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Review on wash water discharge requirements for Scrubbers

 The 2013 VGP took effect on 19 December 2013, and regulates discharges incidental to the normal operation of vessels covered under the scope of the VGP (non-recreational vessels greater than 79 feet in length, which are not vessels of the armed forces, operating in a capacity as a means of transportation). Exhaust Gas Scrubber Washwater Discharge is addressed under section 2.2.26 of the Final 2013 VGP In accordance with Regulation 4 of MARPOL Annex VI, EGCS units may be used as an alternative means of compliance with the more stringent fuel oil sulphur limits established under Regulation 14 of MARPOL Annex VI, subject to approval by the Administration. Owners/operators are reminded that regulations pertaining to the VGP are applicable to discharges into US waters extending to the outer reach of the 3 mile territorial sea as defined in section 502(8) of the US Clean Water Act. Under VGP regulations, the pH limit for the washwater effluent shall not be less than 6.0, measured at the overboard discharge only.This is not consistent with the methods for determining the pH limit under the IMO EGCS Guidelines (resolution MEPC.259(68)), where the pH limit for the washwater effluent is to be no less than 6.5 ...

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