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Scrubbing FAQ

Below is our list with Frequently asked questions FAQ, concerning maritime scrubbing and our Value Maritime scrubber system. We have divided the questions in 3 topics: -Technical Question, -Environmental Questions and Financial Questions. Should you not find the answer you are looking for, please contact us.

Technical

Scrubbers are to be designed to reduce emissions to equal, or less than, the required fuel sulfur limits at any load point when operating within the range of operational limits for which the unit is approved. The maximum HFO sulfur content for which this is achievable is to be stated by the manufacturer

Value Maritime Scrubbers are designed for 100% engine load and 3,5% wt Sulfur in the fuel.

IMO does not specifically limit PM but regulates the sulfate portion of PM formation through the fuel sulfur content requirements of Regulation 14 to MARPOL Annex VI. The U.S. EPA defines PM limits for Category 1 and 2 marine engines (below 30 liters displacement/cylinder). The EPA emission measurement requirements for Category 3 engines (30 liters and over displacement/cylinder) require test bed monitoring of PM. EPA certification is required for all US flagged and US registered vessels. In response to a query put forth regarding the requirements for PM limits, the EPA advised that at this point in time that there is no official guidance regarding the PM limits by substitution with exhaust gas scrubbers in lieu of using low-sulfur fuel. However, as specified in the EPA’s Final Rule for Control of Emissions from New Marine Compression- Ignition Engines at or Above 30

Liters per Cylinder, significant PM emissions control will be achieved through the ECA fuel sulfur requirements.

Environmental

IMO does not specifically limit PM but regulates the sulfate portion of PM formation through the fuel sulfur content requirements of Regulation 14 to MARPOL Annex VI. The U.S. EPA defines PM limits for Category 1 and 2 marine engines (below 30 liters displacement/cylinder). The EPA emission measurement requirements for Category 3 engines (30 liters and over displacement/cylinder) require test bed monitoring of PM. EPA certification is required for all US flagged and US registered vessels. In response to a query put forth regarding the requirements for PM limits, the EPA advised that at this point in time that there is no official guidance regarding the PM limits by substitution with exhaust gas scrubbers in lieu of using low-sulfur fuel. However, as specified in the EPA’s Final Rule for Control of Emissions from New Marine Compression- Ignition Engines at or Above 30

Liters per Cylinder, significant PM emissions control will be achieved through the ECA fuel sulfur requirements.

Value Maritime Scrubbers were originally developed to capture fine particulate matter and removes 99% PM10 and 90% PM2,5 which makes this technology unique and a frontrunner in case new PM regulation will become active.

The compliance with ECA sulfur cap requirements and 2020 global sulfur cap requirements may be through the following:

a. Use of sulfur compliant fuel for inside and outside ECA respectively, or

b. A combination of a scrubber/HFO operation outside ECA and use of 0.1% s compliant fuel inside ECA, or

c. The installation and operation of a scrubber/HFO operation inside and outside ECA that achieve

equivalent SOx emission level of 0.1% s and 0.5% compliant fuel

Washwater criteria limits for pH, PAH, turbidity/suspended PM and nitrates are defined in 10.1 of Resolution MEPC.259(68). The U.S. EPA washwater discharge limits are consistent with the IMO requirements in the VGP for 2013. However, the EPA has added some additional requirements for washwater sampling and analytical monitoring for all 16 PAHs, while the IMO requires monitoring by measuring the most common phenanthrene equivalent. Shipowners/operators must submit all monitoring data to the EPA’s reporting system unless specifically exempted from electronic reporting. Monitoring data must be submitted at least once per calendar year, no later than February 28 of the following year, on the vessel’s annual report. In addition to those requirements, the EPA is in the process of drafting a water quality certification to the VGP that would add other conditions related to

vessels in general.

In the CWA 401 Certifications for exhaust gas scrubber washwater discharge, Connecticut prohibits the discharge of exhaust gas scrubber water and Hawaii requires the reporting of specific information regarding the onboard treatment system.

Guidelines for Port State Control associated with MARPOL Annex VI are described in IMO Resolution MEPC.181 (59), where it is stated that the PSC officer should examine the “approved documentation relating to any installed exhaust gas cleaning systems, or equivalent means, to reduce SOx emissions (Reg. VI/4).” Furthermore, as per 4.2.3.2 and 5.3.2 of the Annex to Resolution MEPC.259 (68), EGCS and their monitoring systems may also be subject to inspection by Port State Control. Section 7.5 also requires that a copy of the recorded data and reports should be made available to the Administration or Port State Authority as requested.

With regard to nitrates, according to 10.1.5.2 of the Resolution “at each renewal survey nitrate discharge data is to be available for sample overboard discharge drawn from each EGCS within the previous three months prior to the survey.” However, the Administration may require an additional sample to be drawn and analyzed at their discretion. The nitrate discharge data and analysis certificate is to be retained onboard the ship as part of the EGC Record Book and is to be made available for inspection as required by Port State Control or other parties.

Value Maritime has approvals from DNVGL, Lloyds & Bureau Veritas and is proven it’s compliant system.

Financial

Our all-inclusive modular concept supports financing arrangements independent from the present ship’s financing. Thus, making even leasing for our maritime scrubber a viable and interesting option. For example, we have just signed a deal with Beequip as one of our leasing partners.