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Updated and Advanced Information of Ballast Water Management Turkish Chamber of Shipping 4 December 2014 NIPPON KAIJI KYOKAI 1

Contents Recent Topics of IMO Preparation for Ballast convention USCG(Information regarding ballast) 2013VGP(Information regarding ballast and EAL) Conclusions 2

Recent Topics of IMO Ballast water discharge disturbs the marine ecosystem river port deep sea 3~5 billion tons of ballast water is getting transferred by int l shipping every year International Convention adopted in 2004 Not entered into effect (As of today) 1973 Dangers of ballast water transfer identified (bacteria may cause disease etc.) 1988 International Convention adopted Convention may come into effect History Ballast water issue first discussed at IMO (reported from Canada for Great Lakes) 1993/1997 Two Guidelines adopted by the IMO (Prevention & Management) 2004 2016* * Regulation schedule TBA due to ratification number and rate 3

Recent Topics of IMO Present status of ratification Requirement to effect Current Status (As of 3 Dec. 2014) Ratified by 30 states 43 States Total Ship Tonnage 35% 32.54% No. Flag State GT % 1 Panama 218,269,034 19.44 2 Liberia 126,439,315 11.26 3 Marshall 95,024,687 8.46 4 Hong Kong 78,299,096 7.24 5 Singapore 69,352,556 6.18 6 Bahamas 52,986,208 4.72 7 Malta 49,707,064 4.43 8 Greece 41,734,666 3.72 9 China 40,612,372 3.76 Advanced information Italy (1.62%) Argentina (0.05%) will ratify in the near future(total ship tonnage will be 34.21%). Japan (1.76%) ratified on 10 Oct. 2014 Turkey (0.53%) ratified on 14 Oct. 2014 10 Cyprus 21,049,236 1.87 From : IMO HP 2014 4

Recent Topics of IMO D-2 Performance standard revised implementation schedule Constructed (= Keel lay) Ballast Water Cap. V(m 3 ) 2012 2013 2014 2015 2016 2017 2018 2019 2020 Before 2009 In or after 2009 before adoption 2009 ~ 2012 After 2012 Before adoption 1500 V 5000 V<1500 or 5000<V V<5000 5000 V Come into effect (Supposition) ( 1) ( 2) ( 1) ( 2) ( 1) After adoption All ( 3) 1 : First renewal survey of IOPP certificate after the Convention coming into effect ( 3) 2 : First renewal survey of IOPP certificate after the anniversary date of the ship in 2016 3 : On delivery 5

Recent Topics of IMO IMO Maritime Environment Protection Committee s (MEPC 65 & MEPC 67) MEPC 65 The procedures of sampling and analysis of ballast water were approved at MEPC65 for trial use. MEPC also agreed that trial would be for 2 to 3 years following entry into force of the Convention. MEPC 67 To facilitate the entry in to force, G8 will be reviewed and a correspondence group to be established Guidelines for PSC to set out the procedure for PSC was adopted which includes following : - To check documentation - To check the operation of BWTS MEPC further agreed that, during the trial period, PSC would refrain from applying criminal sanctions or detaining the ship based on only sampling. - To conduct: Indicative analysis of BW Detail analysis of ballast water Samples taken during stripping operations using eductors is decided to be inappropriate 6 6

Preparation for Ballast convention Application: All ships, but, the Convention shall not apply to: (1) Ships not designed or constructed to carry ballast water and ships that carry only permanent ballast water (that is not discharged) in sealed tanks (2) Ships of a Party which operate only in waters under the jurisdiction of that Party, or ships which operate only in waters under the jurisdiction of another Party (3) Ships that operate only in waters under the jurisdiction of that Party and on the high seas (4) Warships The convention will take effect 12months after the ratification requirements are met. D-1: Ballast exchange Ballast exchange and management D-2: BW performance standard Installation of BWMS Upon the date of entry in to force, ships need: International Ballast Water Management Certificate 7

Preparation for Ballast convention Consideration of D-1 standard Land 50nm 200nm EEZ 50nm Land 200nm EEZ 200m depth Special requirements of local regulation Land 8

IMO Guidelines: Compliance verification Ballast Water Convention G2- Guidelines for Ballast Water Sampling Guidance for Ballast Water Sampling and Analysis (MEPC 65- IMO BWM.2/Circ.42) Preparation for Ballast convention Article 9 (BWM Convention) # Verifying Validity of certificates # Inspecting ballast water records # Sampling of Ballast Water # General Sampling procedures # PSC sampling kit. # Indicative analysis before detailed analysis # Detailed sampling procedures Trial period of 2-3 years No detention in trial period At MEPC 67(Oct 2014) the Guidelines for PSC under the BWM convention was adopted. It takes indicative sampling approach which may require further analysis if necessary

Preparation for Ballast convention PSC inspection-ships Preparation, Pay attention to following items : IMO Regulations International Ballast Water Management Certificate Ballast water management plan and records Maintenance of BWTS and familiarization Sampling inspection by PSC for analysis USCG Bio fouling management plan and record (USCG) Record keeping (USCG and 2013VGP) Monitoring record (USCG and 2013VGP) Other local reg. Various US states Areas like ROPME, Persian Gulf etc. Flag states like Brazil, Malaysia etc. Support the Owners by: Issuance of Statement of Fact upon owner s request in case when flag does not ratifies Ballast Water Convention. Providing necessary information to owners by guidelines, technical info. etc. Offering 24 hours service by Survey Operations Headquarters, representatives stationed in New York, Europe, and Singapore. Various Consulting Services by ClassNK Consulting Services Co. Ltd, 10

USCG(Information regarding ballast) Vessels entering U.S. waters must now adhere to BWDS final rule, based on the implementation schedule in 33 CFR 151.2035, with below options (Ballast water exchange can be allowed until implementation date of installation of BWMS): Installation of BWMS Use of U.S. public water No ballast discharge Discharge to facility onshore or other vessel 33 CFR 151.2025 Ballast water management plan shall include Detailed fouling maintenance and sediment removal procedures BWMS to be approved by USCG Alternate Management System (AMS) will allow for a 5 year acceptance of BWMS approved by Non-US administrations (to IMO standards) during USCG approval process Application method of extension of implementation of BWDS was published Referred documents :TEC-0903, 0945, 0951, 0971, 0981 11

USCG(BWDS) Construct (=Keel lay) USCG(Information regarding ballast) Implementation Schedule Ballast Water Cap. V(m 3 ) 2012 2013 2014 2015 2016 2017 2018 Before 1 December 2013 On or after 1 December 2013 V<1500 1500 V 5000 5000<V All ( 1) ( 3) ( 2) ( 2) 1 : First scheduled drydocking* after 1st January 2014 2 : First scheduled drydocking* after 1st January 2016 3 : On Delivery *Drydocking means hauling out of a vessel or placing a vessel in a drydock or slipway for an examination of all accessible parts of the vessel s underwater body and all through-hull fittings. Extension by 01 JAN 2016 or 01 JAN 2017 may be granted for some vessels 12

USCG(Information regarding ballast) Remarkable information(uscg s understanding) Can BWMS without AMS approval be fitted? No Is USCG rules applied to Minor islands (i.e.saipan, Lota, Tenian, American Samoa)? Yes(There are American EEZs around them) In water survey is considered as scheduled drydock? No(IWS granted by class can be accepted) Are Guarantee dock and emergency dock is considered as scheduled dry dock? No When BWMS with AMS approval can not obtain USCG type approval, what will happen? USCG type approved BWMS to be installed. 13

USCG(Information regarding ballast) Remarkable information(uscg s understanding) Is dry docking only for the purpose of propeller shaft survey is considered as scheduled dry docking? No When serious damage at hull is found at In water survey and the vessel is on dry dock,the dry dock is considered as drydocking? No If vessel discharges no ballast water, BWMS to be fitted on the vessel? No. Ballast water record book to be submitted to National Ballast Information Clear house when entering the US port. 14

2013VGP(Information regarding ballast and EAL) Main items required by 2013Vessel General Permit (2013VGP) are followings: Management and monitoring of ballast water Installation of Environmental Acceptance Lubricant Parameter of BWMS monthly Calibration of sensor fitted on BWMS annually Residual biocide and derivative Submit Annual report (see Appendix H&I) to EPA Installation of BWMS Discharge to facility onshore Use U.S. public water No ballast discharge To be used (2013VGP 2.2.3.5.1) Referred documents:tec-0968, 0981 15

2013VGP(Information regarding ballast and EAL) Main items required by 2013Vessel General Permit (2013VGP) are followings Management and monitoring of ballast water Installation of Environmental Acceptance Lubricant EAL to be applied to oil-to-sea interface unless technical infeasible Lubricant oil having following property: Biodegradable Mminimally-toxic Not bioaccumulative Recordkeeping, reporting MSDS (Material Safety Data Sheet) of EAL Documents to certify conformity of 2013VGP (issued by EAL maker) Submit Annual Report to EPA Referred documents: TEC-0968, 0981 16

2013VGP(Information regarding ballast and EAL) Example of oil-to-sea interfaces < 2013VGP Part 2.2.9 > Stern Tubes Rudder Bearings Controllable Pitch Propeller Wire Rope and Mechanical Equipment Subject to Immersion Thruster Thruster Bearings Azimuth Thrusters Propulsion Pod Stabilizers Paddle Wheel Propulsion 17

2013VGP(Information regarding ballast and EAL) Definition of technically infeasible < 2013VGP Part 2.2.9 > 1. No EAL compatible to machinery and equipment 2. No Alternate product using EAL (e.g. wire rope) 3. EAL conforming to machinery and equipment is not available at any calling port 4. Need to delay replacement or installation of EAL by next dry docking Document describing reasons for not using EAL in all oil to sea interface (technically infeasible) to be onboard(2013vgp Part 4.2.9.j ). 18

2013VGP(Information regarding ballast and EAL) Remarkable information(understanding of EPA) Use of EAL to stern tube air sealing device is necessary or not. Not must, strongly encouraged(2013vgp 2.2.1) If vessel discharge(ballast water, bilge water, gray water )outside 3 nm from shore monitoring for them is necessary or not. No need EAL is necessary to rescue boat and life boat? Necessary for vessels with two stroke engine (2013VGP 2.2.21) Implementation date of USCG and that of 2013VGP is same, if extension of Implementation of USCG is approved, same extension is apply to VGP? Yes(TEC-0981, 2013VGP 1.9.1) 19

Conclusions Under the current circumstance of ratification for Ballast Water Convention, it seems the convention will take effect soon. USCG regulation already in motion for vessels trading in the U.S.. In order to prepare PSC inspection in near future, information to be gathered as much as possible. ClassNK will continue to provide useful and helpful information to our customers. 20

Thank you very much for your kind attention A World Leader in Ship Classification