I support theses proposed MOU amendments:
1) Institute a ban on the discharge of exhaust gas scrubber washwater from all scrubber types,
including bleed off or sludges, in MOU waters.
This proposed MOU amendment met the criteria as it was specific to th...↓
accompanied by scientific data to support the amendment. However, if adopted, some of the
wording of this amendment is likely to change to conform with regulations under the MARPOL
treaty regarding exhaust gas scrubber washwater.
2) Ecology proposes to incorporate the Vessel Sewage No Discharge Zone (NDZ) for Puget Sound
into the MOU to reflect the Washington state NDZ regulation. Chapter 173-228 Washington
Administrative Code (WAC), adopted on April 9, 2018, and effective May 10, 2018. Additional
information is available online at https://ecology.wa.gov/Water-Shorelines/Puget-Sound/Nodischarge-zone. As written, the MOU allows for treated sewage (blackwater) discharges after
advanced wastewater treatment that are now not allowed by the NDZ regulation. To be
consistent with the regulation and to prevent vessel sewage discharges in MOU waters, all
allowances of the sewage discharges in MOU waters should be prohibited. This would not affect
graywater discharge in the MOU.
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