Turkey

/in /by

UPDATE: 06 April 2021

As widely reported by P&I clubs and the Turkish Shipowners Association Turkey’s Ministry for Environment and Urbanization General Directorate for Environmental Management has issued notice E-84973951-140.99-698452 prohibiting discharges from Exhaust Gas Cleaning Systems

Quote:

In line with article 23(b) of the Regulation on Controlling Water Pollution dated 31.12.2004 and published in the Official Gazette No. 25687, “Discharge of waste, petrol and petrol derivatives along with bilge water, dirty ballast water, sludge, slop, oil and similar solid and liquid waste, any type of cargo waste originating from ships and any planes which fly over the parts of the seas which are under Turkish sovereignty, is hereby forbidden”, it is forbidden to discharge any washing water of those scrubber systems into Turkish territorial waters and hereby requested that such decision is notified to the relevant authorities.

Unquote

The notice in Turkish and English can be downloaded here

Wording of the notice suggests that use of compliant fuel or operation of scrubbers in zero discharge mode (if the ship’s EGCS has the capability) are the remaining options for ship operators.

04 February 2020

The following is kindly reproduced from Gulf Agency Company Ltd – Hot Port News 4 February 2020:
https://www.gac.com/news–media/hot-port-news/use-of-scrubber-and-fuel-in-turkish-waters

Quote:

The Turkish Ministry of Transport and Infrastructure General Directorate for Maritime Affairs requires information to be provided about types of fuel to be used by ships coming to the country’s territorial waters and ports, and ships transiting the Turkish Straits.

The sulfur content of the fuel used in ships worldwide has been limited to 0.5% as of 1 January 2020 within the scope of Annex VI of International Convention for the Prevention of Pollution from Ships (MARPOL). This limitation also applies to all ships sailing in Turkish waters.

In addition, the “Regulation on the Reduction of Sulfur Rate in Some Fuel Oil Types” is in force in Turkey, and the use of marine fuels of which sulfur amount exceeds 0.1% by mass is prohibited for ships bound or anchored for more than 2 hours in inland waters and in the administrative areas authorized by Port Authorities within the scope of Article 7 of the Regulation. The said article 7 is not applied in cases where the inland water vehicles with valid certificates are located at sea and when the machines of the ships at the dock are not working and powered by land.

Exhaust gas cleaning systems (scrubber) will be considered as equivalent application within the scope of Rule 4 of MARPOL Annex VI, instead of using suitable fuel, in order to comply with the said sulfur limits. The exhaust gas cleaning systems in question are equipped on the ships according to the issues specified in the International Maritime Organization’s (IMO) decision numbered MEPC 259(68) and certified by the Administration or authorized class organizations.

In this context, there is certain criteria related to the standard of the washing water to be discharged to the sea, and these devices are approved by checking these criteria. In Turkey, there are not any restrictions or prohibitions regarding the discharge of scrubber washing waters into the sea and scrubber types and these issues are within the scope of the Ministry of Environment and Urbanization.

It is, however, forbidden to discharge wastes/sludge generated during the treatment of exhaust washing water and collected in the tank into the sea within the framework of IMO’s decision numbered MEPC 259(68) and burn them on board, and these wastes must be recorded in the exhaust gas cleaning system (EGC) registry by giving them to appropriate land facilities against receipt. Separate 1 cubic meter tanks (IBC Tank) are provided to the coastal facilities for the collection of washing water wastes/mud. When there is a notification of high amount of waste from ships, the issue is reported to the Ministry of Environment and Urbanization and to the Provincial Directorates of Environment and Urbanization, and waste receipt ship operators revise their ships so that they can receive these wastes as soon as possible. Waste generated in the scrubber system and the waste in the ship’s sludge tank are given separately without being mixed and specified in the waste transfer form. The fee is determined for the purchase of such wastes not covered by the “Communiqué on the Fees and Principles to be Applied in the Framework of Waste Collection and Control of Wastes from Ships” and ,in case of disagreement, determined by the relevant Governorship (Provincial Directorate of Environment and Urbanization).

For further details, and information about operations in Turkey, contact GAC Turkey at turkey@gac.com

Unquote

Also see http://www.mevzuat.gov.tr/MevzuatMetin/3.5.200915478.pdf

 

Australia

/in /by

Australian ports and waters are outside of IMO MARPOL Annex VI Emission Control Areas. Under Annex VI regulation 14 the maximum fuel sulphur limit of 0.50% applies from 1 January 2020 (although it should be noted that under local regulation 0.10% applies to cruise ships in Sydney harbour – see below). Regulation 4 also applies and EGCS can be used as an alternative means of compliance if at least as effective in terms of SOx emissions reduction as the fuel sulphur limit.

Marine Notice 02/21 (supercedes Marine Notice 05/19) sets out the requirements for the use of Exhaust Gas Cleaning Systems in Australian Waters and reporting to AMSA.

Key points of the Notice, which can be downloaded here from the AMSA website, are as follows:

  • The EGCS must be approved and operated in line with IMO requirements and the 2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68)
  • Crew members must be properly trained in the use of the EGCS
  • Any EGCS malfunction must be remedied soonest. A malfunction that lasts more than one hour, or repetitive malfunctions, should be reported to the vessel’s flag State Administration and the relevant port State authorities, with an explanation of the remedial actions that are being taken
  • Any EGCS found to be not in compliance with IMO guidelines in any respect (including but not limited to the wash water discharge criteria) may be prohibited from use in Australian waters.

If a vessel is to use exhaust gas cleaning as a method of compliance AMSA requests to be notified before first arrival at an Australian port after 1 January 2020. Information to be provided includes results of washwater testing undertaken during commissioning of the EGCS and repeated every twelve months, as a minimum, for a period of two years. Ships may not be allowed to discharge washwater from an EGCS in Australian waters if this data, or evidence that samples have been taken for analysis, cannot be provided before arrival.

AMSA is currently investigating the potential impacts of EGCS wash water discharges on Australian port environments and has commissioned a study to assess the potential cumulative impacts of wash water discharges from open-loop EGCS over time. This investigation will inform whether any future restrictions on the use of EGCS in Australian waters are needed.

While the discharge of wash water from EGCS is currently permitted in Australian waters, vessel owners, operators and Masters are encouraged to avoid discharging wash water within Australian port limits.

Other Marine Notices can be found at: https://www.amsa.gov.au/about/regulations-and-standards/marine-notices

Sydney

Cruise ships capable of accommodating more than 100 passengers in Sydney Harbour are required to use either low sulphur (maximum 0.10% m/m) fuel or an alternative measure that achieves an equivalent outcome i.e. EGCS.

See:  https://www.amsa.gov.au/marine-environment/air-pollution/sydney-harbour-cruise-ship-emissions

Bahrain

/in /by

Bahrain’s ports and waters are outside of IMO MARPOL Annex VI Emission Control Areas. Under Annex VI regulation 14 the maximum fuel sulphur limit of 0.50% applies from 1 January 2020. While regulation 4 also applies and approved EGCS can be used as an alternative means of compliance, discharges from open loop scrubbers are not permitted in port and anchorage areas.

While Bahrain has to date not ratified MARPOL Annex VI (click to view current status), Ministry of Transportation and Telecommunications Marine Notice PMA/03/2019 (click here to download) applies and section 5 paragraphs 1 through 4 are of particular relevance.

In Bahraini territorial waters and the exclusive economic zone (EEZ) EGCS discharges are permitted if in compliance with the IMO 2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68) and there is no negative impact on marine ecosystems.

A permit to discharge must first be obtained from the Marine Safety & Environment Protection Directorate (MSEPD) at Ports and Maritime Affairs (PMA). The application for a permit must include results of washwater testing undertaken during commissioning of the EGCS and repeated every twelve months, as a minimum, for a period of two years. Ships may not be allowed to discharge washwater from an EGCS in Bahraini waters if this data, or evidence that samples have been taken for analysis, cannot be provided.

Section 5 paragraph 4 goes on to state that PMA strongly encourages the vessel to use the close loop mode (no discharge overboard) when it sails within Bahraini waters.

Marine laws, regulations and notices can be downloaded at the PMA website http://mtt.gov.bh/content/pma-law-and-regulation , although it should be noted that Marine Notice PMA/03/2019 is not listed.

Pakistan

/in /by

7 January 2020

Pakistan’s ports and waters are outside of IMO MARPOL Annex VI Emission Control Areas. Under Annex VI regulation 14 the maximum fuel sulphur limit of 0.50% applies from 1 January 2020. While regulation 4 also applies and approved EGCS can be used as an alternative means of compliance,  discharges from open loop scrubbers are not permitted in port.

This is confirmed as follows in paragraph 8 of the Ministry of Ports & Shipping (Ports & Shipping Wing) Circular No. 001/2020 circulated by the Port Department of Karachi Port Trust:

8. Prohibition on -discharge of wash-water from Open-Loop Scrubbers in Port:
The discharge of wash-water from open-loop scrubbers is prohibited in Port. While in the Port, vessels fitted with hybrid type of scrubbers should switch to the closed-loop mode of operation. As for vessels fitted with open-loop scrubbers, they would need to switch over to compliant fuel instead. It would be advisable to carry out the switch to either closed-loop mode or to compliant fuel well in advance of the vessel’s arrival at the port waters, so that any operational issues can be identified and. dealt with before the ship arrival in Pakistani waters

The document can be downloaded here.