Regulations for OWS

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Atlantic
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Regulations for OWS

Postby Atlantic » Tue Dec 23, 2014 7:04 pm

Hi all and merry Christmas.

I have a question regarding OIly water separators. When can you run it? Do the ship has to be on route? Or is making way ok? We are just puttering around making sure the oil rigs don't fall over so we are not on route I asume.

On transport canada web site I found this.
https://www.tc.gc.ca/eng/marinesafety/t ... ns-617.htm

That says:
In Canadian waters
Concretely, in a normal situation, no more than 5 ppm of an oily mixture may be discharged from a ship in Division I waters if:

The ship is making way;
No oily mixture originates in cargo pump room bilges or is mixed with oil cargo residues;
The discharge is processed through oil filtering equipment that produces an undiluted effluent that has an oil content of no more than 15 ppm and it triggers an alarm and a discharge stopping device as soon as:
the effluent exceeds 5 ppm where discharged in inland waters of Canada, or
15 ppm where discharged in fishing zones 1, 2, 3 or in those internal waters that do not include inland waters of Canada.
The discharge does not contain chemicals or any other substance introduced for the purpose of circumventing the detection of concentrations of oil that exceed the oil content limits specified in these regulations.

But it also says according to MARPOL:
Ships of 400 tons gross tonnage and above other than oil tankers may discharge an oily mixture from the bilges of machine spaces as long as the following conditions apply:

The ship is proceeding en route;
The oil content of the undiluted effluent does not exceed 15 ppm;
The ship has in operation all the equipment required according to its gross tonnage, date of entry into service and the systems that are on board. The different pieces of equipment are set out in Regulation 16 of Annex I of the MARPOL Convention.

Does anybody know Canadas interpretation of an route?

Best Regards

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JK
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Re: Regulations for OWS

Postby JK » Wed Dec 24, 2014 3:47 am

When you look at the regulations it states the Canadian water divisions . you need to know where you are to know what you can pump.
Then they go on to mention :
The following concepts must also be considered:

Shipping safety control zone
The areas of arctic waters shown in Schedule II and described in the zones set out in Schedule I of the Shipping Safety Control Zones Order are prescribed as shipping safety control zones.

Fishing zones 1, 2 and 3

Fishing zones of Canada are the marine areas adjacent to the coast of Canada designated as such by the Oceans Act and the Fishing Zones of Canada (Zones 1, 2 and 3) Order.

Special areas

As mentioned in the MARPOL Convention (see the section about Annex I of MARPOL).


From there you go to:
2.2.1.b. Concept of special areas

Regulation 10 of Annex I of the Convention lists all the special areas, which are the Mediterranean Sea, Baltic Sea, Black Sea, Red Sea, Persian Gulf, Gulf of Aden and the Antarctic area.


then the :
Ships of 400 tons gross tonnage and above other than oil tankers may discharge an oily mixture from the bilges of machine spaces as long as the following conditions apply:

The ship is proceeding en route;
The oil content of the undiluted effluent does not exceed 15 ppm;
The ship has in operation all the equipment required according to its gross tonnage, date of entry into service and the systems that are on board. The different pieces of equipment are set out in Regulation 16 of Annex I of the MARPOL Convention.


would apply

In Canadian waters, you must be underway, which is not docked, anchored or grounded which means you can pump whatever the regulation statres for that Division of water/ overboard.

Considering it is very early and I have had one coffee only, don't take my interpretation as fact. It is your certificate and you need to protect it. Look at the reg again and you decide.
Last edited by JK on Wed Dec 24, 2014 3:52 am, edited 1 time in total.

Atlantic
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Re: Regulations for OWS

Postby Atlantic » Wed Dec 24, 2014 8:31 am

Hi JK, thanks for your reply.

I'm aware of the special areas in MARPOL not sure about fishing zones in Canada though. I'm not the one operating it (and would not, unless i was sure it was legal to do so) but we are having a discussion on board. So if we in Canadian waters its under way but if we leave its en route, that sounds like its less requirement in Canadian waters regarding en route part? I use it en route in Canadian waters and of course all other restrictions are Ok, that should be fine. Its the under way and en route that got me a bit confused.

best regards

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JK
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Re: Regulations for OWS

Postby JK » Wed Dec 24, 2014 10:26 am

I get confused all the time with the regs, so I was very verbose because alleluia, I think I got it.
I waded through the overboard discharge regs for ground up foodstuff from the garborator. It took me a day to figure out that we were mostly OK and what we didn't meet for we could get a certificate from environment. Written by lawyers for lawyers. Good luck with getting anyone from TC to help interprete either.

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Big Pete
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Re: Regulations for OWS

Postby Big Pete » Sat Dec 27, 2014 1:08 am

The special areas are no longer relevant to the operation of OWS. Except for the Arctic special area where all discharges are banned (Zero Discharge Area). Now all OWS have to have 15 ppm alarms and shut downs. Use of OWS with 15 ppm alarms and shut downs have always been permitted in Special Areas, in the past many ships still had old OWS didn't have an alarm or shut down and relied on manual observation and shut downs. These should all have been replaced, years ago, otherwise the ship is not street legal!
Therefore, Except in the Arctic Special Area it is legal to use the Oily Water Separator (obviously so long as it is working correctly and no one has bypassed the 15 ppm monitor!)
However the ship must be "en route" my interpretation of that is that the ship must be " Full Away on Passage" as we used to say. i.e. outside Harbour Limits, Pilot Off and steaming at normal Sea Speed, from one Port to another.
You definitely can not use the Oily Water Separator if you are aground, drilling, pipe laying, in DP Operations,hove to, waiting on Weather or standing bye, carrying out cargo operations (Lightering or transferring cargo to offshore installations etc.)

Those are the internationally agreed rules under Marpol. Some coastal States may have tighter rules,for their waters, none can have lower standards. I have not studied the Canadian Rules but what are quoted do not conflict with Marpol. They are just out of date because all OWS that are fitted now have to have a 15 ppm alarm and shut down and can therefore be used in Fishing areas.
IMO tends to encourage Maritime States not to have different standards as this causes confusion to us simple seamen, however Maritime States often copy elements of MARPOL into their own law and then fail to update it when it becomes obsolete as in this case.

Historically, when MARPOL was first introduced, back in the late 1970'S the first generation of OWS separated to 50 ppm, then after a few years the Regs were tightened and filters were added to bring the discharge down to 15 ppm , then the the 15 ppm Monitor & alarm was fitted, so that the Duty Engineer could investigate and fix the problem if it wasn't working properly, and finally the 15 ppm shut down was fitted, either to stop the pump motor or to dump the overboard discharge back to Bilge or a tank. When all these different permutations were still around there were pages and pages of regulations involving the use of different types of OWS, in different places, those are all gone and the later editions of MARPOL are relatively easy to understand.
Either a Hard Copy or and Electronic copy of MARPOL must be on board every ship and I strongly advise all Engineers to read it, and don't ignore the Appendices and Annexes, if you read it all it does actually start to make sense.

I have worked in the North Sea, off and on for about 30 years and nearly all the Supply Boats, AHTS , Stand By Boats etc working here pump all their ER Bilges ashore, because the Area is tightly regulated and in over 43 years at Sea I have only sailed with a couple of OWS that actually achieved an output of 15 ppm without having to change all the filters after about 15 minutes pumping. It works out cheaper to land all the oily waste Purifier Sludge Bilge Water etc. etc than to change the Filters. No OWS can dispose of oil it can only separate the water and dispose of that, so even if you use it, you still have to pump all the recovered Oil ashore. Purifier Sludge is full of fine particles which separate to the bottom of the Purifier Sludge Tank and if you try to put the water from the bottom of the sludge tank through the OWS you will block the filters immediately.

Stay Legal!

Big Pete
It is always better to ask a stupid question than to do a stupid thing.

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JK
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Re: Regulations for OWS

Postby JK » Sat Dec 27, 2014 4:13 am

Thanks Big Pete! Always good to have someone up to date and actually working with it everyday on here.

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D Winsor
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Re: Regulations for OWS

Postby D Winsor » Sat Dec 27, 2014 11:02 am

On the Great Lakes and the St. Lawrence River Basin where the maximum discharge concentration is 5 ppm there are special zones where the OWS can be used to discharge treated water overboard. These zones are usually 12 miles offshore and not in recognized zones where fresh drinking water can be pumped. The OWS can never be used used to discharge water overboard in ports, rivers or canals.

The vessel must be under way when the separator is set to discharge overboard. When starting and stopping the process the vessels Latitude and Longitude and times must be recorded in both the Bridge & Engine Room Log Books and Oil Record Book along with the quantity discharged.
As expected in order to satisfy regulators on both sides of the Canada/US Border and as Big Pete mentioned there was a lot of experimentation with filters and other devices to aid in getting the ppm count for the discharged water from the traditional coalescent type OWS below the 5ppm threshold.

There is, on the vessel I am currently working, an Alpha-Laval Echostream OWS which is basically a traditional self-cleaning centrifugal purifier that is setup to process more water than oil. I don't want to sound like a salesman for Alpha-Laval, but these units, when used in conjunction with a bilge water holding tank, do a very good job of removing oil and other contaminants including emulsions from the bilge water.
Troubleshooting 101 "Don't over think it - K.I.S.S. it"

Atlantic
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Re: Regulations for OWS

Postby Atlantic » Sat Dec 27, 2014 4:11 pm

Hi Guys

Thanks for all the comments, so en route to port is the normal procedure thanks. Thank you Big Pete for you post.
I have a questing though regarding"Purifier Sludge is full of fine particles which separate to the bottom of the Purifier Sludge Tank and if you try to put the water from the bottom of the sludge tank through the OWS you will block the filters immediately."

I though it wasn't legal to have any connection or ability to transfer between Bilge and sludge system, expect manual drain that have to be monitored and has a self closing valve?

Happy new year to all.

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D Winsor
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Re: Regulations for OWS

Postby D Winsor » Sun Dec 28, 2014 6:33 am

You are correct it is illegal to be able to pump from a sludge tank into the bilge with any pump or system with the capacity to discharge overboard primarily because of the risk of an accidental oil discharge due to system contamination. However doing an internal transfer of decanted water from a sludge tank or bilge to a separate holding tank with a dedicated pump set up for that purpose may be considered acceptable.
With respect to the draining or decanting of water from a purifier sludge tank much of sediment discharged from the purifiers will remain in the tank. The drain line or pump suction is usually located as far as possible away from the purifier sludge discharges so much of the sediment will either remain suspended in the cold oil or will settle out before reaching the suction. Eventually the sludge tank will have to be opened and cleaned out with the collected sediment removed and sent to a shore disposal facility
Troubleshooting 101 "Don't over think it - K.I.S.S. it"

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Big Pete
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Re: Regulations for OWS

Postby Big Pete » Mon Dec 29, 2014 4:00 am

Hi Atlantic,

In the old days, before about 1978, it was normal for the suctions from the Bilge, Waste Oil and Purifier Sludge Tanks and ER Bilges to all go to the General Service Pump suction and the whole lot was pumped directly overboard at Sea and in Port.

Since MARPOL was first introduced, ship Design and construction has slowly evolved to reflect the changing requirements of MARPOL, but Ship construction usually takes some time before it reflects the practicalities of the changed operating procedures. It will of course immediately comply with any requirements that are written into the rules.

It was only a few years ago that rules were introduced requiring that the Sludge system should be separate from the Bilge System and Class Surveyors or Flag State Surveyors carrying out the First MARPOL Survey after that date were supposed to verify that the systems had been separated. However, not all Surveyors crawl through the Bilges to check that the pipe connections have been removed and blanked off, so many older ships are sailing around that can pump the sludge tank through the OWS.

Big Pete
It is always better to ask a stupid question than to do a stupid thing.


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