EGCSA-Euroshore-Scrubber-Water-Sampling-Ship-Guide-2016 17.Pdf

SHIP GUIDE SCRUBBER WATER SAMPLE ANALYSIS PROGRAMME

SHIP GUIDE Scrubber Water Sample Analysis Programme

Contents 1. Introduction ...... 3 2. Purpose of this document ...... 3 3. Important notes ...... 4 4. Quick guide ...... 5 5. Points of contact ...... 6 6. First actions ...... 7 6.1 Sample point identification ...... 7 6.2 Power measurement ...... 7 6.3 Ship information ...... 7 6.4 Ship’s code and sampling data forms ...... 7 7. Sampling kits ...... 8 7.1 Sample box contents ...... 8 7.2 Ordering sample kits ...... 10 7.3 Action on receipt of sample box...... 10 8. Sampling ...... 11 8.1 Equipment ...... 11 8.2 Timing ...... 11 8.3 Data recording immediately before all sampling ...... 11 8.4 Sample labels ...... 12 8.5 Sample point preparation ...... 12 8.6 Filling sample bottles ...... 13 8.7 Data recording immediately after completion of all sampling ...... 13 8.8 Filled sample bottles ...... 14 9. Data requirements ...... 15 10. Sample despatch ...... 16 APPENDIX 1 ...... 18 Sampling Points ...... 18 A1.1.1 Open Loop Systems ...... 19 A1.1.2 Closed Loop Systems ...... 20 A1.1.3 Hybrid Systems ...... 21 APPENDIX 2 ...... 23 Forms & Examples ...... 23 APPENDIX 3 ...... 32 Other Documents ...... 32

1. Introduction There have been concerns expressed that there is not enough information on the composition of scrubber wash water discharges. This has led to perhaps unfounded concerns about the operation of marine exhaust gas cleaning systems in some ports in the European Union.

Following a meeting of the EC’s European Sustainable Shipping Forum (ESSF) scrubber working group on the 2nd July 2014, it was agreed between the Exhaust Gas Cleaning Systems Association, EGCSA and the Association of Port Reception Facility Providers, Euroshore to run a joint campaign of wash water sampling to establish a better understanding of the possibility of harmful components in open and closed loop wash water discharges and to determine the likely concentrations.

During 2015, EGCSA and Euroshore worked with ship operators and scrubber manufacturers to sample the wash water in the exhaust gas cleaning systems of 10 ships and the seawater receiving the wash water discharges.

Following review of the analytical data from this first sampling, it has been agreed that a second round of sampling will be undertaken during 2016/17, which will focus on the concentration of Polycyclic Aromatic Hydrocarbons (PAH) and metals in the wash water discharges and seawater surrounding the ship.

This programme is also aligned with IMO’s requirements in MEPC. 259 (68) – 2015 Guidelines for Exhaust Gas Cleaning Systems, which requests that ship-owners undertake sampling and testing of at least 2 samples over a 24-month period after scrubber system commissioning.

2. Purpose of this document PLEASE READ CAREFULLY Correct sampling and repeatable/reproducible laboratory analyses are critical to the success and validity of the scrubber water analysis programme. This document therefore details: • Information needed by EGCSA before sampling, including basic ship, engine and scrubber details, identification of sampling points on the scrubber system and how engine power is to be obtained. • The sample kits that must be used for the programme • How kits can be obtained and the logistics of returning filled sample bottles to the laboratory, including maximum sample preservation times. • Sampling procedure and the importance of cleanliness and sample point flushing • Ship, engine and scrubber operating data that must be collected during sampling • Details of laboratories that must be used

3. Important notes • Ship-owners will be offered complete anonymity with respect to the sample source • The management of sampling will be by EGCSA • It is intended that ship’s crew take the majority of samples this time • Ship names will be replaced by a code. The ship’s identity will be held by the EGCSA secretariat and will not be released • Ship operators will be provided with analysis results for their ship • The sharing of anonymised sample analysis results from all ships and reporting of the data to ESSF will be undertaken jointly between Euroshore and EGCSA and no information will be released without mutual agreement • The costs of supplying sample boxes to the ship’s agent and all analyses will be for EGCSA and Euroshore. • The ship operator will be responsible for the cost of returning the samples in the sample bottle box to the laboratory by courier.

4. Quick guide SHIP OPERATOR: Nominate vessel for scrubber water sampling

FIRST ACTIONS - see section 6 SHIP: provide basic vessel detail to EGCSA SHIP: provide scrubber system screenshots/ drawings to EGCSA SHIP/EGCSA: identify and agree sampling points (see Appendix 1) SHIP: advise EGCSA of the vessel's method of obtaining engine power(s) EGCSA: send sampling data forms 1 & 2 with vessel's basic details to ship (see Appendix 2)

SAMPLING KITS - see section 7 SHIP: order one sample kit per scrubber unit from EGCSA (see section 5)* SHIP: provide agent and vessel contact details to EGCSA EGCSA: arrange sample kit supply with laboratory SHIP: on receipt, open the sample box and put ice packs only into a freezer SHIP: keep sample bottles in the box in a cool place (but not a freezer)

SAMPLING - see sections 8 & 9 SHIP: Ensure steady engine and scrubber system operation SHIP: Ensure NO SOOT BLOWING SHIP: Take samples no more than 24 hours before berthing SHIP: Ensure sample points and sampling equipment are VERY CLEAN SHIP: Ensure sample points are thoroughly flushed SHIP: Wear PPE as bottles for metals analysis contain small amounts of acid preservatives SHIP: Completely fill sample bottles and complete sample bottle labels SHIP: Stow samples in the box in a cool place (but not a freezer) SHIP: Collect engine & scrubber operating data before & after sampling SHIP: Complete sample data forms 1, 2 (chain of custody) (see Appendix 2)

DESPATCH - see section 10 SHIP: Despatch samples to laboratory as soon as possible after arrival at the berth* SHIP: Email form 1 and any scrubber system screen shots to EGCSA SHIP: Put freezer packs and form 2 into sample box, secure lid & attach address labels SHIP: REMEMBER form 2 must be anonymised with the vessel code not the ship name SHIP: Include a zero value customs declaration only if necessary (see Appendix 3) SHIP: Advise agent to use 48 hour courier SHIP: Advise agent not to send box if it will arrive at the lab on a weekend (Saturday/ Sunday) and to keep the sample box in a cool place (but not a freezer) SHIP: Advise EGCSA of sample despatch and agent's contact details

EGCSA: Advise ship operator of analysis results

*Supply and despatch of sample box to be in mainland Europe unless in USA by special arrangement

5. Points of contact EGCSA will be the sole point of contact for the sample analysis programme. The following persons will manage all enquiries, including those regarding: • Sample kit orders • Sampling points and procedure • Data from engine, boiler and scrubber systems • Transport of samples to the laboratory; and • Analytical data

First point of contact • Insert contact details

Second point of contact • Insert contact details

6. First actions 6.1 Sample point identification Following agreement to participate in the programme, EGCSA will need to discuss the ship’s scrubbing system in detail with the vessel’s Technical Manager and Chief Engineer in order to identify sample points and ensure representative sampling.

A screen shot from the scrubber system computer display, system schematic, pipeline drawing or photographs will be required.

Wherever possible sampling should be from a point immediately adjacent to the full flow of the process water. The diagrams in Appendix A1.1 should be used to help identify the sample points. It is recognised that these may not be fully applicable on all ships. Some typical variations from the standard arrangement of scrubbers are also listed in Appendix A1.2, together with recommendations for sampling of these systems.

6.2 Power measurement Engine (and if relevant, boiler) power is a critical parameter for normalisation of sample analysis data and has to be recorded relevant to each of the scrubber units at the time of sampling. How power is measured/recorded varies from ship to ship and can be more complicated for a scrubber unit treating the exhausts from multiple engines and/or boilers.

On many ships a direct reading of power is not available and so how it is to be determined must be agreed before sampling can be undertaken.

6.3 Ship information The following information will also be required • Ship’s name • IMO number • Ship built date • Ship designation for engines/boilers with scrubbers installed (e.g. Port Main Engine, No.1 Aux Engine etc.) • Manufacturers of engines/boilers with scrubbers installed • Type numbers of engines/boilers with scrubbers installed • Maximum Continuous Ratings (MCR, kW) of engines with scrubbers installed • Power of boilers with scrubbers installed (further discussion will be required if the boiler exhaust is scrubbed) • Number of scrubber units • Scrubber manufacturer • Scrubber type (open loop, closed loop or hybrid; scrubbing single or multiple engines/boilers)

6.4 Ship’s code and sampling data forms Before sampling EGCSA will send to the ship 2 forms containing the agreed basic information about the ship, its engines, boilers, if relevant and scrubbers. The ship’s code for use with the laboratory will also be provided. See Appendix 2 for examples of the forms.

These forms must be used to record data before and after sampling. See sections 8 and 9 for further information.

7. Sampling kits 7.1 Sample box contents It is recognised that scrubber systems vary in configuration and arrangement, however, a baseline sample kit will typically comprise an outer carton/box (which should be kept and used for returning the samples) an inner insulated box which contains ice packs and 6 bottles to enable 2 samples to be taken from each of the 3 positions shown in the diagrams in Appendix A1.1**: 1. Seawater inlet for open loop scrubbing (or seawater surrounding the ship for closed loop scrubbing) 2. Wash water after scrubber, but before wash water treatment 3. Wash water overboard discharge, after wash water treatment, but before any dilution or chemical pH adjustment

**Please note: the exact number of sample bottles supplied will depend upon initial discussions about the scrubber system configuration and the number of sample points identified (see section 6).

Samples from each of these points will be analysed for: 1. PAH (EPA priority 16 by GC-MS – e.g. EPA 8270) 2. Metals (Arsenic, Lead, Cadmium, Chrome, Copper, Nickel, Vanadium, Zinc – by ICP-MS e.g. EPA 200.8)

Figure 1 shows the box and bottles. • X ml/litre green glass bottle for PAH analysis • Y ml/litre plastic bottle for metals analysis (bottle contains 1 ml of concentrated HNO3 (nitric acid))

The insulated sample bottle box will be posted in an outer carton/box, which should be opened carefully and retained for returning the filled samples to the laboratory.

Figure 1: Sample Bottle Kit (ice packs not shown) Each box contains 2 sample bottles (1 x metals and 1 x PAH) for each sample point identified during initial discussions Example photograph – replace as required

7.2 Ordering sample kits • Sample kits can only be ordered via EGCSA – see points of contact • Typically, sample kits will only be supplied in main European ports (Baltic, North Sea, Atlantic, western Mediterranean) *** • A minimum of one week’s notice is required. (Note a sample kit has a maximum shelf life of six months)

Information needed at time of order: • Ship: o Name o Contact name onboard o Email address o Telephone • Port of delivery • Vessel ETA/ETS • Agent: o Company name o Contact name o Postal address o Email address o Telephone

*** For a small number of selected vessels only visiting or trading in the North America ECA, it may be possible to arrange to supply sample kits and undertake laboratory analysis in USA. This will be by separate arrangement.

7.3 Action on receipt of sample box On receipt, the sample box but not the bottles should be opened and the 2 ice packs put into the freezer. The box with bottles should be stored in a cool place but not a freezer.

Figure 2: Ice packs in box Example photograph – replace as required

8. Sampling The sample points agreed with EGCSA must be used. These are given on data forms 1 and 2 (see Appendix 2 for examples)

Correct sampling and repeatable/reproducible laboratory analyses are critical to the success and validity of this analysis programme. Planning and preparation are therefore vital.

8.1 Equipment AS THE TESTS FOR PAH HAVE VERY LOW LIMITS OF DETECTION (PARTS PER BILLION) IT IS IMPORTANT THAT ALL EQUIPMENT USED DURING THE TAKING OF SAMPLES IS THOROUGHLY CLEAN.

THE USE OF ANY HYDROCARBON BASED CLEANING AGENTS OF THE SAMPLING POINT MUST BE AVOIDED.

HOSES THAT ARE ALREADY IN-SITU MUST NOT BE USED FOR FILLING OF SAMPLE BOTTLES BECAUSE OF THE RISK OF SAMPLE CONTAMINATION. IN GENERAL, THE USE OF HOSES, FUNNELS AND SECONDARY CONTAINERS SHOULD BE AVOIDED.

See further information below at 8.5 and 8.6 regarding filling of sample bottles.

8.2 Timing Samples should be taken no more than 24 hours before berthing. (see section 10 regarding the maximum allowable sample preservation time of 7 days before PAH analysis at the laboratory, which may be factor to consider if the vessel is to be held for an extended time at anchor).

The ship should be moving at steady speed throughout the sampling exercise at as high a power as is operationally practical. (It is recognised that the need to meet schedules on regular routes, the uncertainties of spot market operation, weather and sea conditions and the need to save fuel can all effect the power level that can be practically achieved or is operationally allowable.)

Should auxiliary engines be fitted with exhaust gas scrubbers, samples may be taken while the vessel is at sea or at berth, and should be operated at the highest practical load.

Engine and scrubber system operating conditions must be steady.

SOOT BLOWING MUST NOT BE CARRIED OUT DURING THE SAMPLING.

8.3 Data recording immediately before all sampling Before taking samples, it is important to record the following operational information on the forms provided (see next section for more details on data to be recorded and Appendix 2 for examples): • Ship position • Actual engine power relevant to each of the scrubber units being sampled. This is a critical parameter for normalisation of sample analysis data. How power is measured/recorded varies from ship to ship and can be more complicated for a scrubber unit cleaning the exhausts from multiple engines and boilers. the scrubber arrangement and power measurement must be discussed with EGCSA before proceeding. • Wash water flow rate to overboard for each of the scrubber units being sampled • From the scrubber control screen or local instrumentation stations:

o pH at seawater inlet (if applicable) and overboard discharge o Turbidity at seawater inlet (if applicable) and overboard discharge before dilution/chemical addition for pH correction o PAH at seawater inlet (if applicable) and overboard discharge before dilution/chemical addition for pH correction

8.4 Sample labels The ship’s code name and the sample point description from the data forms (see Appendix 2 for examples) must be added to each label. It is suggested this is done before sampling.

After filling the sample bottle take a note of the date and time of sampling. This will be required for the data forms.

Ship code name here

e.g. Scrubber Overboard

Label for glass bottle for PAH Ship code name here analysis

Label for plastic bottle for metals analysis e.g. Scrubber Overboard

Figure 3: Sample bottle labels. Examples - replace as required.

8.5 Sample point preparation The sample points agreed with EGCSA must be used.

While the instrumentation stations at scrubber seawater inlet and overboard discharge typically have a valve from which samples can be taken, this is not always the case. For example, it may be necessary to take before wash water treatment samples from gauge connections after each scrubber unit. Vent valves on sea chests may also be in quite inaccessible places at lower floor plate/bilge level when taking some seawater samples

AS THE TESTS FOR PAH HAVE VERY LOW LIMITS OF DETECTION (PARTS PER BILLION) IT IS IMPORTANT THAT THE SAMPLE POINT IS THOROUGHLY CLEANED AND ANY OILY RESIDUES REMOVED. THE USE OF ANY HYDROCARBON BASED CLEANING AGENTS MUST BE AVOIDED.

THE SAMPLE POINT MUST BE THOROUGHLY FLUSHED TO REMOVE ANY POSSIBLE DEBRIS, UNREPRESENTATIVE MATERIAL AND PRODUCTS OF CORROSION FROM AREAS OF STATIC WATER OR LOW FLOW.

AT LEAST 10 LITRES OF WATER SHOULD BE RELEASED PRIOR TO TAKING THE SAMPLE AND THE WATER FLUSHED THROUGH THE SAMPLE POINT SHOULD HAVE REACHED A STABLE LEVEL OF CLARITY. ANY DIRTY HOSES AND BUCKETS USED FOR CLEANING OR TO COLLECT WATER FLUSHED THROUGH THE SAMPLE POINT MUST NOT BE USED FOR SAMPLE COLLECTION.

8.6 Filling sample bottles Sample bottles should be filled at each sampling point in as short a period as possible under steady engine and scrubber operating conditions.

IF THIS IS UNAVOIDABLE BECAUSE OF THE LOCATION OF THE SAMPLING POINT ALL EQUIPMENT MUST BE AS NEW AND THOROUGHLY CLEAN.

IT IS IMPORTANT THAT THE POSSIBILITY OF CROSS CONTAMINATION BETWEEN SAMPLES IS AVOIDED. IT IS SUGGESTED THAT FOR BEST PRACTICE THE SEA WATER SAMPLES BE TAKEN FIRST, FOLLOWED BY OVERBOARD DISCHARGE SAMPLES, FOLLOWED BY BEFORE WASH WATER TREATMENT SAMPLES.

The sample bottles are supplied pre-cleaned and prepared ready for immediate sampling. Note that the sample bottle should only remain unsealed for the few seconds it takes to fill the bottle completely and without air gap. The seal and cap should be fitted immediately after filling. As the sample bottles for metals analysis contain small amounts of acid preservative it is essential that appropriate safety wear be used.

After filling the sample bottle take a note of the date and time of sampling. This will be required for the data forms.

8.7 Data recording immediately after completion of all sampling Immediately after taking all samples it is important to record the following operational information on the forms provided (see next section for more details on data to be recorded and Appendix 2 for examples): • Ship position • Actual engine power relevant to each of the scrubber units being sampled. As before power is a critical parameter for normalisation of sample analysis data. How power is measured/recorded varies from ship to ship and can be more complicated for a scrubber unit treating the exhausts from multiple engines and boilers. The scrubber arrangement and power measurement must be discussed with EGCSA before proceeding. • Wash water flow rate to overboard for each of the scrubber units being sampled

• From the scrubber control screen or local instrumentation stations: o pH at seawater inlet (if applicable) and overboard discharge o Turbidity at seawater inlet (if applicable) and overboard discharge before dilution/chemical addition for pH correction o PAH at seawater inlet (if applicable) and overboard discharge before dilution/chemical addition for pH correction

8.8 Filled sample bottles On completion of sampling, the sample bottles should be stowed in the sample box and removed from the engine room to a cool place. As some bottles are glass the box must not be put into the freezer.

NOTE: This section of the guide is also included in the sample box. If a copy of the full guide is required, please contact:

• Insert contact details

9. Data requirements Before sampling, dedicated forms based on discussions with the ship’s Technical Manager and Chief Engineer will be sent to the ship by EGCSA. Examples are shown at Appendix 2.

Note: the sample box contains a copy of the sampling instructions - section 8 from this guide, pre- printed address and URGENT delivery labels. Copies of the labels (and a customs declaration form should it be needed) are shown at Appendix 3.

• Form 1 should be completed and sent to EGCSA only and not the laboratory. The following data are required. To supplement the form, it is recommended that photographs or screen shots from the scrubber system control & reporting computers at the time of sampling are also sent. o Latitude and longitude (before and after sampling) o Engine power (or % of MCR) (before and after sampling) o Daily fuel consumption rate at time of sampling (t/day) o Fuel analysis (a copy of the analysis report, if available); or o Fuel viscosity; and o Fuel sulphur content o Hybrid scrubber operating mode during sampling (open or closed loop) o Open loop wash water flow rate through scrubber (before and after sampling); or o Closed loop discharge flow rate before dilution (before and after sampling) ▪ This may need prior discussion with the scrubber manufacturer if no flow meter is fitted o Closed loop discharge: intermediate or continuous o Seawater inlet (if applicable) & overboard pH reading (before and after sampling) o Seawater inlet (if applicable) & overboard PAH reading before dilution/chemical addition for pH correction, (before and after sampling) o Seawater inlet (if applicable) & overboard turbidity reading before dilution/chemical addition for pH correction, (before and after sampling) o Dilution water flow rate (if applicable) o Sampling date and time (at each sampling point) o If the system uses chemicals a record of the chemical name and dosage rate during sampling o Any other relevant information

• Form 2 is a chain of custody, which contains information for the laboratory. THIS MUST BE RETURNED TO THE LABORATORY WITH THE SAMPLES IN THE RE-USABLE BOX. (A blank copy may be sent with the box – this can be disregarded). REMEMBER THE EGCSA CODE ASSIGNED TO THE SHIP MUST BE USED IN PLACE OF THE SHIP’S NAME TO ANONYMISE THE ANALYSIS RESULTS. • The following information should be completed: o Sample bottle label barcodes (see figure 3) o Sampling date and time (at each sampling point) o Seawater inlet (if applicable) & overboard pH reading (before and after sampling)

10. Sample despatch Table 1 shows the maximum allowable sample preservation time before analysis at the laboratory.

MAXIMUM TIME SAMPLING TO ANALYSIS PAH 7 days Metals 1 month

Table 1: Maximum allowable sample preservation time before analysis

The ship should arrange with its agent shipment of the sample box by courier to the following laboratory address:

• Insert contact details

The samples should be despatched as soon as possible after arrival at the berth.

Between sampling and arrival, the samples should be kept in the box in a cool place, but not a freezer.

Immediately before handing over the samples to the agent, the ice packs should be put into the box along with chain of custody form 2 (REMEMBER: form 2 must be included for the laboratory to undertake analysis. It must also be anonymised with the vessel code rather than vessel name). The insulated box should be placed inside the cardboard outer box and taped closed. Attach the address and URGENT labels to the outer box.

Usually it is not necessary to include a customs declaration as these are water samples of zero commercial value and to preserve anonymity it is recommended it is not included unless requested. However, should it be required a letter that can be used is shown at Appendix 3.

A standard courier service can be used and a special overnight service is not required. However, the agent must instruct the courier that the sample box is to be delivered to the laboratory within 48 hours of collection.

As such it is recommended that samples are only taken before ports from where this can be achieved i.e. from main European ports (Baltic, North Sea, Atlantic, western Mediterranean)

Experience from the first round of sampling has shown that there can be delays in collection and delivery by couriers. Typically, standard couriers do not collect after 17:00, which does not fit well with ships’ schedules. The laboratory is also not open to receive samples or undertake analyses at weekends or after 17:00 hours. If, for example, the delivery will coincide with a weekend, then under most circumstances courier collection on a Monday morning should still allow PAH analysis within the 7-day maximum preservation time: • Sampling: maximum 24 hours before berth • Agent: collection of samples from ship as soon as possible after berthing • Courier: collection of samples from agent as soon as possible (if vessel berths at 17:00, then there can be up to a 15-hour delay before the courier collects from the agent) • Courier: maximum delivery time of 48 hours

• Contingency: for weekend 60 hours

The agent should be instructed not to pass the samples to the courier if they cannot be delivered before a weekend. Should this situation arise the agent should hold the samples and pass to the courier at opening of business on Monday morning. Samples should be stored in a cool place but not a freezer while waiting for courier collection

The ship should advise EGCSA (see section 5 - points of contact) when the samples have been taken and collected, and provide contact details for the agent: • Agent company name • Contact name • Email address • Telephone number

This will enable EGCSA to track progress of the sampling and delivery – any samples received by the laboratory outside of the 7-day maximum preservation time will not be analysed for PAH

AN IMPORTANT PART OF EACH SHIP SAMPLING IS PRE-PLANNING TO TAKE INTO ACCOUNT THE SHIP’S SCHEDULE AND ORGANISING THE MEANS BY WHICH SAMPLES WILL BE COLLECTED AND DELIVERED TO THE LABORATORY, WITH A CONTINGENCY PLAN FOR SHIP DELAYS.

APPENDIX 1 Sampling Points

A1.1.1 Open Loop Systems

✓

2 ✓ 3

✓ 1

 Figure A1.1.1: Open loop system sampling points 1. Seawater inlet 2. Wash water after scrubber, but before wash water treatment 3. Wash water overboard discharge, after wash water treatment, but before any dilution or chemical pH adjustment

A1.1.2 Closed Loop Systems

✓

2 ✓ ✓ 3

Figure A1.1.2: Closed loop system sampling points 1. Seawater (see A1.2 point 3, regarding sampling seawater and closed loop scrubbing) 2. Wash water after scrubber, but before wash water treatment 3. Wash water overboard discharge, after wash water treatment, but before any dilution or chemical pH adjustment

A1.1.3 Hybrid Systems

2 ✓

3 ✓

1 ✓  Figure A1.1.3a: Hybrid system open loop mode sampling points 1. Seawater inlet 2. Wash water after scrubber, but before wash water treatment 3. Wash water overboard discharge, after wash water treatment, but before any dilution or chemical pH adjustment

2 ✓

✓ 3

✓  Figure A1.1.3b: Hybrid system closed loop mode sampling points 1. Seawater (see A1.2 point 3, regarding sampling seawater and closed loop scrubbing) 2. Wash water after scrubber, but before wash water treatment 3. Wash water overboard discharge, after wash water treatment, but before any dilution or chemical pH adjustment

A1.2 Other scrubber system arrangements

1. Multiple scrubber units – one seawater inlet a. Take one set of samples* of sea water from the instrument monitoring station, sea chest or sea water pump serving the whole scrubber system. b. Take other samples as per Appendix A1.1 or point 2 in this section.

2. Multiple scrubber units – one wash water treatment system, one overboard discharge a. Take seawater samples as per Appendix A1.1 or points 1 or 3 in this section. b. Take one set of samples* after each of the scrubber units before the wash water pipework is joined into the common wash water treatment system. c. Take one set of samples* from the combined overboard discharge before any dilution or chemical addition to correct discharge pH

3. Closed loop system or hybrid system in closed loop mode – no seawater inlet a. Take one set of samples* from a sea chest or seawater cooling pump forward of the scrubber overboard discharge. (This could be the seawater pump supplying the scrubber system coolers) b. Take other samples as per Appendix A1.1 or point 2 in this section.

*One set of samples from a sampling point = 2 bottles (one for PAH and one for metals analysis) – see Figure 1

APPENDIX 2 Forms & Examples - replace as required.

Note: • Forms 1 & 2 will be sent to the ship by EGCSA • EGCSA will pre-fill the grey cells in the forms with information shown in section 6.3 • Yellow cells in the forms must be completed by the ship before and/or after sampling • Examples are included in this Appendix

APPENDIX 3 Other Documents – update as required

SHIP GUIDE SCRUBBER WATER SAMPLE ANALYSIS PROGRAMME