MARPOL ANNEXURES AND IMPACT

MARPOLANNEXURES AND IMPACT ON SHIP

DESIGN

INCEPTION

• The MARPOL Convention is the main International Convention covering prevention of pollution of the marine environment by ships from operational or accidental causes.

• It is a combination of two treaties adopted in 1973 and 1978 respectively and updated by amendments through the years.

AIM

• The Convention includes regulations aimed at preventing and minimizing pollution from ships – both accidental pollution and that from routine operations.

• These regulations influence the ship design cycle in many ways.Some of these will be discussed.

RECAP OF THE ANNEXES

Annex I: Regulations for the Prevention of Pollution by OilCovers prevention of pollution by oil from operational measures as well as from accidental discharges.

IMPLICATIONS OF ANNEXURE I

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 water. Any discharge into the sea of oil or oily mixtures into the Antarctic Area (south of latitude 60°S) is prohibited.

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)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.

IMPACT OF ANNEX I ON DESIGN• sludge tanks of adequate capacity with regard to the type of machinery and length of voyage• oil fuel tanks protection against collision/grounding (i.e. double hull) for ships with an aggregate oil fuel capacity of 600 m³, delivered on or after 1 August 2010. A max. capacity limit of m³ per oil fuel tank is 2,500³.• 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 01.01.2005 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

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. Every oil tanker ≥ 5,000 dwt delivered on or after 6 July 1996 shall be fitted with double hulls. Oil tankers ≥ 150 GT shall be equipped with Oil Discharge Monitoring Equipment (ODME).

CERTIFICATES & DOCUMENTS 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)

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)

CRIME & PENALTY FOCUSU.S. Regulation summary:• 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.

CRIMES• 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).

ANNEX II:NOXIOUS LIQUID SUBSTANCES IN BULK

CATEGORIZATION OF NOXIOUS LIQUID SUBSTANCES AND OTHER SUBSTANCES

Category X: Noxious Liquid Substances which, if discharged into the sea from tank cleaning or de-ballasting operations, are deemed to present a major hazard to either marine resources or human health and, therefore, justify the prohibition of the discharge into the marine environment;

Category Y: Noxious Liquid Substances which, if discharged into the sea from tank cleaning or de-ballasting operations, are deemed to present a hazard to either marine resources or human health or cause harm to amenities or other legitimate uses of the sea and therefore justify a limitation on the quality and quantity of the discharge into the marine environment

Category Z: Noxious Liquid Substances which, if discharged into the sea from tank cleaning or de-ballasting operations, are deemed to present a minor hazard to either marine resources or human health and therefore justify less stringent restrictions on the quality and quantity of the discharge into the marine environment; and

Other Substances: substances which have been evaluated and found to fall outside Category X, Y or Z because they are considered to present no harm to marine resources, human health, amenities or other legitimate uses of the sea when discharged into the sea from tank cleaning of deballasting operations.

SHIP TYPES AS PER THE IMO• The International Code for the Construction and Equipment of Ships Carrying

Dangerous Chemicals in Bulk IBC Code (Ch- 17&18) provides detailed standards for the construction and equipment of three types of chemical tankers (Types 1, 2 and 3)

• IMO Ship Type 1 is a chemical tanker intended for the transportation of products considered to present the greatest overall hazard. The quantity of cargo required to be carried in a Type 1 ship should not exceed 1,250 m3 in any one tank.

• IMO Ship Type 2 is intended to transport products with appreciably severe environmental and safety hazards which require significant preventive measures to preclude escape of such cargo. The quantity of cargo required to be carried in a Type 2 ship should not exceed 3000 m3 in any one tank.

• IMO Ship Type 3 is a chemical tanker intended to transport products with sufficiently severe environmental and safety hazards. These products require a moderate degree of containment to increase survival capability in a damaged condition. There is no filling restriction for chemicals assigned to Ship Type 3.

CARGO TANK LOCATION

Cargo tanks shall be located at the following distances inboard:

1. Type 1 ships: from the side shell plating, not less than the transverse extent of damage specified in 2.5.1.1.2, (B/5 or 11.5m whichever is less), and from the molded line of the bottom shell plating at centerline, not less than the vertical extent of damage specified in 2.5.1.2.3, (B/15 or 6 m whichever is less), and nowhere less than 760 mm from the shell plating. This requirement does not apply to the tanks for diluted slops arising from tank washing.

2. Type 2 ships: from the molded line of the bottom shell plating at centerline, not less than the vertical extent of damage specified in 2.5.1.2.3, (B/15 or 6 m which ever is less), and nowhere less than 760 mm from the shell plating. This requirement does not apply to the tanks for diluted slops arising from tank washing.

3. Type 3 ships: no requirement"

CARGO TANK LOCATION & CONFIGURATION

OPERATIONAL REQUIREMENTS• Ships constructed before 1 July 1986 shall be provided with a pumping and

piping arrangement to ensure that each tank certified for the carriage of substances in Category X or Y does not retain a quantity of residue in excess of 300 litresin the tank and its associated piping and that each tank certified for the carriage of substances in Category Z does not retain a quantity of residue in excess of 900 litres in the tank and its associated piping. A performance test shall be required to be carried out.

Every ship constructed on or after 1 July 1986 but before 1 January 2007 shall be provided with a pumping and piping arrangement to ensure that each tank certified for the carriage of substances in Category X or Y does not retain a quantity of residue in excess of 100 litres in the tank and its associated piping and that each tank certified for the carriage of substances in Category Z does not retain a quantity of residue in excess of 300 litres in the tank and its associated piping.

• Every ship constructed on or after 1 January 2007 shall be provided with a pumping and piping arrangement to ensure that each tank certified for the carriage of substances in Category X, Y or Z does not retain a quantity of residue in excess of 75 litres in the tank and its associated piping.

After 1 January 2007, the stripping performance requirements will apply to all tankers holding a Certificate of Fitness (CoF).

STRIPPING & DISCHARGE REQUIREMENTS

CERTIFICATION OF CARGO• All non-oil cargoes carried in bulk are

classified by the IMO and/or the vessel’s flag state/administration

• The carriage requirements for a product are then determined by these entities using the guidelines set forth by GESAMP* and IMO

• If regulated by the IBC Code those cargoes must be authorised for carriage on that particular ship and listed on the ship’s Certificate of Fitness (CoF)

• Every chemical tanker is required to have a Certificate of Fitness (CoF) – indicating that it is certified to carry certain products

• The issuance of a CoF will also require a Procedures and Arrangements (P&A) Manual

ANNEXURE IIIAnnex III: Prevention of Pollution by Harmful Substances

Carried by Sea in Packaged Form [1]

Contains general requirements for the issuing of detailed standards on packing, marking, labelling, documentation, stowage, quantity limitations, exceptions and notifications.

For the purpose of this Annexure, “harmful substances” are those substances which are identified as marine pollutants in the as per IMDG code or which meet the other specified criteria.

• Rule does not apply to ship stores and equipment.[3]

• Packaging containing small quantities of harmful substances may be exempted from marking.

• Certain harmful substances have constraints with regard to quantity carried onboard.

• Harmful substances shall be properly stowed and secured so as to minimize the danger to the environment also while ensuring safety of life onboard the vessel. The safety of life is taken care of by the SOLAS and the MLC.

• Packaging of these harmful substances should provide correct technical names and leave no ambiguity in the mind of the user. Marine pollutants should be indicated very specifically.[3]

• Proper analysis of effects of harmful substances are to be taken into account (chemical, physical or biological) while regulating the washing of leakages overboard, especially considering the effects on crew.

• Harmful substances can only be jettisoned when it is necessary for the safety of life onboard.

ANNEXURE IV

Annex IV: Prevention of Pollution by Sewage from Ships [1]

Contains requirements to control pollution of the sea by sewage; the discharge of sewage into the sea is prohibited, except when the ship has in operation an approved sewage treatment plant.

Although the discharge of sewage from ships into the sea is of concern nowadays, the major contributors are still the land based activities.Since, it is still considered that higher seas are capable of assimilating and dealing with raw sewage through bacterial action, sewage disposal is limited only up to certain distance away from the nearest land.

• Governments are responsible for providing adequate reception facilities at ports, but the ship should be capable of stowing the sewage waste (sewage holding tank) until the time comes for proper disposal.[3]

• Also proper sewage treatment facilities onboard are mandatory if sewage has to be jettisoned.

• Discharge pipelines to have proper discharge connections and valves.

• Holding tanks are to be built to the satisfaction of the Government and the Classification Society concerned and should be designed based on endurance, crew capacity, mode of operation etc.[3]

• Same as packaged harmful substances, discharge of sewage is allowed anywhere subject to the condition that safety of life is at stake in the event of some disaster.

ANNEXURE VAnnex V: Prevention of Pollution by Garbage from Ships

(entered into force 31 December 1988)

Garbage means all kinds of victual, domestic and operational waste excluding fresh fish and parts thereof, generated during the normal operation of the ship and liable to be disposed of continuously or periodically except those substances which are defined or listed in other Annexes to the present Convention”

WHY GARBAGE CONTROL?

● Time taken for objects to dissolve to sea

Material Time to degradeTin cans 100 years

Newspaper 6 weeksGlass Indefinite

Polystyrene foam IndefiniteCardboard 2 - 4 months

Pastic six pack rings 400 years +Plastic bottles 450 yearsAluminum cans 200 yearsPainted wood 13 years

SPECIAL AREAS

● Special areas mean a sea area where for recognised technical reasons in relation to its oceanographical and ecological condition and to the particular character of its traffic the adoption of special mandatory methods for the prevention of sea pollution is required.

REQUIREMENTS FOR DISPOSAL OF GARBAGE AT SEA

●

Garbage Type Outside Special Areas In Special Areas

Plastics including ropes, nets, bags Disposal prohibited Disposal prohibited

Floating dunnage, lining, packing materials

>25 miles offshore Disposal prohibited

Ground – downpaper products,rags, glass, metal, bottles, crockery, etc

>3 miles offshore Disposal prohibited

Cargo residues, paper products, rags,glass, metal, bottles, crockery etc

>12 miles offshore Disposal prohibited

Food waste comminuted or ground >12 miles offshore >12 miles offshore

Incinerator ashes >12 miles offshore Disposal prohibited

GARBAGE MANAGEMENT PLANS AND GARBAGE RECORD-KEEPING

Garbage Management Plan

All ships of 400 gross tonnage and above and ships carrying more than 15 persons shall carry a Garbage Management Plan and Garbage Disposal Record

The Plan should include :

- written procedures for: collecting, storing, processing

and disposing of garbage (using onboard equipment)

- the designated person in charge of carrying out the plan

The Plan should be :

- in the working language of the crew and adapted for

individual ships - regularly reviewed and checked by

the Master if the it is being correctly adapted as part of his

weekly inspections.

PROCESSING OF GARBAGE

• Ships may be provided with onboard incinerators, compactors, comminuters or other equipment for garbage processing

• Advantages of such facilities:• disposal of certain garbage possible at sea• onboard storage space reduction• helpful in unloading garbage at a port• -allowing absorption of some types of garbage

STORING AND DISPOSING OF GARBAGE

• All disposal of garbage must be consistent with MARPOL 73/78 Regulations.

• All processed and unprocessed garbage shall be:

• - stored in tight, good condition, securely covered containers so that no

• garbage is released into the environment. (also required by Port Health

• and Agriculture Authorities in many countries from a health and disease

• control point of view) • - landed to reception facilities ashore and the Master shall ensure• that all local regulations are adhered to • - processed according to the vessel’s local agent requirements• such as segregation, cleanliness of garbage and disposal• containers / transportation bag

ANNEXURE VI

Annex V: Regulations for the Prevention of Air Pollution from Ships

Why MARPOL Annex VI?Emission Gases from Ships

Oxides of Nitrogen (NOx) – create Ozone and smogSulphur Oxides (SOx) – create acidificationCarbon Dioxide (CO2) – is a GHGCarbon Monoxide (CO)- is s very toxic gasHydrocarbons (HC) – gas, soot and some particulates

The concentration of the differing exhaust gases is variable according to the engine type, engine settings and fuel type.

The Regulations• There are 19 Regulations but the following

Regulations will impact Vessel operation for• ALL VESSELS ABOVE 400 grt• -Regulation 12 – Ozone Depleting Substances• -Regulation 13 – NOx emissions• -Regulation 14 – Sulphur Oxide emissions• -Regulation 15 – VOC emissions• -Regulation 16 – Shipboard Incinerators• -Regulation 18 – Fuel Oil Quality control

Regulation 12 Ozone Depleting Substances

• “Deliberate” Emissions of Ozone Depleting Substances (HFCs) are prohibited

• New installations can only use HCFCs (hydrochlorofluorocarbons) until 1st Jan 2020.

• These substances, when removed from ships, must be delivered to reception facilities

Regulation 13 - NOx

• Regulation applies to engines > 130 kW and not to engines used solely for

● the purpose of emergencies, related to the emissions from the engines. The

● manufacturer would provide a technical manual for the engines specifying the

● settings in order to comply with the regulations.● NOx emissions are controlled by Tier I, II & III

Regulation 14 - SOx● Under the revised MARPOL Annex VI, the global

sulphur cap is reduced initially to 3.50% effective from 1 January 2012

● Then progressively to 0.50% effective from 1 January 2020.

● The limits applicable in ECAs for SOx and particulate matter were reduced to 1.00%, beginning on 1 July 2010 Being further reduced to 0.10 %, effective from 1 January 2015.

Emission Control Areas

Regulation 15 - VOCs● A tanker carrying crude shall have and implement● onboard a VOC management plan. The plan should

provide● Written procedures for minimising VOC emissions during

loading, sea passage● and discharging● Consideration given to additional VOC generated during

COW● Identify person responsible for implementing the plan● Be written in the working language of foreign going ships

Regulation 16 - Incinerators● Incineration of the following items are not allowed-● Residues of cargo subject to annex I, II & III● Polychlorinated biphenyls (PCB)● Garbage having traces of heavy metals● Refined petroleum products containing halogen

compounds● Sewage sludge and sludge oil not generated

onboard● Exhaust gas cleaning systems

Regulation 18 – Fuel Oil Quality• -“Fuel oil shall be blends of hydrocarbons derived from

petroleum refining”• -“Fuel oil shall be free from inorganic acid”• -“Fuel oil shall not include any added substance or

chemical waste which either:• - Jeopardises the safety of ships or adversely

affects the performance of the machinery, or• -Is harmful to personnel, or• “Contributes overall to additional air

pollution”

REFERENCES[1] International Convention for the Prevention of Pollution from Ships (MARPOL 73/78) PRACTICAL GUIDE (2015)[2] ‘PREVENTION OF MARINE LITTER POLLUUNDER IMO CONVENTI’-1st NOWPAP Workshop on Marine Litter Incheon, Republic of Korea (2006)[3] http://www.marpoltraining.com/

– Annexures I-VI; their application, considerations in design and management.

THANK YOU