IMO REVIEW OF MEPC.1/CIRC.511 AND RELEVANT MARPOL ANNEX I AND ANNEX VI REQUIREMENTS. Comments on the Report of the Correspondence Group

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1 INTERNATIONAL MARITIME ORGANIZATION E IMO SUB-COMMITTEE ON SHIP DESIGN AND EQUIPMENT 51st session Agenda item 18 DE 51/18/3 27 December 2007 Original: ENGLISH REVIEW OF MEPC.1/CIRC.511 AND RELEVANT MARPOL ANNEX I AND ANNEX VI REQUIREMENTS Comments on the Report of the Correspondence Group Submitted by INTERTANKO Executive summary: Action to be taken: Paragraph 15 Related document: DE 51/18/1 SUMMARY This document comments on the Report of the Correspondence Group and suggests few further clarifications that the Sub-Committee may take into consideration and forward them to the working group attention 1 This document is submitted in accordance with the Guidelines on the organization and method of work (MSC/Circ.1099 MEPC/Circ.405). 2 INTERTANKO participated in the Correspondence Group and, from the outset wishes to express its appreciation for the excellent performance of Mr. Kristensen, the Chairman of the Correspondence Group. We also appreciate the openness of the discussions and the valuable exchange of views and data brought forward by each of the participants. 3 The report of the Correspondence Group, DE 51/18/1, provides a very good package of revisions. However, as the report indicates, a few issues are still to be further addressed at DE 51 and INTERTANKO would offer the following comments and suggestions: Amendments to regulation 16 of MARPOL Annex VI and UI 15 of MARPOL Annex I 4 Based on feedback from members, INTERTANKO would state that the capacity of incinerators onboard ships is insufficient. INTERTANKO would therefore suggest that this needs to be mandated through a new regulation 16(10) of MARPOL Annex VI as suggested in annex 3 of the Correspondence Group report. 5 INTERTANKO is also in favour of removing Unified Interpretation 15.5 (UI 15.5) of MARPOL Annex I which may be a contributing factor that hinders ships from being compliant with MARPOL Annex I. The reasons for this INTERTANKO position are the following. For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

2 DE 51/18/ Due to lack of port reception facilities, ships have to rely on onboard incineration to protect the marine environment. The experience indicates that the majority of incinerators have low efficiencies which means a far too long time of usage to handle the waste and the sludge generated onboard. The proposed new regulation would correct this by introducing a necessary minimum standard. 7 If a ship is equipped with an incinerator and homogenizers, UI 15.5 allows that the tank capacity for oil residues (sludge) can be reduced to 50% irrespective that there is no indication for a minimum performance of incinerators. Experience has shown that the reduced capacity of these tanks is not sufficient and might render ships in non-compliance with MARPOL Annex I. Oil Record Book Part I Entries D versus Entries E 8 With regard to Entries D Non-automatic discharge overboard and entries E Automatic discharge, INTERTANKO wishes to provide additional guidance and clarifications and suggested these are included as further interpretations of the ORB. The added clarification is based on feedback from ships which have used the INTERTANKO Guide for Correct Entries in ORB, Part I. The Guide is quite popular with more than 10,000 copies being used by ships. One of the most frequent confusion/lack of proper understanding is with regard to the correct entry on non-automatic versus automatic discharge overboard. Based on consultations with flag Administrations, INTERTANKO has issued the following interpretation of the use of entries D versus entries E:.1 E entries refer to putting the system (1) in auto-mode for discharge overboard or (2) in auto-mode for transfer to holding tank or (3) in manual operation..2 Therefore E entries refer to a system that can be put in auto or manual operation and therefore refer to systems that have sensors (floaters or equivalent) to start/stop discharge from holding tank to overboard or sensors (floaters or equivalent) to start/stop transfer from bilge wells to bilge water holding tank(s), or between bilge tanks..3 D entries are then to be used for all other systems (with or without auto-stop device). 9 The background of this interpretation is: MARPOL Annex I, regulation 16(1), requires that:.1 all ships with GT between 400 to 10,000 shall be fitted with oil filtering equipment complying with MARPOL Annex I, regulation 16(4); and.2 all ships with GT above 10,000 shall be provided with oil filtering equipment, and with arrangements for an alarm and for automatic stopping any discharge of oil mixture when the oil content exceeds 15 ppm complying with MARPOL Annex I, regulation 16(5). This means that ships of: GT between 400 to 10,000 are allowed not to have automatic stopping device; GT above 10,000 must have automatic stopping device; and and all ships must have 15 ppm monitoring system.

3 - 3 - DE 51/18/3 10 Some PSC officers and Vetting Inspectors have the following interpretation: Ships without automatic stopping device are subject to non-automatic discharge overboard, therefore D entries are only accepted and F entries for the failure of the 15 ppm device. Ships with automatic stopping device are subject to automatic discharge overboard therefore E entries are only accepted and F entries for the failure of the 15 ppm devise and the automatic stopping device. 11 INTERTANKO disagrees: for instance, should such an interpretation be correct, a ship with automatic stopping device but without start/stop sensor in bilge wells, the entry for transfer of bilge water from bilge wells to the bilge holding tank would be E17 which is not an automatic transfer. 12 The Sub-Committee is invited to agree with the interpretation given in paragraph 8 and include it as an additional footnote for the D and E entries in Part I of the Oil Record Book. Oil Record Book Part I C11.4 entry record of manual sludge collection 13 The correspondence group suggest a new entry C11.4 for manual sludge collection. INTERTANKO suggests that difference should be made between manual sludge collection by sludge collecting pumps and the manual sludge collection through gravity, which is an uncontrolled process (e.g., uncontrollable drains from M/E scavenges, separators sludge, drains from coamings or workshops). The reasoning for a new C11.4 is to increase transparency because the amount of oil residues is recorded once a week, the disposal of oil residues (sludge) is recorded per operation but without taking into consideration the actual number of manual collections (additions) to the oil residues (sludge) tanks. However, it is not possible to have a correct monitoring and entry for additional collection through gravity. INTERTANKO believes that request for such entries may create confusion for many existing ships which have no sludge collecting pumps. MEPC.1/Cir.511 Revised IBTS flow chart 14 INTERTANKO would suggest the attached alternative for the revised IBTS flow chart which, compared with the proposed flow chart in annex 6 of document DE 51/18/1, has the following additional features: Clean drains block: The clean drain tank should be with skimming arrangement for skimming the oil sheen that might exist on the clean drain and, preferably cascade type (a cascade type is a necessity to fulfill the aim of the tank clean drains). The current flow chart given in annex 6 of the Correspondence Group report does not indicate whether the skimmed water drain should go to the bilge well, the bilge primary tank or if it needs to go through the oily water separator. Oily bilge Water block: All tanks should be of sloping bottom type. Bilge primary tank skimming to go to the sludge tank. INTERTANKO believes that the clean water tank and clean water pump in the flow chart given in annex 6 of document DE 51/18/1 for this block are not necessary and do not reflect the normal designs with 3-way valves and 15 ppm alarm device. Oil residues Sludge block: Oil purifier sludge tank and fuel purifier sludge tank should be separate and of smaller capacity for obvious operational reasons (e.g., an overflow of main engine lube oil to a 20 m 3 tank will be detected when some 15 m 3 of oil is contaminated and unrecoverable in the common sludge drain tank). INTERTANKO would suggest a two-tank system for the incinerator and a boiler fuel tank with a sloping bottom.

4 DE 51/18/3-4 - Action requested of the Sub-Committee 15 The Sub-Committee is invited to consider the above information and request the working group to consider the suggestions made by INTERTANKO in this document. ***

5 DE 51/18/3 ANNEX