LEARNINGS FROM THE WASH WATER SAMPLING

PROGRAMME MARK WEST

INTRODUCTORY BRIEF PROVIDED TO THE ESSF

• UNFOUNDED CONCERNS ABOUT SCRUBBING IN EU PORTS

• LACK OF DATA ON COMPOSITION OF SCRUBBER WASH WATER DISCHARGE

• LIMITED SAMPLING AND ANALYSIS – LOW NUMBER OF INSTALLATIONS (AS OF

JULY 2014)

• JOINT AGREEMENT EGCSA & EUROSHORE TO SAMPLE UP TO 15 SYSTEMS

• IMPROVE UNDERSTANDING

• ANONYMITY FOR SHIP OPERATORS (& EGCSA MEMBERS)

SAMPLING CONDITIONS

• PLAN AT START OF PROJECT:

• NEAR FULL ENGINE POWER AS POSSIBLE

• MULTI-INLET SCRUBBERS RUNNING AT NEAR MAXIMUM CAPACITY

• WITHIN 12 HOURS OF BERTHING IN PORT

• PRACTICAL REALITY

• FULL RANGE OF ENGINE OPERATING POWERS & SCRUBBER CAPACITIES

(MANOEUVRING TO ~MCR)

• UNCERTAINTY OF SPOT MARKET SHIPS

• SCHEDULES ON REGULAR ROUTES

• VARIABLE WEATHER AND SEA CONDITIONS

• FUEL SAVING

• ENGINE BREAKDOWNS ON THE SUBJECT SHIP AND OTHER SHIPS ON THE BERTH

• NO SCRUBBER SYSTEM BREAKDOWNS TO DATE

SAMPLING

• SAMPLES (SYSTEM DEPENDENT)

• SEAWATER/SCRUBBER INLET

• WASH WATER BEFORE TREATMENT

• OVERBOARD DISCHARGE (BEFORE pH CORRECTION)

• SCRUBBER SYSTEM & ENGINE OPERATING CONDITIONS, SHIP POSITION BEFORE &

AFTER SAMPLING

• FOR INTEGRITY ASSURANCE

• LABORATORY PREPARED SAMPLE BOTTLE PACKS

• PREPARATION - CLEANING & FLUSHING OF SAMPLING POINTS & COLLECTION GEAR

• MW HAS SAILED WITH ALL VESSELS IN THE PROGRAMME.

SAMPLE BOTTLE PACK

• 6 BOTTLES REQUIRED PER SAMPLE POINT • 2 x VIALS BTEX, 1 x PLASTIC HG, 1 x PLASTIC METALS, 1x PLASTIC NO2/NO3, 1 x

GLASS PAH • 18 BOTTLES PER BOX

SAMPLE POINTS

• FEW EASY TO ACCESS/USE SAMPLE POINTS BUT WITH CAREFUL PREP SAMPLING INTEGRITY CAN BE MAINTAINED

TIME CHALLENGE

• PROCESS OF TAKING SAMPLES IS QUITE STRAIGHTFORWARD WHEN SAMPLING POINTS HAVE BEEN IDENTIFIED • < 1 HOUR PER SCRUBBER

• LEVEL OF ASSISTANCE VARIABLE, BUT NOT A PROBLEM

• TYPICAL TIME FOR ONE SHIP VISIT IS 3 DAYS: • ~ 1 DAY TO SHIP, ~1 DAY ON SHIP SAILING, ~1 DAY FROM SHIP.

• BIGGEST CHALLENGE IS GETTING SAMPLES TO LABORATORY ON TIME

TIME CHALLENGE

• DELIVERY TO LABORATORY MUST BE WITHIN 48 HOURS IF NO2/NO3 SAMPLES FROZEN OR

WITHIN 24 HOURS IF NOT FROZEN

• SEAWATER SAMPLES TAKE MIN. 6-7 HOURS TO FREEZE, DIFFICULT ON SHORT FERRY ROUTE

TIME CHALLENGE

• LABORATORY DOES NOT WORK WEEKENDS

• COURIERS TYPICALLY DO NOT COLLECT AFTER 17:00 UNLESS SPECIAL SERVICE

• DANISH PORT TO GERMAN LAB OVERNIGHT COURIER - EUR850

• UNLESS SAMPLES INTO COURIER SYSTEM DURING WORKING HOURS ON WEDNESDAY,

RISK OF NON-DELIVERY ON FRIDAY

• TIME CONSTRAINT IS LIMITING IN TERMS OF FINDING SHIPS TO MEET SCHEDULE.

• USING SHIP’S STAFF

• 2 LATE ARRIVALS

• AGENT PUT BOX WITH FULL SET OF SAMPLES INTO FREEZER, GLASS BOTTLES BROKEN!

• POSSIBLE SAMPLING ISSUES

TIME CHALLENGE - EXAMPLE

1. SHIP DELAYED - SAMPLE BOX HAND DELIVERED TO COURIER THURSDAY EVENING, ROTTERDAM

2. SAMPLE BOX REACHES DORTMUND FRIDAY MID-DAY, 30 MINS. FROM LAB.

3. SAMPLE BOX DELIVERED TO LAB MONDAY MORNING!

1

2

3

TIME CHALLENGE

• PRE-PLANNING ESSENTIAL

• UNDERSTAND BASIC LAYOUT OF SYSTEM

• SAMPLE BOXES ONBOARD BEFORE TRAVEL

• KNOW SHIP’S SCHEDULE

• ORGANISE HOW SAMPLES WILL BE COLLECTED AND DELIVERED TO THE

LABORATORY

• CONTINGENCY PLAN FOR SHIP DELAYS

SOME NUMBERS

• 10 SHIPS SAMPLED, 15 SETS OF SAMPLES LANDED

• 40 SAMPLES ANALYSED (ALL AT SGS HERTEN), ~1300 TEST RESULTS

• 12 OPEN LOOP MODE, 3 CLOSED LOOP MODE

• 7 MANUFACTURERS

• 6 HYBRID, 3 OPEN LOOP, 1 CLOSED LOOP

• 5 FERRIES, 2 CONTAINER, 2 TANKER, 1 VEHICLE CARRIER

• 8 SCRUBBERS FOR SINGLE ENGINES, 4 SCRUBBERS FOR MULTIPLE COMBUSTION UNITS

• 2 ECA – BALTIC & NORTH SEA

• 1.48 - 2.87% SULPHUR FUEL

• 90% MCR – MANOEUVRING, 52% AVERAGE

• 10 DAYS – LONGEST TIME ONBOARD!

SAMPLING LOCATIONS

SCRUBBER GUIDELINES – WASHWATER DATA COLLECTION

• MEPC 259.(68) – APPENDIX 3 TO THE 2015 EXHAUST GAS CLEANING SYSTEM

GUIDELINES

• REQUESTS THAT SHIP-OWNERS UNDERTAKE SAMPLING AND TESTING OF AT LEAST

3 SETS OF SAMPLES OVER A 24 MONTH PERIOD POST SCRUBBER SYSTEM

COMMISSIONING.

• pH, PAH, METALS, NITRATE/NITRITE

• SAMPLE ANALYSES FOR ESSF PROJECT MARKED * ARE REQUESTED IN MEPC

259.(68)

ESSF SAMPLE ANALYSIS

• NITRATE AND NITRITE* (TEST METHOD

EN ISO 10304-1)

• BTEX (TEST METHOD DIN 38407-9-2)

• BENZENE

• TOLUENE

• ETHYLBENZENE

• XYLENE

• ELEMENTAL ANALYSIS (TEST METHOD EN

1483)

• MERCURY (HG)

• ELEMENTAL ANALYSIS (TEST METHOD EN ISO 11885)*

• CADMIUM (CD)

• COPPER (CU)

• NICKEL (NI)

• LEAD (PB)

• ZINC (ZN)

• ARSENIC (AS)

• CHROMIUM (CR)

• VANADIUM (V)

ESSF SAMPLE ANALYSIS

• 16 EPA PRIORITY PAH:

• NAPHTHALENE

• ACENAPHTHYLENE

• ACENAPHTHENE

• FLUORENE

• PHENANTHRENE

• ANTHRACENE

• FLUORANTHENE

• PYRENE

• BENZO[A]ANTHRACENE

• CHRYSENE

• BENZO[B]FLUORANTHENE

• BENZO[K]FLUORANTHENE

• BENZO[A]PYRENE

• DIBENZ(AH)ANTHRACENE

• BENZO[GHI]PERYLENE

• INDENO[1,2,3-CD]PYRENE

• TOTAL PAH

POLYCYCLIC AROMATIC HYDROCARBONS* (TEST METHOD EPA 8270 D)

METALS

Emission limit values for discharges of waste water from cleaning of waste gases from incinerators

METALS

• ALL AVERAGES WELL BELOW THE 2010/75/EU LIMITS

• NOTE NO LIMIT FOR VANADIUM

• ONLY TWO RESULTS, LEAD(PB) ABOVE LIMIT – 0.3 & 0.29 mg/l vs. 0.2mg/l* (same ship/engine)

• 40 SAMPLES – LEAD: 3 SW IN, 3 BEFORE WWT, 3 OVERBOARD

• LEAD, COPPER, ZINC, CHROMIUM SEEM LIKELY FROM MATERIALS OF CONSTRUCTION EG FROM WWT, PIPEWORK, SAMPLE POINT

• DEPENDING ON SCRUBBER SET-UP SUGGEST FIT CLEARLY MARKED EASY TO USE NON-METALLIC SAMPLE VALVES AT FOLLOWING POINTS AS STANDARD PRACTICE

• INLET MONITORING STATION OR WHERE BACKGROUND SEAWATER SAMPLES CAN BE OBTAINED

• BEFORE WWT }

• AFTER WWT } AT OVERBOARD MONITORING STATION IF APPROPRIATE

• AT SHIP SIDE OVERBOARD }

• ALSO HELPS MITIGATE ISSUES OF SHIP STAFF TAKING SAMPLES

* ppm

NITRATES

• AA(B) held back to see effects of extended preservation time. • Sample unfrozen for one week then frozen & analysed 16 days after sampling • Note no analysis from EE - courier delay • Results calculated by overboard before pH correction - inlet concentration • No samples near IMO 60mg/l limit on this basis

NITRATES

NITRATES

• IMO MEPC 259.(68) - 2015 EGCS GUIDELINES

• 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….. THE TEST METHOD FOR THE

ANALYSIS OF NITRATES SHOULD BE ACCORDING TO STANDARD SEAWATER ANALYSIS AS DESCRIBED IN GRASSHOFF ET AL.

• SOME SUGGESTIONS:

• NITRATE RESULT SHOULD BE DIFFERENCE BETWEEN NORMALISED DISCHARGE & INLET

(PARTICULARLY IF SAMPLES NOT IN TAKEN IN OPEN SEAS) – DOES MEPC 259.(68) NEED

REWORDING AT SOME STAGE?

• AFFECT OF AGING TO BE FURTHER INVESTIGATED/TAKEN INTO CONSIDERATION

• CONSIDER ALLOWING USE OF ONBOARD NITRATE TESTING FOR PROGRAMMES

• NOTE NITRITE LEVELS ONLY DETECTED IN 4 SAMPLES & MINOR - HIGHEST 0.42 mg/l (NORMALISED)

BTEX

• WORLD HEALTH ORGANISATION

• GUIDELINE VALUE NORMALLY REPRESENTS THE CONCENTRATION OF A CONSTITUENT THAT DOES NOT RESULT IN ANY SIGNIFICANT RISK TO HEALTH OVER A LIFETIME OF CONSUMPTION

• BENZENE 10ppb*

• TOLUENE 700ppb

• ETHYLBENZENE 300ppb

• XYLENES 500ppb

• ESSF ANALYSES

• 16 OVERBOARD SAMPLES ANALYSED (BEFORE pH CORRECTION)

• 11 SAMPLES - BTEX NOT DETECTED

• 5 SAMPLES - 4ppb HIGHEST LEVEL – 2ppb BENZENE + 2ppb TOLUENE

PAH • IMO LIMIT OF 50 ppb AT 45m3/MWh IS

NOT EXCEEDED BY ANY VESSEL

PAH • NAPHTHALENE AND PHENANTHRENE

MOST PREVALENT SPECIES

PAH • INCREASING MOLECULAR WEIGHT

PAH ARE AT TOP OF GRAPH

• INDICATORS EG?

• SAMPLING ISSUE

• AREA OF OPERATION (SHALLOW

WATER SEDIMENT)

• COMBUSTION PERFORMANCE

• WWT PERFORMANCE

SUMMARY • NITRATES – ALL WITHIN IMO LIMITS (IF NOT AGED)

• MEPC 259.(68) NITRATES: DISCHARGE – INLET?

• POSSIBLE IMPLICATIONS OF SAMPLE AGING ON NITRATE LEVELS

• ONBOARD TESTING FOR PROGRAMMES (NOT ONE OFFS)

• NITRITES NOT AN ISSUE

• METALS – VERY LOW BUT SOME EVIDENCE OF MATERIALS OF CONSTRUCTION

• EGCSA STANDARD FOR SAMPLING VALVE LOCATION AND MATERIALS TO BE ESTABLISHED?

• VANADIUM?

• BTEX NOT AN ISSUE

• PAH – ALL WITHIN IMO LIMITS

• SOME EVIDENCE THAT PAH MAY BE AN INDICATOR OF OPERATION, COMBUSTION

PERFORMANCE, WWT PERFORMANCE?

FOR CONSIDERATION

• EGCSA SAMPLING PROGRAMME

• MORE THAN ONE LAB

• FULLY ANONYMISED DATABASE (MEMBERS &/OR PUBLIC?)

• PAH AND METALS FOCUS – OTHERS?

• EGCSA TO CREATE NEW STANDARD FOR WASH WATER DISCHARGE CRITERIA?

LEARNINGS FROM THE WASH WATER SAMPLING PROGRAMME

QUESTIONS & DISCUSSION

MARK WEST

MARK WEST IS A SELF-EMPLOYED CONSULTANT AND PROJECT MANAGER WITH OVER 30 YEARS EXPERIENCE IN THE MARINE INDUSTRY; MUCH OF HIS WORK OVER THE LAST 12 YEARS HAS BEEN ASSOCIATED WITH MARPOL ANNEX VI AND TRIALS OF EQUIPMENT FOR THE CONTROL AND MONITORING OF EXHAUST EMISSIONS FROM SHIPS.

HE WAS BP’S REPRESENTATIVE ON TRIALS OF TWO LARGE SEAWATER SCRUBBER SYSTEMS ON PASSENGER VESSELS, INCLUDING THE FERRY PRIDE OF KENT FROM 2003 AND AN INDUSTRY REPRESENTATIVE ON THE IMO DRAFTING GROUPS FOR THE FIRST ITERATION OF THE EXHAUST GAS CLEANING SYSTEM GUIDELINES. HE HAS WRITTEN AND EDITED THE EGCSA GUIDE TO EXHAUST GAS CLEANING SYSTEMS AND CO-AUTHORED A SNAME PAPER ON SOX EMISSIONS. MARK HAS PRESENTED AT EGCSA TRAINING COURSES AND WAS A SPEAKER AND TECHNOLOGY PANEL HOST AT THE SIBCON 2014 SESSION ON SCRUBBERS.

BEFORE STARTING HIS OWN BUSINESS IN 2003, MARK HELD VARIOUS TECHNICAL MANAGEMENT ROLES IN CASTROL MARINE LUBRICANTS AND WAS A SEAGOING ENGINEER FOR 11 YEARS. HE HAS A UK CLASS 1 CERTIFICATE OF COMPETENCY - CHIEF MARINE ENGINEER OFFICER.