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North P&I Club: No Scrubs- More Ports Declare Ban on EGCS Discharges *Update*

06 May 2020

The North P&I Club on Monday (4 May) published an update on the stands taken by major ports worldwide on the use of scrubbers and the allowance of EGCS discharge: 

Exhaust gas cleaning systems (EGCS) – more commonly referred to as scrubbers – are an accepted equivalent measure in complying with the IMO 2020 global sulphur cap. The use of scrubbers has split the shipping industry. Ports around the world are looking at the impact of scrubber use in their waters.

A number of ports and regions have already stated that they will not allow the discharge of washwater from scrubbers.

The table below summarises North’s understanding of the positions taken by ports that have or will prohibit the use of scrubbers, or have placed conditions on their use.

This information is to the best of our knowledge and is for guidance only. For up to date and definitive information, contact the local authorities or agents.

Country Port Open loop EGCS discharge allowed? Comments
Australia All Yes According to AMSA Marine Notice 05/2019, wash water testing should be conducted upon commissioning of the EGCS and repeated every twelve months, as a minimum, for a period of two years. Ships may be directed not to discharge wash-water from an EGCS in Australian waters if this data, or evidence that samples have been taken for analysis, cannot be provided to AMSA before arrival at the first Australian port.

 

Bahrain Bahrain No
  • Open loop operation not allowed in port or at anchor
  • Open loop operation is allowed in Bahraini territorial waters and exclusive economic zones (EEZ) as long as it can be proved that the discharge of washwater complies with MEPC.259(68) and there is no negative impact on marine ecosystems.

 

Belgium All No
  • Belgian federal law states discharge only allowed in coastal and open seawaters when at least 3nm off coast
  • Discharges must not imperil EU Water Framework Directive objectives.
  • Flemish regional law also confirms discharge not allowed in ports or inland waters.
Bermuda All ports Yes The maximum allowed sulphur content in fuel for Controlled Plants is 2.0%. Ships equipped with Exhaust Gas Cleaning Systems (EGCS) shall seek the prior approval of the Environmental Authority before its use in Bermuda’s territorial waters.  Wash-water and residue from the EGCS shall not be disposed of in Bermuda or discharged into Bermuda’s waters but shall be stored on board the ship until outside of Bermuda’s waters.
PR China Inland river Emission Control Areas (ECAs), Port areas within coastal ECAs and Bohai Sea – the sea area within lines connecting the junction point of shorelines of Dandong, Dalian and shorelines of Yantai, Weihai.

 

No
  • China MSA guidance prohibits the discharge of water washings from open- loop scrubbers in certain areas. The prohibited areas are:
    • Inland river Emission Control Areas (ECAs)
    • Port areas within coastal ECAs
    • Bohai Sea – the sea area within lines connecting the junction point of shorelines of Dandong, Dalian and shorelines of Yantai, Weihai.
  • The guidelines also prohibit the incineration of the water washing residues from any type of exhaust gas scrubber. Ships are required to keep accurate records of the stowage and disposal of the washing washings.
  • If a vessel is not able to store the washing water it is required to switch to low sulphur fuel (not exceeding 0.5%) prior to entering the above areas. The guidelines also state that under certain circumstances a vessel may apply for an exemption if it uses fuel that does not meet the MSA’s requirements.
  • A copy of the MSA’s guidelines for ships operating within the ECAs, including enforcement details can be found here.

 

Egypt Suez Canal No
  • Suez Canal Authority has issued Circular 08/2019.
  • Clarification provided here
  • The authority puts no conditions or restrictions on marine fuels until Egypt ratifies MARPOL Annex VI – as such, the sulphur cap is not in force.
  • Wash water from open-loop scrubbers is not permitted to be discharged during transit of the canal
Estonia All Ports Restricted
  • https://veeteedeamet.ee/sites/default/files/content-editors/clarification_of_exhaust_gas_cleaning_system_egcs_operations_in_territorial_waters_and_ports_of_estonia.pdfCircular Number 4 (21.10.19) refers to paragraph 10.1.6.1 of MEPC 184(59) and the restrictions on discharging chemical EGCS wash water including enclosed ports and estuaries. Exceptions for discharge into the sea are made if the ship operator can demonstrate that the washing water meets international requirements, required PH levels and does not cause adverse effects on human health or the environment. Prior authorisation is always required to discharge into the port area.The water Act which entered into force on 01.10.2019 does not treat washing water discharges as a violation of pollutant discharge from ships, if in compliance with MARPOL.The use of closed-loop EGCS is permitted in the territorial waters and ports of Estonia, if it meets the relevant requirements and is certified, however discharging of the washing water is not permitted.
Germany Inland Waterways , canals and ports within inland waterways No
  • EGCS discharge is not permitted according to the convention on the collection, deposit and reception of waste generated during navigation on the Rhine and other inland waterways (CDNI Convention) .Restrictions apply to all inland waterways intended for general traffic except for the German part of Lake Constance and the stretch of the Rhine upstream of Rheinfelden.https://www.cdni-iwt.org/presentation-of-cdni/?lang=en

 

Gibraltar Gibraltar No
  • Closed loop scrubbers are permitted in Gibraltar waters, Hybrid scrubbers operating in closed loop mode are also permitted, and open loop scrubber are temporarily not permitted as a precautionary measure until the Gibraltar Government arrives at a definitive policy decision with regards to (solely) open loop scrubbers
Hong Kong All Hong Kong Yes
  • A ban on EGCS wastewater is not listed, however Hong Kong regulation L.N 135 of 2018 states that an exemption from use of non-compliant fuel is granted if the authorities are satisfied with the abatement technology used to reduce sulphur dioxide emissions. More detail on this and the duration of exemption can be found by accessing the document via link below.https://www.elegislation.gov.hk/hk/2018/ln135!en

 

Ireland Dublin and Waterford No
Latvia All Ports Conflicting advice
  • EUROPEAN COMMISSION REPORT (2016): Allowed – no restrictions, but national authorities are of the position that open-loop scrubber discharge should be prohibited in territorial waters and ports
  • ABS Report (2018): Prohibited in port waters
  • Correspondents Pandi Balt Ltd advised in August 2018 that washwater discharges currently allowed under regulations but likely to be prohibited in future

 

Lithuania All Ports Conflicting advice
  • EUROPEAN COMMISSION REPORT (2016): Allowed – no restrictions (in accordance with IMO Washwater Guidelines MEPC 184(59)).
  • ABS Report (2018): Prohibited in territorial waters and ports
  • We understand Lithuanian authorities are studying whether EGCS wash water discharges have serious impacts on the marine environment or not. When results will be clear, conclusions will be provided.
Malaysia All Ports No
  • Malaysia shipping notice MSN 07/2019 prohibits the use of open loop scrubbers within 12 nautical miles from land. Vessels calling at Malaysian ports must operate in closed loop mode or change over to compliant fuel before arrival.MSN072019 (2).pdf

 

Norway The World Heritage Fjords sea areas of Geirangerfjord and Nærøyfjord

 

Restricted
Pakistan Port of Karachi and Port Bin Qasim No
  • The Government of Pakistan Ministry of Maritime Affairs (Ports and Shipping) circular number 001/2020 prohibits the discharge of wash-water from open loop scrubbers. If closed loop scrubbers are not in use then compliant fuel should be used and changed over before arriving in port waters.

 

Panama Panama canal No
  • NT NOTICE TO SHIPPING No. N-1-2020 “Vessel Requirements”, Section 31 states the following and can be accessed hereThe use of open loop scrubbers or hybrid scrubbers in open loop mode is prohibited in Panama Canal waters. Vessels opting to use closed loop scrubbers or hybrid scrubbers in closed/ zero discharge mode shall submit documents to the panama-canal authority as detailed in section 31 E.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.”

 

Portugal All Ports No
  • Use of open loop scrubbers are not allowed from entry of the ship into the port, along the port channel and at berth (moored), until the ship leaves the port. Only closed loop operation is allowed.

 

Singapore Singapore No
  • Ban on the use of open loop scrubbers expected to take effect on 1 January 2020

 

Spain Algeciras, Cartagena, Huelva No
  • Use of open loop scrubbers is prohibited at the Spanish ports of Algeciras, Cartagena and Huelva. At present no other Spanish ports have imposed this ban.
Sweden Stockholm Restricted
  • Whilst there is no ban in Swedish waters on the use of open loop scrubbers our correspondents have advised that there is an open loop scrubber ban in Stockholm.
United States Californian Ports and Waters No
  • The Californian ARB OGV regulations stipulate only distillate fuels can be used to comply with the 0.1% sulphur limit
  • Changeover to compliant distillate fuel (MGO or MDO) prior to entering Californian waters

 

United States Connecticut Ports and Waters No
  • Discharge of exhaust gas scrubber washwater into Connecticut waters from any vessel is prohibited
  • VGP 2013: 6.5.9 Discharge of exhaust gas scrubber washwater into Connecticut waters from any vessel covered under the VGP or sVGP is prohibited.
  • This condition is necessary for compliance with CGS section 22a-427, Standards No.1, 2, 9, 12, 14, 15, and 24 of the CT WQS.
United States Hawaii Ports and Waters Yes – conditional
  • 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 categories of effluent 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

 

United Arab Emirates Abu Dhabi Ports Yes – conditional
  • Abu Dhabi Ports Company Policy:
  • Sludge generated from exhaust gas scrubber washwater discharge must not be discharged into port 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 http://www.adports.ae/wp-content/uploads/2017/01/20131003_Vessel-Discharge-Draft-C.pdf

 

United Arab Emirates Fujairah No

 

A full copy of the chart can be accessed here.


Photo credit: Manifold Times
Published: 6 May, 2020

 

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