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MARPOL

and
other legal requirements
for the
protection of the environment
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 1
Course Objectives
Objective and Approach

The objective of this course is to ensure the proper This presentation should be considered as the
understanding and the knowledge of the vehicle for all the facilitators and participants to
environmental requirements and relevant regulations lead and participate receptively to an interactive
through presenting useful information, solving and interesting training session
exercises, answering questions and creating
discussions, in order to refresh the already acquired
knowledge relative to the protection of the
environment

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 2
MARPOL
and
other legal requirements
for the
protection of the environment

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 3
What is ECT?
Environmental Compliance Training - Initial

A systematic and controlled way for ensuring that all personnel


meet or exceed the minimum requirements of the Company’s
Environmental Management System (EMS) requirements

It consists of 3 different basic modules:


 Environmental Compliance
 MARPOL and legal environmental requirements
 Handling of E/R Waste – ORB entries

This is module 2: MARPOL and legal environmental requirements


© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 4
Training Agenda
 MARPOL ANNEX I - Prevention of Pollution by Oil
 MARPOL ANNEX II - Prevention of Pollution by Noxious Liquid Substances
 MARPOL ANNEX III - Prevention of Pollution by Harmful Substances
 MARPOL ANNEX IV - Prevention of Pollution by Sewage from Ships
 MARPOL ANNEX V - Prevention of Pollution by Garbage from Ships
 MARPOL ANNEX VI - Prevention of Air Pollution from Ships
 SEEMP – Ship Energy Efficiency Management Plan
 EU MRV - IMO DCS
 VGP – Vessel General Permit
 BWM – Ballast Water Management
 BFMP – Biofouling Management Plan

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 5
Section 1

MARPOL ANNEX I
Prevention of Pollution by Oil

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 6
MARPOL ANNEX I
Handling of Oil and Oily Mixtures
from Machinery Spaces

Applicable to all Ships

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 7
Definition of Oily Bilge Water - Oil Residue (Sludge)

What is considered as oily bilge water?

What is considered as sludge?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 8
Oil Pollution Prevention - Definitions
Oily Bilge Water
The water which may be contaminated by oil resulting from leakage or maintenance
work in machinery spaces. Any liquid entering the bilge system including bilge wells,
bilge piping, tank top or bilge holding tanks is considered oily bilge water

Oily Bilge Water Holding Tank


The tank collecting oily bilge water prior to its discharge, transfer or disposal

Oil Residue (Sludge)


The residual waste oil products generated during the normal operation of a ship such
as those resulting from the purification of fuel or lubricant oil for main or auxiliary
machinery, separated waste oil from oil filtering equipment, waste oil collected in
drip trays and waste hydraulic and lubricating oils

Oil Residue (Sludge) Tank


The tank which holds oil residue (sludge) from which sludge may be disposed ashore
through the standard discharge connection or any other approved means for disposal

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 9
Tank Identification in IOPP Supplement

As oily bilge water holding tanks As oil residue/sludge tanks are


are considered those listed in considered those listed in
item 3.3
……………….... item 3.1
…………………
of the Supplement of the vessel’s of the Supplement of the vessel’s
IOPP Certificate IOPP Certificate

Any discharge overboard of bilge Must be provided with a designated


water shall be in accordance pump for disposal
with MARPOL Annex I
Must not have discharge connections
connected directly to the bilge piping
system, oily bilge water holding tanks,
tank top or oily water separators

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 10
Sample of Tank Identification in IOPP Supplement

item 3.1 item 3.3

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 11
Handling of Oil and Oily Mixtures
Oily Bilge Water Oil Residues (sludge)

• Transferred to the oil residue


• Any discharge overboard (sludge) tank for later
should be according to disposal
MARPOL Annex I
……………………………..
incinerator
• Burned in the …………………
• Transferred from the
• Delivered to
bilges to the bilge
reception facilities directly
…………………………….
holding tank for
from the sludge tank through
discharge overboard via
OWS the standard discharge
the…………
connection
• Delivered to
reception facilities • Disposed in accordance with
……………………….......
items 3.2.2 and 3.2.3 of the
IOPPC Supplement
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 12
Regenerated Fuel
Regeneration of fuel from oil residue (Sludge):
 Prohibition of transferring fuel from leakage tanks (listed in IOPP section 3.1) back to
fuel tanks unless such method is listed in item 3.2.3 or as a note in the bottom of the
IOPP supplement.
Example of entry in the Supplement Form A to the IOPP certificate.
3.2 Means for the disposal of oil residues (sludge) retained in oil residue (sludge)
tanks:
3.2.1 Incinerator for oil residues (sludge) □
3.2.2 Auxiliary boiler suitable for burning oil residues (sludge) □
3.2.3 Other acceptable means, state which.... □
1. Dirty Fuel Oil Tank oil residues can be disposed via the fuel oil
system as regeneration of fuel (Transfer to HFO Settling Tanks
Port and Starboard)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 13
Oily Water Separator (OWS)

The OWS separates oil from oily


waste water accumulated in the E/R
bilge holding tank(s) of the vessel,
before discharging it to the sea

Under MARPOL - IMO Resolution


MEPC.107(49), discharged water
has to contain less than
………………………………………… of oil
15 parts per million (ppm)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 14
Oily Water Separator (OWS)

The OWS must be:


 capable of handling any oily mixtures from the machinery space bilges
 effective over the complete range of oils which might be carried on board
 capable of handling satisfactorily oil of very high relative density or with
emulsified mixtures

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 15
Discussion
Who are allowed to operate the OWS as
per MSOPR-11.2 ?

Whenever OWS is being tested or


operated, the CE acts as the officer in
charge and shall personally record
testing and operation of the OWS in
the ORB and solely sign for it.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 16
Discussion How can we ensure that there is no method to discharge bilges overboard by
by-passing the OWS?
 By using Environmental Seals in:
 Piping connections, fittings, the OCM, and other control equipment of the OWS
 System crossover and connection valves where bilge systems tie into ballast, general
service and other pumping or ejector systems, and systems capable of bilge removal
without the use of the OWS
 Every blank or potentially removable flange associated with any piping leading
overboard, such as but not limited to the following piping: bilge, sewage, grey water,
boiler blow down, cooling water, etc.
 Any overboard valves connected to ejectors situated in compartments such as but not
limited to steering gear, bow/stern thrusters, and compartments such as the Bosun
store forward, pump rooms etc.
 Sludge and dirty oil tanks manholes in engine room spaces and all attached level,
temperature and other removable accessories fitted to them as far as practically
possible
 Portable pumps and flexible hoses
 By allowing specific personnel to discharge bilges and supervise them
 By enforcing the company’s environmental policy
 By familiarizing the personnel with the consequences of the violations of MARPOL Annex I
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 17
Oil Content Monitor (OCM)

The OCM is a monitoring equipment connected with the OWS, for


measuring, indicating and continuously detecting the oil content in
water
flag administration
 Must be approved by the……………………………..
parts per million (ppm)
 The content of oil is measured in………………………………………

 Records of the date and time of the total quantity discharged, of


the oil content and the rate of discharge shall be kept
at least 3 years
for………………………………………
 OWS and OCM to be maintained and operated as
manufacturer’s instructions
per…………………………………………….
 If OWS or OCM fails, no discharge overboard is allowed until the
defect is rectified and flag dispensation is closed out.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 18
OCM Calibration

The OCM must be calibrated at intervals not exceeding 5 years after its
commissioning, or as specified in the manufacturer's instructions, whichever
is shorter as required by MEPC.285 (70) and Company’s instructions
Calibration certificates are issued every 5 years by an approved contractor
ashore and must be:
 maintained on board
 maintained ashore by the Technical Department

When a new calibrated and certified Measuring cell for the OCM is installed
on board by the vessels C/E or Service Engineers, details along with
the name of service engineer must be recorded in the ORB (Part-I, Code I) &
PMS (Refer to MSOPR-11.3)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 19
Example of how an OWS with absorber works
1. Rough separation: An eccentric spiral pump
draws the mixture out of the bilge
2. Fine separation: A very open porous coalescer
causes, due to its oleophilic surface, fine
separation of even the smallest oil drops
3. The OCM takes samples and controls the use of
the absorber
4. Absorber bypass: If the OCM detects less than
14ppm the operation is done without the
absorber and cleaned water is guided outboards
5. Operation with absorber: If the OCM detects
more than 14ppm the water passes through the
absorber
• if after the extra cleaning the new
measurement < 15ppm, the cleaned water is
guided outboards
• if the OCM shows > 15ppm, the cleaned water
is guided back to the bilge water tank

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 20
Certificates Required On Board
IOPP (International Oil Pollution Prevention) Certificate and Supplement
 Validity for 5 years after the completion of the specific initial
inspection
 Intermediate inspection between 2nd and 3rd anniversary date* of the
certificate
 Endorsed annually by the Classification Society of the vessel (with a
window of ±3 months from anniversary date* of the certificate)
Calibration of Oil Content Monitor (15 ppm Bilge Alarm): performed by
Manufacturer or service engineer authorised by the Manufacturer
Certificate of Type Approval for Oily Water Separator: Issued once by a
Recognised Organisation (RO) on behalf of the flag administration
Certificate of Type Approval for Oil Content Monitor (15 ppm Bilge
Alarm): Issued once by RO on behalf of the flag administration

*OWS and OCM approved by the administration are accepted by USCG and no separate USCG certification is required.
*Anniversary date means the day and month of each year which will correspond to the date of expiry of the certificate.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 21
Discharge of Oil and Oily Mixtures

Name the conditions that must be satisfied to discharge of oily bilge water to sea:
MARPOL Annex 1 – Regulation 15
 The ship is en route
 The oil content is ≤ 15ppm
 The oily mixture is processed through OWS, with alarm arrangements
and automatic stopping device when discharge in Special Areas
(Please refer to the IOPP Supplement item 2.2.2 to check if the
equipment can be used in Special Areas)
 The oily mixture does not originate from cargo pump-room
bilges on oil tankers
 The oily mixture in case of oil tankers, is not mixed with oil cargo residues
 MARPOL does not set the limit on the distance to the shore for normal
operation of the OWS.
 Local regulations must be observed in waters under jurisdiction of a coastal
State.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 22
Discharge of Oil and Oily Mixtures

What are the differences between discharging of oily bilge water


outside and inside Special Areas?

There are no differences, if the previous conditions are satisfied, with the
exemption of the Antarctic Sea and Arctic waters where any discharge of oily
mixtures is prohibited

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 23
Special Areas under MARPOL Annex I
Name as many Special Areas you can

 The Mediterranean Sea


 The Baltic Sea
 The Black Sea
 The Red Sea
 The Gulfs area
 The Gulf of Aden
 The Antarctic area
 The North West European Waters
 Oman area of the Arabian Sea
 Southern South African Waters

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 24
Posting
General Practice for Documents Required to be Posted in the Vicinity of OWS:
 Bilge Piping Diagram
 Operation Instructions of the specific model of OWS
 Emergency shut down procedure of the specific model of OWS
 Areas where discharge is allowed/not allowed
 CFR Poster – for vessels calling US ports
 Calibration of Oil Content Monitor
 Certificate of Type Approval for OWS
 Certificate of Type Approval for OCM
 Poster MSOPOST-11.1

 It is the Best Practice to prepare affix a board to clearly and neatly post all required documents.
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 25
Discussion

What should you do in the case that the bilge water tanks are full
and the OWS is not working?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 26
Discussion- possible reactions
 Inform TSI and ECM in the first instance
 Carry out Risk Assessment and Management of Change
 Request for Flag Administration Dispensation Letter
 Transfer the bilges to other tank(s), approved by the Class, for later disposal or
delivery to shore facilities
 Transfer the bilges to Sludge Tank for later delivery to shore facilities
 Transfer the bilges to deck/cargo tank for later disposal (in case of tankers)
 Transfer to any non-IOPP tanks are not allowed without permission from the
Flag Administration
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 27
MARPOL ANNEX I
Handling of Oil and Oily Mixtures
from Cargo Spaces - Slops

Applicable to Oil Tankers

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 28
Discharge of Slops

Name the conditions that must be satisfied to discharge slops at sea:

 ODME and control system is operational and in use and slop tank
arrangement is available
 En route
 Distance from the nearest land ≥ 50 nm
 NOT in a special area (as per MARPOL Annex I)
 Instantaneous discharge rate of oil content does not exceed 30 liters per
nautical mile
 Total quantity of oil discharge into the sea < 1/30.000 of the total
quantity of the particular cargo of which the residue formed a part

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 29
Bilge - Sludge - Slop
Management Record Keeping

Company’s Policy

Rough notes, sounding logs and/or other documents used


by E/R personnel to record tank soundings and monitor
tank levels should be
maintained for at least 3 years

Such notes must be dated even if on scrap paper


Electronic sounding logs are not accepted (MSOPR 11.14).

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 30
Violation Consequences

What do you think that the violations of MARPOL Annex I may result in ?

heavy fines

and / or

imprisonment

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 31
Discussion

Why do you think that we must not pollute the marine environment?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 32
Discussion – Possible answers

Because:
 We destroy the environment
 It is against Company’s Environmental Policy and values
 It may result in heavy fines and / or imprisonment
 We have been committed not to do so, when we signed the EC Declaration and in
case of non-compliance we may face disciplinary action, including termination of
employment, liability for criminal, civil and administrative penalties

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 33
Section 2

MARPOL ANNEX II
Prevention of Pollution by Noxious Liquid
Substances in Bulk

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 34
Noxious Liquid Substances - NLS

Pollution Category X Category Y Category Z Other Substances


Category • Major hazard • Hazard • Minor hazard • No harm

… to marine resources and human health

Discharge is prohibited in:


Antarctic Sea, Arctic Waters & areas as per local regulations

Discharge provisions apply to ballast water, tank washings or other


residues, and mixtures containing NLS substances.
Exceptions as per P&A Manual and IMO criteria.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 35
NLS Discharge Standards
What are the discharge standards of NLS ?

≥ 7 kn (for self-propelled ships)


En route
≥ 4 kn (for not self-propelled ships)

Piping Underwater (below waterline)


Outlet Not mandatory for Category Z on ships
Location constructed before 1/1/2007

Nearest ≥12 nm and water depth


land ≥25m

Discharge of residues should be in accordance


with local requirements.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 36
Certificates & Manuals on Board

What Certificates & Manuals are on board the ship to ensure


compliance with the requirements of MARPOL Annex II ?

as per IBC Code as per MARPOL


International Certificate of Fitness International Pollution Prevention
for the Carriage of Dangerous OR
Certificate for the Carriage of Noxious
Chemicals in Bulk Liquid Substances in Bulk
(CoF) (NLS Certificate)

Shipboard Marine Pollution


Procedures & Cargo Record
Emergency Plan for Noxious
Arrangements Manual Book
Liquid Substances (SMPEP)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 37
Procedures & Arrangements (P&A) Manual

Each ship is provided with a ship-specific Procedures & Arrangements


(P&A) Manual describing all physical arrangements and operational
procedures related to ship’s cargo operations with respect to

cargo slops residue ballasting and


tank cleaning
handling handling discharging de-ballasting

which must be followed in order to comply with the requirements of


MARPOL Annex II.

Approval of the P&A Manual by the Flag or Class is mandatory

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 38
Noxious Liquid Substances – Category X

 After the unloading of a Category X substance, the relevant tank shall


be prewashed before the ship leaves the port of unloading.
 The resulting residues shall be discharged to a reception facility until
the concentration of the substance in the effluent to such facility is at
or below 0.1% by weight.
 When the required concentration level has been achieved, remaining
tank washings shall continue to be discharged to the reception facility
until the tank is empty.
 Any water subsequently introduced into the tank may be discharged
into the sea in accordance with the discharge standards mentioned
before.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 39
Noxious Liquid Substances – Categories Y and Z Substances

 With respect to the residue discharge procedures for substances in


Category Y or Z the discharge standards, previously displayed shall
apply (prewash is not always necessary).
 Especially for High-Viscosity or Solidifying Substances in Category Y
the following shall also apply:
• The residue/water mixture generated during the prewash shall
be discharged to a reception facility until the tank is empty; and
• Any water subsequently introduced into the tank may be
discharged into the sea in accordance with the above mentioned
discharge standards.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 40
Noxious Liquid Substances – Persistent Floaters

 The amendment to MARPOL Annex II includes a new definition on a


so-called “persistent floater”
 Substances classified as persistent floaters are defined by having a
viscosity equal to or greater than 50 mPa.s @20°C and/or with a
melting point ≥0°C as identified by section 16.2.7 and in column 'o'
of Chapter 17 of the amended IBC Code, e.g.
• Castor oil
• Fatty acids, (C12+)
• Groundnut oil
• Palm oil and its variations
• Paraffin wax, highly-refined
• Sunflower seed oil

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 41
Noxious Liquid Substances – Persistent Floaters
The requirements are only applicable when the port of unloading is located inside certain
regional areas, according to new regulation 13.7.1.4 in MARPOL Annex II.

The regional areas are listed in regulation


13.9 of MARPOL and include the ports
north of Gibraltar and east of the west
coast of Ireland, and ports in the North,
Norwegian and Baltic Seas.

For all ships Prewash procedures for persistent floaters to which regulation 13.7.1.4 of Annex II of MARPOL
applies…shall be treated as solidifying or high viscosity substances for the purposes of the prewash.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 42
Handling of Chemical Cargoes
Whenever a nominated cargo is a chemical cargo, the Master should verify whether it is included
in the list of substances that the vessel is certified to carry.

Information regarding the Chemical Cargoes to be carried should be


available on board and include a cargo stowage plan indicating all cargoes
on board, including for each dangerous chemical to be carried:
 A full description of the physical and chemical properties, including
reactivity, necessary for the safe containment of the cargo
 Action to be taken in the event of oil spill
 Countermeasures against accidental personal contact
 Fire fighting procedures and fire fighting media
 Procedures for cargo transfer, tank cleaning, gas freeing and ballasting

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 43
Section 3

MARPOL ANNEX III


Prevention of Pollution by Harmful Substances
Carried by Sea in Packaged Form

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 44
Application

• Harmful substances: as identified by International Maritime Dangerous Goods (IMDG) Code


• Packaged form: the form of containment specified for harmful substances in the IMDG Code

 Packages shall minimize the hazard to the marine environment


 Packages to be durably marked or labeled to indicate that the harmful
substance is in accordance with IMDG Code
 The transport information to be in accordance with IMDG Code and be available
 The vessel to carry a special list, manifest or stowage plan setting forth the
harmful substances on board and their location
 Harmful substances to be properly stowed and secured

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 45
Section 4

MARPOL ANNEX IV
Prevention of Pollution by Sewage

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 46
Sewage Pollution Prevention - Definition
Sewage refers to:

Drainage and other wastes from any What is considered as “Grey Water”?
form of toilets and urinals
Drainage from dishwater,
Drainage from medical premises shower, laundry, bath and
(dispensary, sick bay, etc.) via wash washbasin drains
basins, wash tubs and scuppers
located in such premises
What is considered as “Black Water”?
Drainage from spaces containing
living animals Drainage from toilets, urinals,
hospitals and animal spaces
Other waste waters when mixed with
the drainages defined above

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 47
Sewage Discharge

Fill in the gaps (….)

Sewage status From an approved Comminuted and Not comminuted or


Sewage Treatment Plant disinfected from a holding disinfected from a holding
(STP) tank tank
Distance from the No restrictions ≥ ……nautical
3 miles ≥ ……
12 nautical miles
nearest land
Ship’s speed …………………….. ≥ 4 knots ≥ 4 knots
No restrictions
Comments The effluent shall not Sewage stored in holding Sewage stored in holding
produce visible floating tanks shall not be tanks shall not be discharged
solids nor cause discharged instantaneously instantaneously but at a
discoloration of the but at moderate rate when moderate rate when the ship
surrounding water ship is en route is en route

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 48
Sewage Discharge
According to some National Requirements, the discharge of treated sewage is not allowed when the
ship is in their ports or within their territorial waters

In this case, National and Local regulations shall be followed, superseding MARPOL Annex IV restrictions

For example, in the United States, specific waters are designated as "no
discharge zones" where treated and untreated sewage discharges are
prohibited in these areas and vessel discharges are regulated through
the Environmental Protection Agency's Clean Water Act (CWA) National
Pollutant Discharge Elimination System (NPDES) Program

For example, China issued the “Discharge standard for water pollutants
from ships” that controls the requirements for the discharge of treated
sewage

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 49
STP Operation and Maintenance

Fill in the gaps (….)

 STP is considered critical equipment  High level alarm sensor of STP is considered
Sufficient spares are to be carried on board critical equipment
as …………………………….
 Testing of clean effluent to be carried out  At least 1 spare sensor must be on board
weekly
…………..
weekly
 High level alarm must be tested ………….
 Sewage spills into bilge tanks must be prevented

 In case STP is designed to overflow to BHT, all existing connections


between them must be identified by the C/E and /or Technical
Superintendent (TSI) and inform the Environmental Compliance
Manager (ECM)
 STP effluent test should include testing of Total Suspended Solids
(TSS), Chlorine, Biochemical Oxygen Demand (BOD5), pH and
Chemical Oxygen Demand (COD).
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 50
Grey Water Management - Ports Specific Requirements
 No existing requirement under MARPOL
 Regulated under Vessel General Permit (VGP) of the United
States Environmental Protection Agency
• Vessels with grey water holding tank should discharge
the grey water in a distance greater than 1 nautical
mile from shore while underway
• Vessels without grey water holding tank should
minimize the production of grey water while in waters
subject to VGP
 Regulated under some National and Local Requirements.
• Turkey prohibits discharging grey water into their
teritorial waters.
• Australian States prohibit discharge of grey water in
regulated waters.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 51
Collecting Treated Sewage and Grey Water on board
 Occasionally, capacity of holding tank listed in the ISPPC section 1.3 is insufficient
for longer ship’s stay in the area where discharge overboard is not allowed.
 On number of CSM vessels Class approved arrangements are fitted to allow
collection of treated sewage and grey water in a designated ballast or other tanks.
 Approved arrangement is shown on the ISPPC and can be utilized according to the
approved ship specific procedure.
• Vessels not having an approved arrangement should communicate the necessity
to utilize an available tank to the Technical Superintendent in advance.
• Permission from the Flag Administration for storing treated sewage and grey
water in assigned tank has to be obtained prior to any transfer.
• Procedure provided by the Flag Administration has to be followed until the tank is
emptied and restored to its previous condition.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 52
Section 5

MARPOL ANNEX V
Prevention of Pollution by Garbage

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 53
Garbage Pollution Prevention - Definition

What is considered as garbage?

All kinds of food wastes, domestic wastes and operational wastes, all
plastics, cargo residues, incinerator ashes, cooking oil, fishing gear, and
animal carcasses generated during the normal operation of the ship

Garbage does not include fresh fish and parts thereof generated as a
result of fishing activities undertaken during the voyage

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 54
Garbage Management Plans & Garbage Record Keeping
As per MARPOL Annex V Regulation 10

100 GT and Above Shall carry a Garbage


Management Plan
All ships
Certified to carry
15 or more persons
Shall carry a Garbage
400 GT and Above
Record Book

Must permanently post


All ships with 12 meters or more in a Placard (for CSM
length overall GMPOST-5.1) for the
discharge requirements
CSM Garbage Record Book should be used. of Garbage and the
possible Penalties for
Flag GRBs are currently not required.
failure to comply
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 55
Let’s Fresh up the Segregation Categories of Garbage

Non-recyclable plastics and plastics mixed “Non-recyclable plastics” (Red)


with non-plastic garbage
Incinerator ashes “Incinerator ashes” (Black)

Food wastes “Food Waste” (Green)

Rags Labelled only

Recyclable garbage

o Glass “Glass” (Blue)

o Cooking oil Labelled only

o Aluminum cans “Aluminum Cans” (Grey)

o Paper, cardboard, corrugated board Labelled only

o Wood “Wood” (Brown)

o Metal “Metal” (Grey)

“Plastics” (Yellow)
o Plastics (including Styrofoam or similar plastic
material)
Hazardous wastes “Hazardous Waste” (Red)

E-waste “E-waste” (Red)

Cargo residues (non-HME) “Cargo residues (non-HME)” (Brown/White Stripes)


Cargo residues (HME) “Cargo residues (HME)” (Red)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 56
Garbage Categories

 A. Plastics
 B. Food Waste
 C. Domestic waste
 D. Cooking Oil
 E. Incinerator ashes
 F. Operational waste
 G. Animal carcasses
 H. Fishing gear
 I. E-Waste
 J. Cargo residues (non-HME)
 K. Cargo residues (HME)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 57
Garbage Categories

What is considered as Operational waste ?

All solid waste collected on board during normal maintenance or


operations of a ship, including but not limited to:
 Slurries
 Un-pumpable solid residues collected during cleaning of oil
(cargo, fuel, bilge, sludge, etc.) and other tanks
 Materials used for cargo stowage & handling
 Cleaning agents and Additives contained in cargo hold and
external wash water
 Ash and Clinkers not resulted from garbage incineration
 Hazardous Waste, including used or expired chemicals
 Oily Rags

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 58
Garbage Categories

What is considered as E- waste ?

As E-waste is considered all the electrical and electronic equipment


used for the normal operation of the ship or in the accommodation
spaces, including all components, sub-assemblies and consumables
which are part of the equipment at the time of discarding, with the
presence of material potentially hazardous to human health and/or
the environment

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 59
Garbage Record Book
Garbage Record Book is divided in 2 parts

GRB - PART I
 All ships
 For all garbage except cargo residues
 New Category I: e-Waste

GRB - PART II
 Ships that carry solid bulk cargoes
 For all cargo residues
 Category J: Cargo residues (non-HME)
 Category K: Cargo residues (HME)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 60
Special Areas under Annex V: Garbage

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 61
Waste Receptacles Outside the Accommodation:
 Metal Containers
 Leak Proof
 Protected against sea water
 Located away from ship’s side
 With lid and plastic seals
Inside the Accommodation, Engine Room and Galley:  No hazard to adjacent spaces
 Non-combustible materials  Not to block access to safety equipment
 Without openings  Not stored in cofferdams.
 Water-proof
 Washable for wet waste;
 Safely stored
 Segregated waste
 Marked with the garbage category
 Warnings on dangers of particular types of waste;
 Suitable fire protection devices in closed vicinity;

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 62
Discussion
What actions should you take if you notice a crewmember not to comply with
the Company’s Garbage Management Plan policy ?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 63
Discussion – Possible actions
 Stop the crewmember in case an environmental breach is imminent
 Inform the crewmember about the Company’s Garbage Management Plan Requirements
 Inform the Garbage Management Officer or the Master
 Report the incident through the Open Reporting System
 Inform the crewmember about the consequences of the violations of MARPOL Annex V

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 64
Section 6

MARPOL ANNEX VI
Prevention of Air Pollution

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 65
NOx Emissions
Which vessels have to comply with the NOx regulation ?

 Ozone production from NOx pollutants: Oxygen atoms freed from nitrogen dioxide by
the action of sunlight attack oxygen molecules to make ozone. Nitric oxide can
combine with ozone to reform nitrogen dioxide, and the cycle repeats

 All vessels with diesel engines installed onboard on or after 1/1/2000 with power
output more than 130kw have to comply with the NOx regulation
 This regulation applies also on older engines, installed onboard prior to 1/1/2000 but
which undergo a conversion of engine systems & components that affect the engines
NOx emissions, or increase the engine MCR more than 10% after this date
 Requirements do not apply to engines installed on board and used solely in case of
an emergency (i.e. emergency generator, lifeboat engines, etc.)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 66
NOx Emission Control Areas
Name as many NOx Emission Control Areas you can:

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 67
Reduction of NOx emissions
Engine Certification and Survey Requirements

 Engine Technical File


Contains the identification of all originally installed components & settings which
affect NOx emissions

 Engine International Air Pollution Prevention Certificate


Is a statement of compliance supplemented by the Engine Technical File

 Air Pollution Prevention Certificate


It remains valid only if the Engine compliance with NOx regulation is validated at
every IAPP survey
Issued by the Administration for a period not more than 5 years

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 68
Reduction of NOx emissions
What do the Class surveyors check, to ensure engine’s compliance with NOx regulation ?

 The EIAPP certificate of each engine


 Whether the Engine NOx emission affecting components, as detailed in the
Technical File, are maintained in good condition
 Whether the components replacement complies with the Technical File
requirements and recorded in the “Record Book of Engine Parameters’’
 If the engine settings affecting NOx emissions are maintained within the limits
detailed in the Technical File and any adjustments are recorded in the “Record
Book of Engine Parameters’’
 Inspect of engine components included in the Technical File as per the
“Onboard Verification Procedure’’ attached to the Technical File

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 69
Reduction of NOx emissions

Engine Certification and Survey Requirements

Since the “Engine Parameter Check’’ is an indirect method, the following


additional documents should become available to the surveyor:
 Engine logbook parameter records (mainly exhaust gas temperatures, but
also fuel, lube oil, cooling water and charge air temperatures and pressures)
 Records/diagrams of compression and combustion pressures

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 70
Maintaining the engines according to NOx regulations
What should the C/E do to ensure that the engines are maintained according to the NOx regulations ?

 Check that the operational parameters are logged and are within the maker’s specified limits

 Use suitable components and their ID numbers are recorded in the “Record Book of Engine
Parameters’’, whenever a replacement of components is carried out

 Make sure that whenever adjustments are carried out to engine settings, these are within the
specified range and recorded in the “Record Book of Engine Parameters”

 The engine’s Technical File and the EIAPP must always be onboard and maintained in an
excellent condition

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 71
SOx Emission Control Areas
Name as many SOx Emission Control Areas you can:
The North Sea Area

The North American Area The Baltic Sea Area

The US Caribbean Sea Area


China ECA Area

Any other ports or areas may have their specific requirements.


© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 72
Maximum Permitted Sulphur Content of Fuel
Sulphur
Enforcement limit Grade Operating area Reference
date
(% m/m)

0.50 All grades Global limit (since 01/01/2020) Revised MARPOL Annex VI adopted by Res. MEPC. 176(58)

For MGO supplied in EU territory and waters Directive 1999/32/EC as amended by Regulation 1882/2003 and Directive
0.10 MGO
(since 01/01/2008) 2005/33

European (outside IMO ECA) & Turkish inland


Already in Directive 1999/32/EC as amended by Regulation 1882/2003 and Directive
force 0.10 All grades waterways and when berthed at EU & Turkish
2005/33 & Turkish Maritime Regulations applicable since 01/01/2012
ports

North America ECA, US Caribbean ECA, Baltic


0.10 All grades Revised MARPOL Annex VI adopted by Res. MEPC. 176(58)
ECA, North Sea ECA & English Channel

CARB Marine Notice (mandatory use of either MGO or MDO with the set
MGO (DMA) California waters and 24 NM of the California
0.10 maximum sulphur limit to main propulsion diesel engines, auxiliary diesel
MDO (DMB) baseline (since 01/01/2014)
engines and boilers. HFO is not allowed to be used)

Vessels using scrubbers may use fuel with higher percentage of Sulphur, however specific local requirements should be considered.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 73
Reduction of SOx emissions
 Ensure that vessels operations will fully comply with the
MARPOL Annex VI requirements regarding SOx emissions,
both inside and outside SOx Emission Control Areas (ECAs)

 The fuel oil received and consumed must satisfy the Annex VI
maximum Sulphur content limit

 The C/E should ensure this by verifying that the Sulphur


content is written on the Bunker Delivery Note (BDN), and
that it is not above the limit stated

 In the situation that the BDN shows compliant fuel, but test
results of the “commercial sample” indicates non-compliance,
the TSI has to be notified immediately.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 74
Fuel oil samples under MARPOL
There are three defined fuel oil samples under MARPOL, each provided with a set of IMO
guidelines:
 MARPOL delivered sample – the traditional sample taken during bunkering, accompanying
the Bunker Delivery Note (BDN) which represents the fuel oil delivered on board.

 In-use sample – represents the fuel oil in use on the ship.

 On board sample – represents the fuel oil intended to be used or carried for use on board
the ship.

The “commercial sample” is not required by MARPOL

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 75
General Practice for Change-over Procedures – (MSOPR-02.2)
What is the General Practice for Change-over Procedures ?
 Calculate the required time for safe change over of fuels
 Start at calculated time prior to entering the ECA, to ensure that upon crossing the ECA
border the fuel oil system of the M/E and/or D/G has been fully flushed with the low
sulphur fuel
 The less the segregation of the 2 fuel oil systems between the tanks the greater will be the
time interval required for the change over
 The time required for fully flushing the fuel system depends upon several parameters, which
are mentioned below:
The existence of separate service and settling tanks
The volume of the service and settling tank, in case these are common for the two fuel
types
The existence of separate purifiers, heaters, etc. for the two fuel types
Requirements for gradual adjustments of the F.O. temperature and viscosity, if applicable

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 76
Change-over procedure calculation
What tool is available on board to calculate the Fuel Oil Change – Over procedure ?

The MSOF-2.2 FOBAS Change-Over Calculator

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 77
Exhaust Gas Cleaning System (EGCS) - Scrubber
 Marine scrubbers generally use sea water to remove sulphur oxides and particulate matter from the
exhaust gas.
 EGCS can be used both inside and outside of ECAs.
 Vessels fitted with EGCS are permitted to carry fuel oil with sulphur content exceeding that required by
MARPOL Annex VI Regulation 14.
 Discharges of EGCS wash water to sea must be continuously monitored.
 Several ports and regions limit or ban discharging of wash water into their waters.
 Some coastal states (i.e. Australia and USA) require analytical monitoring of wash water.
 Residues generated by EGCS should not be incinerated or discharged into the sea but delivered to
adequate shore reception facilities.

EGCS Malfunction

 In case of EGCS malfunction (e.g. an alarm is triggered), immediate action should be taken to identify
and rectify the fault.
 In case of EGCS breakdown, if the EGCS cannot be put back into a compliant condition within one hour
the vessel should switch over to compliant fuel.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 78
Control of Volatile Organic Compounds (VOCs)

Vessels carrying crude oil and trading in terminals at which VOCs’ emissions
are to be regulated must be provided with a Volatile Organic Compounds
Management Plan

Control of Vapour Emissions

Vessels undergoing closed operations in terminals, at which vapour emissions


are to be controlled, must be provided with:
 A Vapour Emission Control System (VECS), approved by the Administration
 A Vapour Emission Control Manual, which covers all necessary procedures,
including crew training requirements

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 79
Control of Incineration Emissions
Incineration of the following substances is prohibited
 Cargo residues of crude oil and oil like substance cargoes, chemical cargoes
included in Chapter 17 of the IBC Code
 Polychlorinated biphenyls (PCBs), which are mainly liquid substances used as
coolants and lubricators in electrical apparatus like transformers
 Garbage when containing more than traces of heavy metal
 Refined petroleum products containing halogen compounds
 Polyvinyl Chlorides (PVCs) unless the Incinerator is IMO type approved for
burning these substances
 Cargo residues of harmful substances (IMDG code) and NLS
 Residues of the Exhaust Gas Cleaning System (EGCS).

Special rules on incineration under domestic law may apply in some ports and in
some special areas prohibiting the use of incinerators (Ref GMP section 03.1)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 80
Ozone Depleting Substances

Ozone Depleting Substances Application


Chlorofluorocarbons (CFC) Refrigeration, Air conditioning, Foam
Application, Aerosol propellant
Halon Fire extinguisher

Carbon tetrachloride, Methyl Cleaning fluid, Fire extinguisher


chloroform
Hydrobromofluorocarbons (HBFCs) Fire suppressant

Hydrochlorofluorocarbons (HCFCS) Refrigeration, Air conditioning, Foam


(R22, R141b) application, Aerosol propellant
Methyl Bromide Fumigant

Bromochloromethane (BCM) Fire extinguisher

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 81
Control of Shipboard Refrigerants Emissions
What measures are taken onboard the ship to control refrigerants emissions ?

 Recover and reuse refrigerants by using a recovery unit, together with an empty gas
bottle which is supplied to all vessels
 Maintain recovery units in good working order at all times
 Order required spares via the Technical Superintendent
 Register any detected loss of gas in the Refrigerant Record Book
 Repair any leaks and record the loss of gas
 Plan and execute the maintenance of the Air Conditioning and refrigerating plants in
accordance with the manufacturer’s instructions and as described in the PMS

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 82
Section 7

SEEMP
Ship Energy Efficiency Management Plan

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 83
SEEMP Part I – Applicability

According to MARPOL Annex VI Chapter 4 Regulations 19 & 22:


SEEMP Part I
 Old SEEMP = …………….........
400 GT
 All vessels > …....
 SEEMP Part I does not require approval
 Each vessel shall keep onboard a ship-specific SEEMP, to be verified by attending
Class surveyor, as part of International Ship Energy Efficiency Certificate (IEEC)
issuance

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 84
SEEMP Part I
Name as many best practices for fuel-efficient operation of ships as you can
mentioned in Resolution MEPC.282(70)

 Improved voyage planning  Hull maintenance


 Weather routing  Propulsion system
 Just in time  Propulsion system maintenance
 Speed optimization  Waste heat recovery
 Optimized shaft power  Improved fleet management
 Optimized ship handling  Improved cargo handling
 Optimum trim  Energy management
 Optimum ballast  Fuel Type
 Optimum propeller and propeller inflow  Age and operational service life of a ship
considerations  Trade and sailing area
 Optimum use of rudder and heading control
systems (autopilots)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 85
SEEMP Part II - Applicability

According to MARPOL Annex VI Chapter 4 Regulations 19 & 22A:


SEEMP Part II
 New SEEMP = ……………………..
5.000
 All vessels > ……..….GT

SEEMP Part II – (Ship Fuel Oil Consumption Data Collection Plan) shall include a
description of the methodology that will be used to collect the data required by
regulation 22A.1 of Annex VI and the processes that will be used to report the data to
the ship’s Administration”.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 86
SEEMP Part II - Approval
SEEMP Part II to be reviewed and approved by the Verifier.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 87
SEEMP Part II - Content
 Introduction;
 Ship Particulars;
 Flag, IMO Number, Homeport, Ship type, Deadweight, Gross/Net Tonnage, EEDI.
 Company information (Ship owner/ISM Manager), Name, IMO Number, Address.
 Emission Sources and Fuel Types Used;
 Main Engine, Aux. Engines, Aux. Boilers, IG Generators, Hydraulic Pump units.
 MDO/MGO, LFO, ULFO, HFO, LPG, LNG, Methanol.
 Emission Factors;
 MGO=3.206, LFO=3.151, HFO=3.114, LPG=3.030, LNG=2.75 (in t-CO₂/t-fuel).
 Method to measure Fuel Oil Consumption;
 Bunker Delivery Notes;
 Periodic stocktakes of fuel tanks during bunkering and at departure and arrival ports.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 88
SEEMP Part II - Content
 Method to measure Distance Travelled;
 Distance over ground (via GPS);
 Reported based on the voyage distance, calculated from berth to berth.
 Method to measure Hours Under Way;
 Steaming time as in Deck Logbook;
 Actual time at sea from previous noon report.
 Procedure for reporting data to Administration;
 Vessel reports to the office the fuel consumption through noon report (InfoPath);
 Data received is imported automatically in the database;
 Final report of the year is produced in the office by retrieving all noon reports available in the
database;
 Final report is reviewed/validated in the office and sent to the Verifier.
 Data Quality

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 89
Energy Efficiency Design Index

 EEDI is the theoretical indicator for vessel’s Energy Efficiency


 Building contract placed on/after 1 January 2013
 In the absence of contract, keel laid after 1 July 2013 or the delivery of
which is on/after 1 July 2015
 NOT applicable to vessels sailing entirely within flag state waters
 The EEDI sets CO2 emissions reference and is calculated once for each
vessel. It is a reference value for the energy efficiency indicating how
many grams of CO2 a vessel emits for the transportation of 1 tonne of
cargo over a distance of one nautical mile
 The EEDI dimension is given as: gr CO2 ÷ (tonnes x nautical miles)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 90
Energy Efficiency Operational Indicator (EEOI)
 The EEOI is an approach to assess the efficiency of a ship with respect to CO2 emissions

 In its most simple form the Energy Efficiency Operational Indicator is defined as the ratio of
mass of CO2 emitted per unit of transport work
EEOI = Environmental Cost ÷ Benefit to Society
 Energy Efficiency Operational Indicator = M CO2 / (transport work)

 Measured as grams CO2 / (tonne x nautical mile)

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 91
Energy Efficiency Index for Existing Ship (EEXI)

 Applicable for ships over 400 gross tonnage (GT) in line with the Energy Efficiency Design Index (EEDI)
 Entry into force January 1, 2023, on first annual, intermediate or renewal International Air Pollution
Prevention (IAPP) survey or the initial International Energy Efficiency Certificate (IEE) survey
 A review shall be completed by 1 January 2026 by the Organization to assess the effectiveness of the
regulation in reducing the carbon intensity of international shipping
 Attained EEXI ≤ Required EEXI = (1 − y /100) • EEDI reference line value
where y is the reduction factor specified in Reg. 25 of MARPOL Annex VI.

Ship type Size y Ship type Size y


DWT ≥ 200,000 15 DWT ≥ 15,000 30
General cargo ship
Bulk carrier 20,000 ≤ DWT < 200,000 20 3,000 ≤ DWT < 15,000 0-30*
10,000 ≤ DWT < 20,000 0-20* DWT ≥ 5,000 15
Refrigerated cargo carrier
DWT ≥ 15,000 30 3,000 ≤ DWT < 5,000 0-15*
Gas carrier 10,000 ≤ DWT < 15,000 20 DWT ≥ 20,000 20
Combination carrier
2,000 ≤ DWT < 10,000 0-20* 4,000 ≤ DWT < 20,000 0-20*
DWT ≥ 200,000 15 LNG carrier DWT ≥ 10,000 30
20,000 ≤ DWT < 200,000 20 Ro-ro cargo ship (vehicle carrier) DWT ≥ 10,000 15
Tanker 4,000 ≤ DWT < 20,000 0-20* DWT ≥ 2,000 5
DWT ≥ 200,000 50 Ro-ro cargo ship
1,000 ≤ DWT < 2,000 0-5*
120,000 ≤ DWT < 200,000 45 DWT ≥ 1,000 5
Ro-ro passenger ship
80,000 ≤ DWT < 120,000 35 250 ≤ DWT < 1,000 0-5*
Containership
40,000 ≤ DWT < 80,000 30 Cruise passenger ship having non- GT ≥ 85,000 30
15,000 ≤ DWT < 40,000 20 conventional propulsion 25,000 ≤ GT < 85,000 0-30*
10,000 ≤ DWT < 15,000 0-20* * Reduction factor to be linearly interpolated between the two values
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 92
Carbon Intensity Indicator (CII)
 Applicable for ships over 5,000 GT in line with IMO Data Collection System (DCS)
 Each ship must have an approved SEEMP (Part III) on board as of January 1, 2023 Year Reduction Factor (z)
 SEEMP will be subject to verification and company audits 2023 5%

 A review shall be completed by 1 January 2026 by the Organization 2024 7%

 Required annual operational CII = (1 −z/100) • CIIR 2025 9%


2026 11 %
Where, z is the annual reduction factor and CIIR is the reference value. 2027 **
 Operational carbon intensity rating A, B, C, D or E, indicates a major superior,
minor superior, moderate, minor inferior, or inferior performance level.

Values of dd vectors, d1, d2, d3 & d4 for different ship types

Ship type d1 d2 d3 d4
Bulk Carrier 0.86 0.94 1.06 1.18
DWT ≥ 0.81 0.91 1.12 1.44
Gas Carrier 65,000
DWT <
65,000 0.85 0.95 1.06 1.25
Tanker 0.82 0.93 1.08 1.28
Container ship 0.83 0.94 1.07 1.19
General cargo ship 0.83 0.94 1.06 1.19
Refrigerated cargo carrier 0.78 0.91 1.07 1.20
Combination carrier 0.87 0.96 1.06 1.14
DWT≥ 0.89 0.98 1.06 1.13
100,000
LNG Carrier DWT <
0.78 0.92 1.10 1.37
100000
Ro-ro cargo ship (VC) 0.86 0.94 1.06 1.16
Vectors and rating bands Ro-ro cargo ship 0.66 0.9 1.11 1.37
Vectors d1, d2, d3 & d4 show the deviation from the required CII Ro-ro passenger ship 0.72 0.90 1.12 1.41
© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 Cruise passenger ship 0.87 0.95 1.06 1.16 93
Carbon Intensity Indicator (CII)
SEEMP Part III, CoC
31st December
End of DCS
Data Collection

30th
November 31st March
Deadline to
Deadline to submit DCS for
Audit the review
Company

31st May:
DCS
Deadline to Verification
issue SoC

If rated as D for 3 consecutive


years or as E
• Develop a plan of corrective
actions CoC: Confirmation of Compliance
• Revise SEEMP Part III
• Obtain CoC and SoC SoC: Statement of Compliance

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 94
SEEMP Part III - Approval
SEEMP Part III to be reviewed & approved by the Administration or a Recognised Organisation

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 95
SEEMP Part III - Content
 Introduction;
 Required CII over the next 3 years, attained CII & rating over 3 consecutive years;
 Name, IMO Number, Flag, Ship type, Deadweight, Gross Tonnage, Applicable CII.
 CII starting point and records of 3 consecutive years.
 Calculation Methodology;
 The attained CII is calculated as per the Guidelines on operational CIIs and the calculation methods
(CII Guidelines, G1).
 Required data for calculation of attained CII;
 Ship’s Carrying Capacity (DWT/GT), distance travelled and fuel oil consumption for each type of fuel.
 Method for obtaining data for calculation of attained CII;
 Data will be obtained as per SEEMP Part II;
 Correction factors and voyage adjustment;
 The available corrections and adjustments depend on the ship type;

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SEEMP Part III - Content
 Self-evaluation and improvement;
 List of measures to be considered and implemented including responsible
company personnel
 Speed Optimization
 Impediment and contingency measures
 Calculation showing the combined effect of the measures and that the required
operational CII will be achieved
 Plan of Corrective actions (if applicable)

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Section 8

EU MRV - IMO DCS

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EU MRV

 EU MRV stands for European Union Monitoring, Reporting and Verification


 Introduced by the EU (Regulation 2015/757);
 Applies to vessels of 5000 GT and over, conducting voyages into, out of and
between EU ports.
 Covers shipboard Carbon Dioxide (CO₂) emissions

 What to monitor and report for each voyage?


 Fuel Oil Consumption;
 Transport Work (cargo x distance travelled);
 Time spent at sea.

 When to report?
 Annually for the previous year, latest by 31st March;
 First reporting for the year 2018;

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MRV Monitoring Plan - Content
 Part A: Purpose and Scope;
 Part B: Basic Data
• Ship identification
 Flag, IMO Number, Homeport, Ship type, Deadweight, Gross Tonnage.
• Company information (DOC Holder)
 Name, IMO Number, Address, Contact Person.
• Emission Sources
 Main Engine, Aux. Engines, Aux. Boilers, IG Generators, Hydraulic Pump units.
• Fuel Types
 MDO/MGO, LFO, ULFO, HFO, LPG, LNG, Methanol.
• Emission factors
 MGO=3.206, LFO=3.151, HFO=3.114, LPG=3.030, LNG=2.75 (in t-CO₂/t-fuel).

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MRV Monitoring Plan - Content
 Part C: Activity Data;
• Fuel Consumption (method of monitoring)
 Method A: Bunker Delivery Notes and periodic stocktakes of fuel tanks;
 Method B: Bunker fuel tank monitoring onboard; Selected for the CSM Fleet.
 Method C: Flowmeters for applicable combustion processes;
 Method D: Direct CO₂ emission measurement.
CO₂ emitted = Fuel consumption x Emission factor
• Time spent at see
 Hours from port of departure to port of arrival, excluding anchoring.
• List of Voyages
 Into, out of, between EU ports.
Example 1: Load in Busan, load/unload & bunkering in Singapore, discharge in Rotterdam
=> Voyage: Singapore – Rotterdam.
Example 2: Load in Busan, bunkering in Singapore, discharge in Rotterdam
=> Voyage: Busan – Rotterdam.

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MRV Monitoring Plan - Content
 Part C: Activity Data; (Continued)
• Cargo Carried
 Tonnes for cargo ships;
 Tonnes of deadweight for general cargo ships;
 Cubic meters for LNG carriers;
 Number of passengers for passenger vessels.
• Distance Travelled
 From berth of port of departure to berth of port of arrival in Nautical miles.
Transport Work = Cargo carried x Distance travelled
 Part D: Data Gaps
 Methods to treat data gaps for fuel consumption, distance travelled, cargo carried and
time spent at sea.
 Part E: Management
 Regular checks and control activities (reviews, validations, corrections, etc.).
 Part F: Further Information
 Definitions, abbreviations, other information.

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MRV Monitoring Plan

Monitoring Plan to be
reviewed and accepted by the
Verifier

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EU MRV – Reporting

 Annual Reporting
• Amount for each type of fuel consumed;
• Total aggregated CO₂ emitted;
 From all voyages between, departed from and to EU ports.
 CO₂ emissions occurred within EU ports at berth.
• Total distance travelled;
• Total time spent at sea;
• Total transport work.

 Average Energy Efficiency:


• Fuel Consumption:
 Total Annual Fuel Consumption / Total Distance Travelled
 Total Annual Fuel Consumption / Total Transport Work

• CO₂ Emissions:
 Total Annual CO₂ Emissions / Total Distance Travelled
 Total Annual CO₂ Emissions / Total Transport Work

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EU MRV – Verification

 Verification
• Verifier: Legal entity accredited to carry out verification.

• Verification: Activities carried out to assess the conformity of the documents submitted.
 Assessment of Monitoring Plan;
 Verifications of Emission Report;
 Issuance of Document of Compliance (latest 30 June);
 Inform the EC and Flag State of DOC issue.

• Results are published on 30 June every year.

• Vessel shall carry onboard a valid Document of Compliance


from 30 June each year.

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IMO DCS

 IMO DCS stands for IMO Data Collection System


 According to MARPOL Annex VI, Regulation 22A;
 IMO Resolution MEPC.282(70) “2016 Guidelines for The Development of a Ship
Energy Efficiency Management Plan (SEEMP)”, as amended by
MEPC.70/18/Ass./Corr.1.
 Covers shipboard Carbon Dioxide (CO₂) emissions;
 Applies to vessels of 5000 GT and over, conducting voyages worldwide.

 What to monitor and report ?


 Fuel Oil Consumption;
 Distance Travelled;
 Hours Under Way.

 When to report?
 Annually for the previous year, latest by 31st March;
 First reporting for the year 2019;
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IMO DCS – Reporting and Verification

 Annual Reporting
• Amount for each type of fuel consumed;
• Total aggregated CO₂ emitted;
• Total distance travelled;
• Total time spent at sea.
 Verification
• Verifier: Legal entity accredited to carry out verification.
• Verification: Activities carried out to assess the conformity
of the documents submitted.
 Assessment/Approval of SEEMP Part II;
 Verifications of Emission Report;
 Issuance of Statement of Compliance (latest 31 May);
 Report to flag and flag reports to IMO database.
• Results remain confidential

Vessel shall carry onboard a valid Statement of Compliance


from 1 June each year.
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EU MRV and IMO DSC

What Seniors Officers need to know:


 EU MRV Monitoring Plan and IMO DCS SEEMP Part II are vessel specific and almost
identical.
 Specific procedures relevant to two plans are addressed in SEEMP, SEPR-10.1 for EU MRV
and SEPR-11.1 for IMO DCS.
 Both plans must be reviewed/approved by the Verifier or the Flag State. The review is
indicated on first page.
 Copy of the plans must be available on-board evidencing the review.
 DOC issued for EU MRV is valid until 30 June every year.
 SOC issued for IMO DCS is valid until 31 May every year.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 108
EU MRV and IMO DSC

Seniors Officers must make sure to:


 Report accurate data every day via the noon reporting to the office:
 Quantity and type of fuel consumed by various emission sources;
 ROB for all types of fuel;
 Distance travelled;
 Time spent at sea, at anchorage or in port.
 Report quantities of every bunkering and new ROB for each type of fuel, always attaching
BDN to the report.
 Report quantity of cargo in case of loaded condition, as well as remaining cargo in case of
part discharging.

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 109
EU MRV and IMO DSC – Annual Reports

Typical problems when compiling the annual reports:


 Missing or inaccurate fuel consumption;
 Inaccurate quantities ROB for various fuel types;
 Discrepancies with different fuel types and emission sources;
 Missing BDNs;
 Inaccurate new quantities ROB after bunkering;
 Missing or inaccurate times spent at anchorage and/or in port;
 Missing or inaccurate cargo information/quantities;

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What is coming next?

Market Based Measures (MBMs).


 MBMs put a price on emissions to provide an economic incentive to reduce CO₂, CH4
(Methane), N2O (Nitrous Oxide) emissions by narrowing the price gap between fossil
fuels and zero carbon.
 The European Commission has already discussed such MBMs and introduce them for
the year 2024.
 Shipping is now included in the EU Emissions Trading System (EU ETS) from 1 January
2024.

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EU Emission Trading System (EU ETS)
 EU ETS is a Cap-and-Trade system market-based-measure (MBM) to reduce GHG
emission.
 It is entered into force on 5.6.2023
 It will be implemented from 01.01.2024 for cargo & passenger ships of GRT ≥ 5000 and
from 01.01.2027 for offshore ships of GRT ≥ 5000.
 From 2025 an emission report should be submitted to the independent verifier followed
by submittal of the verified report to the administration authority by end of March.
 The responsible entity for reporting is the shipowner or any other firm that has assumed
the responsibility on behalf of the shipowner.
 EU Emission Allowances (EUAs) can be bought in the open market by anybody. Charterers
can buy issued or future EUAs via EEX/brokers and via bilateral relationships. Only
shipping company will have access to the auction.
 The cap is the threshold specifying the total amount of GHG that could be emitted by the
operators. This value is reduced annually at fixed intervals.

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EU Emission Trading System (EU ETS)
 The ETS emissions are monitored and reported through the EU MRV reporting system.
 Under EU ETS, the relevant emission factors are Tank-to-Wake.
 Taxable emissions are those originating from a voyage between two port of calls, where a
ship stops to load or unload cargo or to embark or disembark passengers, or the port
where an offshore ship stops to relieve the crew.
 Stops for dry-dock or making repairs to the ship and/or its equipment are not considered
a port of call.
 The reporting period is from 1 January until 31 December of the calendar year. The part
of the voyage which falls in 2023 is subject to the 2023 reporting, while the part in 2024
will is subject to 2024 reporting and emission taxes.
 Under EU MRV, there are two methods to calculate N2O and CH4 emissions, the
calculation approach and the measurement approach. Under the measurement
approach, direct GHG emissions measurements are used. For the calculation approach
there are three different methods:
 1- Method A: BDN;
 2- Method B: Bunker fuel tank monitoring;
 3- Method C: Flow meters.
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IMO Measures on Reducing CO2 Emissions
1st Policy Package, MARPOL Annex VI Amendments
(Entered
Operational Measure, SEEMP I into force on 1 Jan 2013)
Technical Measure, EEDI
SEEMP for all vessels >400 GT (no approval required) CO2 emission standards for new-buildings

Intermediate Package, MARPOL Annex VI Amendments


Operational Measure, SEEMP II (IMO Data Collection
System) (Entered into force on 1 March 2018)
SEEMP II for all vessels > 5000 GT (RO approval
required)

2nd Policy Package, MARPOL Annex VI Amendments


(Entered into force on 1 January 2023)
Operational Measure, Carbon Intensity Indicator (CII)
Technical Measure, EEXI
For all vessels > 5,000 GT (SEEMP re-approval required);
Annual monitoring of CII, Baseline lowered each year For all vessels above 400 GT, CO2 emission standards,

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Section 9

Vessel General Permit 2013 (VGP)

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VGP Application
VGP Applies to all Columbia vessels:
 All vessels subject to NPDES except those less than 24 meters in length and
recreational crafts
 Non-recreational vessels less than 79 feet
 Vessels greater than 79 feet in length
 Non military vessels greater than 79 feet
 Commercial fishing vessels

To which waters is the VGP applied ?

 The permit is applicable to US inland waters and the 3 nautical miles territorial sea
 All navigable waters of the Great Lakes under the US jurisdiction are also included

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Discharges - subject to VGP
Name as many discharge types eligible for coverage under the VGP
 Deck washdown and runoff and above  Gas Turbine Wash Water
waterline hull cleaning  Graywater
 Bilgewater  Motor Gasoline and Compensating Discharge
 Ballast Water  Non Oily Machinery Wastewater
 Anti-Fouling Hull Coatings/Hull Coating  Refrigeration and Air Conditioning Condensate
Leachate  Seawater Cooling Overboard Discharge
 Aqueous Film Forming Foam  Seawater Piping Biofouling Prevention
 Boiler Economizer Blowdown  Boat Engine Wet Exhaust
 Cathodic Protection  Sonar Dome Discharge
 Chain Locker Effluent  Underwater Ship Husbandry and Hull Fouling
 Oil to Sea Interfaces Coatings
 Distillation and Reverse Osmosis Brine  Well Deck Discharges
 Elevator Pit Effluent  Graywater mixed with Sewage
 Firemain Systems  Exhaust Gas Scrubber Washwater Discharge
 Freshwater Layup  Fish Hold Effluent

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Deadlines for submitting a NOI

Discharge Authorization
Category of vessels NOI Deadline
date
New vessel For e-NOIs: For e-NOIs:
…… days prior discharging ….. days after submission
7 Paper NOIs:
For 7
For Paper NOIs:
…… days prior discharging ….. days after submission
New owner or operator By 30date of transfer of 30 of transfer or date EPA
Date
of a vessel – transfer of ownership or operation receives the NOI whichever
ownership and/or is later
operation of a vessel
whose discharges are
authorized under the
permit

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Inspections

The USCG is permitted to inspect the VGP on behalf of the EPA


 Summary of inspection focus areas and questions:
 Are the vessel Master and senior crew aware of the VGP?
 Has the NOI been submitted for the vessel?
 Are records of routine visual inspections maintained?
 Are records of annual inspections maintained?
 Are records of VGP dry dock inspection available?
 Documentation of Corrective Action Assessments
 Ballast Water Management Plans
 Ballast Water Record Book
 Bilge water Discharges

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Section 10

Ballast Water Management (BWM)

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BALLAST WATER MANGAEMENT

What is the aim of the Ballast Water Management Convention ?


 To minimize the transfer of invasive aquatic species between ecosystems
 To minimize the transfer of bacteria harmful to human health

What is called Ballast Water Management System ?

Any system which processes ballast water to kill, render harmless or remove
organisms. The BWMS includes all ballast water treatment equipment and all
associated control and monitoring equipment

What is the aim of the Ballast Water Treatment ?


The aim of the Ballast Water Treatment is to actively remove, kill and /or inactivate
organisms prior to discharge.

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Dealing with ballast water
Regulation D-1 : Exchange Standard

 95% Exchange Regulation D-2 : Treatment Standard


 200 nautical miles & 200 meters deep;
or  Organisms > 50 microns
 50 nautical miles & 200 meters deep < 10 organisms per m3
 Methods  Organisms => 10 microns < 50 microns
 Sequential < 10 organisms per ml
 Flow through  Vibrio cholerae
 Dilution < 1 cfu per 100 ml
 Escherichia coli
< 250 cfu per 100 ml
 Intestinal enterococci
< 100 cfu per 100 ml

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Ballast Water Exchange Requirements
 Alternative to the distance and depth requirement, the
exchange may take place in designated exchange areas.
 If the requirements on the distance from the nearest land and
water depth are not met throughout the journey and an
exchange area does not exist, an exchange is not required.
The flag state should be informed and the circumstance must
be documented in the Ballast Water Record Book.
 Individual tanks should always be exchanged completely.
Under no circumstances should a partial exchange take place
within a tank.
 As many complete tanks should be exchanged as the time
allows without delaying the journey.

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Requirements for Ballast Water Treatment (IMO)

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Ballast Water Treatment Systems

Physical Disinfection
Residual
Solid-Liquid Control:
Chemical Treatment:
Separation - Chlorination
- Chemical Reduction
( Sulphite /
- Electro-chlorination Bisulphite )
Treatment:
(or Electrolysis)
- Hydrocyclone Physical
- Surface Filteration enhancement
- Ultrasonic
treatment

Chemical
Enhancement: Physical:
- Coagulation / - UV irradiation
Flocculation

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Ballast Water Management Plan

What are the main characteristics of a Ballast Water Management Plan ?

 Approval by Flag is Mandatory (For D-1 and D-2 Standard)


 Ship-specific
 Can combine both exchange and treatment systems
 Must be Available Onboard
 Should contain contingency measures in case of BWTS failure

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What kind of records is required to be kept regarding the Ballast Water Management Plan ?

 Ballast Water Reporting Form


 Ballast Water Handling Log
 Sediment removal and Flush
 Training Record

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US Ballast Water Management Requirements

The US Ballast Water regulations require all ships to:


 Clean ballast tanks to remove sediments
 Rinse anchors and chains when retrieved
 Remove fouling from the hull, piping and tanks on a regular basis
 Maintain a BW management plan
 Maintain records of ballast and fouling management
 Report to be submitted not less than 24 hours before arrival

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BWTS Failure
In case BWTS becomes inoperative
 During operation in port, BW intake:
• Uptake of BW must be suspended
• BWMP Contingency measures to be activated
• Port State to be informed of the BWTS failure and its consent to be obtained for bypassing BWTS
• Flag State to be notified of the BWTS failure
• BWTS failure to be recorded under code 3.6 in the BWRB

 During operation in port, BW discharge or en-route to a port of intended BW discharge, in addition to actions listed above:
• Port State to be notified of the BWTS failure and approached for permission to activate contingency measures per the
ship’s BWMP
• Port State instructions on handling untreated/non-neutralised BW to be obtained and followed
• BWTS failure to be recorded under code 3.6 in the BWRB

 En-route or during operation in the USA port:


• Respective Captain of the Port (COTP) shall be notified of the BWTS failure and approached for permission to activate
contingency measures per the ship’s BWMP
• COTP instructions on handling untreated/non-neutralised BW to be obtained and followed
• BWTS failure to be recorded under code 3.6 in the BWRB

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Comparison Between IMO & USCG
Ballast Water Treatment Type Approval Procedures

IMO USCG
BWM Convention requires a Type Approval USCG requires a Type Approval certificate, issued by
certificate by the Administration or that the USCG in accordance with 46 CFR 162.060
particular flag State acknowledge another
BWTS with IMO Type Approval certificate can after a
Administration’s Type Approval certificate in
review process by USCG be listed as Alternate
writing (ref Reg. D-3 and G8 6.3-6.5)
Management System

An Alternate Management System can be used 5


years from the date vessel is required to have a
BWTS installed

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Section 11

Biofouling Management Plan


(BFMP)

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What is the Biofouling Management Plan ?

The BFMP provides effective procedures and practical guidance


to the vessel’s crew on biofouling management measures in
order to minimize the risk of transferring invasive aquatic
species from ships' biofouling

The ship should implement management practices, including


the use of anti-fouling systems and other operational
management practices to reduce the development of
biofouling. The intent of such practices is to keep the ship’s
submerged surfaces and internal seawater cooling systems as
free of biofouling as practical

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Information in BFMP

The BFMP management plan should be ship-specific and included in the


ship's operational documentation. The plan should address the following:
 Relevant parts of CSM BFMP Guidelines (Appendix I)
 Details of the anti-fouling systems and operational practices or
treatments used, including those for niche areas
 Hull locations susceptible to biofouling, schedule of planned inspections,
repairs, maintenance and renewal of anti-fouling systems
 Details of the recommended operating conditions suitable for the
chosen anti-fouling systems and operational practices
 Details relevant for the safety of the crew, including details on the anti-
fouling system(s) used
 Details of the documentation required to verify any treatments recorded
in the Biofouling Record Book

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The Biofouling Management Officer
Who is the Biofouling Management Officer and what are his responsibilities ?

The Chief Engineer is the designated Biofouling Management Officer

He is responsible for:
 Ensuring implementation of the Biofouling Management Plan
 Maintaining the Biofouling Record Book
 Conducting of training for Biofouling Management and Treatment
Procedures

The Biofouling Management Officer shall be supported by other offices and


crew to ensure proper collection of data in compliance with the BFMP

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Types of Anti-fouling coatings
How many types of Anti- fouling coatings exist and how do they work ?

 Biocidal coatings that release chemicals such as copper


compounds or other pesticides that aim to deter
biofouling organisms

 Biocide-free coatings that do not depend on chemicals or


pesticides for their anti-fouling properties, but instead rely
on their physical nature

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Name as many niche areas on the ship that may accumulate biofouling

 Propeller thrusters and propulsion units


 Sea chests
 Rudder stock and hinge
 Stabilizer fin apertures
 Rope guards, stern tube seals and propeller shafts
 Cathodic protection anodes
 Anchor chain and chain lockers
 Free flood spaces inherent to the ships' design
 Sea chest and thruster tunnel grates
 Echo sounders and velocity probes
 Overboard discharge outlets and sea inlets
 Areas prone to anti-fouling coating system damage or grounding

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In-water inspection, cleaning and maintenance

 In-water inspections to be undertaken periodically augmented by specific


inspections to address any situations of elevated risk
 In-water cleaning can be an important part of biofouling management
and introduces different degrees of environmental risk, depending on the
nature of biofouling, the amount of anti-fouling coating system residue
released and the biocidal content of the anti-fouling coating system
 Any maintenance or repair activities should take care not to impede
future in-service cleaning and / or maintenance
 Regular polishing of uncoated propellers to maintain operational
efficiency will also minimize macrofouling accumulation

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Information required in Biofouling Record Book

 Details of the anti-fouling systems and operational practices used, where and
when installed, areas of the ship coated, its maintenance and its operation
 Dates and location of dry-dockings / slippings and any measures taken to
remove biofouling or to renew or repair the anti-fouling system
 The date and location of in-water inspections, the results of that inspection
and any corrective action taken to deal with observed biofouling
 The dates and details of inspection and maintenance of internal seawater
cooling systems, the results of these inspections, and any corrective action
taken to deal with observed biofouling and any reported blockages
 Details of when the ship has been operating outside its normal operating
profile including any details of when the ship was laid-up or inactive for
extended periods of time

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Information required in Biofouling Record Book
Cases that require to be recorded in the Biofouling Record Book include:
 Every dry-docking
 When the hull area, fittings, niches and voids below the waterline have been
cleaned by divers
 When the internal seawater cooling systems have been inspected / cleaned or
treated
 For ships with a Marine Growth Prevention System (MGPS) fitted, Record of
operation and maintenance and any instances when the system was not operating
in accordance with the BFMP
 Periods of time when the ship was laid up / inactive for an extended period of time
 Periods of time when ship operating outside its normal operating profile
 Details of official inspection or review of ship biofouling risk
 Any additional observations and general remarks

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Record of Biofouling Management Actions
SAMPLE OF BIOFOULING RECORD BOOK ENTRIES
HULL INSPECTION

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 140
Thank you for your
attention

Any questions?

© 2024 | COLUMBIA Shipmanagement | Prepared by Alpha Marine Consulting PC | Revision 2 | January 2024 141

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