This scenario has encouraged me to start this investigation about the effect produced by these

residual water discharges. Specifically, we have the purpose to study and analyse the effect of
these discharges in the port of Barcelona and its surrounding waters.

2. ANALYSIS OF THE CURRENT SITUATION

At present and since 01st January 2020, we have a new sulphur cap in a truly clear regulation
about sulphur oxides emissions on board the ships. This regulation is contained in Marpol
Convention, specifically on its Annex VI, regulation 14. This regulation states that the sulphur
content of any fuel oil used or carried on board of a ship for its use shall not exceed 0.5% mass
by mass.
As we have seen before, one of the options that ship’s owners have, to be in compliance with
this new regulation, is to install on board of their ships an exhaust gas cleaning system and they
have to choose one of its modalities, open loop, closed loop or hybrid system. But here we find
one of the main current problematic.
Presently, there are several countries and certain ports which have been banned the use of open
loop exhaust gas cleaning systems in their waters. The main reason is because this system, as
we are going to see later, discharges its residual water overboard. Although this residual water,
theoretically, is not a pollutant residue at all, because certain parameters from this residual water,
must follow an IMO Resolution from Marine Environment Protection Committee. This
Resolution is MEPC.259(68), 2015 guidelines for exhaust gas cleaning systems.
The above-mentioned Resolution regulates among others, on the point 10 of its Annex, the
washwater discharge criteria. This point states that the washwater used in the gas cleaning
process of exhaust gas cleaning systems, must be continuously monitored, and recorded, when
this system is being used by ships in ports, harbours, or estuaries.
The values which must be monitored are at least pH, PAH (Polycyclic Aromatic Hydrocarbons),
turbidity/suspended particle matter, and temperature. For the parameters listed above, this
Resolution indicates the limits which must comply any washwater discharge from scrubbers.
Furthermore, Resolution MEPC.259(68) defines both schemes, A and B, for the approval,
survey and certification of an exhaust gas cleaning system.
In this section, the Resolution establishes the minimum content and all requirements for
Technical Manual for Schemes A and B.
MEPC.259(68) also determines the type and scope of inspection that each exhaust gas cleaning
system is subjected as well as the documentation set that a ship fitted with an scrubber system
must have on-board, available for its inspection, if required by authorities, for instance during
a Port State Control. This Documentation is set out in the above- mentioned Resolution and
depending on the scheme, is required as follows:

 Ships fitted with an exhaust gas cleaning system certified as per Scheme A, must have on-board:
- Sulphur Oxides Emissions Compliance Plan (SECP) approved by the Administration.
- Sulphur Oxides Emissions Compliance Certificate.
- Technical Manual for Scheme A approved by Administration.
- On-board Monitoring Manual approved by Administration.
- EGC Record Book, with a form approved by the Administration.

 Ships fitted with an exhaust gas cleaning system certified as per Scheme B, must be provided
with:
- Sulphur Oxides Emissions Compliance Plan (SECP) approved by the Administration.
- Technical Manual for Scheme B approved by Administration.
- On-board Monitoring Manual approved by Administration.
- EGC Record Book, with a form approved by the Administration.

3. EXHAUST GAS CLEANING SYSTEMS

As mentioned above, Marpol Convention on its Annex VI, regulation 14, stablishes that ships
cannot use a fuel with a sulphur concentration cap over limits prescribed on regulations 14.1
and 14.4. Regulation 4 of same Annex defines what should be understood as “equivalents”.
Equivalents concept, as per Annex VI definition, is any fitting, material, apparatus or appliance
to be installed on board of a ship as well as any alternative fuel, procedure or compliance
method used as an alternative to the required by the Annex VI of Marpol Convention, if such
fitting, material, apparatus or appliance to be installed on board of a ship as well as any
alternative fuel, procedure or compliance method are at least as effective in terms of emission
reductions, so in this case, we are talking about sulphur oxides emission reductions, as that
required by this Annex.
If we analyse the above-mentioned regulation, we can extract that the Administration of a Party
may allow to its ships the use of any of the mentioned options, to be in compliance, for instance,
with regulation 14. So, the exhaust gas cleaning systems are considered, effectively, equivalents
or an equivalent arrangement. In this way, is stated on the supplement, also known as Record
of Construction and Equipment, to International Air Pollution Prevention Certificate of a ship
fitted with an scrubber system approved by the Administration. We can check on section 2.3 of
this supplement, if ship is fitted with an equivalent arrangement approved in accordance with
regulation 4.1 an that is at least as effective in terms of sulphur oxides emission reductions as
compared to using a fuel oil with a certain sulphur content limit.
Exhaust gas cleaning systems are basically an air pollution control system, which is used to
remove certain particulates, specifically sulphur oxides particulates from the exhaust gases of
a ship. Generally, the molecules of sulphur oxides that are part of exhaust gases from engine,
are separated from the gas flow when they meet a liquid. This liquid may be only water, a
chemical compound, or a combination of both.
This technology has been used in chemical industry from several years ago, mainly to remove
certain pollutant gases, for example, hydrogen sulphide, sulphur dioxide, dioxins, hydrogen
fluoride, heavy metals as well as certain methane compounds and carbon dioxide (biogas).
 The operation principle of the scrubbers used on board of a ship is the same than the scrubbers
used in the chemical industry. The exhaust gas cleaning system installed on a ship, is formed
basically by an exhaust gas cleaning unit, also known as scrubbing tower, a water treatment
unit, where residual water from cleaning process is treated to obtain water in compliance with
system parameters and in case of open loop system, with MEPC.259(68) Resolution parameters,
a sludge tank for storing all residues from water treatment unit and finally a group of water
pumps, valves and sensors that compounds all system.
As we mentioned above, an exhaust gas cleaning system can be approved and certified by two
different schemes, A and B. Next and prior to analyse all types of wet exhaust gas cleaning
systems, we will check the differences between both schemes.
3.1. SCHEME A FOR APPROVAL, CERTIFICATION AND SURVEY OF AN EXHAUST
GAS CLEANING SYSTEM

Scheme A contemplates an initial verification and certification of the system. Resolution

MEPC.259(68) foresees three options for this initial verification and certification. These
options are as follows:
- Unit approval, in which the exhaust gas cleaning unit, is certified for an emission limit value
stablished by manufacturer, using a fuel with a sulphur content cap limited by manufacturer too
and for a range of operating values.
- Serially manufactured units used for exhaust gas cleaning units which are nominally similar
with same mass flow ratings as that certified as per unit approval option. In this case, the
equipment manufacturer may submit, for acceptance by Administration, a conformity of
production arrangement. Units certified through this option are subject to the number of surveys
that the Administration may consider assuring that these units follow values approved by
Administration.
- Product range approval, used for exhaust gas cleaning units with the same design, but with
different maximum exhaust gas mass flow capacity. In this case, Administration may accept,
instead of testing the exhaust gas cleaning unit with all capacities, to test the scrubber units with
only three of its capacities, but these capacities should include the highest, the lowest and
intermediate one.
Each exhaust gas cleaning unit should be certified in compliance with the certified value (from
manufacturer), for each operating condition and limits stated on the exhaust gas cleaning unit
Technical Manual, which should be approved by Administration. All values should follow all
parameters regulated by Resolution MEPC.259(68).
For each unit approved and certified under specification of scheme A, the Administration should
issue a Sulphur Oxides Emissions Compliance Certificate (SECC). Furthermore, all these units
should have an Exhaust Gas Cleaning Technical Manual, approved by the Administration. This
Manual should keep on board of the ship and should contain all data specified in the above-
mentioned Resolution.
All units certified and approved by scheme A, are subject to survey on installation and at initial,
annual, intermediate and renewals surveys by the Administration, as well as, to the Port State
Control inspections.