10.1 Washwater discharge criteria footnote
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Statutory Documents - IMO Publications and Documents - Resolutions - Marine Environment Protection Committee - Resolution MEPC.184(59) – 2009 Guidelines for Exhaust Gas Cleaning Systems – (adopted on 17 July 2009) - Annex – 2009 Guidelines for Exhaust Gas Cleaning Systems - 10 Washwater - 10.1 Washwater discharge criteria1

10.1 Washwater discharge criteria footnote

  10.1.1 When the EGC system is operated in ports, harbours, or estuaries, the washwater monitoring and recording should be continuous. 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 EGC system is in operation, except for short periods of maintenance and cleaning of the equipment. The discharge water should comply with the following limits:

  10.1.2 pH criteria

  10.1.2.1 The washwater pH should comply with one of the following requirements which should be recorded in the ETM-A or ETM-B as applicable:

  • (i) The discharge washwater should have a pH of no less than 6.5 measured at the ship’s overboard discharge with the exception that during manoeuvring and transit, the maximum difference between inlet and outlet of 2 pH units is allowed measured at the ship’s inlet and overboard discharge.

  • (ii) During commissioning of the unit(s) after installation, the discharged washwater plume should be measured externally from the ship (at rest in harbour) and the discharge pH at the ship’s overboard pH monitoring point will be recorded when the plume at 4 metres from the discharge point equals or is above pH 6.5. The discharged pH to achieve a minimum pH units of 6.5 will become the overboard pH discharge limit recorded in the ETM-A or ETM-B.

  10.1.3 PAHs (Polycyclic Aromatic Hydrocarbons)

  10.1.3.1 The washwater PAH should comply with the following requirements. The appropriate limit should be specified in the ETM-A or ETM-B.

  10.1.3.2 The maximum continuous PAH concentration in the washwater should not be greater than 50 μg/L PAHphe (phenanthrene equivalence) above the inlet water PAH concentration. For the purposes of this criteria, the PAH concentration in the washwater should be measured downstream of the water treatment equipment, but upstream of any washwater dilution or other reactant dosing unit, if used, prior to discharge.

  10.1.3.3 The 50 μg/L limit described above is normalized for a washwater flow rate through the EGC unit of 45 t/MWh where the MW refers to the MCR or 80% of the power rating of the fuel oil combustion unit. This limit would have to be adjusted upward for lower washwater flow rates per MWh, and vice-versa, according to the table below.

Flow Rate (t/MWh) Discharge Concentration Limit(μg/L PAHphe equivalents) Measurement Technology
0 – 1 2250 Ultraviolet Light
2.5 900 – ” –
5 450 Fluorescencefootnote
11.5 200 – ” –
22.5 100 – ” –
45 50 – ” –
90 25 – ” –

  10.1.3.4 For a 15-minute period in any 12-hour period, the continuous PAHphe concentration limit may exceed the limit described above by up to 100%. This would allow for an abnormal start up of the EGC unit.

  10.1.4 Turbidity/Suspended Particle Matter

  10.1.4.1 The washwater turbidity should comply with the following requirements. The limit should be recorded in the ETM-A or ETM-B.

  10.1.4.2 The washwater treatment system should be designed to minimize suspended particulate matter, including heavy metals and ash.

  10.1.4.3 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 washwater dilution (or other reactant dosing) prior to discharge.

  10.1.4.4 For a 15-minute period in any 12-hour period, the continuous turbidity discharge limit may be exceeded by 20%.

  10.1.5 Nitrates

  10.1.5.1 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 washwater discharge rate of 45 tons/MWh whichever is greater.

  10.1.5.2 At each renewal survey nitrate discharge data is to be available in respect of sample overboard discharge drawn from each EGC system with the previous three months prior to the survey. However, the Administration may require an additional sample to be drawn and analysed 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 be available for inspection as required by Port State Control or other parties. Requirements in respect of sampling, storage, handling and analysis should be detailed in the ETM-A or ETM-B as applicable. To assure comparable nitrate discharge rate assessment, the sampling procedures should take into account paragraph 10.1.5.1, which specifies the need for washwater flow normalization. The test method for the analysis of nitrates should be according to standard seawater analysis as described in Grasshoff et al.

  10.1.5.3 All systems should be tested for nitrates in the discharge water. If typical nitrate amounts are above 80% of the upper limit, it should be recorded in the ETM-A or ETM-B.

  10.1.6 Washwater additives and other substances

  10.1.6.1 An assessment of the washwater is required for those EGC technologies which make use of chemicals, additives, preparations or create relevant chemicals in situ. The assessment could take into account relevant guidelines such as resolution MEPC.126(53), procedure for approval of ballast water management systems that make use of active substances (G9) and if necessary additional washwater discharge criteria should be established.


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