배기가스세정장치의 세정수 배출금지에 대한 법적 문제 연구

Abstract

Sulfur contents of fuel oil used in vessels are to be reduced from the current 3.5% m/m to 0.5% m/m since January 1, 2020. And according to the provisions of Regulation 4, regarding to equivalents, exhaust gas cleaning system has recently attracted attention as alternative technologies are allowed. The exhaust gas cleaning system refers to a technology for discharging exhaust gas to the atmosphere at a sulfur content of 0.5% m/m or less or 0.1% m/m or less by desulfurizing the exhaust gas emitted from the combustion engine of a ship mainly through water treatment. There is an increasing number of cases in terms of the advantage of being able to use conventional fuel oil which may be relatively inexpensive. However, in the case of an open-loop exhaust gas cleaning system, the influence of the marine ecosystem due to potential heavy metals, etc. other than the criteria mentioned in the Guidelines for Approval of the exhaust gas cleaning system is not accurately reported in terms of discharging the exhaust gas. In some countries such as China and Singapore, the ban on washing water is being announced. This is a sufficiently recognizable measure as part of realizing the precautionary principle. If harmfulness of the cleansing water is scientifically recognized and the ban on all the waters are to be taken into consideration, the open-loop exhaust gas cleaning system approved by the state in accordance with guidelines developed by the International Maritime Organization, the Grandfathering clause should be stipulated for use under normal operating conditions in accordance with the guidelines at the time of installation. It would be appropriate to apply stricter standards to exhaust gas cleaning system newly installed by revising the guidelines of the exhaust gas cleaning system by examining the hazardousness of the washing water as soon as possible.