2 ratio monitoring is
to be continuous.
Records at required frequency (per Schemes
A or B) scrubber usage, washwater pressure
Monitor scrubber Record key scrubber
and temperature, exhaust pressure and
operation parameters
temperature, engine load, rate of chemical
usage
Record continuously washwater discharge pH,
Record key parameters
PAH and turbidity levels. Temperature is also
and
Monitor washwater normally recorded. Nitrates levels (from NOx)
adjust them by controlling
discharge should be periodically tested and recorded.
washwater treatment prior
Levels of any additives to the washwater
to discharge
discharge should be periodically recorded.
Warning:
Under scheme A,
 if a continuous exhaust gas monitoring system is not fitted, daily spot checks of the SO2/CO2 ratio are recommended in order to
confirm the proper operation of EGCS. If a continuous exhaust gas monitoring system is fitted, only daily spot checks of the above
parameters
 would be required to verify proper operation of the EGC unit.
 If the EGCS manufacturer is unable to provide assurance that the EGC unit will satisfy the Certified Value by means of the
verification procedure shown. It is recommended that Scheme B, the continuous exhaust gas monitoring of each EGC unit, be used
to assure continuous compliance with requirements related to fuel oil sulphur content.

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 An EGC Record Book should be maintained by the ship and record maintenance, service of the unit including like-for-like
replacement. The form of this record should be submitted by the EGCS manufacturer and approved by the Flag Administration. This
EGC Record Book should be available to read in conjunction with engine-room log-books and other data as necessary. Alternatively,
this information should be recorded in the vessel’s planned maintenance record system as approved by the Flag Administration.
For Scheme B
 Exhaust gas composition in terms of SO2 (ppm) and CO2 (%) should be measured at an appropriate position downstream of the
EGC unit and such measurement should be in accordance with the requirements of emission testing specified. SO2 and CO2 should
be continuously monitored and recorded by a data recording and processing device at a rate which should not be less than 0.0035
Hz. If more than one analyser is to be used to determine the SO2/CO2 ratio, these should be tuned to have similar sampling and
measurement times and the data outputs aligned so that the SO2/CO2 ratio is fully representative of the exhaust gas composition.
 Onboard Procedures for Demonstrating Compliance with Emission Limits Section 5.5 of Chapter 5 of the IMO EGCS Guidelines
specifies that data recording systems should comply with the requirements for data recording and processing device specified in as
2.7 well as relevant requirements for onboard monitoring manuals (OMM) specified in 2.8. It also specifies that daily spot checks of
the parameters listed in 2.4.4.4 are needed to verify proper operation of the EGC unit and that the results of these checks should be
recorded in either the EGC Record Book or in the engine-room logger system.
16. PROTECTIVE EQUIPMENT
The safety and protective equipment specified is to be stored at locations outside the compartment
containing the EGCS and easily accessible in the event of any leakages of liquids containing sodium
hydroxide solutions. The safety and protective equipment is to cover all skin so that no part of the
body is unprotected. The locations at which the equipment is stored are to be clearly marked to be
easily identifiable.
 Large apron of chemical-resistant material

 Special gloves with long sleeves
 Suitable footwear
 Suitable protective equipment consisting of coveralls and tight-fitting goggles or face shields or
both
Eyewash and safety showers are to be located in the vicinity of sodium hydroxide solution filling
stations and sodium hydroxide solution supply pumps.
17. REQUIREMENTS FOR MC (NOTATION) SHIPS
For ships registered with the notation MC, remote control devices and monitoring devices of EGCS and
changeover devices of exhaust gas pipes are to be included as the “any other devices considered
necessary by Class” specified Rules for Automatic and Remote Systems. In cases where EGCS and
changeover devices of exhaust gas pipes are Control controlled fully automatically, alarm devices
indicating abnormal conditions of related devices may be accepted.
18. BACKPRESSURE
Scrubbers have an impact on the operation of engine / boiler to which they are added if they cause
excessive exhaust system backpressure. Continual compliance with IMO MARPOL Annex VI Regulation
13 requirements on NOx emissions may be affected if the engine is operated at an exhaust
backpressure outside of the approved limits detailed in the Technical File (NOx technical file).
Generally, a fan has been provided on the scrubber outlet to the exhaust pipe to lower the pressure in
the scrubber and thereby prevent excessive backpressure in the system. A fan may not normally be
required for a scrubber attached to a single engine but is more common on scrubbers connected to
multiple engines and boilers to prevent higher backpressure from one engine or boiler affecting the
other interconnected fuel burning units, either stationary or in operation.
Due to the potential impacts on engine operation through excessive backpressure and safety concerns
of exhaust backflow to idle units, the impact of the scrubber fan failure on safe operation of the fuel
burning units should be carefully considered. The scrubber manufacturer should submit complete
details related to the anticipated backpressure across the full load range of operation, and this should

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be verified as being compatible with the engine or boiler manufacturer backpressure limits to
determine that the backpressure will not create problems for the safe and continued operation of the
equipment.
There is a higher load on the aux engines.
If there's a problem with backpressure the risk of increased turbocharger wear exists.
19. ELECTRICAL SYSTEMS
Scrubber systems require electrical power and a control and monitoring system. For wet scrubbers,
the electric load is primarily for pumping the washwater.
For dry scrubbers, it is for the pneumatic systems that transport the pellets to and from the scrubber.
The electrical load for pumping can be substantial; several hundred kW for open loop scrubbers for
large engines. There are also other additional electric loads to consider such as sludge removal,
alkaline dosing, seawater cooling, induced draft fans and process control.
It is expected that the total electric load will be about 115 to 125 percent of the scrubber pump’s
electric load.
Besides electric power to the scrubber, an automation and control system must be installed. Control
panels can be local to the scrubber, but basic scrubber control should be available from the engine
control room with a tie-in for the scrubber alarms to the ship’s central alarm and monitoring system.
Warning:
The Chief Engineer must ensure the Electrician or dedicated person responsible for electrical issue
must study and familiar with electrical distribution system and if any modification made in main switch
board or feeder circuit breakers.
Limits of all the alarms must be verified for compliance and a regular checking and testing PMS to
establish.
Monitor the stock of approved test gas.
Sea load must be evaluated and arrival departure checklist to be amended as necessary basis power.
20. PIPING SYSTEMS IN ENGINE ROOM ASSOCIATED WITH SCRUBBER
Scrubbers require several piping systems to be installed, each with different material requirements.
Considerations for the key piping systems are as follows:
Seawater Supply
For open loop scrubbers, seawater is supplied to the scrubber for the scrubbing process, standard
seawater piping material can be used. Typical materials are steel pipe with polyethylene or rubber
lining, galvanized piping or glass reinforced epoxy (GRE) pipe, which must be an approved type for
use in machinery spaces. For closed loop scrubbers, seawater is used for cooling purposes and the
same pipe material requirements would apply for those pipes.
Freshwater/Seawater Supply for Closed Loop

For closed loop scrubbers that use treated freshwater for scrubbing, the piping should be of
Appropriate material suitable for the closed loop chemistry.
Scrubber Drainage Pipe

The water draining out of the scrubber is acidic and corrosive, driving the need for special piping
materials. Like inert gas scrubbers on tankers, steel pipe with polyethylene or rubber lining can be
used. Alternatively, approved GRE piping has been known to perform satisfactorily. Valves should be
rubber-lined butterfly type or of suitable stainless-steel grade. In closed loop systems, the washwater
will be considered corrosive until the point where the water is dosed with the alkaline material and the
pH is raised.

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Exhaust Pipe
Exhaust piping before the scrubber would typically match that for standard exhaust systems; however,
the exhaust gas exiting the scrubber would tend to have a high relative humidity and, therefore,
highly corrosion-resistant materials such as stainless steel would be preferable.
Sludge Pipe
The sludge generated by the scrubbing process may be acidic; therefore, the associated piping should
be of acid corrosion-resistant material.
Washwater Processing Tanks

Tanks for storing and processing the washwater (used in closed loop systems) should also be made
from corrosion resistant materials. Fiberglass or appropriate approved plastic materials have been
found to be practical in this application.
21. FLOODING
One concern with wet scrubber operations is scrubber flooding, which will occur if the washwater
drainage from the sump, either by pump or gravity drain, stops or is blocked. This will quickly cause
flooding of the scrubber and overflow of the water down the exhaust pipe and subsequent damage to
the attached engine/boiler may occur. The scrubber automation system should prevent such critical
situations, and this may be achieved with a high-water level alarm, an automatic stop of the water
supply to the scrubber and opening of the exhaust bypass (if fitted), with simultaneous appropriate
functions for maintaining the associated fuel burning systems in a safe status.
Warning:
The Chief Engineer must review the Scrubber Pipeline drawings and ensure appropriate PMS carried
out at routine intervals to monitor closely the status of deterioration especially for the section directly
carrying acidic water.
Each length of such pipe must be properly tagged and record of PMS to be maintained, which must be
verified by the vessel manager during ship’s visit.
Proper RA to be carried out basis type of pipes and internal coatings prior any hot work in such pipes.
22. VESSEL STABILITY
For existing ships, a review of the stability may need to be considered based on the additional weight
of the scrubber. Typical scrubber installation adds 250 tonnes to the ship, a lot of the weight high up
in the ship affecting stability. The actual weight is based on reserve power as many old vessels must
install additional power source to meet the power requirements.
Stability and lightship weight need to be evaluated due to the additional weight of the scrubber
system. In general, if the change in lightship displacement exceeds 2% of the lightship displacement
from the most recent approved lightship data and/or the change in lightship Longitudinal Center of
Gravity (LCG), relative to the most recent approved lightship data, exceeds 1.0% of the Length
Between Perpendiculars (LBP), a stability test may be required on the vessel and stability calculations
would need to be revised to indicate the changes.
The actual design In-Line or split type does have effect on stability as many old vessels does have
space restriction.
Warning:
 The Chief officer must calculate actual constant upon installing / retrofitting’s of scrubber. As many
a times the stability manual may not be amended due to additional weight criteria is not meeting
the IACS standard of 2%.
 The Chief Officer also must evaluate the GM by conducting a rolling period test to identify the actual
difference.
 Proper weight evaluation is important to prevent dead fright claims during draft loading.

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23. REDUNDANCY
Redundancy of the scrubber or active scrubber system components is not currently explicitly required
by the implementing regulations for sulfur emissions. However, if these systems fail while the ship is
operating in an area where low-sulfur fuel is required, the ship will no longer follow the emission
regulations. In addition, if there are failures, there could be resulting safety related issues that can be
of concern.
Regulation 3 to MARPOL Annex VI provides general exceptions and exemptions to the Annex for the
purpose of securing life at sea and any emission resulting from damage.
In the case of damage, this would exempt collision, accidental and heavy weather damage, but due
diligence in design and operation must be exercised to minimize equipment breakdowns. Accordingly,
providing redundancy in scrubber systems for components such as water supply pumps and
automation will help mitigate the impact of failure on operations and avoid emission noncompliance.
Consideration should be given to both the likelihood and consequences of the failure of an EGCS when
it is used to comply with mandatory regulation. The likelihood of failure will depend on the reliability of
the system components and the redundancy included in the system’s design.
Building in redundancy reduces the likelihood that the system will fail.
For example, designing a wet SOX scrubber with three pumps each capable of meeting 50% of the
washwater pump demand would allow the scrubber to continue to operate in the event of a single
pump failure. A complete set of new pumps with motor is an alternative. (However, if having complete
set of new spare pump then same must be replaced within one hour in case of failure)
Other areas where redundancy can be built in include the exhaust gas and wash water monitoring
systems. The consequences of an EGCS failure will depend on whether the ship can employ alternative
means to comply with the requirements.
For example, in the event of a main engine SOX scrubber failing a ship may be able to bypass the
scrubber and use compliant fuel. Enough compliant fuel will need to be stored on board if this is to be
used in the event of a scrubber failure. However, if no compliant fuel is available the ship would no
longer be able to comply with the applicable regulations.
Examples of factors which affect EGCS performance and their effects
Factor Effect
SO2 concentration in exhaust gas Increases lead to performance degradation
Fuel oil combustion unit load Affects exhaust gas flow rate
Lower flow velocity leads to increased performance by fixing
Exhaust gas velocity
washwater flow rate
Washwater pH at EGC unit inlet Alkalization leads to improved performance
Ratio of washwater flow rate to
Increases lead to improved performance
exhaust
(Because of increased contact time between exhaust gas and
gas flow rate (L/G ratio)
washwater)
EGCS size (Because of increased contact time between exhaust gas and
washwater)
Amount of additive when chemical
agents are added to improve Increases lead to improved performance
performance
Number of times exhaust gas is
cleaned

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24. EQUIPMENT TYPE APPROVAL FLOW DIAGRAM
Full type approval would encompass the design assessment, validation or type testing and
manufacturing assessments as per the IMO definition for type approval under MSC.1/Circ.1221.
Block diagram for Statutory Performance Approval.

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25. EGCS CLASSIFICATION CONCEPTS
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.
As per design criteria there are 3 types of Exhaust Gas Cleaning Scrubbers:
1. Open Loop type.

2. Close Loop type.
3. Hybrid type.
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 washwater, 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 must 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.
Engine Exhaust Gas Chemistry:

S + O2 → SO2 ~ 95% (Sulphur + Oxygen → Sulphur dioxide ~ 95%)
SO2 + ½O2 → SO3 ~ 5% (Sulphur dioxide + Half oxygen → Sulphur trioxide ~ 5%)
SOx Reactions in a Scrubber:
SO2 + H2O → H2SO3 (Sulphur dioxide + water → Sulfurous Acid)

SO3 + H2O → H2SO4 (Sulphur trioxide + water → 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:
1. the dry scrubber-type and

2. the wet scrubber-type.
The basic principles for the dry and wet scrubbing concept are described further in this section.

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26. POSTER FOR DISCHARGE CRITERIA
To be posted in the engine control room and Bridge

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27. DRY SCRUBBERS
A dry scrubber does not use water or any liquid to carry out the scrubbing process, but instead exposes
hydrated lime-treated granulates to the exhaust gas to create a chemical reaction that removes the
SOx emission compounds. Since the exhaust does not pass through water it is not cooled, therefore,
dry scrubbers can be placed before an exhaust gas economizer (EGE) or used in conjunction with SCR
units, which typically require exhaust gas temperatures above 350° C to enable the catalysts
tocoperate correctly, reducing both SOx and NOx emissions. They are commonly used on land-based
EGC installations. A schematic of a dry scrubber system is shown in Figure.
28. WET SCRUBBERS
The exhaust gas passes through a liquid medium in order to remove the SOx compounds from gas by
chemically reacting with parts of the wash liquid. Systems are identified by their operation as either
an,
 open loop or
 closed loop system.
 Hybrid systems offer both methods of scrubbing.
The most common liquids are untreated seawater and chemically treated freshwater.
In open loop operation, water is sourced, discharged from outside the vessel and passed through the
tower. The source water generally must be seawater with a high sodium chloride content.
In a closed loop scrubber, the water is generally treated freshwater except for a few closed loop
systems that use seawater.
Additives are used to react with the washwater after each pass through the scrubbing tower for water
treatment and recycling back into the scrubber in a continuous closed cycle. Additional additives and
freshwater/seawater (as designed) are added as needed to maintain effective water levels and correct
chemical composition.
Due to washwater discharge limitations set by the IMO and various regional and U.S. Federal
regulations, the pH of the washwater discharge must be measured prior to overboard discharge.
Monitoring of turbidity and PAH are also mandatory.

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While there can be substantial differences in the detailed design of EGCS and the liquid medium used
to carry out the scrubbing process, all wet scrubbers operate using the same basic chemical processes.
The objective is to dissolve the water-soluble gases contained in the exhaust gas by mixing the
exhaust gas with the scrubbing liquid using some combination of water spray or cascading liquid
system.
Some scrubbers employ a packed bed of various shapes and materials through which the water flows
downward, cascading over maze-like packing as the exhaust gas travels through the liquid, promoting
mixing of the two streams.
Other scrubbers may have a tower-like structure with spray nozzles and baffles to create a turbulent
environment and mix the streams.
In all wet scrubbers the intent is to maximize the surface area of liquid in contact with the exhaust gas
to promote SOx absorption in the liquid while not excessively restricting exhaust flow and exceeding
the exhaust backpressure limits of the engine or boiler. Once the SOx mix with the liquid, various
chemical reactions such as SO2 + H2O + ½ O2 → H2SO4 (sulfuric acid) can take place depending on the
chemistry of the liquid. In all cases, alkaline liquid must be provided to neutralize the acidic SOx-based
constituents.
In an open loop scrubber using seawater, the washwater will react with SOx to produce mainly sodium,
but also, some calcium sulfate and sulfites. When in alkaline (hard) river or estuary water, which
contains calcium-based and other salts, calcium sulfate or other sulfites may form in the washwater. As
there is always free oxygen in the exhaust, SOx will form sulfates (SO4) from the SO3 portion of the
SOx. Where the SO2 is further oxidized, the SOx gas can also produce acid sulfate. Since the natural
alkaline buffer salts are used up in the reactions, the pH of the washwater mixture in the scrubber will
be lowered.
In addition, the drop-in temperature of the exhaust gas can cause unburned hydrocarbons to condense
and the momentum effects of changes in direction will cause larger particles to fall out of the gas
stream. These combine and mix in the scrubber to form larger particles in the scrubber effluent. In
marine closed loop type scrubbers, freshwater/seawater is treated with an alkaline substance, usually
sodium hydroxide (NaOH), or caustic soda as it is more typically known, to create the desired level of
alkalinity in the washwater. Some effluent is periodically removed, and some freshwater/seawater is
added to maintain the proper chemistry, as well as to extract the sodium sulfate salt produced.
28.1 Effectiveness Of Wet Scrubbers
Since the primary goal of scrubbers is removal of SOx from the exhaust stream to achieve SOx
emission levels equivalent to ships consuming low-sulfur fuel, the effectiveness of scrubbers in SOx
removal is of great importance and the key measure of their performance.
One key element of wet scrubber performance, particularly in an open loop operation, is the need for
alkaline substances in the water. Closed loop alkalinity is directly controlled by the dosing process that
injects an alkaline material into the washwater, so the performance of the scrubber can generally be
controlled. For open loop scrubbers, the alkalinity of the washwater depends on the characteristics of
the source water that the ship is traveling through. Therefore, the effectiveness of an open loop
scrubber is significantly reduced if the vessel operates in brackish or soft freshwater with a lower pH
than normal seawater.
Some river waters are hard, meaning they contain significant amounts of alkaline substances, and can
be just as effective for scrubbing as seawater. Alkalinity of water is expressed in units of pH, and a
higher pH washwater improves the removal of SOx. Levels of pH below 7 can significantly reduce
scrubber effectiveness. However, washwater throughput volume is another parameter that impacts
scrubber effectiveness. Even when using washwater with a lower alkaline pH, a SOx removal rate to
the required levels can possibly be achieved if an enough volume of washwater is used.

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Table below lists estimates of scrubber effectiveness in the removal of harmful substances from
exhaust gases based on minimum levels of alkalinity being present in the washwater.
Scrubber Performance Factor Rate % Remark

Makes 3.5% S fuel equivalent
SOx Removal Required 97.10
to 0.1% S fuel
Expected SOx Removal Rate >96 Depends on alkalinity of the water
When using heavy fuel, particulates
Typical Particulate Removal Rate 30 - 60 emissions are higher than for 0.1% S
distillate diesel fuel
Notes:
 If burning fuel with 3.5% sulfur, the scrubber must remove 97.1% of the SOx in the exhaust to
achieve emissions like 0.1% S fuel.
 Scrubbers are expected to have removal rates in excess of 96%, so some of the scrubbers may be
able to achieve equivalence with 0.1% S fuel, but not all scrubbers will. Manufacturers should
specify the maximum sulfur content in the fuel that the scrubber can reduce to 0.1% S fuel
equivalency.
28.2 Open Loop Scrubbers
An open loop scrubber uses seawater as the medium for cleaning or scrubbing the exhaust, as shown
in Figure. Seawater is normally supplied by a dedicated pump.
CO2 dissolves in seawater forming carbonic acid, bicarbonate or carbonate ions depending on the pH.
The positive companion ion can be calcium (Ca2+) or sodium (Na+), here the sodium carbonate salt is
used as an example.
When the carbonate/bicarbonate ion reacts with an acid, CO2 is released.
 Na2CO3 + H2SO3 → Na2SO3 + H2O + CO2

(Sodium carbonate + Sulfurous Acid → Sodium Sulfite + water + carbon dioxide)
 Na2SO3 + ½O2 → Na2SO4
(Sodium Sulfate + ½ Oxygen → sodium sulphate )
 Na2CO3 + H2SO4 → Na2SO4 + H2O + CO2
(Sodium carbonate + sulfuric acid → Sodium Sulfate + water + carbon dioxide)
Each EGC system manufacturer has their own techniques for how the scrubber mixes the exhaust gas
and the water. As previously mentioned, an open loop scrubber is only effective if the source water is
alkaline. However, some river water is ‘hard’ water with significant alkalinity, in some cases higher
than seawater, so open loop scrubbers can also work effectively in some port and river areas. Note
that it is necessary to know the alkalinity of the water before this can be determined.
Therefore, the effectiveness of an open loop scrubber depends on the chemistry of the water that the
vessel is operating in. If the water is not alkaline (pH is too low), the scrubber will not meet the
required performance level and the operator will have to use low-sulfur fuel to follow the applicable
SOx emission regulations.
Open loop scrubbers have larger water flow rates than closed loop scrubbers because there is less
control over water alkalinity and more water is needed to make the scrubbing process effective when
lower alkalinity water is used.
After the basic scrubbing process takes place in the main scrubber tower, the exhaust mixture may
pass through a demister or water droplet separator to remove water particles from the gas, which
reduces the potential for steam generation as the exhaust exits to the atmosphere. This is
advantageous because, while a steam plume is harmless, it creates the appearance of exhaust smoke

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being emitted and should be avoided. Many systems incorporate or have the option to fit a re-heater
after the EGC system unit.
The water mixture generated during the scrubbing process falls to a wet sump at the bottom of the
scrubber. This water, called washwater, is removed from the scrubber sump by gravity or by a pump
after passing through a deaerator in some systems, to a hydro-cyclone or separator to remove
residuals from the washwater.
The removed residuals must be retained onboard and held in a dedicated residue tank. MARPOL Annex
VI Regulation 16, Paragraph 2.6 prohibits incineration of sludge generated from a scrubber; it must be
disposed of at suitable reception facilities ashore.
The collected residue will contain PM, ash, heavy metals, etc. removed from the exhaust gas, as well
as insoluble calcium sulfate and silt entrained in washwater drawn from estuaries, rivers or harbor
waters. Where the source of the washwater has a large amount of silt, this silt can make up the
dominant portion of the sludge volume. Sludge generated from substances like silt in the incoming
water can cause issues only with open loop scrubbers.
28.3 Closed Loop Scrubbers

In a closed loop-type scrubber, treated water is circulated through the scrubber to keep the scrubbing
process independent of the chemistry of the waters the vessel is sailing in. There is little or no water
discharged overboard from the scrubbing process, thus reducing the need for processing the
washwater to make it suitable for discharge. Sodium hydroxide as a chemical additive is typically used
in marine EGCS to control the water alkalinity, which can also be produced by electrolysis of seawater.
The closed loop scrubber internals are like those of an open loop scrubber, and the chemical processes
to remove the SOx emissions are similar. The major difference between the two systems is that rather
than going overboard, most of the circulating washwater is processed after it leaves the scrubber tower
to make it suitable for recirculation as the scrubber washwater medium. The washwater can be fresh or
salt water depending on the scrubber design. In this treatment process, the residues are removed from
the washwater, and the water is dosed with caustic soda to restore its alkalinity prior to returning to
the scrubber tower.
Manufacturers claim a closed loop scrubber requires about half or less of the washwater flow than an
open loop scrubber to achieve the same scrubbing efficiency. The reason for this is that higher levels of
alkalinity are ensured by the direct control of the pH level using the caustic soda injection process.
In fresh water scrubbers, SO2 combines with a salt and consequently does not react with the natural
bicarbonate of seawater. There is no release of CO2.

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2NaOH + SO2 → Na2SO3 + H2O
{Sodium hydroxide (Caustic Soda) +Sulfur dioxide → Sodium Sulfite + Water}
 Na2SO3 +SO2 +H2O → 2NaHSO3
(Sodium Sulfite + Sulfur dioxide + water → Sodium Hydrogen Sulfite)
 NaOH + H2SO4 → NaHSO4 + H2O
(Sodium hydroxide +sulfuric acid → Sodium Hydrogen Sulfate + water)
 2NaOH + H2SO4 → Na2SO4 + 2H2O
(Sodium hydroxide + sulfuric acid → sodium sulphate + water)
In a closed loop system, the dirty washwater exiting the scrubber goes to a process or circulating tank.
A limited quantity of washwater from the bottom of the process tank, where the residuals have
collected, is extracted using low suction. It then goes to a hydro-cyclone or separator, like an open
loop system, where the residuals are removed, or for some systems the extracted water passes
through a bleed-off treatment unit (BOTU).
During any of the processes, the cleaned bleed-off water is discharged either overboard or to a holding
tank, depending on the ship’s location and local regulations. Residual sludge removed from the
washwater goes to a residue /sludge tank for disposal ashore. Make-up water is added to the process
tank to replace the washwater lost in the particulate treatment process, bleed off and evaporation
during the scrubbing process.
A pump circulates the scrubbing water from the process tank back to the scrubber. The water passes
through a seawater cooler before re-injection into the scrubber. A dosing unit adds caustic soda back
to the scrubbing water, either in the processing tank or to the water as it leaves the tank, with the
amount varied depending on the alkalinity requirements for the water.
28.4 Hybrid Scrubber

There are advantages to open loop-type systems, such as the avoidance of purchasing and handling
caustic soda, and the avoidance of processing washwater. Closed loop system advantages include the
scrubber working with the same efficiency independently of where the vessel is operating, and there is
little or no water discharge making it best suited for coastal, port and inland waters. In order to utilize
the advantages of both systems, some manufacturers have proposed hybrid scrubbing systems. These
can be operated as an open loop system when in the open ocean and as a closed loop system when in
a sensitive sea or river area. The changeover from open to closed loop is done by changing over the
circulating pump suction from seawater to the freshwater circulating tank, and by changing the
washwater discharge from the overboard discharge to the circulating tank.

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Warning:
It is very important for any ship’s crew for the first thing to know exactly what type of scrubber is
fitted on board. Is it
 Open Loop
 Close Loop
 Hybrid Type
For Open Loop Scrubber:
 The Chief Engineer Must Check with the Master prior commencement of the voyage the local
requirements of wash water discharge. Many countries prohibit wash water discharge. A list is
available in the Annex.
 If a vessel is heading for a port where wash water discharge is prohibited. The Chief Engineer must
follow up with the second officer and obtain the territorial demarcation so he can timely plan to
change over to compliant fuel.
 The Chief Engineer must review the tentative port stay and evaluate enough compliant fuel on board
to perform the voyage.
29. EXHAUST GAS BYPASS
An exhaust gas bypass for a scrubber allows the exhaust gas to bypass the scrubber and go directly to
the atmosphere. Unless made with suitable materials able to withstand the high exhaust temperatures,
wet scrubbers are not normally recommended to be operated dry, i.e. operated with exhaust gas
passing through them without washwater flowing.
For scrubbers that are suitable for dry operation, a separate bypass may not be required. For most
scrubbers, fitting a bypass is a requirement if there is a need to be able to operate the equipment
connected to the scrubber when the scrubber is non-operational. This would apply to engines and
boilers considered as essential services for a vessel. When the scrubber is not needed, such as when
low-sulfur fuel is being used, the exhaust bypass can be used, and the scrubber shut down may
generate saving on EGC system electric power consumption.
The bypass valve, which may be a metal-to-metal seated butterfly valve, controls the direction of the
exhaust flow between the scrubber and atmosphere.
Where the valve is a two-damper design, an interlock would be required to prevent both dampers from
being closed at the same time. Exhaust bypass valves may require frequent maintenance because of
the hot gas environment and soot accumulation that occurs.

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29.1 Integrated Scrubbers with Multiple Inlets
If it is desired to connect multiple engines or boilers to one scrubber, special features are needed for
the scrubber and for the exhaust pipes leading to the scrubber. A scrubber suitable for multiple
connections are called an integrated scrubber and they are custom designed to suit the specific number
and sizes of connected engines or boilers. Each system will need to be evaluated and approved based
on its merits about interconnections and safe vessel operations. Any arrangements proposing the
interconnection of exhaust systems, along with the isolation and control system arrangements
involved, would require specific class approval.
When using an integrated scrubber, bypasses for each exhaust are required. For safety reasons,
special measures are needed to make sure that the isolation valves are positioned and sealed
properly when an engine or boiler is out of service so that exhaust will not backflow down the exhaust
pipe to the idle engine or boiler. An exhaust fan is also typically needed to keep the exhaust system
backpressure low enough and to keep the scrubber exhaust line at lower than atmospheric pressure
as a safety measure to prevent the exhaust from leaking back into the exhaust system of an idle
engine or boiler.
Warning:
 It is very important for any ship’s crew for the first thing to know exactly what type of integrated
scrubber uptake the vessel is designed with.
 It is not a compulsory requirement to connect the boiler uptake with scrubber manifold especially for
cargo vessels where uses of boiler is minimal.
 In that case the Chief Engineer must issue a standing instruction to switch over Exhaust Gas Boiler
(composite type to oil fired boiler) whenever required to comply local regulations.
 Even when vessel is at high seas and for some reason ME and or Scrubber equipment is switched off
the boiler if needed must be fired with compliant fuel.
 Proper record must be maintained in EGCS Record book for such change over.
Integrated Scrubbers with Multiple Inlets.

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30. CONTINGENCY MEASURES
MARPOL Annex VI Regulation 3.1.2 provides criteria for 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.
Under that criteria, a ship needs to follow regulation 5.6 and notify their flag Administration for
guidance as to necessary measures to be taken. In the case of SOx scrubber breakdown, switching to
compliant fuel is typically expected until scrubber repairs are completed. For the exemption to be
granted by the Flag Administration, the vessel would need to demonstrate that due diligence had been
exercised in both design and operation. In addition, national and regional guidance has also been
issued on the topic.
For example, the UK has issued Marine Guidance Note MGN 510 addressing potential non-compliance
of scrubber systems.
30.1. Under MEPC.1/Circ.883 guidelines to be followed in case of any system failure:
 As soon as possible after evidence of a malfunction (e.g. alarm is triggered), the ship should act
to identify and remedy the malfunction.
 The ship should follow the process to identify and remedy the malfunction in the Exhaust Gas
Cleaning System – Technical Manual that is approved at the time the EGCS is certified or in
other documentation provided by the EGCS manufacturer.
 An EGCS malfunction event should be included in the EGCS Record Book including the date and
time the malfunction began and, if relevant, how it was resolved, the actions taken to resolve it
and any necessary follow-up actions.
 A system malfunction that cannot be rectified is regarded as an accidental breakdown. The ship
should then change over to compliant fuel oil if the EGCS cannot be put back into a compliant
condition within one hour. If the ship does not have compliant fuel oil or enough compliant fuel
oil on board, a proposed course of action, in order to bunker compliant fuel oil or carry out
repair works, should be communicated to relevant authorities including the shipʹs
administration, for their agreement.
Warning:
 In case of equipment failure or any malfunction immediately follow the maker’s guideline for trouble
shooting and record all the information including GPS position, Time in UTC and nature of problem.
 Inform the office, Evaluate distance from nearest land and nearest port. Verify stock of low Sulphur
fuel on board and capabilities to sail till next port.
 If unable to rectify within one hour need to notify Flag state, Nearest Port state or next port state,
Maker, Agent, Charterer, Owner and Office. Class must be reported for exemption if required.
30.2 Short-term exceedances
A short-term temporary emission exceedance is an exceedance of the applicable Emissions Ratio that
may occur due to the EGCS dynamic response when there is a sudden change in the exhaust gas flow
rate to the EGCS. There may be a short period during which the measured emission values might
indicate that the applicable Emissions Ratio limit has been exceeded. This is a common behaviour of
monitoring equipment and EGCS dynamic response (due to a sudden change in exhaust gas flow rate).
A time lapse between when the sensor takes its reading and when the unit responds may trigger an
alarm from the continuous emission monitoring device even though the EGCS has not malfunctioned.
Thus, transitory periods and isolated spikes in the recorded output do not necessarily mean
exceedance of emissions and should therefore not be considered as a breach of the requirements.
The typical operating conditions that may result in a short-term temporary emission exceedance should
be specified by the EGCS manufacturer in the EGCS Technical Manual that is approved at the time the
EGCS is certified.

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30.3 Interim indication of ongoing compliance in the case of sensor failure
When running on a fuel oil with a constant sulphur content and at constant washwater engine load
ratio, all parameters monitored according to the 2015 EGCS Guidelines (MEPC.259(68)) (i.e. Emission
Ratio, washwater pH, etc.) will be in a certain interrelation, all depending on each other. If one of the
parameters changes, some other(s) will necessarily also have to change.
This interrelation also serves as an indicator of instrumentation malfunction; i.e. if a single sensor
signal starts to deviate or even does not display, the effect on the other parameters may indicate
whether the change in signal is caused by sensor failure or whether the performance of the EGCS itself
has changed. If the other parameters are continuing at the normal levels, it is an indication that there
is only an instrumentation malfunction rather than non-compliance regarding the levels allowed in the
exhaust gas and the discharge water.
 If a malfunction occurs in the instrumentation for the monitoring of Emission Ratio or discharge
water (pH, PAH, Turbidity), the ship should keep records of interim indication for demonstrating
compliance. The documentation and actions should include (but are not limited to):
 the manual or automatic recording of the data at the time of malfunction may be used to
confirm that all other relevant data as recorded for the performance of the EGCS are showing
values in line with values prior to the malfunction;
 the ship operator should record the sulphur content of the various grades of fuel oil used in the
affected fuel oil combustion units from the time when the malfunction started;
 the ship operator should log the malfunctioning of the monitoring equipment and (for Scheme
A) record all parameters that might be suitable to indicate compliant operation. This record
could serve as an alternative documentation demonstrating compliance until the malfunction is
rectified; and
 the monitoring equipment that has suffered a malfunction should be repaired or replaced as
soon as practicable.
30.4. Notifications to relevant Authorities
Any EGCS malfunction that lasts more than one hour, or repetitive malfunctions should be reported to
the flag and port Stateʹs Administration along with an explanation of the steps the ship operator is
taking to address the failure. At their discretion, the flag and port State's Administration could take
such information and other relevant circumstances into account to determine the appropriate action to
take in the case of an EGCS malfunction, including not acting.
Warning:
 For maintenance and troubleshooting in case of any failure the Chief Engineer strictly adhere with
Maker’s manual issued for the vessel.
 In case of any failure a proper Risk Assessment must be carried out prior commencement of
voyage.
 The Risk assessment must be approved by vessel manager.
31. RESPONSIBILITY
 Under TQM document ID ADM-03.08 the Chief Engineer is responsible for maintenance (PMS)
and spare inventories, recordkeeping, training and survey, certification, record book and
manuals for EGCS.
 The Chief Engineer is further responsible for timely switching over of fuel when and as
necessary to comply the MARPOL Annex VI requirements.
 For any malfunction or breakdown, the Chief Engineer is responsible for timely report to Master
so the Master can notify all parties concern as per the MEPC.1/Circ.883 guidelines.
 The Electrician is responsible for conducting all the alarm and calibration test, must report to
the CE in case of any observations or abnormalities.
 The second officer is responsible for appropriate passage planning and marking fuel switchover
zone in chart.

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ANNEX I: REGIONAL AND LOCAL REGULATIONS
1. European Union
The EU Sulfur Directive 1999/32/EC, as amended by Directives 2005/33/EC and 2009/30/EC,
mandated all ships to use fuel with a maximum sulfur content of 0.10 percent m/m when ‘at berth’
(including at anchor) in EU ports. This requirement became effective January 1, 2010. The Sulfur
Directive was further amended by Directive 2012/33/EU to align with the revised IMO regulations and
included the reduction of the sulfur limit to 0.5 percent for operation in EU waters (i.e. outside SECAs)
beginning January 1, 2020. The EU have now issued Directive (EU) 2016/802 which has codified the
original 1999 Directive and subsequent amendments into a single codified regulation.
The Sulfur Directive also permits trials of emission abatement technology for a period of 18 months or
the fitting of EGCS meeting the requirements of the IMO guidelines by providing emission reductions
equivalent to the use of low-sulfur fuels and equipped with continuous emission monitoring equipment.
As part of the efforts the ESSF has encouraged the EU Member States to publish their policy on the
discharge of wash water from EGCS units within their territorial waters.
2. United States
The U.S. has adopted MARPOL Annex VI through Title 40 of the Code of Federal Regulations (CFR) Part
1043, Control of NOx, SOx and PM Emissions from Marine Engines, which is applicable to all U.S.
flagged vessels wherever they operate plus foreign flagged vessels while operating in U.S. navigable
waters and the U.S. Exclusive Economic Zone (EEZ). The use of EGCS technology is permitted;
however, additional requirements or prohibitions by other statutes or regulations, mainly with respect
to water pollution, apply.
Canadian vessels operating only within the Great Lakes are exempt from the NOx requirements
contained in Title 40 of the CFR, as Canada established an alternative NOx control measure that is in
accordance with the Vessel Pollution and Dangerous Chemicals Regulations (SOR/2012-69) under the
Canada Shipping Act.
Environmental regulatory policy in the U.S. is developed by the EPA and, for marine applications,
policies were implemented through 40 CFR Part 94, Part 1042 and Part 1043. The EPA set emission
standards for all new compression ignition engines intended for use on a commercial marine vessel.
The regulations are set as a tiered approach to emission reductions across three categories of engines:
Category 1: under 7 liters;
Category 2: 7 to under 30 liters; and
Category 3: 30 liters and above.
Additional limits on hydrocarbons (HC), carbon monoxide (CO) and, for category 1 and 2 engines, PM
apply. The U.S. EPA has a goal to reduce PM as part of the overall objective of reducing harmful
emissions from engine exhaust. While no PM standards apply for Category 3 engines, PM emissions
must be measured for certification testing and reporting. EPA certification is required for all U.S.
flagged vessels.
The EPA requirements differ in several fundamental areas from the IMO requirements. For example,
the EPA requires an engine to remain within the certified emissions limit throughout its service life and
has identified a ‘not to exceed’ (NTE) limit requiring engine emissions to remain within defined limits
from the individual emission test cycle mode points. Additionally, the sulfur content of fuels available
for use in locomotives, ships and non-road equipment in the U.S. is determined by the EPA Non-road
Diesel Equipment Regulatory Program. This program is aimed at regulating the supply of available
fuels, with an eventual goal to reduce the sulfur level to meet an ultra-low sulfur diesel (ULSD) limit of
15 ppm (0.0015 percent), enabling the implementation of advanced emission control strategies.
Currently, the EPA diesel fuel program restricts the production and sale of 1,000 ppm (0.1 percent)
sulfur marine fuel oil for use on vessels with Category 3 engines. The EPA emissions requirements are
complex, a complete explanation of its applicability is outside the scope of this Advisory, but it is

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important to highlight the difficulties faced by engine builders and shipowners when designing and
operating engines that may need to meet a number of international and/or regional emissions
regulations.
Vessels must comply with all Federal and State regulations; individual U.S. States have set additional
air emission limits. California’s Fuel Sulfur and Other Operation Requirements for Ocean-Going Vessels
within California Waters and 24 Nautical Miles of the California Baseline (or, the Ocean Going Vessel
(OGV) Fuel Regulation) has been enforced since July 2009 and was designed to provide significant air
quality benefits by requiring ships to use cleaner, low-sulfur marine distillate fuel in ship main engines,
auxiliary engines and auxiliary boilers. The OGV Fuel Regulation does not apply to propulsion boilers.
Amendments were made to align California’s OGV Fuel Regulation requirements with the North
American ECA, including the addition of the 1.0 percent sulfur limit effective August 1, 2012. The
original regulation required the use of 0.1 percent sulfur distillate fuel, beginning January 1, 2012, but
was amended on June 23, 2011, extending the effective date for Phase II by two years, to January 1,
2014.
The CARB regulations do not specifically allow the use of any fuel other than low-sulfur distillate fuel
for compliance. However, CARB has permitted the use of ECA compliant non-distillate, low-sulfur fuel
or equivalent alternative emission control technologies under a ‘Research Exemption’, which is
applicable during the sunset review period. This is the period during which CARB staff will evaluate the
emission reductions achieved by the ECA Regulations and compare them to the emission reductions
achieved by the California OGV Fuel Regulation. In all cases, the vessel owners/operators must notify
the CARB authority to agree to the ‘Research Exemption’. The notification is to be sent prior to the first
entry into regulated California waters.
2.a. U.S. Environmental Protection Agency (U.S. EPA)
The EPA’s Vessel General Permit (VGP) 2013 regulations cover scrubber washwater discharge limits,
which have some variations compared to the IMO guidelines. Differences include the pH of the
washwater discharged from the scrubbing process to be no less than 6.0 measured at the ship’s
overboard discharge and no other methodology of pH determination would be acceptable. This
requirement would be applicable within 3 nm of U.S. shores. For more detailed and specific
requirements, including reporting procedures, reference may be made to the specific sections of the
VGP 2013, such as 2.2.26 Exhaust Gas Scrubber Washwater Discharge and other associated sections.
Beyond the 3 nm range, the U.S. Coast Guard may consider on a case-by-case basis the alternate
calculation-based methodology and/or computational fluid dynamics or other established empirical
formulae for verification of washwater discharge criteria for the pH of exhaust gas cleaning systems,
which is in accordance with Section 10.1.2.1.2 of the 2015 Guidelines.
In the U.S., the VGP 2013 Part 6 identifies additional requirements for specific states and tribes for
their Clean Water Act (CWA) § 401 certifications for exhaust gas scrubber washwater discharge. An
example of these additional requirements is those mandated by the states of Connecticut and Hawaii.
Due to different possible requirements mandated by different states in the U.S. and other countries,
due consideration is to be given to the installation of a hybrid scrubber system for vessels unless the
owner/operator can be certain that the intended area of operation will not be subject to prohibition
from washwater discharge at the present time or in the future.
3. Hong Kong Special Administrative Region of the PRC
As of July 1, 2015, the Air Pollution Control (Ocean Going Vessels) (Fuel at Berth) Regulation,
mandatorily requires ocean-going vessels to use compliant fuels while berthing in Hong Kong.
Compliant fuels, defined by the regulation, are marine fuels with a sulfur content of ≤0.5 percent,
liquefied natural gas and any other fuels approved by the air pollution control authority.
The new Regulation requires vessels to:

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 Switch to compliant fuel within one hour of arriving at their berth and burn compliant fuel until
one hour prior to departure
 Record dates and times of vessel’s arrival, departure and of commencement and completion of
fuel change-over operations as soon as practicable after each occurrence
 Keep records onboard the vessel for a period of at least three years, readily available for
inspection at all reasonable times
Approved technologies such as SOx scrubbers may be used subject to their capability of achieving a
reduction of sulfur dioxide, which could be considered at least as effective as the use of low-sulfur
marine fuel. Ocean going vessels installed with such approved technologies may be exempt from
switching to one of the compliant fuels. Written applications for exemptions on the basis of the use of
approved technologies must be made to the authorities at least 14 days before the date on which the
vessel intends to make its first exempted call at Hong Kong.
Additional information may be obtained from “Air Pollution Control (Ocean Going Vessels) (Fuel at
Berth) Regulation” Chapter 311AA, gazette Number E.R. 2 of 2015.
4. China MSA:
Issued on 23 October 2019
According to “Atmospheric Pollution Prevention and Control Law of the People Republic of China”
Regulation on the prevention and control vessels-inducted pollution to the Marine Environment” etc
relevant laws and regulations, International Convention for the prevention of the pollution from ships,
concluded by the People Republic of China and requirements of Implementation scheme of the
domestic Emission Control areas for atmospheric pollution from vessels, China MSA formulates
implementation scheme of 2020 Global Marine Fuel Oil Sulphur Cap.
The specific requirement of the scheme applicable to foreign ships mainly includes the following
contents:
4.1. Requirements for using and carrying of fuel oil as well as alternative measures.
Here is the summary of the requirements for using and carrying of fuel oil as well as alternative
measures while ship enters Chinese waters in below table:

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4.2. Supervision and control
Local maritime authorization should conduct site inspection to international ship in accordance with
their internal site supervision and management guide.
Moreover, local maritime authorization could carry out supervision and inspection through sampling &
testing of marine fuel oil, for determining whether the sulphur content of marine fuel oil exceeds the
standard according to IMO’s “Early Application of the Verification Procedures for a MARPOL Annex VI
Fuel Oil Sample” (MEPC.1/Circ.882) and subsequently effective provisions of amendment to Annex VI
of MARPOL.
As for the ship which is in breach of the regulation, maritime authorization should give corresponding
treatment in conformity with “Atmospheric Pollution Prevention and Control Law of the People’s
Republic of China” etc. relevant laws & regulations and requirements mentioned in the Scheme.
Local maritime authorization will verify the completeness and truthfulness of the submitted FONAR and
then give corresponding treatment in conformity with requirements mentioned in the Scheme.
Maritime authorization mainly conducts enforcement and punishment basing on the stipulation in
Article 63 & 103 of “Atmospheric Pollution Prevention and Control Law of the People’s Republic of
China” as follows:
Article 63 Vessels with direct access to inland rivers and river-seas shall use regular diesel that meets
the prescribed standards. Ocean-going vessels shall use marine fuels that meet the atmospheric
pollutant control requirements after reaching a port. New docks shall plan, design, and build shore-
based power supply facilities, and existing docks shall gradually renovate their shore-based power
supply facilities. Vessels shall give priority to shore power in use of power.
Article 106 Where a violator of this Law uses marine fuels that fail to meet the prescribed standards
or requirements, the marine safety administration or fishery administrative department shall, according
to its duties, impose a fine of not less than CNY 10,000 but not more than CNY 100,000.
No official benchmark for the discretionary determination of penalty against violation of Article 106 is
issued so far, but Maritime authorization will take account of following facts (including but not limit to)
when deciding the amount of fine:
a. GT of the ship
b. Size of out of sulphur cap
c. Frequency of exceeding the standard.
4.3 Recommendation
We would like to give our recommendations as follows:
a. Ship should meet the requirements mentioned in “Implementation Scheme of 2020 Global Marine
Fuel Oil Sulphur Cap” when entering Chinese waters in line with the required timeline.
b. Optimize route for bunkering at large port to ascertain the quality of fuel oil.
c. Before entering port, ensure that all documents related to MARPOL Annex VI are complete and
up-to-date.
d. Make preparation for cleaning tank & spare tank in advance.
e. Keep all documents supporting the alternative measures adopted by ships meet with the
equivalent requirements set out in Article 4 of MARPOL Annex VI on board.
Note:
 Fuel oil in this scheme refers to oil that is delivered to the ship to combust for propulsion or
operation, including both distillate fuel oil and residual fuel oil.
 The Domestic Emission control areas for Atmospheric Pollution from vessels (herein referred to
DECAs) include both the coastal control area and the inland river control area.

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5. Malaysia has joined the list of countries banning the discharge of scrubber wash water.
Vessels fitted with scrubbers that call at Malaysian ports must change over to compliant fuel or operate
in closed-loop mode before entering Malaysian waters (12 nautical miles from land).
For further details please refer the circular under MSN 07/2019 issued by port authority.
6. The Panama Canal has been added to the list of ports and regions where the use of open loop
scrubbers is prohibited.
NT NOTICE TO SHIPPING No. N-1-2019 “Vessel Requirements”, Section 31 b. (7) states:
“Vessels are not required to changeover to light fuel on their propulsion engines if equipped with a type
approved closed-loop exhaust gas cleaning system (scrubbers) kept in operation, during the entire

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transit. The date and time of the period of operation of this equipment shall be recorded in the engine
room logbook. “
Additionally, Section 28 (5) of the same document states:
“Residues from the Exhaust Gas Cleaning System (EGCS) wash water are to be collected on board.
Discharging these residues into the water bodies under the responsibility of the Panama Canal or
incinerating them on board is not permitted.”
7. Singapore's Maritime Port Authority (MPA) said on Friday (Nov 30) that it is banning with effect
from Jan 1, 2020, the discharge of "wash water" used in ships to scrub engine exhaust.
The ban on so-called open-loop scrubbers in Singapore, home to the world's top ship refuelling or
bunkering hub, is a potential setback to shippers that have invested millions in the exhaust gas
cleaning systems.
The move is to help prepare one of the world's busiest ports for new International Maritime
Organisation (IMO) rules that come into force in 2020 and oblige ships to use cleaner fuels.
"To protect the marine environment and ensure that the port waters are clean, the discharge of wash
water from open-loop exhaust gas scrubbers in Singapore port waters will be prohibited," said Andrew
Tan, Chief Executive Officer of the MPA during an event in Singapore.
"Ships fitted with hybrid scrubbers will be required to switch to the closed-loop mode of operation," Mr
Tan said, adding that Singapore will be providing facilities for the collection of residues generated from
the operation of scrubbers.
To comply with the new rules, shippers can switch to burning costlier but cleaner fuels like marine
gasoil or low-sulphur fuel oil, shift to alternative fuels like liquefied natural gas, or invest in exhaust
gas cleaning systems, known as scrubbers.
Open-loop scrubbers use seawater as a scrubbing liquid and the waste stream is treated before being
discharged back into the sea. In closed-loop systems, scrubbing is performed using water treated with
additives and the liquid is recycled back into the scrubber. Hybrid scrubbers are a combination of both.
Note:
 Please refer the annex for the latest update of list of countries / ports prohibits discharge of exhaust
gas cleaning scrubber wash water.

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ANNEX II: LIST OF COUNTRIES AND PORT PROHIBITS WASH WATER
DISCHARGE FROM EXHAUST GAS CLEANING SCRUBBERS OPEN LOOP
SYSTEM:
WASH WATER
COUNTRY PORT DISCHARGE COMMENTS CIRCULAR
ALLOWED?
Sulphur Directive
EU Directives Allows Wash
(SD)1999/32/EC; Water
Water Discharge However
Other Than Framework Directive (WFD)
EU YES Local Port Authority Has
Listed 2000/60/EC & EU Directive
Developed Independent
2016/802/EC (all in add. to
Requirements
IMO)
Belgian federal law states
discharge only allowed in
coastal and open
seawaters when at least 3
nm off coast.
Wet van 26 maart 1971 op
Discharges must not de bescherming van de
Belgium All No imperil EU Water oppervlaktewateren tegen
Framework Directive verontreiniging (Vlaams
objectives. Gewest), as amended
Flemish regional law also
confirms discharge not
allowed in ports or inland
waters.
Discharge of wash water Discharge is not allowed in
effluent prohibited in inland waterways and the
Germany All No inland waters, rivers, Rhine, pursuant to Articles 1
certain ports as well as and 3 of the CDNI
Kiel Cana Convention
No Discharge of wash water

effluent "should" be General authority position for
Latvia All Conflicting prohibited in territorial now
advice waters and ports
Port Rules and Conditions of
Discharge of wash water
Use approved by the Ministry
Lithuania All No effluent prohibited in port
of Transport and
water area
Communication
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
Norwegian
Norway No scrubbers is prohibited in
fjords
the Norwegian fjords. Also,
for ships using closed or
hybrid type scrubbers, a
device for reducing visible
emissions to air is
required.

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Refer to Port of Dublin’s
NOTICE TO MARINERS No.
Ireland Dublin No 37 of 2018 Prohibition on No. 37 of 2018
the Discharge of Exhaust
Gas Scrubber Wash Water
As per Port of Waterford’s
marine notice ‘Prohibition
on the Discharge of
Exhaust Gas Scrubber
Waterford No Wash Water’, discharge of
scrubber washwater is
prohibited in port limits
from the start of January
2019.
Port notice No. 15 of 2018
states that given the
potential for impact on
sensitive ecosystems, and
the abundance of Natura
Cork No Marine Notice 15 of 2018
2000 sites within the
jurisdiction of the port
company, discharge of
scrubber washwater is
prohibited in port waters.
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
The Californian ARB OGV
as well as any discharge of
regulations stipulate only
washwater is prohibited.
distillate fuels can be used
Californian Vessel discharge regulations
United to comply with the 0.1%
Ports and No for Port of Long Beach also
States sulphur limit Changeover
Waters state that it is prohibited to
to compliant distillate fuel
discharge washwater from
(MGO or MDO) prior to
scrubbers in port waters.
entering Californian waters
However, pursuant to CARB’s
Marine Notice 2017-1
discharge is permitted if the
vessel has an experimental
or temporary research
permit.
Discharge of exhaust gas Connecticut has laid down
scrubber washwater into specific conditions as part of
Connecticut waters from the 2013 Vessel General
any vessel is prohibited Permit (VGP) requirements.
Connecticut In accordance with section
United VGP 2013: 6.5.9 Discharge
Ports and Regulated 6.5.9[UK1] of the 2013 VGP,
States of exhaust gas scrubber
Waters discharge of exhaust gas
washwater into
scrubber washwater into
Connecticut waters from
Connecticut waters from any
any vessel covered under
vessel covered under the VGP
the VGP or sVGP is
is prohibited. Please see CGS
prohibited.
section 22a-427, and

Page 53 of 68

This condition is necessary Connecticut Water Quality
for compliance with CGS Standards (CT WQS).
section 22a-427,
Standards No.1, 2, 9, 12,
14, 15, and 24 of the CT
WQS.
Additional requirements
under VGP 2013 Section
6.6.
The State of Hawaii (Clean
Water Branch) issued
‘Blanket Section 401’
Water Quality Criteria
(WQC). This covers 27
United Hawaii Ports Yes – categories of effluent
States and Waters conditional discharge from an
applicable vessel (EGCS
washwater being one) that
have received the best
control or treatment into
waters of the State of
Hawaii incidental to the
normal operation of the
applicable vessels
Use of open loop scrubbers
is not permitted.
Environmental Policy for
Ships states: “Washwater
and residue from the EGCS
shall be not disposed of in
Bermuda or discharged
into Bermuda’s waters but
United
Bermuda No shall be stored on board
States
the ship until outside of
Bermuda’s waters”. If a
vessel has to use closed
loop scrubber in territorial
waters of Bermuda,
permission needs to be
sought from the
authorities.
Notice to Shipping No. 01
of 2019 states that
discharging EGCS
washwater into bodies of
Notice to Shipping No. 01 of
Panama All No water under the
2019
responsibility of Panama
Canal is not permitted. Use
of closed loop systems is
permitted.
Abu Dhabi Ports Company
United Policy: Sludge generated
Abu Dhabi Yes – Port Rules (Issue 2.2) – May
Arab from exhaust gas scrubber
Ports conditional 2019
Emirates washwater discharge must
not be discharged into port

Page 54 of 68

waters. Exhaust gas
scrubber washwater
discharge may only be
discharged in port waters if
free from pollutants. Any
exhaust gas scrubber
sludge should be
discharged from a vessel
to an ADPC licensed waste
disposal contractor
As per notice to mariners

no. 252, Harbour Master of
Fujairah has announced
Fujairah No that use of open loop
scrubbers will be banned in
port waters. The circular
can be found here.
Ban on the use of open
loop scrubbers expected to
Singapore All No
take effect on 1 January
2020
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 washwater 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
Ban on discharge at states that a ban in the entire
China All No
Coastal waters coastal domestic ECA will be
announced in due course.
Our local correspondent,
Huatai, has published a
useful circular on China’s ban
on scrubber washwater
discharge, which can be
accessed here. China MOT
recently circulated a draft
recommending that the ban
on the discharge of
washwater be extended to
within 12nm of all coastal
areas and regions near the
southern island province of
Hainan.

Page 55 of 68

EPA 2015/0695
Australia All Yes (cruiseships have special
reg.)
In DG Engineering Circular
02 of 2019, India appear
to indicate that scrubber
washwater discharges are
allowed if the criteria set
out in MEPC.259(68) are
met. However, this is DG Engineering Circular 02 of
India All Regulated
qualified with a 2019
requirement that local
regulations should also be
followed. As of now, it is
not clear if local
restrictions will be imposed
in some areas
At the Low Sulphur Bunker
Fuels seminar held in
Kuala Lampur on 29
Malaysia All No August 2019, Malaysia MSN 07/2019
announced that it has
introduce a ban on open
loop scrubbers.
Above information may change without notice. Advice all users to contact the local agent for the specific port you are calling to obtain the latest
guidelines.
All local notification must be maintained along with this annex for record keeping and referred to during passage planning.

Page 56 of 68

ANNEX III: WE ARE CURRENTLY AWARE OF THE FOLLOWING REGIONS/STATES/PORTS WITH LOCAL
REGULATIONS THAT HAVE AN EFFECT ON THE DISCHARGE OF EXHAUST GAS SCRUBBER WASHWATER, ALTHOUGH
THE LIST SHOULD NOT BE CONSIDERED AS COMPLETE. (Poster)

Page 57 of 68

ANNEX IV: FREQUENTLY ASKED QUESTIONS
Q. Doesn’t an EGCS merely move the pollution from the air into the sea?
A. This is a common misconception – scrubber wash water removes and converts sulphur oxides from
the exhaust gases, so they are discharged in the wash water as harmless sulphate. After sodium and
chloride, sulphate is the most common ion in seawater. Even if all the sulphur in all of the world’s
petroleum reserves were to be scrubbed, the increase in ocean sulphate would be infinitesimally small.
Scrubber wash water discharges are also continuously monitored and subject to strict discharge limits.
Various studies have concluded that any reduction in pH from scrubbing, will be insignificant when
compared with that resulting from increasing atmospheric CO2 absorbed by the oceans.
Q. What about the numerous anecdotes about EGCS being unreliable and requiring a lot of
maintenance?
A. This may have been the case some years ago before exhaust gas cleaning became widespread.
However, scrubbing is an established technology. There have been some reports of pipe failures due to
using incorrect materials or incorrect coatings. The key to successful EGCS is extremely professional
project management and high-quality installation teams. EGCS are designed for the life of the ship.
Q. Can we expect laws – international, regional or domestic – that will eventually control or ban the
discharge of EGCS effluent (particularly in confined waters and ports)?
A. IMO already requires that the wash water parameters of pH, polycyclic aromatic hydrocarbons
(PAH) and turbidity are continuously monitored, and the results logged against time and ship’s
position.
There are a few ports that have prohibited the use of open loop scrubbers in their water’s basis local
ecological requirements.
Q. If using closed-loop and hybrid scrubber systems, what happens with the chemical waste? Is it
disposed in an environmentally sound manner?
A. The scrubber guidelines require that waste generated by closed loop EGCS is delivered to shoreside
reception facilities. It cannot be discharged to the sea or incinerated onboard.
Q. If the EGCS malfunctions in service, is the vessel in breach of MARPOL Annex VI?
A. The key advice that EGCSA has received is that ship operators should be open and advise flag and
coastal / port state without delay of the issue and remedial action that is being taken. In the event of a
problem preventing system operation, the ship would not be considered as being in immediate breach
of the regulations because non-compliance would be unintentional and the provisions of regulation
3.1.2 of MARPOL Annex VI would apply.
If EGCS operation is not possible, the ship is advised to change over to compliant fuel. However, if
there is no compliant fuel on board, the ship should be allowed to complete the current leg of its
voyage without deviation and then carry out repair works or bunker compliant fuel.
Q. When transiting an ECA, what would be required of a vessel if a failure occurs on its installed
scrubber system?
A. 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.
Class has determined that miscellaneous equipment such as the scrubber washwater pumps and/or
other rotating, reciprocating components, together with the power supply to these components
essential for the operation of the scrubber, are to be provided with redundancy arrangements.
Therefore, continuous operation of the fuel combustion units and scrubber systems is achievable to

Page 58 of 68

maintain the vessel’s propulsion and maneuvering capability, together with continual compliance with
MARPOL Annex VI Regulation 14.
Q. Are scrubber systems acceptable for use in the state of California in lieu of low-sulfur fuel?
A. California Air Resources Board (CARB) does not currently accept SOx scrubbers as an alternative
means for using low-sulfur 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).
Q. How will Port State Control verify the cleaning rate of the scrubbers?
A. Guidelines for PSC associated with MARPOL Annex VI are described in IMO Res. MEPC.181 (59),
where it is stated that the PSC officer should 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 should 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.
Q. Which monitoring devices are needed for an EGCS and what is the marine service experience
of these devices?
A. 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 washwater is required to be continuously monitored for pH, PAH and turbidity.
The pH electrode and pH meter should have a resolution of 0.1 pH units and temperature
compensation. The electrode should comply with the requirements defined in BS 2586 or of equivalent
or better performance, and the meter should meet or exceed BS EN ISO 60746-2:2003.
The PAH monitoring equipment should be capable of monitoring PAH in water in a range to at least
twice the applicable discharge concentration limit. The equipment should be demonstrated to operate
Page 59 of 68

correctly and not deviate more than 5 percent in washwater with turbidity within the working range of
the application. The turbidity monitoring equipment should meet requirements defined in ISO
7027:1999 or USEPA 180.1.
Q. Are there any requirements on particulate matter (PM) monitoring by the IMO, U.S. EPA or other
such organizations?
A. 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.
Q. What are the IMO and regional regulations governing discharge water?
A. Washwater criteria limits for pH, PAH, turbidity/suspended PM and nitrates are defined in 10.1 of
Resolution MEPC.259(68). The U.S. EPA washwater discharge limits are consistent with the IMO
requirements in the VGP for 2013. However, the EPA has added some additional requirements for
washwater 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.
Q. Please elaborate on the washwater discharge criteria in the final 2013 VGP.
A. 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.
Q. Will the scrubber function as designed at all loads?
Page 60 of 68
A. 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.
Q. Are there any particular sludge disposal restrictions in place? Can the sludge produced be
incinerated on board?
A. 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.
Q. Redundancy Except where low sulphur fuel oil can be used in case of failure of the scrubber,
redundancy must be provided. Is a risk analysis of failure required?
A. There is no straight requirement for redundancy of scrubbers as this is not a matter of safety,
however, it is required that the scrubber will have full efficiency within SECA/ECA areas on the
full load range, otherwise an alternative way of fulfilling SOx requirement must be made
available onboard. Check also local regulation such as CARB about the acceptance of scrubber
as an alternative to low Sulphur fuels.
Q. NaOH What is the impact on safety from using caustic soda onboard?
A. Reference Safety Data Sheet is giving the basic requirement for handling NaOH with care. The
storage must be carefully addressed, as NaOH is extremely corrosive, so specific appropriate coating
shall be considered for the storage capacity.
Q. Documentation Concerning type approval or approval under Scheme B, what shall be provided?
A. Type-approved scrubbers require a specific system technical manual which must meet the
requirements and be carried on board. Scheme B scrubbers do not require type approval; instead the
monitoring equipment fitted must be approved by the administration. There must be a scrubber record
book or logging system, a record of daily checks on the monitoring system and each system also
requires a technical manual in a specific format. An On-Board Monitoring Manual is also required for
each scrubber and each ship must have an approved SOx Emissions Compliance Plan (SECP).
Q. How does a scrubber reduce sulfur oxide (SOx) emissions?
A. A scrubber sprays alkaline water into the vessel’s exhaust, which removes SOx from the ship’s
engine and boiler exhaust gases. In a seawater system the sea’s natural alkalinity largely neutralizes
the results of SO2 removal before discharge back to the sea. In a fresh water system, the wash-water
used for scrubbing and neutralization is treated with an alkaline chemical such as sodium hydroxide. In
both cases the sulfates resulting from the SO2 removal will be discharged with the wash-water to the
sea.
Q. Will the use of scrubbers increase the speed of the vessels and subsequently CO2 emissions?
A. No, there is no link between scrubbers and vessel speed. All practical methods which reduce CO2
emissions are welcome, and the option of slow steaming is one way of reducing fuel usage and CO2
emissions that is always available. Scrubbers do not interfere with this in any way.

Page 61 of 68

ANNEX V: ALKALINITY LEVELS TABLE
The tables show alkalinity levels in various areas and ports. The alkalinity of open sea areas is
relatively constant whilst more variable in ports. In order to provide some indication of the exhaust
cleaning capability of these waters, three examples are considered:
 The alkalinity of Dover is 1100 to 1300 μmol / l compared with 2800 to 3100 for Calais however
Wärtsilä-Hamworthy has successfully used the Pride of Kent, a large Ro-Ro ferry operating between
these ports, as a long-term trial platform for an open Exhaust Gas Cleaning System using seawater
with SO2 removal rates unaffected.
 Helsinki has a similar alkalinity to Dover; however, St Petersburg on the River Neva to the east has
a significantly lower alkalinity, which is likely to impact sulphur oxide removal efficiency. Under
these conditions chemical addition could be used.
 Ports fed by rivers such as Rotterdam, Antwerp and New Orleans have alkalinities like or higher than
that of the open ocean.
AREAS PORTS
Alkalinity (μmol/l) Alkalinity (μmol/l)
LOCATION MIN PORT MIN MAX RIVER
North Sea 2200 Amsterdam 2200
Norwegian Sea 2300 Antwerpen 2200 4500 Scheldt
North Atlantic Ocean 2300 Bilbao 2200
South Atlantic Ocean 2300 Bordeaux 2300 2400 Gironde
Mediterranean Sea 2400 Calais 2800 3100
Black Sea 2500 Dover 1100 1300
Gulf of Mexico 2250 El Ferrol 2280
Caribbean Sea 2250 Hamburg 2050 2400 Elbe
Panama 1800 Hanko 1600
Panama Canal 1000 Helsinki 1250 1500
Gulf of Alaska 2000 Hull 1350 Humber
North Pacific Ocean 2100 Kotka 900 1000 Kymijoki
South Pacific Ocean 2200 Miami 2300
Red Sea 2400 New Orleans 2400 3000 Mississippi
Persian Gulf 2500 Oslo 1350
Arabian Sea 2300 Rotterdam 2200 2700 Rhine
Bay of Bengal 2300 St Petersburg 490 Neva
Indian Ocean 2200 Travemünde 1800
Gulf of Thailand 2000
South China Sea 2000
Philippine Sea 2100
Coral Sea 2150
Tasman Sea 2300
Gulf of California 2150

Page 62 of 68

APPENDIX I: SHIP SPECIFIC INFORMATION TABLE
SL.NO SUBJECT INFORMATION
1 EGCS Manufacturer
2 EGCS Model
3 EGCS Type
4 EGCS Serial number
5 Approval Under Scheme A or B
Operating Limits or Operating value
6
ranges.
7 Exhaust uptake list.
Number & Power of ME (KW) / 2 or 4
8
Stroke
Number & Power of AE (KW) / 2 or 4
9
Stroke
Numbers of boilers, the maximum air/fuel
10
ratio at 100% load.
Maximum & Minimum wash water flow
11
rate.
12 Wash Water inlet pressure.
minimum inlet water alkalinity of
13
washwater.
14 Exhaust Gas inlet temperature range.
Maximum & Minimum exhaust gas out let
15
temperature range.
Exhaust gas differential pressure range
and the maximum exhaust gas inlet
16 pressure when the fuel oil combustion unit
is operating at MCR or an 80% power
rating.
Corrective actions to be taken in cases
where the applicable maximum allowable
17
SO2/CO2 ratio or the washwater discharge
criteria are exceeded.
The maximum and minimum exhaust gas
18
mass flow rate of the unit.
Any requirements or restrictions
19
applicable to the EGC unit.
EGC units fitted to main propulsion diesel
engines should meet the requirements of
paragraph 4.3.1 at all loads between 25 to
20
100% of the load range of the engines to
which they are fitted. Indicate the
value.
21 EGC units fitted to auxiliary diesel engines

should meet the requirements of
Page 63 of 68

paragraph 4.3.1 at all loads between 10 to
100% of the load range of the engines to
which they are fitted.
EGC units fitted to boilers should meet the
requirements of paragraph 4.3.1 at all
loads between 10 to 100% of the load
22 range (steaming rates) or, if the turn
down ratio is smaller, over the actual load
range of the boilers to which they are
fitted.
In those cases where the fuel oil
combustion equipment may be required to
operate under idling conditions, the SO2
23 emission concentration (ppm) at
standardized O2 concentration (15.0%
diesel engines, 3.0% boilers) should not
exceed 50 ppm
Data should be retained for a period of not
less than 18 months from the date of
recording. If the unit is changed over that
24
period, the shipowner should ensure that
the required data is retained on board and
available as required. (MEPC.259(68) 7.4
25 Total MGO (S >0.1%) holding capacity
Class Approved independent MGO pipeline
26
plan Number and date of Issue

Page 64 of 68

APPENDIX II: SHIP BOARD DOCUMENT CONFIRMATION LIST.
Sl No ITEM UNDER REGULATION YES NO

1 SOX Emissions Compliance Plan (SECP). MEPC.259(68) 2.1.3 ☐ ☐
Applicable for Scheme A Only MEPC
2 SOX Emissions Compliance Certificate (SECC) ☐ ☐
259(68) 4.2.1.3
Applicable for Scheme A Only. MEPC
3 ETM Scheme A (EGC Technical Manual) ☐ ☐
259(68) 4.2.2.1 (Survey item)
Applicable for Scheme B Only.
4 ETM Scheme B (EGC Technical Manual) ☐ ☐
MEPC.259(68) 5.6.1
5 Onboard Monitoring Manual (OMM) MEPC.259(68) section 8 ☐ ☐
EGC Record Book or Electronic Logging
6 MEPC 259(68) Section 4.4.10 ☐ ☐
System
Following the installation survey as
required by paragraph 4.2.3.1, section 2.6
7 of the Supplement to the ship's MEPC.259(68) section 4.2.3.4 ☐ ☐
International Air Pollution Certificate
should be duly completed
8 IAPP Certificate (Supplement) ☐ ☐
Product Quality Assurance Certificates
9 ☐ ☐
(PQA) for all component
Certificate of Final Inspection of probe and
10 ☐ ☐
calibration‐ display units
Class – Statement of Fact for low sulphur
11 ☐ ☐
fuel oil installation (0.1%)
Class – Statement of fact‐Vessel General
12 ☐ ☐
Permit (VGP) for US
13 Class approved drawings ☐ ☐
14 EGCS‐ Function test certificate by Class ☐ ☐
15 MSDS for Chemicals if in use ☐ ☐
16 Test Gas for analyzer – MSDS certificate ☐ ☐
17 Crew Training documents ☐ ☐
18 Critical Spare List ☐ ☐
☐ ☐
☒ ☐

Page 65 of 68

APPENDIX III: TRAINING CHECKLIST
Refer the chapter from
Sl No Subject Yes No
maker’s manual
Corrective actions in case of exceedances of
1 the applicable maximum allowable SO2/CO2 ☐ ☐
ratio, or wash water discharge criteria;
Guidelines from maker’s
In accordance with regulation 10 of MARPOL
manual how to demonstrate
2 Annex VI, EGC units may also be subject to ☐ ☐
measurement records and
inspection by port State control.
calibration
Guidelines from maker’s
The EGC unit should be designed in such a
3 manual how to carry out ☐ ☐
way as to facilitate inspection as required.
inspection
Guideline for record keeping
4 EGC Record Book entries ☐ ☐
criteria
Under Scheme A, if a continuous exhaust gas
monitoring system is not fitted, it is
recommended that a daily spot check of the
exhaust gas quality in terms of
Refer the maker’s manual
SO2(ppm)/CO2(%) ratio, is used to verify
and identify the process and
compliance in conjunction with parameter
5 demonstrate appropriate ☐ ☐
checks stipulated in paragraph 4.4.7. If a
record keeping if required
continuous exhaust gas monitoring system is
under Scheme A
fitted, only daily spot checks of the
parameters listed in paragraph 4.4.7 would be
needed to verify proper operation of the EGC
unit.
For Scheme-B the SO2(ppm) and CO2(%) to
Refer maker’s manual and
be continuously monitored and recorded onto
6 train the crew for proper ☐ ☐
a data recording and processing device at a
handling
rate which should not be less than 0.0035 Hz.
If more than one analyser is to be used to
determine the SO2/CO2 ratio, these should be
Notify the crew the ship
tuned to have similar sampling and
7 specific arrangement and ☐ ☐
measurement times and the data outputs
identify how to tune.
aligned so that the SO2/CO2 ratio is fully
representative of the exhaust gas composition
For Scheme B- Daily spot checks of the
parameters listed in paragraph 4.4.7 are
8 needed to verify proper operation of the EGC ☐ ☐
demonstrate exact guideline
unit and should be recorded in the EGC Record
Book or in the engine-room logger system.
Handling of data recording and processing
9 train the crew for handling ☐ ☐
device.
and record keeping
Familiarization with SOx Emissions compliance Demonstrate the crew the
10 ☐ ☐
Plan (SECP) physical manual, location
Familiarization with On board Monitoring Demonstrate the crew the
11 ☐ ☐
Manual (OMM) physical manual, location

Page 66 of 68

Maintain a list of equipment
There may be some equipment such as small
and post in Engine control
engines and boilers to which the fitting of EGC
room as well as in bridge.
units would not be practical, particularly where
such equipment is located in a position remote Ensure ship specific guideline
from the main machinery spaces. All such fuel has been issued for such
12 oil combustion units should be listed in the equipment. ☐ ☐
SECP. For these fuel oil combustion units
Proper amendments carried
which are not to be fitted with EGC units,
out in arrival-departure
compliance may be achieved by means of
checklist to ensure proper
regulations 14.1 and/or 14.4 of MARPOL
valves has been set for
Annex VI.
compliant fuels.
When the EGC system is operated in ports,
harbours, or estuaries, the washwater
monitoring and recording should be
continuous. The values monitored and
Demonstrate the location and
recorded should include pH, PAH, turbidity and
limitation of the measuring
temperature. In other areas the continuous
13 equipment and how to use ☐ ☐
monitoring and recording equipment should
the equipment and who is
also be in operation, whenever the EGC
responsible for any settings
system is in operation, except for short
periods of maintenance and cleaning of the
equipment. The discharge water should
comply with the following limits.
The nitrate discharge data and analysis
certificate are to be retained on board the ship Demonstrate the procedure
14 as part of the EGC Record Book and be and record keeping ☐ ☐
available for inspection as required by port arrangements
State control or other parties.
Requirements in respect of sampling, storage, Demonstrate maker’s manual
15 handling and analysis should be detailed in the for how to collect sample and ☐ ☐
ETM-A or ETM-B as applicable the record keeping process
Handling of EGCS sludge or washwater
residue.
10.4.2
Each ship fitted with an EGC unit should Demonstrate location of
record the storage and disposal of holding tank and the ship
specific process for shore
16 washwater residues in an EGC log, including disposal and record keeping, ☐ ☐
the date, time and location of such storage indicate the rank of
and responsible person for this
disposal. The EGC log may form a part of an task.
existing log-book or electronic recording
system
as approved by the Administration.
Discuss the process as guided
under the circular and ensure
System Malfunction- Handling and reporting all person handling the
17 equipment are aware of the ☐ ☐
procedures (MEPC.1/Circ.883)
requirements and notify the
Chief engineer in time. The
chief engineer must issue

Page 67 of 68

appropriate standing
instructions to his crew for
compliance.
Demonstrate guidelines
issued under the maker’s
manual.
Safety aspect of the equipment. Asphyxiation Only trained and qualified

18 Hazards and Electrical hazards. Thermal personnel can work on the ☐ ☐
hazards. Exhaust Gas Cleaning (EGC)
system. Inexperienced
personnel must be supervised
until they are skilled enough
to operate the system.
Demonstrate safety icons
19 Safety Icons from maker’s manual and ☐ ☐
explain the implication
Demonstrate guideline from
maker’s manual for different
20 Familiarization of different running mode ☐ ☐
running mode and when to
use such different mode.
Demonstrate how to use and
when to use. Keep a note If
the ship is sailing in a fuel
Importance of maneuvering mode and bypass sulphur regulation area using
21 ☐ ☐
mode noncompliant fuel, activating
Bypass Mode means that the
ship is no longer in
compliance
Demonstrate guideline and
process indicated in makers
Guidelines after emergency stop or manual for suitable re setting
22 ☐ ☐
uncontrolled stop arrangements after blackout
or emergency stop and
necessary record keeping.

Page 68 of 68

Exhaust Gas Cleaning Scrubber Management Plan

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Exhaust Gas Cleaning Scrubber Management Plan

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Document ID: HSE-07.

Ship Type : Bulk carrier

IMO Number : 9696046

Flag MARSHAL ISLANDS, MAJURO

Draft (Summer) 18.3 M

Call Sign V7HJ2

Year Built 2014

Shipyard SUNGDONG DOCKYARD

Number of Crew / Passengers 25

Type of Scrubber Open Loop

EXHAUST GAS CLEANING SCRUBBER

10 IMO exhaust gas cleaning system (EGCS) guidelines 12

11 Ship compliance and documentation 20

13 Residue tanks are to satisfy the following requirements 27

14 Sodium hydroxide tank 27

15 Scrubber automation and monitoring requirements 28

17 Requirements for MC (notation) ships 30

20 Piping systems in engine room associated with scrubber 31

24 Equipment type approval flow diagram 34

25 EGCS classification concepts 35

26 Poster for discharge criteria 36

29 Exhaust gas bypass 42

ANNEX I: REGIONAL AND LOCAL REGULATIONS 46

LIST OF COUNTRIES AND PORT PROHIBITS WASH WATER

ANNEX III WASHWATER DISCHARGE POSTER 57

ANNEX IV FREQUENTLY ASKED QUESTIONS 58

ANNEX V ALKALINITY LEVELS TABLE 62

SHIP SPECIFIC SECTION

APPENDIX II SHIP BOARD DOCUMENT CONFIRMATION LIST 65

APPENDIX III TRAINING CHECKLIST 66

ESSF: European Sustainable Shipping Forum.

• Use low-sulfur marine fuels in existing machinery.

10. IMO EXHAUST GAS CLEANING SYSTEM (EGCS) GUIDELINES

Among other sections, the following provisions were retained:

The two EGCS schemes apply the following concepts:

10.1.1: EGCS Technical Manual for Scheme A (ETM-A)

7. Through range performance variation in washwater characteristics.

8. Design requirements for the washwater system.

Operating limits, or range of operating values which should be included in ETM-A

Onboard verification procedures should be in accordance with following:

10.1.3: Emission Limits

Sl No Subject Limit range

2) Emission Measurement Testing:

Sl No Subject Limit range

A summary of these requirements is given below.

Onboard Procedures for Demonstrating Compliance with Emission Limits.

10.2.1: EGCS Technical Manual – Scheme B (ETM-B)

g) Other parameters as necessary concerning the operation of the EGC unit.

5. Through range performance variation in washwater characteristics.

6. Design requirements of the washwater system.

10.2.2: Emission Testing

EGCS Guidelines requirements related to exhaust gas measurements.

10.2.3: Data Recording and Processing Device

1. It should be of a robust, tamper-proof design with read-only capability.

3. It should be capable of preparing reports over specified time periods.

10.2.4: Onboard Monitoring Manual (OMM)

2. The OMM should, at a minimum, include the following:

c) The analyzers to be used, their service, maintenance, and calibration requirements.

d) Analyzer zero and span check procedures.

4. The OMM should be approved by the Flag Administration

11. SHIP COMPLIANCE AND DOCUMENTATION

3. An SECP under Scheme A should be in accordance with the following: