E

MARINE ENVIRONMENT PROTECTION MEPC 65/7/2

COMMITTEE 8 March 2013
65th session Original: ENGLISH
Agenda item 7

INTERPRETATIONS OF, AND AMENDMENTS TO, MARPOL AND

RELATED INSTRUMENTS

Proposal for amendments to the 2012 Guidelines for the Implementation

of MARPOL Annex V, as adopted by resolution MEPC.219(63)

Submitted by Antigua and Barbuda, Barbados and the Republic of Korea

SUMMARY

Executive summary: This document proposes to amend the 2012 Guidelines for the
Implementation of MARPOL Annex V, adopted by resolution
MEPC.219(63), for the clarification of the disposal requirement of
soot-entrained drainage generated after washing the
boiler/economizer on board

Strategic direction: 2

High-level action: 2.0.1

Planned output: 2.0.1.18

Action to be taken: Paragraph 17

Related documents: Resolution MEPC.201(62) and resolution MEPC.219(63)

Introduction

1 The Committee, at its sixty-second session, adopted the revised MARPOL Annex V
for the Prevention of Pollution by Garbage from ships by resolution MEPC.201(62), which
entered into force on 1 January 2013.

2 In addition, the Committee, at its sixty-third session, adopted the 2012 Guidelines for
the implementation of MARPOL Annex V by resolution MEPC.219(63), to provide guidance
to all stakeholders for the smooth implementation of Annex V. The Committee further
adopted the Guidelines for the development of garbage management plans to reflect revised
requirements in MARPOL Annex V by resolution MEPC.220(63).

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3 In accordance with the revised MARPOL Annex V and the related guidelines, most
of the garbage which could be disposed of at sea in the past, depending on its types and
features or distance from the nearest land, can no longer be disposed of at sea on or
after 1 January 2013. Instead, it shall be consequently discharged to the port reception
facilities, as appropriate.

4 Notwithstanding the recently adopted new requirements mentioned above, the

disposal requirements for "Operational Wastes" specified in the revised MARPOL Annex V
and the 2012 Guidelines for the implementation of MARPOL Annex V, especially, the
disposal requirements for the "Soot-entrained Drainage", generated after washing the
boiler/economizer, are still vague. Accordingly, it is proposed that a clear definition on the
disposal of soot-entrained drainage generated after washing the boiler/economizer is needed
for an efficient implementation of Annex V and relevant guidelines.

Consideration on the "Operational Wastes" and "Other Similar Discharges"

5 Operational Wastes is defined in regulation 1.12 of MARPOL Annex V as follows:

"Operational Wastes means all solid wastes (including slurries) not covered by other
Annexes that are collected on board during normal maintenance or operations of a
ship, or used for cargo stowage and handling. Operational wastes also includes
cleaning agents and additives contained in cargo hold and external wash water.
Operational wastes does not include grey water, bilge water, or other similar
discharges essential to the operation of a ship, taking into account the guidelines
developed by the Organization."

6 Further guidance on "Operational Wastes" is provided in the 2012 Guidelines for the
implementation of MARPOL Annex V as follows:

1.7.3 The definition of "Operational Wastes" (regulation 1.12 of

MARPOL Annex V) excludes grey water, bilge water, or other similar discharges
essential to the operation of a ship. "Other Similar Discharges" essential to the
operation of a ship include, but are not limited to the following:

boiler/economizer blowdown;
boat engine wet exhaust;
chain locker effluent;
controllable pitch propeller and thruster hydraulic fluid and other oil sea
interfaces (e.g. thruster bearings, stabilizers, rudder bearings, etc.);
distillation/reverse osmosis brine;
elevator pit effluent;
firemain systems water;
freshwater lay-up;
gas turbine wash water;
motor gasoline and compensating discharge;
machinery wastewater;
pool, spa water and recreational waters;
sonar dome discharge; and
welldeck discharges.

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7 Given the definition in MARPOL Annex V and the guidance contained in the
Guidelines mentioned above, it is considered that the "Operational Wastes" can include the
garbage generated from the normal maintenance and operation of a ship. Therefore, it
should be understood that its disposal into the sea is prohibited. However, among the
operational wastes, "Other Similar Discharges" essential to the operation of a ship, such as
the examples provided in paragraph 6 above, can be regarded as materials which could be
discharged into the sea en route.

8 If so, different interpretations remain as to whether the soot-entrained drainage

generated after washing the boiler/economizer should be regarded as "Operational Wastes"
or as "Other Similar Discharges", which could lead to misunderstandings among all related
stakeholders due to the lack of clear definition and requirements on its category and
disposal.

Consideration on the disposal of "Soot-entrained Drainage" generated after washing

the boiler/economizer

9 Most main or auxiliary boilers on board ships are normally equipped with the
exhaust gas economizer on funnel deck. This is to further produce steam required for heating
systems such as bunker and lubrication oil heating systems and main or auxiliary diesel
engine jacket water heating systems, by using the waste heat contained in the exhaust
gases emitted from the main or auxiliary diesel engine(s). Consequently, the solid soot
contained in exhaust gases will be deposited on the gas side of the exhaust gas economizer.

10 As the operation of boiler/economizer is repeated, heat efficiency and production of

steam will be gradually reduced by the deposition of solid soot on the gas side. Reportedly,
ship operators normally wash the soot down to clean away the solid soot deposited on the
gas side of the exhaust gas economizer. Then, they have been disposing of this waste into
the sea or to a port reception facility under certain circumstances considering the local and/or
port environmental restrictions applicable to such a discharge because of the lack of specific
disposal requirements on the soot-entrained drainage in the past.

11 However, under the revised MARPOL Annex V, which took effect

on 1 January 2013, it would appear that the soot-entrained drainage would be considered as
"slurries" which belong to categories of operational wastes collected on board during normal
maintenance or operations of a ship, and which may not be disposed of into the sea.

12 On the other hand, the definition of "other similar discharges" and the examples
allowable for discharge into the sea provided in paragraph 1.7.3 of the 2012 Guidelines for
the implementation of MARPOL Annex V include materials such as "gas turbine wash water"
which may be considered as of a very similar composition to boiler/economizer wash water.

13 Thus, when there were some requests for an interpretation on whether

soot-entrained drainage can be regarded in the same category as "gas turbine wash water"
that is deemed to be "other similar discharges" by related industries, or as operational waste
that may not be discharged, the Administrations would have no choice but to answer that it
should not be discharged directly overboard until determined to be acceptable by the
Committee, as there were no explicit references or requirements on this matter.

14 In this regard, the co-sponsors are of the opinion that soot-entrained drainage
generated after washing the boiler/economizer on board should be regarded as "Operational
Wastes" since it can be only collected during periodical "maintenance" of boiler/economizer,
and also considered as "slurries" as defined in the regulation 1.12 of MARPOL Annex V.
Moreover, it may contain considerable amounts of oily substances which can potentially
cause marine pollution, creating oil traces on the sea surface.

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15 Given such discussions, the co-sponsors are also of the opinion that appropriate
amendments to the 2012 Guidelines for the implementation of MARPOL Annex V would be
highly beneficial to achieve a common understanding amongst all related stakeholders, and
amended guidelines should elaborate on regulation 1.12 of MARPOL Annex V, specifying
the definition of the operational wastes.

16 However, the co-sponsors would also like to note that a reasonable consensus on
this issue among the IMO membership is necessary, since the revised MARPOL Annex V
has already entered into force and amendments to the related guidelines on the disposal of
soot-entrained drainage are urgently needed to minimize confusion arising from different
interpretations. Thus, based on the proposed draft amendments which are set out in the
annex to this document, the Committee is invited to decide on reasonable disposal
requirements for soot-entrained drainage, taking into account various opinions provided by
the Member States, shipowners' associations and related stakeholders attending this
session.

Action requested of the Committee

17 The Committee is invited to consider the proposal in paragraphs 15 and 16 above

and the draft amendments to the 2012 Guidelines for the implementation of MARPOL
Annex V in the annex, and take action as appropriate.

***

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Annex, page 1

ANNEX

DRAFT AMENDMENTS TO THE 2012 GUIDELINES FOR THE IMPLEMENTATION OF

MARPOL ANNEX V, AS ADOPTED BY RESOLUTION MEPC.219(63)

1 INTRODUCTION
..

1.7.3 The definition of "operational waste" (regulation 1.12 of MARPOL Annex V)

excludes grey water, bilge water, or other similar discharges essential to the operation of a
ship. "Other similar discharges" essential to the operation of a ship include, but are not
limited to the following:

boiler/economizer blowdown;
boat engine wet exhaust;
chain locker effluent;
controllable pitch propeller and thruster hydraulic fluid and other oil to sea
interfaces (e.g. thruster bearings, stabilizers, rudder bearing, etc.);
distillation/reverse osmosis brine;
elevator pit effluent;
firemain systems water;
freshwater lay-up;
gas turbine wash water;
motor gasoline and compensating discharge;
machinery wastewater;
pool, spa water and recreational waters;
sonar dome discharge; and
welldeck discharges.

.1 Notwithstanding other similar discharges stated above, soot-entrained

drainage generated after washing the boiler/economizer gas side should be
regarded as "Operational Wastes". Thus, its direct disposal into the sea is
prohibited. Considering that it may contain considerable amounts of oily
substances that can potentially cause marine pollution, creating oil traces
on the sea surface, the following measures on the disposal of
soot-entrained drainage may be considered by shipowners and operators.

Ships with soot-collecting facilities should collect all soot-entrained

drainage generated after washing the boiler/economizer, and after
decanting, the separated solid soot should be collected and
subsequently disposed of to the port reception facility. Any remaining
decanted soot water could possibly be processed through the ship's
machinery bilge water system if the oily water separator and oil content
meter are capable of detecting the pollutants contained in it, or
evaporated through adequate heating facilities with the residual sludge
or solid material disposed of to the port reception facility. If not, the
remaining decanted soot water should be retained on board for
eventual discharge to the port reception facility.
Ships without facilities to collect or decant soot-entrained drainage are
requested to ensure the provision of adequate soot-collecting facilities
for its collection or disposal.
..
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