A. USE OF EGCS OR “SCRUBBERS”
1. Regulation on the use of Scrubbers:
The use of open loop “scrubbers” is permitted by the OMI to reduce emissions of sulphur oxides from ship engines; they are, therefore, an alternative means for reducing the sulphur content of marine fuels. The operating conditions of these systems, as well as the inspection criteria for them, are regulated by the following standards:
• IMO Resolution MEPC 259(68). This resolution establishes guidelines for the use of exhaust emission systems on ships, as well as for the verification and certification of these systems. This resolution updates and replaces resolution MEPC 184 (59).
• R.D 61/2006, of January 31. This standard includes the conditions regulated by Annex VI of the MARPOL agreement on the sulphur content of marine fuels. In this sense, the third additional provision of RD 61/2006 that regulates the “Exceptions regarding the limitation of the sulphur content of certain liquid fuels derived from petroleum”, considers as an exception in its letter h)
“h) To the fuel used on board ships that use emission reduction methods that allow continuous reductions in SO2 emissions that are at least equivalent, according to the values in Annex X, to those that would be achieved with the use of fuels for maritimepurposes that fulfill with the requirements of this royal decree.
Nevertheless, it is highlighted that, in accordance with the provisions of Directive (EU) 2016/802, on the control and inspection of sulphur contents in documents and the methods of reducing emissions, all this can be inspected by this Harbour Master’s Office.
2. Requirements for the use of scrubbers in the Port of Ceuta:
Every ship that has an Exhaust Gas Cleaning System (EGCS), for its acceptance and in order to avoid the use of low sulphur fuel, in waters of the EEZ, territorial sea and Spanish port waters, must notify it to the Harbour Master’s Office at least 72 hours in advance, providing the following documents in accordance with the guidelines of Resolution MEPC 259 (68) and according to the Plan chosen for the approval, recognition and certification of the EGCS:
OPEN LOOP SCRUBBERS:
Regarding the use of gas washing systems that operate with an open loop system, in addition to the aforementioned requirements, the following ones must be also taken into consideration:
Washwater discharge criteria1:
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.
“Resolution MEPC.184(59), of July 17 2009. The washwater resulting from the exhaust gas cleaning systems that use additives, preparations and relevant chemical products created in situ referred to in point 10.1.6.1 of Resolution MEPC.184 (59) may not be discharged into the sea, including harbours, docks and estuaries, unless the ship operator demonstrates that such washwater discharge has no significant negative impact or risk to human health or environment. If the chemical used is Caustic Soda, it is sufficient that the washwater meets the criteria established in Resolution MEPC.184 (59) and its pH does not exceed 8.0”
Determinant factors:
Both in Zone I and Zone II of the Port, the Port Authority of Ceuta (APC) may determine the use of open loop Scrubbers to certain areas of use and the level of discharge permitted, as long as:
• The Harbour Master’s Office reports propitiously to the Port Authority on the ship’s compliance with the provisions of Resolution MEPC259 (68) of the IMO.
• The ship operator provides verified and certified information by its classification agency that proves what is the polluting load of the spill, what are the applied treatments and what is the flow or volume expected to be discharged.
• The ship operator demonstrates that the discharge does not jeopardize the achievement of the quality objectives established for the port waters, nor does it imply non-compliance with the control of the discharge of priority substances as regulated by RD 817/2015, “by which establishes the criteria for monitoring and evaluating the state of surface waters and environmental quality standards” and in accordance with the provisions of the corresponding Hydrological Plan.
In any case, whenever the use of open-loop scrubbers is allowed in zone I of the port, the Port Authority of Ceuta may establish a sampling and monitoring program to characterise both, the polluting load of the discharges and the impact on water and sediments.
3. Documentation:
The documents will be attached under the heading “documents attached to the DUE (electronic document)” at least 72 hours in advance by creating an alarm so that they can be reviewed as a priority. In addition, after the documentation has been uploaded to DUE Port, it must be sent by email to capitania.ceuta@fomento.es
and to ambiente@puertodeceuta.com.
Once the documentation has been reviewed by the Harbor Master’s Office regarding the compliance with the aforementioned requirements, the Port Authority of Ceuta may authorise the use of “Open Loop Scrubbers” in port waters.
B. USE OF BALLAST WATER MANAGEMENT SYSTEMS:
Regarding the discharge of ballast water, the standards established in the International Convention for the control and management of ballast water (BWM) will be applied. In relation to the use of ballast water management systems (BWMS), those who have a type-approval certificate issued in accordance with the requirements of the revised G8 guidelines of the International Maritime Organization (IMO) will be authorised.
LINKS OF INTEREST:
Guidelines for exhaust gas cleaning systems in ships:
International Agreement for the Control and Management of Ballast Waters and Sediments of Ships:
http://www.imo.org/es/OurWork/Environment/BallastWaterManagement/Documents/BWM2Circ13Rev1es.pdf
