3.3 Scrubber water and the marine environment
The first, and widely cited, reports on the impact the use of scrubbers have on the marine environment claimed that pollutant concentrations in discharged scrubber water are not alarmingly high and will rapidly dilute to concentrations well below toxic levels (Kjølholt et al. 2012, IMO; MEPC 74/INF.24 2018). However, recently there has been an increasing number of both reports and scientific articles showing that scrubber water is toxic to marine biota and either recommending stricter rules for where scrubbers could be used or advocating a complete scrubber ban (Hassellöv et al. 2020, Thor et al. 2021, Picone et al. 2023). Experimental studies have shown that low concentrations of scrubber water cause severe disruption of the early development of marine invertebrates, such as planktonic copepods (small crustaceans with a central position in all marine pelagic food webs), and in larvae of blue mussels, sea urchins and polychaetes (Thor et al. 2021, Magnusson and Granberg 2022, Picone et al. 2023). In some cases, significant toxic effects occurred already at concentrations as low as 0.001% scrubber water.
Vessels equipped with open-loop scrubbers discharge wastewater from the scrubbing process (scrubber water) to the ocean as long as the engine is running. In busy ship lanes and harbours, there is therefore a continuous input of this polluted water to the environment. The number of ships equipped with scrubbers has increased over the past decade. Between 2015 and 2022, the global number of vessels equipped with scrubbers increased from 242 to 4737 (Det Norske Veritas (DNV- GL)), and in the Baltic Sea the number increased from 178 in 2018 to 462 in 2020 (HELCOM 2021). The volumes of discharged scrubber water to the ocean, and also volumes of other ship related waste streams like bilge water, grey- and black water, have been calculated using the Ship Traffic Emission Assessment Model (STEAM), where input data on activity, position and technical information of most ships in operation are obtained via the automatic identification system (AIS) (Jalkanen et al. 2021). STEAM generates data on volumes of discharged scrubber water and the geographical location of the discharges. The Baltic Sea had 462 ships equipped with scrubbers in 2020, and estimations of the volumes of scrubber water generated and discharged show that they may be as high as 0.6 billion m3/year (Ytreberg et al. 2022a).
There is a clear risk that the scrubber water pollutants will be harmful to the Baltic ecosystems. Pelagic organisms are the primary target since they are found where the scrubber water is discharged, but benthic communities and sensitive coastal habitats near ship lanes will also be affected. Many stretches of shipping lanes in the Baltic Sea run close to coast lines or shallow sea areas, e.g., in the Gulf of Finland, south of Gotland, the Oresund Sound and the Belt areas. In all these areas there are zones which are important breeding and nursery grounds for fish, stopover sites for huge numbers of migrating birds feeding on invertebrates in shallow water, areas of great importance for over wintering sea birds, etc. (Larsson 2012, Sundblad and Bergstrom 2014, Kraufvelin et al. 2018). To these ecosystems the dilution of scrubber water in the sea might not necessarily be enough to keep concentrations of potentially hazardous components at safe levels. As an example, embryos of haddock developed heart malformations after exposure to diluted crude oil where the concentration of total PAHs amounted to 0.1 µg/L, which corresponds to a dilution of around 0.001% scrubber water (Sorhus et al. 2023b).
3.4 Polycyclic aromatic compounds (PACs) – one of the most toxic fractions of scrubber water
Classes of PAC
PACs are compounds with at least two benzene rings or benzene-like rings fused together. They include the better known polycyclic aromatic hydrocarbons (PAHs) but encompass also compounds with nitrogen, sulphur, or oxygen in the ring structure i.e., the heterocyclic PACs. In addition, PACs can be alkylated or contain different functional groups, allowing the PACs to include thousands of compounds. PACs without alkylation or functional groups are often referred to as parent compounds or unsubstituted compounds, while PACs with alkylation or functional groups are referred to as substituted compounds (Boehm 1964, Stout et al. 2015).
Unsubstituted PAHs receive most attention in risk assessments and in ecotoxicological research, but when alkylated PAHs are included in chemical analysis of environmental samples affected by oil spills, they are often found to occur at higher concentrations than the unsubstituted PAHs (Golzadeh et al. 2021, Grung et al. 2021). Alkylated PAHs can have one to several alkyl groups attached to the ring structure. The parent PAH and the corresponding alkylated PAHs form a “homologue series”, where each compound group has a prefix indicating the number of carbon atoms in the attached alkyl groups. A C0-PAH is hence the parent PAH, C1-PAH is a PAH with one methyl group, a C2-PAH has two methyl groups or one ethyl group, a C3-PAH has three methyl groups, one methyl group and one ethyl group, or a propyl group, and C4-PAH may have various combinations of methyl- ethyl-, and propyl groups or a butyl group. The position of the alkylation(s) on the ring structure and the various combinations of alkyl groups generate numerous isomers of alkylated PAHs. Besides the alkylated PAHs there are PAHs with an oxygen or nitrogen containing functional group attached to the parent compound. Alkyl- and oxygen containing PAHs are abundant in petroleum and oil while nitrogen- and oxygen containing PAHs are formed during incomplete combustion (Zhao et al. 2020, Goto et al. 2021).
In the 1970s, a list of 16 PAHs, consisting of compounds with 2 – 6 aromatic rings, were selected by the United States Environmental Protection Agency (US EPA) to be used when assessing risks to human health from drinking water (Andersson and Achten 2015a). The 16 US EPA PAHs were selected for three reasons: there were existing analytical standards available, they were known to occur in the environment, and they were known to be toxic. The intention was not that they should be used as a standard reference set for general risk assessment (Keith 2015). Yet this is the case for example in the EU Water Framework Directive where all PAHs that are regulated belong to the 16 US EPA PAHs (Directive 2013/39/EU). This practice has resulted in a situation where numerous PACs with potential toxic effects, such as alkyl-, oxygen-, and nitrogen containing PAHs, are not regulated at all.