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SUB-COMMITTEE ON BULK LIQUIDS AND GASES 17th session Agenda item 11 BLG 17/11/2 30 November 2012 Original: ENGLISH

REVIEW OF RELEVANT NON-MANDATORY INSTRUMENTS AS A CONSEQUENCE OF THE AMENDED MARPOL ANNEX VI AND THE NOx TECHNICAL CODE Issues related to resolution MEPC.184(59) on 2009 Guidelines for Exhaust Gas Cleaning Systems Submitted by Denmark SUMMARY Executive summary: This submission addresses outstanding issues with regards to the amendments to the washwater discharge criteria for exhaust gas cleaning systems as found in section 10 of the 2009 Guidelines for Exhaust Gas Cleaning Systems, adopted through resolution MEPC.184(59) 7.3 7.3.1 7.3.1.1 Paragraph 6 BLG 17/INF.3; MEPC 59/4/16, MEPC 59/4/19, MEPC 59/24; MEPC 60/4/19, MEPC 60/4/25, MEPC 60/22; MEPC 61/4/3, MEPC 61/4/6 and resolution MEPC.184(59)

Strategic direction: High-level action: Planned output: Action to be taken: Related documents:

1 MEPC 59 adopted resolution MEPC.184(59) to amend the Guidelines for Exhaust Gas Cleaning Systems set out in resolution MEPC.170(57). The amendments mainly concerned the discharge conditions. At MEPC 60, these amendments were questioned, and it was decided to refer the matter to this Sub-Committee. At BLG 15, it was decided to allow further time for examination by inviting Member Governments and international organizations to submit the outcome and experiences in applying the 2009 Guidelines for Exhaust Gas Cleaning Systems (BLG 15/19, paragraph 11.44). 2 This submission addresses issues arising from the amendments with regards to the use of exhaust gas cleaning installations at sea. 3 Whilst the resolution MEPC.170(57) distinguished between discharge in harbours, ports and estuaries and discharge at open sea, the 2009 Guidelines only outline two options for compliance without distinguishing between open sea and harbours, ports and estuaries. The discharge requirements under paragraph 10.1.2.1 are:

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BLG 17/11/2 Page 2 .1 .2 a pH value of no less than 6.5 at the ship's overboard discharge; or a pH value of no less than 6.5 measured 4 metres from the discharge point.

Measuring the pH value using option .2 is only practically feasible when the ship is at rest in harbour, since monitoring 4 metres from the overboard discharge cannot be performed when the ship is in motion. Accordingly, option .1 will be the only requirement to apply at open sea, implying that a pH of 6.5 at the overboard discharge should be met. Being unable to use option .2 makes the pH requirement more stringent at open sea than in port, which is not helpful in addressing the environmental concerns on the basis of which the requirements are developed. This follows the fact that there are no environmental benefits of more stringent requirements at open sea, where mixing and dilution is swift and efficient. On the contrary, following the current guidelines, a ship should perform significant dilution of the washwater prior to discharge, resulting in pumping of large amounts of seawater and leading to an undesired rise in energy consumption and thereby CO2 and air pollution emissions. 4 Denmark has carried out an assessment of possible impacts of scrubber water discharges on the marine environment. A summary of the study, which was published in June 2012, is submitted as document BLG 17/INF.3 and the full report can be downloaded at: http://www2.mst.dk/Udgiv/publications/2012/06/978-87-92903-30-3.pdf. The study was commissioned by the Danish Environmental Protection Agency and carried out by COWI Consult A/S. The results show that discharge of washwater with low pH value due to content of sulphuric acid has a negligible effect on the marine environment in the long term due to the buffering capacity of seawater even in the worst case scenarios analysed. 5 In order to clarify the pH criteria for washwater applicable at sea and in ports, harbours and estuaries, section 10 of the 2009 Guidelines for Exhaust Gas Cleaning Systems should be reconsidered by the Sub-Committee. Action requested of the Sub-Committee 6 The Sub-Committee is invited to consider the information above and take action as appropriate.

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