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 
Another deficiency is pointed out by Lahtinen (2016). For the thresholds considering the inlet 
values, the definition of “inlet water” is rather unclear for CL systems; it may be understood as 
fresh feed water into the system or as washwater in recirculation in the system and entering the 
scrubber tower. A further issue linked to the consideration of the inlet values, but also to the 
normalization of thresholds, is the temporary storage by CL systems. In such case, it is nearly 
impossible to determine the applicable limit value. To this regard, the revised EGCS Guidelines 
introduces fixed thresholds (pH, PAHs and turbidity) for discharges from temporary storage, 
without consideration of inlet values and specific flowrates. Again, it poses more stringent 
values for CL systems (especially regarding PAHs: PAHypne < 50 ug/L). 
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