TEXTE Environmental Impacts of Exhaust Gas Cleaning Systems for Reduction of SOx on Ships — Analysis of status quo 
Report compiled within the framework of the project ImpEx 
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Maintenance and servicing of the washwater and discharge water monitoring systems and 
ancillary components should be recorded in the EGCS Record Book. 
Specification of design guidance for water sampling points/valves (representative and 
accessible location). 
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A guidance for voluntary discharge water data collection is included. This guidance had as 
basis the submission PPR 5/11. 
No modifications were made to the limit values described in section 10.1 of the “2015 EGCS 
Guidelines”. The discharge water quality criteria, however, should be reviewed in the future as 
more data become available, including relevant research and development results, on the 
content of discharge water and its effects, taking into consideration any advice given by the 
Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP). To 
this regard, MEPC 74 requested GESAMP to establish a Task Team to assess the available 
evidence related to the environmental impact of EGCS discharge water, including the studies and 
analyses submitted to IMO Committees (PPR and MEPC), other analyses and results from 
research projects, as well as the results of available simulations for predicting the environmental 
concentrations of target substances (MEPC, 2019). The first findings of the work of the GESAMP 
Task Team on EGCS were reported to PPR 7 in document PPR 7/INF.23 and are presented in 
chapter 7 of this report. 
The draft of the “2020 EGCS Guidelines” also indicates that in case of a breakdown of the EGCS or 
associated equipment, corrective actions should be recorded and the relevant flag and port 
State's Administration should be notified, in accordance with MEPC.1/Circ.883/Rev.1. The 
referred circular is a proposed draft to update and supersede MEPC.1/Circ.883 with a view to 
adoption and approval by MEPC 75. This circular defines an EGCS malfunction as “any condition 
that leads to an emission exceedance, with the exception of the short-term temporary emission 
exceedance cases (...) or an interim indication of ongoing compliance in the case of sensor failure” 
According to this circular, identification and remediation of malfunctions should be initiated 
following the trouble-shooting process specified by the EGCS manufacturer. The short-term 
exceedances refer only to the air emission (emission ratio: SO2 (ppm)/CO; (%v/v)) and not to 
the water emission (discharge water quality criteria). For the interim indication of ongoing 
compliance in the case of sensor failure, including instrumentation for the monitoring of 
discharge water (pH, PAH and turbidity), the required documentation and actions are 
determined based on the assumption that all monitored parameters keep certain interrelation. 
5.2 European regulations for EGCS discharge water 
On European level, several regulations apply to EGCS discharge water. The EU Sulphur Directive 
(Directive (EU) 2016/802, 2016) regulates the SOx emissions from ships. It implements the 
MARPOL Annex VI (with regards to SOx). The limit values for sulphur content in fuels are 
established in accordance with MARPOL Annex VI. In Article 8, the use of Emission Abatement 
Methods (e.g. EGCS) as alternative methods for compliance is permitted. For their approval, 
Article 9 refers to the Guidelines developed by the IMO. 
Another main instrument applicable to EGCS discharges under European law is the EU Directive 
on port reception facilities for the delivery of waste from ships (Directive (EU) 2019/883, 2019), 
which includes both sludge and bleed-off water in its scope. This Directive indicates that 
Member States should: 
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