Marine Scrubbers:

The Guide 2015

The Comprehensive Resource
For Marine SOx Scrubbers

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 Marine Scrubbers:
The Guide 2015

Expert Contributor: Catherine Austin

Editors: Fiona Macdonald & Isabelle Rojon
Published by: Fathom Maritime Intelligence
Design: Benjamin Watkins

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marine | energy | environment

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First published in 2015 by Fathom Maritime Intelligence.

Copyright 2015 Fathom Eco-Efficiency Consultants Ltd.

All rights reserved. No part of this publication may be reproduced or stored or transmitted by
any means or in any form, electronically or mechanically, including photocopying, recording, or
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ISBN: 978-0-9932678-9-5

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reproduced in this book. However, the publishers would be pleased, if informed, to correct any
errors or omissions in subsequent editions of this publication.
 Contents

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Abbreviations IV

1 International & Regional Sulphur Regulation 1

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1.1   MARPOL Annex VI 2
1.1.1     Regulatory Control 4
1.2   International SOx & PM Emission Regulation 4
1.2.1    Why Are SOx & PM Regulated? 5
 1.2.2    What Does Regulation 14 Enforce? 6
  1.3   Emission Control Areas 7
  1.3.1
 1.3.2
1.3.3
  1.4
1.5
1.5.1
 1.5.2
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   How And Why Are ECAs Designated?
  Where Have ECAs Already Been Established?
  Possible Future ECAs
  Overview Of Compliance Options
  Regional Regulations 
   EU Sulphur Directive 2012/33/EU
   Hong Kong Fuel Switch Scheme
7
8
10
11
11
11
13
 1.5.3    Turkish Regulations 14
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2 Scrubber Regulations, Guidelines & Enforcement 15
2.1   International Regulations & Guidelines For Scrubber Use 16
2.1.1     The 2009 Guidelines For Exhaust Gas Cleaning Systems 16
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2.1.2    Statutory Scrubber Approval Procedures 17

2.1.3   Monitoring Requirements 17
2.1.4   Documentation Requirements 19
2.2   Washwater Discharge Regulations 22
2.2.1   International Washwater Regulations   22
2.2.2    United States Washwater Regulations
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24
   
3 The Market Landscape 27
3.1   The History Of Scrubbers In The Marine Market 28
3.2   An Overview Of The Current Market 30
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 3.2.1    Snapshot Of Key Orders And Installations 31

 3.2.2    Distribution Of Scrubber Uptake By Ship Type 31
 3.2.3    Uptake Of Scrubbers By Scrubber Type 33
3.2.4    Installations Of Scrubbers On Newbuilds And Retrofits 34
3.3   Drivers And Barriers To Uptake 35
3.3.1   Drivers 35
3.3.2   Barriers 38
3.4   Looking Into The Future 41

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 4 Scrubber Technologies 43
4.1  Introduction 44

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4.2   Wet Scrubbers 44
4.2.1   Open-Loop Systems 44
 4.2.2   Closed-Loop Systems 47

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4.2.3   Hybrid Systems 47
4.3   Dry Scrubbers 49

5 Choosing A System: Cost Considerations 51

5.1  Introduction 52
5.2   CAPEX Costs Examined 52
5.3   OPEX Costs Examined 55
5.3.1
5.3.2
5.3.3
5.3.4
5.3.5
5.4
5.4.1
  Crew Training

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  Required Chemicals (Closed-Loop Scrubbers)

  Maintenance And Repair

  Backpressure And Noise
    Disposal Of The System
  Return On Investment
    Financing Options
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55
56
56
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57
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5.5   Life-Cycle Cost Analysis 61
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5.5.1     Example 1: LCCA For A Wet Scrubber 62
5.5.2     Example 2: LCCA For A Hybrid Scrubber 63
5.5.3     Example 3: LCCA For An Open-Loop Scrubber With 80% ECA Operation 65
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5.5.4     Example 4: LCCA An Open-Loop Scrubber With 50% ECA Operation 67

5.6   Additional Considerations 69

6 Practical Considerations 71
6.1  Introduction 72
6.2   Considerations For All Scrubber Systems 72
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6.2.1   Weight And Stability Of The Scrubber 74

6.2.2   Exhaust Backpressure 76
  6.2.3   Electrical Consumption 76
  6.2.4   System Faults 77
6.2.5   System Access 77
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6.2.6    Exhaust Gas Bypass 78

 6.2.7    Auxiliary Equipment Considerations 78
6.3   Practical Considerations Specific To Scrubber Type 79
6.3.1     Wet Scrubbers 79
6.3.2   Dry Scrubbers 85

7 Frequently Asked Questions 87

8 Review Of Systems And Suppliers 91

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CHAPTER ONE

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International & Regional Sulphur
Regulations

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 1.2.2 WHAT DOES REGULATION 14 ENFORCE?
The parameters of Regulation 14 require that:
Outside ECAs, the maximum limits for sulphur content of the fuel oils are:

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• 3.50% on and after 1 January 2012.
• 0.50% on and after 1 January 2020.

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The 0.50% limit is subject to a global review of the availability of such fuel oil.
The review must be completed by 2018 and may recommend the postponement of
the 0.50% limit until 2025.

Inside ECAs, the maximum limits for sulphur content of the fuel oils are:

• 1.00% on and after 1 July 2010.

• 0.10% on and after 1 January 2015.

in Figure 2. PA
The SOx requirements under Regulation 14 of MARPOL Annex VI are illustrated

Figure 2. MARPOL Annex VI SOx Requirements

MARPOL Annex VI Requirements - SOx
1 Jan 2012
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Revised SOx control
on basis of fuel loaded
4.50%
1 Jan 2020*
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1 Jan 2025

3.50%

Outside ECA
Fuel oil
sulphur 1 July 2010
limits 1 Jan 2015
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1.50%
1.00%
0.50% Inside ECA
0.10%
*Depending *Depending on the outcome
on the outcome of aofreview
a review of
offuel oil availability,
fuel to
oil availability, to
be completed
be completed 2018, the2018, the 2020
2020 datecould
date could bebedeferred to 2025.
deferred to 2025.
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 1.5.2 HONG KONG FUEL SWITCH SCHEME
In 2014, the Hong Kong Environmental Protection Department adopted a new
regulation to limit local air pollution from marine traffic.

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As of 1 January 2015, Ocean-Going Vessels (OGVs) have to switch to LSF with a
maximum 0.5% sulphur content when at berth in Hong Kong waters.
All OGVs must initiate the fuel switch upon arrival at berth, complete the switch to

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LSF within one hour, then use LSF throughout the berthing period until one hour
before departure unless:
• Using LSF will pose a safety risk to the OGV.
• All practicable measures according to the established fuel switch procedures
have been followed to ensure the use of LSF as soon as possible after berthing
and as late as possible before departure.
• There is a justified and unexpected event beyond the shipmaster’s control

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causing delay to the departure of the OGV. In that case, the shipmaster must
ensure the event is recorded in the logbook.
In line with international practices, exemptions from the fuel switching requirements
are provided in the following situations:
• OGVs due to be at berth for less than two hours.
• OGVs adopting alternative fuel, such as LNG, or compliance method with
emission reduction performance comparable to that of using LSF.
• OGVs calling Hong Kong under emergency conditions.
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• Warships or ships on military services.
Enforcement will in the first instance involve inspection of logbooks detailing the
fuel switch, and Bunker Delivery Notes. Authorities may also sample the fuel being
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used while at berth and analyse the collected sample and the sealed bunker sample
for sulphur content.

The proposed maximum penalty for non-compliance will be a maximum fine of

HK$200,000 (approximately US $25,800) and up to six months imprisonment.
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Another new rule in Hong Kong bans dark smoke emissions of shade two or darker
on the ringelmann chart for three minutes or longer continuously at any one time.
In cases of contravention involving foreign ships, parties would each be liable
to a fine of HK$25,000 for a first conviction, and to a fine of HK$50,000 for any
subsequent conviction.
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Local Bunker Supplies

Additionally, since 1 April 2014, a new law requires that local bunker suppliers sell
MGO with a maximum sulphur content of 0.05%.
The regulation is primarily aimed at reducing emissions from local ships, but
will also mean that OGVs lifting distillates in Hong Kong should get a fuel with
maximum 0.05% sulphur.

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CHAPTER TWO

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Scrubber Regulations,
Guidelines & Enforcement

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 2.1.2 STATUTORY SCRUBBER APPROVAL PROCEDURES
The 2009 Guidelines set out two statutory approval procedures known as Scheme
A and Scheme B:

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• Scheme A: Unit certification with in-service parameter and emission checks.
Scheme A requires significant testing and an approval process which results
in a Type Approval.

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• Scheme B: Continuous emission monitoring with parameter checks. Scheme
B requires the use of sophisticated emissions monitoring equipment on a
continuous basis.

Both schemes are statutory approvals. Class societies have to provide unit approval
after the manufacturer’s request, approval of ship specific installation, independent
verification (Class Type Approval) and verification of performance.

2.1.3
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Scheme A permits online monitoring of the plant’s washwater effluents and
operating parameters but only occasional monitoring of air emissions. Scheme
B differs in that there is online monitoring of air emissions but only periodical
monitoring of washwater effluents. Scheme B assumes that MEPC Type Approval
is not present and so monitoring of air emissions is required.

MONITORING REQUIREMENTS
The data resulting from the various monitoring requirements in the 2009 Guidelines
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are to be recorded onto a robust, tamper proof, read-only device together with
time and ship’s position signals capable of producing period reports demonstrating
compliance as required. This data should be retained for a minimum of 18 months
from the date of recording.
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2.1.3.1 SCHEME A
Under ‘Scheme A’, the scrubber is formally tested to assess its operational
behaviour, approved and certified before being put into service.

Different fuels and loads are required to prove that the scrubber can comply with the
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emission limits. Each scrubber unit approved under this Scheme would be issued
with a SOx Emissions Compliance Certificate (SECC). Periodic survey and testing
will occur to ensure the system is operating within the standards that have been
previously approved.
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For Scheme A approvals, the scrubber must be certified as meeting the emission
limit value specified by the manufacturer (the ‘certified value’) for continual
operation with fuel oils of the manufacturer’s specified maximum sulphur content,
over the range of declared exhaust gas mass flow rate.

Alternatively, it is possible for the manufacturer to obtain a ‘product range approval’

for the same scrubber design by undertaking emissions testing at the highest,
intermediate and lowest capacity ratings.

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 2.2 WASHWATER DISCHARGE REGULATIONS
Scrubber washwater discharge is addressed both on an international level by the
IMO and on a regional level by the United States Environmental Protection Agency

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(EPA). Both regulations specify discharge limits and contain monitoring requirements
and resemble each other in many of the requirements. The main difference between
the two regulations is that the IMO 2009 Guidelines are voluntary, whereas the EPA
regulation sets mandatory requirements.

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For ease of understanding, the IMO and EPA regulations will be outlined separately
in Sections 2.2.1 and 2.2.2, respectively.

2.2.1 INTERNATIONAL WASHWATER REGULATIONS

The IMO washwater regulations which specify the discharge water quality criteria
and monitoring requirements for a number of parameters are contained in the 2009

2.2.1.1
Guidelines.

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DISCHARGE WATER QUALITY CRITERIA
According to the IMO 2009 Guidelines, scrubber washwater discharges should
comply with the following limits:

• pH of no less than 6.5.

• Turbidity not more than 25 formazin nephlometric units or 25 nephlometric
turbidity units above inlet turbidity.
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• Nitrates not higher than that associated with 12% NOx removal or 60 mg/l for
washwater discharge rate of 45 tons/MWh, whichever is greater.
• Depending on the washwater flow rate, the maximum concentration of PAH
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should be within the limits outlined in Table 5:

Table 5. Permitted PAH Limits For Washwater Discharge

Flow Discharge Concentration Limit Measurement Technology
Rate (μg/L PAHphe equivalents)
(t/MWh)
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0-1 2,250 Ultraviolet Light

2.5 900 Ultraviolet Light
5 450 Fluorescence
11.25 200 Fluorescence
22.5 100 Fluorescence
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45 50 Fluorescence
90 25 Fluorescence

Any scrubber washwater residues should not be discharged to sea or incinerated

onboard, but instead be delivered ashore to adequate reception facilities. The storage
and disposal of such residues should be recorded in the EGC Record Book.

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CHAPTER THREE

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The Market Landscape

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Chapter Three

3.1 THE HISTORY OF SCRUBBERS IN

THE MARINE MARKET
The 1930s saw the adoption of scrubbing technology to remove sulphur oxides

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(SOx) and particulate matter (PM) from gaseous emissions in land-based industries.
Scrubbing technologies were initially transferred to the marine market as an
inexpensive way to produce inert gas for reducing the fire hazard in the cargo tanks
of tankers during unloading. During the 1960s, scrubbers were introduced as a

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method for scrubbing exhaust gas emissions from the tanker’s boiler plant.
In 1991, the first prototype scrubber for controlling exhaust gas emissions was
installed onboard a ship, enabling thorough cleaning of gas from the main and
auxiliary engines, either by the same unit or by two separate installation units.
By 1998, the seawater scrubber had advanced enough to enable a comprehensive
field trial. The Canadian ice breaker Louis S. St-Laurent was subjected to 22 days of

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testing during a six-week transatlantic voyage. At the same time, a different scrubber
prototype was fitted to the passenger ferry Leif Ericson to investigate washwater
quality through the washwater treatment plant. In addition, installations on the
Zaandam, the Pride of Kent, and the Suula, not only demonstrated the scrubber’s
ability to remove pollutants but also to fit into the space occupied by the silencer to
maximise the available cargo space.
Due to size and space constraints on ships, scrubbers were further developed to
allow a single unit to function for both the main and auxiliary engines.
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Figure 7 provides a brief timeline of the evolution of scrubbers in the marine market.
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Figure 7. Timeline Of Scrubbers In The Marine Market

1930 Scrubbers introduced as a method to reduce emissions from plants on land.

Technology initially used for reducing fire hazard onboard ships.
1960 Scrubbers introduced for cleaning emissions from the tanker’s boiler plant.
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1991 The first prototype scrubber is installed onboard a ship.

1998 The first comprehensive trial takes place onboard the Louis S. St-
Laurent and the Leif Ericson.
2007 The Exhaust Gas Cleaning Systems Association (EGCSA) is formed
to provide information on scrubbers.
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2008 IMO accepts scrubbers as an acceptable alternative method for

complying with SOx emission reduction regulations.
2009 The first ever Sulphur Emissions Control Area Compliance
Certificate is granted to a marine scrubber.

2015 As of 31 January, CE Delft estimate 300 scrubbers to be either

installed or on order.

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 3.2.1 SNAPSHOT OF KEY ORDERS AND INSTALLATIONS
A selection of key orders and installations (up to and including 2015) include:
• The world’s first commercial order for open-loop scrubbers was placed in 2010

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by Ignazio Messina for the installation of five scrubbers from Hamworthy
Krystallon on four new 45,000 DWT Ro-Ro ships. Four scrubbers were fitted to
each auxiliary engine with an additional one for the auxiliary boiler, the target

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being mainly the Mediterranean. Since collaborating with Wärtsilä, Hamworthy
offers an option for hybrid scrubbers.
• Carnival announced their US $400 million expenditure on designing and fitting
scrubbers to more than 70 ships across its 10 brand fleet.
• Colour Line has retrofitted a Wärtsilä scrubber specifically designed for cruise
ships and ferries on a high speed ferry and is planning to install it on three
more ferries.
• Royal Caribbean has installed scrubbers on 15 ships to date, using technology

3.2.2
•
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from Alfa Laval, Wärtsilä, Belco Marine and Yara Marine.
Brittany Ferries has invested US $500 million in scrubbers.
DFDS has invested more than US $150 million in scrubbers.
In December 2014, Royal Caribbean retrofitted 13 of its ships with scrubber
technology.

DISTRIBUTION OF SCRUBBER UPTAKE BY SHIP TYPE

As the list of key orders and installations in Section 3.2.1 shows, the Ro-Ro and
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ferry industries have thus far been among the higher and early adopters of scrubber
technology due to spending lengthy operating times in ECAs and their fixed routes.

The EGCSA data from July 2014 is presented in Table 8 and shows the orders
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and installation numbers of scrubbers on different ship types. As identified by the

organisation, ferries and Ro-Ros have experienced the highest uptake of scrubbers,
with approximately 60 in place by mid-2014 accounting for 49% of the total number
of scrubbers fitted. The EGCSA identifies the second highest uptake to come from
containers and tankers with 16 applications recorded each by mid-2014.4
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Table 8. Orders And Installations Of Scrubbers On Different

Types Of Ships, Recorded In July 2014
Ship Type Orders &
Installations
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Cruise 15
Container 16
Ferry/Ro-Ro 60
Tanker 16
Bulk 11
Other 4
Total 122

Source: EGCSA (2014). Presentation held at the seminar ‘A Practical Guide to ECA Compliance in
2015’, Lloyd’s Maritime Academy, 17-18 June 2014

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EGCSA (2014). Presentation held at the seminar ‘A Practical Guide to ECA Compliance in 2015’,
Lloyd’s Maritime Academy, 17-18 June 2014
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CHAPTER FOUR

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Scrubber Technologies

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Chapter Four

4.1 INTRODUCTION
A variety of scrubbers are available to the market for reducing gaseous emissions

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of sulphur oxides (SOx) and particulate matter (PM) and ensuring compliance with
MARPOL Annex VI regulatory requirements.
For the purpose of SOx removal, a number of scrubber technology options are
available to ship owners and operators. These are:

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• Wet scrubbers with an open- and closed-loop mode.
• Hybrid scrubbers.
• Dry scrubbers.
Table 10 outlines the maximum percentage of SOx and PM emissions that wet and
dry scrubbers can remove:

Wet
Dry
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TABLE 10. Emissions Removal By Scrubber Type
Scrubber Type
>99%
>99%
SOx

Source: Lloyd’s Register (2015). Your Options for Emissions Compliance

app. 80%
80 – 90%
PM

4.2 WET SCRUBBERS

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A wet scrubber system uses a flue gas desulphurisation process to remove SOx and
PM from the exhaust gas.
Wet scrubbers are available in both an open-loop seawater mode and closed-loop
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chemical mode. The open-loop option uses high seawater alkalinity to remove SOx
whereas the closed-loop system uses an aqueous chemical solution to scrub the gas.

Waste discharge varies between the systems. In an open-loop system the washwater
is treated and then discharged into the sea. In a closed-loop system the exhaust gas
is recirculated, following a regeneration process.
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Requirements for treatment, monitoring and discharge of washwater are contained

in the IMO MEPC.184(59) Guidelines. See Section 2.2 for further information and
guidance on washwater discharge regulation and requirements.

4.2.1 OPEN-LOOP SYSTEMS

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The open-loop scrubber system, also known as the ‘seawater scrubber’, uses
seawater to remove SOx and PM from gaseous exhaust emissions (see Figure 13).
Open-loop scrubbers function by pumping seawater into the scrubber system in
which exhaust gas is sprayed at different stages. The natural salinity of the seawater
induces a chemical reaction with the SOx in the exhaust gas, forming sulphuric acid
(H2SO4) as a bi-product.
Because the washwater is treated with seawater and no chemicals are used in the
process, the washwater discharge from open-loop scrubbers can be discharged back
into the sea without recirculation.

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 Figure 13. An Open-Loop Scrubber Configuration
Seawater

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Exhaust Open-loop washwater
gas
Treated washwater

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Scrubber

Water
treatment

Sludge tank

Pump

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Source: Lloyd’s Register (2015). Your Options for Emissions Compliance

Figure 13 illustrates the process of exhaust gas cleaning via an open-loop scrubber
system. The seawater is led along the pipes to the scrubber unit where the exhaust
gas is sprayed with the water to remove pollutants. After the process is complete,
the dirty seawater is taken to the water treatment unit where it is separated from
the clean water. The black water is then pumped to the sludge tank and the clean
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treated washwater is transferred along the pipes and back into the sea.

A research study by Fridell and Salo (2014) demonstrated that for an open-loop
wet scrubber system using seawater for SO2 abatement, the abatement of volatile
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particles was very high with a 92% removal success rate and a 48% solid fraction
reduction. The study also revealed polycyclic aromatic compounds to be reduced
significantly in the exhaust. Reduction in PM were analogous to the reductions
gained if switching from heavy fuel oil (HFO) to marine gas oil (distillate).1

4.2.1.1 THE WASHWATER

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An open-loop scrubber uses centrifugal forces to separate suspended matter from

the washwater.
The suspended matter is drained away as sludge and stored in a tank while the
remaining washwater is treated and diluted for pH adjustment in preparation for
release into the sea.
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The washwater, which is filtered from the sludge using carbon particles and other
particulate fuel impurities, is likely to be in the form of a warm acidic jet (this
however depends on variables such as onboard treatment and discharge pipe
configuration).
In accordance with Resolution MEPC.184(59), discharged washwater is required
to reach a pH greater than 6.5 at a distance of 4m from the point of discharge.
Furthermore, the sludge in the waste water tank should not be released untreated
into the sea, but be disposed of at a suitable port.
See Section 2.2 for further information on washwater discharge requirements.

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Fridell & Salo (2014). Measurements of Abatement Particles and Exhaust Gases in a Marine Gas Scrubber,
Journal of Engineering for the Maritime Environment
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CHAPTER FIVE
Choosing a System: Cost Considerations

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Chapter Five

5.1 INTRODUCTION
When choosing a scrubber system, there are a number of factors which should be
taken into consideration. The capital expenditure (CAPEX) for the unit itself as well

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as varying operational expenditures (OPEX) can significantly affect the total cost
and value of the unit to the ship owner.
The value of a scrubber and its potential to ensure compliance with an economic

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advantage is influenced by an array of variables. Therefore, the following factors
should be taken into consideration for each scrubber application:

• The initial cost of the scrubbing unit, including the raw material costs and the
labour costs associated with installation (CAPEX).
• The price of fuel and the differential between low-sulphur fuel (LSF) and heavy
fuel oil (HFO).
• Operational profile of the ship.
•

•
•
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Maintenance and repair including:
- The type of fuel used as it will affect the maintenance of components such
as the pipes;
- The replacement of components.
Crew training.
Costs associated with documentation, e.g. if the scrubber fails to function
correctly then documentation will need to be provided to prove that non-
compliance was due to a technical fault.
• Uncertainty and sensitivity factors – some factors cannot be predicted or
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controlled, such as future fuel prices, inflation, regulatory uncertainty regarding
Emission Control Areas (ECAs) and the influence this will have on the quantity
of LSF or HFO consumed. The baseline or ship route can be altered in order to
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reduce voyage length but there is a high uncertainty regarding the impact this
will have on scrubbers and their life-cycle cost.
• The return on investment (ROI) which is directly related to the price differential
between HFO and LSF.
• The downtime of the ship during installation.
• The disposal of the unit once its lifetime comes to an end.
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• Current ship design, including existing freshwater capacity, ship design layout,
tank arrangement and available space.

5.2 CAPEX COSTS EXAMINED

The cost of scrubber units mainly depends on the type of scrubber, the size of the
ship and its engine size, and the required size of the scrubber.
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Table 12 shows estimated costs for scrubber equipment for two different ship types
and differing operational patterns.

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 5.4 RETURN ON INVESTMENT
The ROI for scrubber systems is principally dependent on current fuel prices,
particularly the difference in price between LSF and HFO. It also depends on the

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time period that the ship will operate in an ECA.

When considering ROI, it is essential to consider the quantity of HFO burned when
operating a scrubber versus the cost of fuel switching from HFO to LSF (distillates)

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when entering or leaving ECAs. Scrubber systems may not always be economically
viable if the CAPEX and OPEX costs are larger than the cost of switching to LSF.
The following figures provide estimates on scrubber ROI for varying fuel price and
ECA operation scenarios.

Figure 18. ROI For A Wet Scrubber With Various Fuel Price Spreads
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PAYBACK TIME (years)

CAPEX: US $5.84 million

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Discount rate: 9%
8 Projected time: 10 years
HFO price of US $650/tonne
7
ECA 0%
6
ECA 25%
5
ECA 50%
4
ECA 75%
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3
ECA 100%
2

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0
200 300 400 500 600 700 800

MGO - HFO Spread (US$/t)

Source: Green Ship of the Future (2012). ECA Retrofit Technology, Technical Report

As explained previously, fuel price differential and operational time in an ECA are
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the key driving forces behind the scrubber’s economic viability.

Figure 18 shows that for a US $350 fuel price differential and 50% ECA operational
time, the payback is approximately six years. Where the fuel price differential is low
(less than US $200), even with 100% ECA operational time, the payback is at least
seven years, highlighting the critical role fuel prices play in determining whether
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abatement technology is an economically viable long-term solution for compliance.

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CHAPTER SIX
Practical Considerations

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Chapter Six

6.1 INTRODUCTION
The practicality of installing and operating scrubber systems requires careful
consideration.

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This Chapter provides an overview of some of the practical challenges associated
with the type of scrubber used (open-loop, closed-loop, hybrid and dry).

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Combined with the Life-Cycle Cost Analysis (LCCA) information provided in
Chapter 5 of this Guide, this Chapter aims to assist ship owners in making an
informed decision regarding the integration of a scrubber into their shipping
operations.

6.2 CONSIDERATIONS FOR ALL SCRUBBER SYSTEMS

Certain practical challenges and considerations are common to all scrubbers, no

Practical Consideration
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matter what type. These are briefly summarised in Table 19. Some of the challenges
and considerations which require more attention are discussed in more detail in
Sections 6.2.1 - 6.2.6.

Table 19. Practical Considerations For All Scrubber Systems: An Overview

Why It Needs To Be
Considered
Applicable To
Newbuilds And
Retrofits?
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Physical Weight and Scrubbers vary by weight and Yes. Although for
integration stability of the have a significant influence on a newbuild the
scrubber (see the overall stability of the ship. system is a primary
Section 6.2.1) As the scrubber is placed high, component and so can
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any weight difference may render be considered early

the ship unstable. A 20 tonne on, whereas in retrofit
weight can significantly alter the cases the scrubber may
stability margin. need to be installed
where space permits,
e.g. in the weather deck
or above the main deck
enclosure.
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Water handling Particularly applicable to hybrid Yes

systems and open-loop. The large
quantities of washwater require
large power input and pipes to
hold the pressure. For a 50 MW
plant with an open-loop scrubber,
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4,500m3/hour of washwater is
required with a power of 0.5 MW
and a 30 inch diameter pipe.1
Exhaust Around 30kPa (Kilopascal) can Yes
backpressure (see be tolerated by most engines.
Section 6.2.2) Anything more than this can result
in power and engine degradation.
For 3kPa of backpressure
exceeded, performance may be
degraded by 1%.2

72 EGCSA (2011). Exhaust Gas Cleaning Systems Selection Guide

1
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EGCSA (2011). Exhaust Gas Cleaning Systems Selection Guide
2
 Space occupied The scrubber will reduce the cargo Yes, but less for
by the scrubber carrying capacity. If the scrubber newbuilds as scrubber
has the ability to replace the will be incorporated

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silencer, then space will be saved. into ship design.
Installation and Approximately six months are No. For retrofits, a
downtime required from initial contract scrubber which can
signing to installation of the be installed during
scrubber. Dry-docking schedules operation or with

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therefore need to be leveraged little downtime is
for installation. preferable.
Electrical power As scrubbers have large power Yes.
(see Section requirements, additional
6.2.3) generating capacity may be
needed.
Maintenance Corrosion of Corrosion of components of the Yes.
pipework scrubber may arise from the

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seawater.
Maintaining a This is to reduce excessive Yes.
buoyant exhaust exhaust cooling during scrubbing.
Breakdown Failure modes Careful analysis of potential Yes.
failures and the integration
of failure modes should be
considered so that in the case
of a scrubber failure, compliance
is still possible through
alternative modes such as LSF.
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Furthermore, failure modes
should be incorporated to ensure
propulsion is not lost.
Monitoring Under Scheme B (see Section Yes.
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system 2.1.3.2) if the monitoring system

were to break down, it would
not be possible to prove whether
compliance is occurring or not.
Scrubber Unit disposal Additional costs are associated Yes.
system with removing the scrubber
disposal from the ship and disposing of
it in compliance with disposal
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regulations.
Fuel Heating and Many thermal properties exist Yes.
purifying the which affect the ability for
HFO sufficient gas cleaning to take
place.
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Frequently Asked Questions

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87 www.fathommaritimeintelligence.com
 WHAT ARE THE BENEFITS AND CHALLENGES
OF USING SCRUBBERS?
The table below lists the different benefits and challenges of using scrubbers:

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Benefits Challenges
Lower fuel cost Investment cost
Greater fuel availability Novel equipment and system to be

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integrated into the ship’s core operating
procedures.
Single grade of fuel oil onboard simplifying Washwater discharge controls to be met.
bunker tank distribution and usage.
Good retrofitting possibilities, dependent on Reliability of required monitoring systems.
ship type.
Additional space and power requirements.

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Unclear interpretation of washwater
criteria by various port states and even by
individual ports.

WHAT OPERATIONAL ISSUES MUST BE CONSIDERED

WHEN USING SCRUBBERS?
Space and weight: Some systems can be fitted in an existing or extended funnel or
outside the funnel, but the weight of the unit when full and its effect on the ship’s
stability must be considered. The water treatment plants required for wet systems
E
can be located in the ship’s engine room or, dependent on the design, in one of a
number of other possible locations on the ship. Manufacturers should be able to
advise operators on the best location for individual ships.
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Waste: As the sludge from the washwater treatment system cannot be incinerated
onboard arrangements must be made for its storage and subsequent discharge
ashore. Washwater from scrubbers should be monitored and its discharge should
comply with special discharge criteria as set out in Resolution MEPC.184(59).

Power: Power requirements for a wet scrubber are estimated to be generally

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around 10-30kW for each MW of engine power. By contrast, dry scrubber power
consumption is given as being as low as 1.5-2 kW per MW of engine power.

Reliability: The various monitoring systems required will need to be reliable

enough to operate continuously as required without undue maintenance demands.
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The same applies to the washwater treatment system components. Scrubber

performance also needs to be guaranteed: operators need to have confidence that
Annex VI requirements will be met 100% of the time.

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 WHAT GUIDELINES ARE IN PLACE TO ENSURE THE
CERTIFICATION OF THE SCRUBBER?
Scrubbers have to comply with the 2009 Guidelines for Exhaust Gas Cleaning

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Systems. They specify the requirements for the testing, survey, certification and
verification of the scrubber.

Please note that the ship’s flag State (the Administration) has to approve of the

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use of scrubbers and is not mandated to accept such proposals automatically. It
may furthermore impose additional requirements to those given in the Guidelines
(Resolution MEPC.184(59)). Consequently, before ordering or installing a
scrubber, ship owners should check with the Administration whether it accepts
such arrangements and whether there are any specific requirements.

WHAT SHOULD BE CONSIDERED WHEN

SELECTING A SCRUBBER?

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When selecting a system, ship owners must consider the different timescales of
ECAs and other emissions-limiting zones and the consequential variations in SOx
limits the ship may encounter globally. Care must be taken to ensure that the system
selected and installed is capable of ‘cleaning’ the quantity of exhaust gas produced
to bring eventual emissions down to the lowest level required by the regulations in
every zone the ship may enter.

WHAT TYPES OF SCRUBBERS CURRENTLY EXIST AND

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WHAT DISTINGUISHES THEM FROM EACH OTHER?
Currently there are two main types of scrubbers:
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• Wet scrubbers that use water (seawater or fresh) as the scrubbing medium; and
• dry scrubbers that use a dry chemical.

Wet systems are further divided into:

• ‘open-loop’ systems that use seawater;

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• ‘closed-loop’ systems that use fresh water with the addition of an alkaline
chemical; and
• ‘hybrid’ systems, which can operate in both open-loop and closed-loop modes.
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Review of Systems and Suppliers

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 www.aecmaritime.com

AEC MARITIME BV
SOx Scrubbers “SOx scrubbing made simple”

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AEC Maritime has developed a simple all-in-one scrubber solution “ SOx scrubbing made simple”, one that
cools gases, removes sulphur and eliminates particulates at the same time. Because of the low backpressure, it
works with any engine, is almost maintenance-free, fuel efficient and easy to use.
AEC Maritime offers closed-loop, open-loop and hybrid scrubbers that comply with the IMO MARPOL

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standards. The AEC scrubbing system has been approved and certified.

Ship Types All ship types

Retrofit/Newbuild Both

Scrubber Type Wet scrubber. Both closed- and open-loop options are possible.
Exhaust Gas Source Both engine and boiler exhaust gas can be processed.
Covered
% Sulphur Fuel for 0.1%
Equivalent
% Particulate Removal
Real-Time Feedback

Power Requirements
Max 3.5% sulphur

85%
Yes.
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Less than 0.5% of total engine power.

Maintenance No special requirements. The system is very low maintenance as there are no moving
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Requirements parts in the open tower, no filters in the closed-loop system.
Footprint According to the company, the scrubber is currently the most compact scrubber system
on the market.
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Installation The ship has to be in dock for the initial installation but some parts can also be done at
Considerations sea. Three weeks are normally required for the installation.

Approval Procedure Scheme B

Class Society Approval Yes. Approved to IMO MARPOL standards.

Technological Maturity AEC Maritime has 20 years experience on land-based scrubbers and five years on
maritime scrubbers.
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Market Uptake Nine ships so far have been installed with an AEC scrubber, including on Scandlines
and Aggregate-Bontrup ships. Most orders have come from the ferry, bulk container and
Ro-Ro sector.

Cost of Technology Between €1,000,000-2,000,000 depending on size.

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Cost of Installation Between €800,000 - 1,500,000

Cost of Maintenance Between 0.5% - 1% of the scrubber per year.
Financing Options No.
Available

FATHOM
COMMENT
AEC Maritime’s scrubber benefits from a simple structure to ensure ease of maintenance.
According to the company, just four hours of training are required by a crew member to enable
full operational control. Furthermore, the power consumption is very low (just 0.5% engine
power is required compared to the standard 1.5%), making the scrubber one of the most92
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energy efficient SOx removal methods on the market today.
 www.croceanx.com

CR OCEAN
ENGINEERING LLC

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Blue PMS 660
Black
60% black

CR Marine Scrubber
CR Ocean Engineering (CROE) is a technology designer and vendor with roots dating back to 1917. CROE
focuses on ship exhaust pollution control system. The CR marine scrubber is highly efficient, relatively small,

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lightweight and uses a reduced water circulation system. Furthermore the system replaces the silencer, has an
all-metallic construction and it is designed to safely run dry without the complication of an exhaust bypass.

Ship Types All ship types

Retrofit/Newbuild Both

Scrubber Type Wet scrubber (open, closed and hybrid).

Both engine and boiler exhaust gas can be processed. Single engine and multi-streaming

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Exhaust Gas Source
Covered configuration is available.
% Sulphur Fuel for 0.1% 3.5%
Equivalent
% Particulate Removal >80%
% CO2 Removal Purposely operated to minimise CO2 reduction to avoid potential carbonate build-up in
piping and pumps.
Real-Time Feedback Yes. The system is provided with continuous emission monitoring for both the air emissions
and the water discharge. The operator can see at any time how the system is operating.
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Power Requirements Low electrical requirement due to the lower water amounts being pumped.

Maintenance The metallic construction of the scrubber extends its lifetime. The no-bypass system reduces
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Requirements complexity and increases the reliability of the unit.

Footprint Retains a low footprint. The no-bypass reduces the amount of space required compared
to a complex system of bypass ducting, valves and controls.
Installation Although docking is preferred for simplicity and cost, the system can be installed at sea.
Considerations Typical shipyard installation time is 1-2 weeks.

Class Society Approval ABS, DNV and Lloyd’s Register.

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Technological Maturity More than 50 years of operation on land.

Market Uptake Two closed-loop systems are being installed on a bulk carrier in North America and
three open-loop systems on two Ro-Ro ships in Europe. Marine installations include
bulk carriers, Ro-Ro and Ro-Pax. Other recent selections include cruise ships and ferries.
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Cost of Technology Very competitively priced.

Cost of Installation Fitting in funnels to reduce cost of installation.

Cost of Maintenance Minimal.
Financing Options Available Financing can be obtained through a third party partner that CROE could bring to the table.

FATHOM
COMMENT
CR Ocean Engineering’s scrubber retains the distinct advantage of installation at sea to
minimise downtime. The scrubber also offers real-time feedback, providing the ship owner
or operator with the option to adjust the scrubber for flexible use. Furthermore, CR Ocean
Engineering boast over 60 years of experience which has been channelled into the development96
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of this technology to provide an efficient SOx removal rate of more than 97.14%.
 www.fujielectric.com/products/saveblue/

FUJI ELECTRIC
SAVEBLUE WET SCRUBBER

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The SaveBlue wet scrubber has been hailed the “World’s Smallest Scrubber”, cleaning SOx and PM from exhaust
gas emissions to comply with the most stringent environmental regulations. The wet scrubber permits ships to
burn C grade bunker fuel in ECAs while complying with the recent 0.1% permitted sulphur content. The scrubber
unit incorporates a laser gas analyser which continuously measures and analyses SO2 and CO2 concentrations at

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exhaust port. The scrubber unit contains an electrostatic precipitator to remove PM from the exhaust gases while
a sophisticated wastewater treatment system separates the sludge from the washwater for disposal.

Ship Types All ship types

Retrofit/Newbuild Both

Scrubber Type Both. The closed-loop mode will be available from August 2015.

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% Sulphur Fuel for 0.1% 3.5%
Equivalent

Maintenance The exhaust gas analyser enables fast response times and improved maintenance cycles.
Requirements
Footprint The wet scrubber measures approximately 3.14m3 for a 10MW engine.
Installation Usually at dock although some components can be modified at sea.
Considerations
Between 3 and 6 weeks are required for scrubber installation but this can vary according
to ship type.
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Technological Maturity The open-loop mode has been available from October 2014 while the closed-loop mode
will be available from August 2015.
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Market Uptake The system is new to the market and so figures on orders are unknown at the current time.
Due to the small size and its ease of applicability it is expected that the scrubber will spark
particular interest among owners of smaller ships.

Cost of Technology The exact cost of the technology is unknown, however, a ROI of three years is given by
the company.
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FATHOM
COMMENT
Fuji Electric’s SaveBlue wet scrubber achieves a 50% size reduction compared to conventional
scrubbers on the market today, enabling relatively easy retrofit to ships where space is
restricted. Furthermore, the scrubber incorporates a laser gas analyser which continually
monitors SOx and CO2 emissions at sea and at port with immediate feedback to facilitate
rapid response times and improved maintenance cycles for operational efficiency. Based on
7,500 hours of operation in an ECA and a US $250 fuel price differential, Fuji Electric claim 101
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return on investment can be achieved in 3 years or less.
 www.wartsila.com

WÄRTSILÄ
Wärtsilä Exhaust gas cleaning scrubbers

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Wärtsilä provide wet scrubbers in open- and closed-loop and a hybrid configuration. Venturi & Inline
scrubber types are available for all three modules. The open-loop scrubber is based on the technology used in
Hamworthy’s inert gas system for more than 50 years. All systems comply with IMO SOx requirements both
in and out of ECAs.

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Ship Types All ship types

Retrofit/Newbuild Both

Scrubber Type Wet scrubber. Both closed- and open-loop as well as a hybrid system.
Exhaust Gas Source Both engine and boiler exhaust gas, with safety measures.
Covered
3.5 (with venturi) & 2.5 (open-loop inline)

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% Sulphur Fuel for 0.1%
Equivalent
% Particulate Removal Up to 90%
Real-Time Feedback Yes, all systems are installed with continuous emission monitoring both for exhaust gas and water.

Power Requirements Open-loop: ~1.5% of engine power

Closed-loop: ~0.5% of engine power
Maintenance Regular inspections of spray nozzles, pumps and other equipment. Calibration of
Requirements measuring equipment is required.
E
Footprint Depending on engine sizes, type of scrubber (inline or venturi) and preferred system size
(single or multiple inlet scrubbers).
Installation For the scrubber installation, some docking is always required, and is planned carefully
Considerations to follow the ship’s normal docking schedule. Some pre-work and final installations can
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be done at sea. Approximately three weeks are required for the installation.

Approval Procedure Scheme B

Class Society Approval According to customer needs.
Technological Maturity Fully developed system that has been installed and approved on many ships. Wärtsilä have
a test hall in Moss and long experience of exhaust gas cleaning.
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Market Uptake Long reference list on over 50 ships with over 100 scrubber units. References include
every type of scrubber in Wärtsilä’s portfolio (venturi, inline, open-loop, closed-loop,
hybrid…) and different types of ships (cruise, ferry, tanker, bulker, container and special
ships). Most orders so far have come from cruise ships and ferries.

Cost of Technology Starting from €1 million (a lot of factors affect the price).
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Cost of Installation Price determined by yard, but according to Wärtsilä’s experience it is 1.5 x equipment price.
Cost of Maintenance 1% of equipment cost/year.
Financing Options Yes.
Available

FATHOM
COMMENT
The Wärtsilä scrubber is one of the most widely installed across the industry, having proven
significant emission reductions across a wide number of ships. In the hybrid module, a fan
can be installed on the cold side to reduce backpressure if needed. Wärtsilä offer customised
designs based on individual requirements and ship operating profiles for maximum flexibility
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and efficiency.