PREVENTING POLLUTION FROM SHIPS

September 2009

V.Ships Mission Statement

V.Ships aims to be recognised as the first choice global supplier of the highest quality services to the shipping industry with absolute regard to safety and the marine environment
For V.Ships Environmental Policy full text click here

V.Ships Environmental Policy

V.Ships recognises environmental protection and management as one of its highest priorities and as a result, every effort is to be made to conserve and protect the marine environment from all forms of pollution. V.Ships aim is to eliminate the possibility of pollution at source by ensuring that high standards of safety and environmental awareness are maintained and that all relevant legislation and conventions are followed. V.Ships is also committed to the continuous improvement of methods used to carry out this aim.

DIRECT SEA POLLUTION CAUSES

Almost all pollution incidents are avoidable Most discharges are via operational incidents
FAILURE TO FOLLOW PROCEDURES CAUSES: heavy fines and/or imprisonment for those involved

significant costs for Owners in case of all pollution acts

damage to V.Ships reputation

SHIPBOARD SEA POLLUTION SOURCES

OIL POLLUTION PREVENTION

(Marpol 73/78 Annex I) Main Shipboard Oil Pollution Sources: engine room bilges and fuel tanks ballast bunker operations tankers cargo operations tank washing and ballasting operations on tankers other operations tankers accidents
accidental oil spills contribute to less than 5 - 10% of all oil pollution.

OIL POLLUTION PREVENTION

The history of main tanker accidents:

1967 March 18, Cornwall, Eng.: Torrey Canyon ran aground, spilling her entire cargo of 120,000 tons of crude oil off the Scilly Islands while entering the English Channel. This resulted in the biggest oil pollution incident ever recorded up to that time and was a result of poor navigational practices.

OIL POLLUTION PREVENTION

1978 March 16, off Portsall, France: wrecked supertanker Amoco Cadiz spilled 68 million gallons, causing widespread environmental damage over 100 mi of Brittany coast 1979 July 19, Tobago: the Atlantic Empress and the Aegean Captain collided, spilling 46 million gallons of crude. While being towed, the Atlantic Empress spilled an additional 41 million gallons off Barbados on Aug. 2. 1983 Aug. 6, Cape Town, South Africa: the Spanish tanker Castillo de Bellver caught fire, spilling 78 million gallons of oil off the coast

OIL POLLUTION PREVENTION

In 1989 March 24, Prince William Sound, Alaska: tanker Exxon Valdez hit an undersea reef and spilled 10 million gallons of oil into the water, causing the worst oil spill in U.S. history and probably the one which gained the biggest media coverage to date. The U.S. public demanded action - and duly got it. The United States introduced its Oil Pollution Act of 1990 (OPA 90), making it mandatory for all tankers calling at U.S. ports to have double hulls.

OIL POLLUTION PREVENTION

1991April 11, Genoa, Italy: Haven spilled 42 million gallons of oil in Genoa port. May 28, Angola: ABT Summer exploded and leaked 1578 million gallons of oil off the coast of Angola. It's not clear how much sank or burned. 1993 Aug. 10, Tampa Bay, Fla.: three ships collided, the barge Bouchard B155, the freighter Balsa 37, and the barge Ocean 255. The Bouchard spilled an estimated 336,000 gallons of No. 6 fuel oil into Tampa Bay. 1996 Feb. 15, off Welsh coast: supertanker Sea Empress ran aground at port of Milford Haven, Wales, spewed out 70,000 tons of crude oil, and created a 25-mile slick. 1999 Dec. 12, French Atlantic coast: Maltese-registered tanker Erika broke apart and sank off Brittany, spilling 3 million gallons of heavy oil into the sea.

OIL POLLUTION PREVENTION

2000 Nov. 28, Mississippi River south of New Orleans: oil tanker Westchester lost power and ran aground near Port Sulphur, La., dumping 567,000 gallons of crude oil into lower Mississippi. The spill was the largest in U.S. waters since Exxon Valdez disaster in March 1989.

2002 Nov. 13, Spain: Prestige suffered a damaged hull and was towed to sea and sank. The oil tanker Prestige sank off Spain's NW coast, taking more than 70,000 tonnes of fuel into the Atlantic with it.

OIL POLLUTION PREVENTION

Special Areas * according to Marpol:
Mediterranean, Baltic, Black Sea, Red Sea, Gulfs area, Gulf of Aden,Oman Area of the Arabian Sea, ** NW European waters, Southern South Africa waters Any discharge into the sea of oil or oily mixtures into the Antarctic Area (south of latitude 60S) is prohibited.

In Annexes I, II, V - MARPOL defines certain sea areas as "special areas" in which, for technical reasons relating to their oceanographic and ecological condition and to their sea traffic a higher level of protection than other areas of the sea is required.

* * The Special Area requirements for these areas have not taken effect because of lack of notifications from MARPOL Parties whose coastlines border the relevant special areas on the existence of adequate reception facilities

OIL POLLUTION PREVENTION

1.Control of discharge of oil or oily mixtures from ships machinery space and from fuel tanks
1.1.Outside Special Area Discharge may take place if :
en route (discharge spread over great area) processed through an oil filtering equipment (15 ppm) the oil content without dilution <15 ppm (parts per million)

1.2. In a Special Area :

oil filtering equipment (15 ppm) should have alarm (oil content meter) and automatic stopping device (3-way valve) Oil residues which cannot be discharged into the sea in compliance with the previous provisions shall be retained onboard for subsequent discharge to reception facilities

OIL POLLUTION PREVENTION

1.3. For ships 4,000 GT and oil tankers 150 GT (delivered after 31 December 1979) no ballast water shall be carried in any oil fuel tank
Carrying large quantities of oil fuel and consequently ballast water, requires discharge to reception facilities or into the sea following procedures specified in 1.2. 1.4. In a ship 400 GT constructed after 1 July 1982, oil shall not be carried in a forepeak tank or a tank forward of the collision bulkhead.

OIL POLLUTION PREVENTION

2. Construction requirements for all ships machinery space:
sludge tanks of adequate capacity with regard to the type of machinery and length of voyage
standard discharge connection fitted to the ships discharge pipeline for residues from bilges and sludge tanks to enable connection to reception facilities oil fuel tanks protection against collision/grounding (i.e. double hull) for ships with an aggregate oil fuel capacity of 600 m, delivered on or after 1 August 2010. A max. capacity limit of m per oil fuel tank is 2,500

OIL POLLUTION PREVENTION

3. Requirements for equipment of all ships machinery space
All ships 400 GT must be fitted with oil filtering equipment (Oily Water Separator) producing an effluent with oil content <15ppm Ships 10000 GT shall be fitted with oil filtering equipment (15ppm) with alarm and automatic stopping device Oily Water Separators (OWS) and Oil Content Meters (OCM) (bilge alarms) shall be approved as per IMO resolutions: A.393(X), MEPC.60 (33) or since 01.012005 MEPC.107(49) which states that: - OWS to be tested also with a stable emulsion - OCM to include a recording function for date, time, alarm and operating status. All records to be stored for 18 months

OIL POLLUTION PREVENTION

4. Control of discharge of oil or oily mixtures from oil tankers cargo area
4.1. Outside Special Area discharge may take place if: the instantaneous rate of discharge of oil content does note exceed 30 litres per nautical mile proceeding on voyage more than 50 miles from land discharge monitoring and control system is used to discharge residue the total quantity of oil discharged into the sea does not exceed 1/15,000 or 1/30,000* of the total quantity of the particular cargo of which the residue formed a part ( * for tankers delivered after 31 December 1979 ) the tanker is equipped with Oil Discharge Monitoring and Control System and a Slop Tank arrangement 4.2. In Special Area" only discharge of clean or segregated ballast is allowed (oil content in discharge<15 ppm)

OIL POLLUTION PREVENTION

5.Construction requirements for oil tankers cargo area
5.1. Every crude oil tanker of 20,000 dwt and above and every product carrier of 30,000 dwt and above delivered after 1 June 1982, shall be provided with segregated ballast tanks (SBT)
5.2. In no case shall ballast water be carried in cargo tanks, except - weather conditions so severe that it is necessary to carry additional ballast water for the safety of the ship - in exceptional cases where the particular character of the operation of an oil tanker renders it necessary to carry ballast water
In case of crude oil tanker ,such cargo tanks have been crude oil washed (COW) Additional ballast water shall be processed and discharged in compliance with 1.4. and an entry shall be made in the Oil Record Book Part II

OIL POLLUTION PREVENTION

5.3. Crude oil tankers 40,000 dwt delivered on or before 1 June 1982, shall comply with the requirements of 1.5.1. and 1.5.2. or may in lieu SBT, operate with a cargo tank cleaning procedure using crude oil washing (COW)
5.4. Product carriers 40,000 dwt delivered on or before 1 June 1982 shall comply with the requirements of 1.5.1. and 1.5.2. or may in lieu SBT, operate with dedicated clean ballast tanks (CBT). The product carrier shall be equipped with an oil content meter, approved by the Administration to enable supervision of the oil content in ballast water being discharged. 5.5. Oil tankers 70,000 dwt delivered after 31 December 1979 shall comply with the requirements of 1.5.1. and 1.5.2.

OIL POLLUTION PREVENTION

5.6. Every crude oil tanker 20,000 dwt and every product carrier 30,000 dwt delivered after 1 June 1982, are required to be equipped with the segregated ballast tanks providing a measure of protection against oil outflow in the event of grounding or collision. This regulation does not relate to tankers that meet double hull and double bottom requirements 5.7. Every oil tanker 5,000 dwt delivered on or after 6 July 1996 shall be fitted with double hulls (the entire cargo tank length shall be protected by ballast tanks or spaces other than tanks that carry oil) Such tankers delivered before 6 July 1996 shall comply with the 1.5.7. requirements not later than 5 April 2005 or the anniversary of the date of delivery of the ship on the date or in the year specified in the following statement:

OIL POLLUTION PREVENTION

The full timetable for the phasing out of single-hull tankers Category of oil tanker Category 1 Date or year 5 April 2005 for ships delivered on 5 April 1982 or earlier 2005 for ships delivered after 5 April 1982 5 April 2005 for ships delivered on 5 April 1977 or earlier 2005 for ships delivered after 5 April 1977 but before 1 January 1978 2006 for ships delivered in 1978 and 1979 2007 for ships delivered in 1980 and 1981 2008 for ships delivered in 1982 2009 for ships delivered in 1983 2010 for ships delivered in 1984 or later

Category 2 and Category 3

OIL POLLUTION PREVENTION

IMO amendments to MARPOL 73/78 (adopted 12/2003, entry into force 5/4/2005) - simplified statement Category 1 phase-out up to 2005 Categories 2&3 phase-out up to 2010 Condition Assessment Scheme CAS required for Categories 2&3 over 15 years old Oil Tanker Categorization Category 1 pre-MARPOL (pre-1982) Category 2 MARPOL (post-1982) Category 3 smaller tankers (5,000-20,000/30,000dwt)

OIL POLLUTION PREVENTION

BUT

Flag state may extend Categories 2&3 up to 2015 or 25th anniversary (whichever earlier) if satisfactory results of the CAS

Flag state may extend Categories 2&3 with only double bottoms (db)or only double sides (ds) which may trade up to 25th anniversary of delivery (even past 2015)

HOWEVER

Port state may deny entry of either of such flag-state-extended tankers

5.8. OIL TANKERS CARRYING HEAVY GRADE OIL AS CARGO

Double hull is required from 5/4/05 for Heavy Grade Oil (HGO) as cargo for tankers 5,000 dwt and above, and for tankers 600 - 4,999 dwt (except single-hulls built with db and ds) from anniversary date in 2008

OIL POLLUTION PREVENTION

BUT

Flag state may allow single-hull tkr 5,000 dwt with only db or only ds to continue with HGO up to 25th anniversary (even beyond 2015) Flag state may allow single-hull tkr 5,000 dwt to continue with HGO between 900 and 945 kg/cubic meter until 25th anniversary or 2015 whichever is earlier, if results of the CAS satisfy Administration Flag state may allow single-hull 600-4,999 dwt to continue with HGO until 25th anniversary or 2015 whichever is earlier

HOWEVER

Port state may deny entry of any of the above mentioned flag-state-extended tankers carrying HGO

OIL POLLUTION PREVENTION

5.9.Condition Assessment Scheme (CAS) CAS (Applies to oil tankers 5,000 dwt ) CAS will be performed at intervals of up to 5 years and 6 months First CAS to be undertaken at first renewal (i.e. special) survey or intermediate survey after 5/4/05 of every tanker which has reached its fifteenth year CAS is to be harmonised with ESP (Enhanced Special Survey)

OIL POLLUTION PREVENTION

5.10.On oil tankers 5000 dwt constructed on or after 01.01.2007 the pump- room shall be provided with double bottom. 5.11. Tankers delivered on or after 01.01.2010 have to be constructed providing adequate protection against oil pollution in the event of stranding or collision. (Oil outflow performance in case of accident collision or grounding)
5.12. Oil tankers 150 GT shall be provided with slop tank arrangements of total capacity not less then 3% of total carrying capacity. Oil tankers 70,000 delivered after 31.12.1979, shall be provided with at least two slop tanks.

OIL POLLUTION PREVENTION

6. Equipment requirements for oil tankers cargo area
6.1. Oil tankers 150 GT shall be equipped with Oil Discharge Monitoring Equipment (ODME) approved by the Administration, which includes: - a recording device to provide continuous record of the discharge in litres per nautical mile and total quantity discharged, or the oil content and rate of discharge.
Record shall be identifiable as to time and date and shall be kept for at least three years; any discharge of oily mixture is automatically stopped when exceeding the permitted instantaneous rate of discharge of oil; Design of the oil content meter to be incorporated in the system shall comply with IMO requirements.

OIL POLLUTION PREVENTION

6.2. Oil tankers 150 GT
shall be provided with effective oil/water interface detectors approved by the Administration for a rapid and accurate determination of the oil/water interface in slop tanks and shall be available for use in other tanks where the separation of oil and water is effected and from which it is discharged directly to the sea.

OIL POLLUTION PREVENTION

6.3. Every crude oil tanker 20,000 dwt delivered after 1 June 1982 shall be fitted with a cargo tank cleaning system using crude oil washing (COW) approved by Administration.

OIL POLLUTION PREVENTION

7. Oil Record Book requirements
Part I - Machinery space Operations for tankers 150 GT and for non tankers 400 GT Part II - Cargo/ballast operations for oil tanker 150 GT

When making entries, the date, operational letter code and item number must be inserted and the required details recorded in the record of operations
Each completed operation to be signed and dated by officer in charge as soon as the operation is over.

OIL POLLUTION PREVENTION

Entries in the Oil Record Book must be:

accurate signed by person in charge of operation. entered without delay signed by Master on each page available for inspection

OIL POLLUTION PREVENTION

Oil record book (cont.) Mistakes to be struck through with a single line, the wrong entry signed and followed by the correct entry. No full empty lines between each recorded entry are permitted ,

ORB is to remain onboard for min. three years from the date of last entry
Only an official ORB is to be kept. A rough or working copy is not permitted. All entries recorded in ink. ORB can be inspected by authorized authorities that may make copy of entries and require the Master to certify them as true copy
Proper record keeping is to be verified at each superintendents visit to the ship

OIL POLLUTION PREVENTION

ORB is worthy of a special mention as this is a particular area that Port State Control inspectors frequently discover errors. It is also an area where a vessel can be fined heavily if the entries are wrong or have been deliberately falsified Refer also to: Fleet Operations Section 6.2.9 Safety & Environmental Procedures Section 9.4.4 INTERTANKOs A Guide for Correct Entries in the Oil Record Book UK P&I Club Oil Record Book entries

OIL POLLUTION PREVENTION

8. Approved Shipboard Oil Pollution Plan (SOPEP) required for oil tankers 150 GT and non-tankers 400 GT SOPEP - based on IMO guidelines* is written in the working language of the master and officers. The plan shall consist of: - the procedure to be followed by the master or other persons having charge of the ship to report an oil pollution incident, - the list of authorities or persons to be contacted in the event of an oil pollution incident;
For ships fulfilling reg. 17 of Marpol Annex II, SOPEP may be combined with the shipboard marine pollution emergency plan for noxious liquid substances and the title is changed to Shipboard marine pollution emergency plan. SMPEP

* MEPC.54(32) as amended by resolution MEPC.86(44)

*

OIL POLLUTION PREVENTION

The plan SOPEP shall consist of (cont.):

- a detailed description of the action to be taken immediately by

persons on board following the incident - the procedures and point of contact on the ship for co-ordinating shipboard action with national and local authorities.
click here for SOPEP Contact points updated as of 30/06/2009 for full txt of VMS SOPEP click here

Computerised, shore-based damage stability and residual structural strength calculation programs shall be accessible on board all oil tankers 5,000 dwt .

OIL POLLUTION PREVENTION

9. Onboard Oil Spill Equipment
should comprise: - protective clothing - emulsifiers for deck cleaning - sorbents - scupper plugs - non-sparking hand scoops, shovels and buckets - a minimum of one non-sparking pump with hoses

OIL POLLUTION PREVENTION

Onboard Oil Spill Equipment (continued)

The full list of equipment and supplies is to be listed in the vessel's SOPEP Manual. Oil Spill Removal Equipment is to be marked with two red bands and kept in a marked storeroom During cargo operations and bunkering, the equipment and supplies should be ready for immediate use.

For VMS 9.4.5 Onboard Oil Spill Removal Equipment txt click here

OIL POLLUTION PREVENTION

10. Oil loading terminals, repair ports and ports

in which ships have oily residues to discharge, have to be equipped with facilities for the reception of such residues and oily mixtures. Each Party shall notify the Organization for transmission to the Parties concerned of all cases where the facilities provided under this regulation are inadequate.

OIL POLLUTION PREVENTION

11. Surveys and Certification
- are required for ships 400 GT and oil tankers 150 GT. International Oil Pollution Prevention Certificate (IOPPC) shall be issued: - after an initial or renewal survey - by the Administration or organization duly authorized by it. - for a period not exceeding five years. Certificate shall cease if the relevant surveys are not completed, if the certificate is not endorsed, upon transfer of the ship to the flag of another State.
Click here to open IOPPC example

OIL POLLUTION PREVENTION

11. Port State Control (PSC) on operational requirements*
1. when in a port a ship is subject to inspection by authorized PSC officers
2. if there are clear grounds for believing that the master or crew are not familiar with essential shipboard procedures preventing pollution by oil, all steps are to be taken to ensure that the situation has been brought to order. 3. if ships equipment is broken or missing or ship has suffered damages en route, Port Authorities must be informed accordingly and if remedies were agreed with the flag state, the ship is not to be detained.

* Refer to the Procedures for port State control resolution

A.787(19) as amended by resolution A.882(21);

OIL POLLUTION PREVENTION

4.The most common MARPOL Annex I deficiencies found by PSC officers :
filtering equipment OWS malfunctioning 15 ppm alarm arrangements (inoperative alarm and auto stop) illegal OWS bypass SOPEP retention of oil onboard ,quantity of oily water retained onboard not corresponding with ORB entries and OIPP Record of Construction and equipment prevention of pollution by oil (IOPP) quantity of oil residues landed ashore or incinerated contrary to quantity expected to be produced from machinery spaces discharge violation noted by oil coating inside clean discharge pipes from OWS indications of discharge pipe/valve removal inconsistent entries in ORB

OIL POLLUTION PREVENTION

5. Certificates and documents to be carried onboard:

Oil Pollution Prevention Certificate (including the Record of Construction and Equipment (Form A or B) Statement of compliance for Condition Assessment Scheme (Tankers only) Type of Approval Certificates:

Oily Water Separator 15 PPM Alarm Oil Discharge Monitoring and Control System (Tankers Only) Oil/Water Interface Detector (Tanker Only)

OIL POLLUTION PREVENTION

Documents
All ships: Oil Record Book (Part 1) SOPEP * Tanker specific (Marpol Annex I): Oil Discharge Monitoring and Control System* ODME Manual
(recordings from ODME equipment to be kept onboard for at least 3 years)

Crude oil Washing Manual*, if applicable Oil Record Book (part 2) Access to shore based damage stability and residual strength Calculations Dedicated Clean Ballast Tank Operation Manual* Damage Stability Approval* Vapour Emission Control System Procedure (Manual) *
* Should be approved by or on behalf of the Flag Administration

OIL POLLUTION PREVENTION

12. Crime and penalty focus
U.S. Regulation summary:

MARPOL Annex I - the most frequently violated Over $200 million dollars in criminal fines since 1998 as well as : restitution, community service and probation with court supervised environmental compliance programs. Personal punishment : 17 years of imprisonment since 1998 for senior shipboard officers and engineers.

OIL POLLUTION PREVENTION

Direct causes of crimes

Many cases constitute deliberate discharges of tons of waste oil, sludge and other pollutants. Crimes committed for financial motive. Deliberate crimes omitting pollution prevention equipment Cost saving, easiest & quickest method of performing task Discharges made at night, hiding of bypass equipment, use of dispersants, tricking of OCM, falsification of Oil Record Book and Tank Sounding Log, etc. Faking of vessel records to mislead port authorities. Most cases involve circumventing of justice (destruction of evidence, alteration of documents, providing false witness, committing perjury).

OIL POLLUTION PREVENTION

illegal bypass example

OIL POLLUTION PREVENTION

Each of these vessels was ISM certified and had passed Class, Flag and Port State inspections

OIL POLLUTION PREVENTION

European Ship Sourced Pollution Directives
New EU legislation dealing with criminal liability in the form of Directive 2005/35/EC that came into force on 1 April 2007 imposes criminal liabilities for ship-source pollution. Unlike MARPOL, the Directive makes no distinction between operational and accidental discharges The Directive exposes not only ships crews, owners and operators to liability but also any other party connected to the ship, including salvors and classification societies.

Satellite monitoring Clean Sea Net provides monitoring of illegal discharges with oil spill alert within 30 min, including slick position, its extent, shape , as well as wind and wave data.

OIL POLLUTION PREVENTION

13. Equipment and Best Management Practices
VMS water pollution prevention (Fleet Operations, Safety & Environmental Procedures, Tanker Operation Instructions)

1. General
necessary precautions are to be taken and procedures are to be strictly followed during all oil transfer operations, which must not be left unattended every ship is to be supplied with posters regarding the prohibition of the discharge of any pollutants. Anyone sighting a pollutant around or near the vessel has to inform the Master immediately Click here for water pollution poster

OIL POLLUTION PREVENTION

General (cont.) inert gas generators should be started before entering restricted waters to avoid the possibility of pollution.

2. Bilges
Bilges must be kept dry at all times utilizing bilge holding tank. All oil and water leaks must be stopped or reduced.
Engineer officer is to examine bilges regularly, leaks and spillages must be identified and eliminated (no oil leak collecting tins etc are allowed) Cleansing agents, emulsifiers, solvents or surfactants used for cleaning purposes are to be minimized in the bilges of a ship, to limit emulsion formation.

OIL POLLUTION PREVENTION

2. Bilges (cont)
The contents of the bilge holding tank(s) are to be discharged via the vessels oily water separation system, ensuring that the oil content of the effluent does not exceed 15 ppm

3. The Oily Water Separator (OWS)

personnel is to be fully familiar with its operation and testing on no account is the OWS to be by-passed any faults and incorrect operating practices found by port state inspection can lead to the detention of a vessel. operation manual for the OWS is to be studied by the relevant personnel in order to become fully conversant with it. crew is to be familiar with the approved cleaning chemicals that do not form emulsion

OIL POLLUTION PREVENTION

3. The Oily Water Separator (OWS) cont.

any flanges located at or near the OWS and overboard discharge valves that are not used, should be blanked off

all flanges connected to any flexible hoses maintained on board which may create the wrong impression or suspicion that an illegal by-pass is being used should be removed. alarms and recording devices must be fully operational oil Record Book and the Deck Log can be closely checked for discrepancies by the inspectors Pumping capacities can be scrutinised OWS discharge valve is to be closed and locked when the vessel is in port or in a Special Area as defined by MARPOL

OIL POLLUTION PREVENTION

3. (OWS) cont.

It is to be noted that it is illegal to sail from a port without a functioning OWS and it is a requirement that sufficient spares for the unit are carried onboard. The Chief Engineer is fully responsible for the maintenance and operation of the OWS and its operation must only be carried out by officers fully familiar with the equipment When the equipment is not in use, the Chief Engineer is to ensure that a system is in place to lock-out the equipment to avoid unauthorized operation with keys being held by the C/E

OIL POLLUTION PREVENTION

3. (OWS) cont. Operating instructions and an operating diagram are to be posted on or next to the OWS unit. Regular operational tests and checks of the OWS and associated equipment must be carried out in accordance with the PMP and also no later than 24 hours before arrival in port where possible Minimum recommendations are that full inspection and cleaning of the OWS is to be carried out at least every two months with filters cleaned on a monthly basis. All tests must be recorded in the engine log book and oil record book However it is advisable that filters clearing should not be carried out immediately prior to entering port, as it may be interpreted as suspicious by PSC or MARPOL inspectors.

OIL POLLUTION PREVENTION

3. (OWS) cont. The tank from which the OWS takes suction should be cleaned on a two monthly basis. A sample is to be landed yearly for testing in a shore laboratory; the test standard is to be USEPA 1664.

The Oil Content Monitor is to be calibrated yearly. Where possible an interlock device preventing discharge overboard whilst flushing water supplied to the Oil Content Monitor (OCM) is to be fitted.
Any defects discovered with the OWS and associated equipment must be rectified without delay. Where a defect cannot be repaired on board for want of spare parts or the need for specialist service, the management office must be notified and a remedial action plan agreed upon. If the vessel is about to enter port knowing that the OWS is defective, the fact must be reported in the pre-arrival notices via agents according to local regulations.
for RESOLUTION MEPC.107(49) Revised guidelines and specifications for pollution prevention equipment for machinery space bilges of ships. Click here These Guidelines relate to equipment installed on or after 01.01.05

OIL POLLUTION PREVENTION

3. (OWS) cont. quantity of water discharged overboard in any logged period must not exceed the certificated capacity of the OWS unit. If any such discrepancy occurs, a full explanation must be recorded in the ORB. consistent units of measurement of volumes, rates and capacities used in the engine room should be used. (For example the units of measurement used in tank sounding tables should be the same as those used in recording volumes processed in the OWS) tank and equipment titles used in the ORB and in log books must match those of tanks and equipment identified in the ships IOPP certificate. Bilge tanks must be identified by their location (e.g. frame number) and capacity as well as their correct title

OIL POLLUTION PREVENTION

3. (OWS) cont. failure to comply with above instructions can lead to prosecution and authorities such as the USA have made it clear that they will seek jail sentences for senior officers of ships breaching pollution regulations. USA officials are to scrutinise the E/R alarm book and compare the times recorded for bilge /sludge tank alarms and subsequent pumping out with the ORB times of pumping bilges overboard, checking for any discrepancies.

OIL POLLUTION PREVENTION

3. (OWS) cont.
The Master must be advised, before the OWS is used, to ensure that the operation is in compliance with MARPOL and that all risks have been fully considered. The bridge team is to be advised when the equipment is in use in order that they can keep a watch astern to ensure that no oily sheen is sighted on the water. If such a sheen is sighted then the operation must be immediately stopped. Where possible, consideration should be given to limiting the use of the oil water separator to daylight hours. Where possible, consideration should be given to posting a watch (additional to the navigation watch) to visually monitor the sea surface in way of the discharge. For more details on OWS click here Ref. is also to be made to the Fleet Operations Section 6.5.5. e and Safety & Environmental Procedures Section 9.4.3

OIL POLLUTION PREVENTION

4. Disposal and handling of sludge

sludge is to be considered as contaminated, hazardous and toxic. There is a significant danger of explosion and fire as well as the dangers associated with toxic chemicals. Therefore it must be handled with care by competent staff using appropriate equipment and protective clothing. sludge containing oil or petroleum wastes from the engine room must be disposed of in full compliance with MARPOL .
expected sludge generation should be around 0,8 1,0 % of HFO plus 0,5% of DO consumption.

OIL POLLUTION PREVENTION

Disposal and handling of sludge (cont.)
Disposal will be:

direct to shore facilities or with the use of onboard incinerators or by other means covered by supplement to the IOPP Certificate Form A/B

if not stated in the IOPP Supplement Form A/B and the vessel has insufficient free capacity onboard to reach shore reception facilities, the transfer of engine-room sludge to the cargo system slop tanks may only be carried out after contact with the management office and flag authorisation.
a Risk Assessment (SAF03) and Critical Operations Checklist (SAF16) must be created by the vessel and reviewed by the management office prior to any such transfer.

OIL POLLUTION PREVENTION

5. Other procedures
that, if followed correctly, will help prevent pollution from engine room sources

FO 6.3.4 FO 6.3.5 FO 6.3.13 FO 6.3.18 FO 6.9.5 S&E 3.0 S&EP 4.4.4 (h) S&EP 4.6.3 S&EP 9.4 S&EP 9.7

Planned Maintenance System Defects and Damages Pipeline Identification, Valves Calibration Completion of Dry-docking Risk Assessments & Critical Operations Use of Detergents Lock Out Tag Out Procedures Water Pollution Disposal and Handling of Sludge

OIL POLLUTION PREVENTION

6. Tankers Cargo Operations - the main oil pollution sources:
Failure to monitor operations correctly Poor use of checklists Responsibilities delegated from officers to crew Failure of equipment Insufficient planning Complacency Failure to follow procedures

OIL POLLUTION PREVENTION

6.1. PLANNING (Oil Tanker Operating Instruction)

Cargo Loading/Discharge Plan (Form MAR08) includes as a minimum: final ullages, correct sequence of loading/discharge with expected times, ballasting, stress, stability and draft conditions at each stage, operating envelope of loading arms.

The Chief Officer in conjunction with another officer ensure that all valves are correctly set.
Plan is to be approved by the Master and signed by each officer and pumpman. Junior officers are encouraged to take part in planning. Plan is to be discussed and agreed in writing with the terminal personnel.

OIL POLLUTION PREVENTION

6.2. COMMENCING OPERATIONS
Before any operation proper procedures must be adopted in accordance with Oil Tanker Operating Instruction

4.6 Cargo Planning 4.16 Commencing Operations 6.3 Precautions Before and During Loading 8.5 Precautions Before Discharge 11.4.1. Tank Cleaning Plan All or parts of the above refer to the blanking of manifolds not in use, checking valves and lines, the use of checklists, scuppers in place, trips and alarms tested, commencing loading slowly, checking valves and lines again once cargo operations underway, checking cargo going into/out of correct tanks, proper watch keeping and communications as well as the readiness of salvage pumps and clean-up equipment in case of a spill.

OIL POLLUTION PREVENTION

6.3. MONITORING OF OPERATIONS
Monitoring of all cargo operations is essential for the purpose of safety and the avoidance of pollution.
Monitoring comprises:

the cross checking of fixed with portable gauges the calculation of loading/discharge rates unplanned deviations in the loading rate must be investigated immediately checking pressures at the manifold ensuring cargo is being loaded/discharged from the correct spaces and that spaces not involved in the operation are checked check of moorings

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6.3. MONITORING OF OPERATIONS (cont.)

effective manifold and deck watch looking for leaks both on the ship and over-side checking stress and stability checks of IG checks of the pump room careful topping off ensuring cargo is fully stopped after loading the use checklists!

ENSURE THAT THE CARGO PLAN IS FOLLOWED BY ALL! VMS Ref. = Oil Tanker Operating Instructions : all chapters!

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6.4. CHECKLISTS

Checklists are an essential and useful tool in safe operation and if used correctly they help prevent an incident. However they do not detract from an officers responsibility to follow the fully laid down procedure. There are references to particular checklists in almost every chapter of the tanker manual to accompany procedures and the relevant checklists are held within the forms manual. All checklists must be signed and a log entry made once completed. Where a checklist does not exist for a specific and critical operation (e.g. tank cleaning) then a critical operations checklist (SAF 16) is to be made and used onboard for such an operation. (ref .S&EP 3.7) Over and above Company checklists, the tanker manual references the Ship-Shore and Ship-to-Ship Transfer checklists as contained within ISGOTT (tanker manual refs 3.7, 3.8, 3.30.4, 3.30.5, 4.14, 6.3 and 8.5). Another non-Company checklist to be used is for crude oil washing. Such a form will be available in the COW operating manual carried onboard (ref . Oil Tanker Operating Instructions 11.9).

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6.5. RESPONSIBILITIES
Section 2 of Oil Tanker Operating Instructions defines the responsibilities (in relation to tanker operations) of the following personnel:

Master: e.g. supervision of cargo system and checking cargo plans Chief Officer: e.g. preparing the cargo plan, monitoring and control of cargo operations, personal supervision, producing written instruction and checking stress/stability. 2nd & 3rd Officers: e.g. monitoring of cargo operations as instructed by the Chief Officer and ensuring that a proper watch is maintained. Chief Engineer: e.g. maintenance of equipment and advising the Chief Officer of any bunker or other transfer to take place. Pump man and Ratings: assisting in cargo operations as required by the Chief Officer

There are examples of incidents occurring where the Chief Officer has delegated various responsible tasks to ratings instead of the deck officer.
The use of the word assist in relation to the pump man and ratings is not intended to detract from the responsibility of the officers who are trained and experienced in cargo handling.

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6.6. FAILURE OF EQUIPMENT

There are many important items of equipment that are used in cargo operations. If one or more of these were to fail or not be operated correctly a pollution incident could easily occur. These items have two or more things in common with each other that directly effect their operation:

Planned Maintenance (effectively carried out) Routine Testing (part of PMP or as required before operations) Calibration Understanding the correct use (read the instruction manuals) Following procedures correctly (read the relevant sections of the VMS)

Reference to the above is to be found throughout the VMS

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7. Bunker Operations
the main problems refer to:
Insufficient planning Failure to monitor operations correctly Poor use of checklists Responsibilities Failure of equipment Complacency

All bunker procedures are contained in the Fleet Operating Manual, Ch 6, Sect.7.2
For further details of bunkering operations including specific responsibilities, bunkering plan and checklist please click here

(Some key points related to Oil Pollution Prevention are listed in the following slides):

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Bunker filling limits :

Tanks up to 700m3 = 90% Tanks over 700m3 = 95% Tanks with known air-locking difficulties = 90%

Responsibilities:

Master; to ensure all regulations complied with Chief Officer; to deploy pollution prevention equipment Chief Engineer: to plan and supervise as well as ensure all equipment is in good order. This responsibility cannot be delegated. He must also ensure the designated person is aware of valve settings, ullages (present and final), quantities to be bunkered, flow rates, communications and filling sequence Designated Person in Charge: must be a qualified engineer nominated by the C/Eng and effectively responsible directly to the Chief Engineer for the bunkering operation Deck Watch: at least one person to be stationed by the hose connection and checking for kinking, chafing or leakage. Another person to check moorings and leaks from vents, overflow pipes etc.

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Bunkering Plan: Chief Engineer to prepare plan that comprises;

The identification, location and capacity of tanks to be loaded Initial, final and %-age level of each tank Sequence to be loaded Procedures to monitor tank levels and valve settings Copy of the bunkering plan to be displayed during operations

Training: The designated person in charge is to conduct regular training sessions for all those involved in bunkering operations. For the state of Washington, names of attendees are to be recorded. Training is to include the following:

The pre-bunkering plan Description of the bunkering system (i.e. lines, valves etc) Discussion regarding penalties for non-compliance and spills Oil transfer procedures, including responsibilities English phrases or hand signals used for communication Emergency shutdown procedures

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Pre-transfer preparation the procedure which includes understanding the planning, characteristics and limitations of equipment the requirements of MARPOL Annex VI ensuring that all air vents are open/free according to design ensuring that proper fitting bolts and gaskets are prepared ensuring that all unused manifolds are correctly blanked ensuring ullage/sounding equipment in good order use the bunkering operation checklist (TEC08 or TEC08a)
Pre-transfer Conference: held to discuss the following: procedures for communications between ship and delivery vessel/facility (e.g. advising when changing tanks and topping off) emergency shutdown procedures (both ship and delivery vessel/facility) identification of point of transfer and roving watchmen to delivery vessel/facility loading rates and time required to stop pumping

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Bunkering Checklists Using the checklist TEC 08 correctly is the best way of guaranteeing a safe bunkering operation. Note that in Washington State waters a separate checklist, TEC 08a, is to be used. Starting the Transfer Person in charge on ship to advise person in charge at facility that operations about to commence Valves and lines to be set by a nominated person and then double-checked by the designated person in charge Valves not used for the operation to remain closed and blanked manifold connections to be checked for tightness Operation to commence slowly and checks to ensure oil going into correct tanks before increasing the rate

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During Transfer Keep regular communication Keep rate safe and within agreed limits Check rate by taking regular soundings Make frequent checks of connections and for leaks Monitor tanks not being bunkered to ensure oil entering only into correct tanks Shut down if: fire at or near ship local thunder and lightning storms sea conditions not suitable burst of pipe or overflow any unexpected soundings or level alarms Flow Surges : changes in the pumping rate and the closure of valves must be gradual and planned to prevent pressure surges resulting in damage to the pipeline system. Care also to be taken at end of operation when blowing through

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Topping Off
The designated person in charge is to supervise topping off and: give notice to the bunkering facility/vessel when ready reduce flow rate before and during topping off test and maintain communications call more crew members if required when shutting down, ensure that the bunker vessel/facility valves are closed before the ships own valves are shut

Completion
The designated person in charge must check personally that: - all tank valves are closed and vents operational - all openings are closed and tight to protect against entry of sea water - the pipelines and hoses/arms between the ship and bunker facility have been cleared - sufficient ullage space is available before draining lines to ships tanks before disconnecting arms/hoses, - drain cock to be opened and drained to save-alls - manifold blanks securely fitted after disconnection

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14. Oil Pollution Act 1990 (OPA 90)
- authorized as an Act by the United States Congress in 1990 - produced as a result of: - Marine Pollution and in particular of the M.V. Exxon Valdez incident - series of amendments to the US Federal anti-pollution acts known as the Federal Water Pollution Control Act

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The OPA 90 requirement; All Vessels carrying oil in bulk as a cargo into United States waters must have an approved Vessel Response Plan (VRP) on board.
Under OPA 90, the clean-up must be carried out by the organisation, which spilled the oil, this organisation is known as the Responsible Party - this is
any person owning, operating or demise-chartering the vessel concerned.

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The Key elements of the OPA 90 Vessel Response Plan (VRP):

general information about the ship notification procedures and contact numbers onboard spill mitigation procedures shore based response activities a list of contacts training procedures drill procedures plan review and update procedures specific information for each US Coast Guard Zone an appendix for vessel specific information The OPA 90 VRP consists of the ship's MARPOL SOPEP but contains additional information on the shore based organisations and individuals that are named in it. Some states have requirements that are more rigorous than those defined in OPA 90.

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In the event of a discharge or threat of a discharge of oil from the vessel, the U.S.C.G. operated NRC (National Response Centre) in Washington DC should be notified by the ship immediately (even prior to calling company head office).

Failure to make such notification will make the Master personally liable to criminal prosecution

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The detailed course on OPA 90 shipboard and shore based organization for dealing with oil discharges click:

Marine Pollution Prevention OPA 90. ppt and Marine Pollution and Prevention OPA 90 Course Notes