Experience with legislation on environmental protection

1
Experience with legislation on environmental
protection

• Erik I. Tvedt
• Senior Surveyor in Charge
• NEA Statutory Advisory Team
• Copenhagen Design Support Centre

2
Objectives

• Introduction
• Details of IMO new legislation on environmental
  protection
• MARPOL Annex I
• MARPOL Annex II and IBC Code
• MARPOL Annex VI
• Ballast water management
• Anti-fouling systems
• Recycling of ships and Green Passport
• Lloyds Register classification notation on
  environmental protection

3
What is Copenhagen Design Support Centre (CDSC)???

• Design Support and Plan Approval for the Nordic
  countries
• One stop shop for both advise and traditional
  Plan Approval
• All disciplines represented
• Specialises in
• Off-shore support vessels
• RO/PAX vessels
• Chemical carriers
• MODU certification
• Augmented by our colleagues in Hamburg and
  Rotterdam
• Further back-up by the rest of the Lloyds
  Register Group around the globe

4
What is NEA Statutory Advisory Team

• A group of statutory specialists within CDSC
• Skills in the following areas
• Stability
• Fire Safety
• Life Saving Arrangements
• SOLAS Chapter V
• MARPOL
• Other MEPC issues
• EU regulations
• Advising clients and Lloyds Register Group field
  surveyors on statutory issues
• Working with clients on design problems
• Participates in IMO and EU work (often by
  invitation of the DMA)

5
A politically incorrect formula

• Cp Perceived cost of pollution
• Mas Miles of affected shoreline
• Mvs Number of voters on affected shoreline
• Ndb Number of dead birds
• J Number of journalists present
• Cf Country factor
• My message this is the decade of environmental
  regulation!

6
Introduction Things to remember

• Statutory rules and regulations are made by
• Civil servants
• Academia
• Industry representatives (and that means your
  representatives!)
• Statutory rules and regulations are promulgated
  by politicians
• Statutory rules and regulations are put into
  force by flag administrations
• Statutory rules and regulations are enforced by
  Recognised Organisations (RO)
• Statutory rules and regulations are to be adhered
  to by ship-owners, shipyards, designers,
  equipment manufactures etc.
• The only one with responsibility for the ship is
  the shipowner!!!!!

7
One more thing

• Flag is always right
• Class as an RO are acting on behalf of the
  flag state administration in order help the
  shipowner to comply with statutory regulations.

8
Part IKey Dates for Statutory legislation (1)

• Enter into force date for a convention
• 12 month after the ratification date on which day
  the convention has been ratified sufficient
  number of stats with enough percentage of Gross
  Tonnage of the worlds fleets.
• At present IMO conventions enter into force
  within an average of five years after adoption.
• Enter into force date for a resolution containing
  amendments
• Final implementation date according to tacit
  acceptance procedure.
• Normally six months after the deemed acceptance
  date

9
Key Dates (2)for Statutory legislation

• Application key dates for a specific
  amendments/regulations
• Building Contract Signed Date
• Construction Date (keel-laying date or similar
  stage)
• Delivery Date
• First survey after a certain date (including
  initial survey)

10
Key Dates (3)for LR Rules and Regulations

• Application key dates (after 1 July 2003)
• Building Contract of Construction Signing Date
• Sister/optional ships not later than one year.
• To see detail in Lloyds Register Ship Rules,
  Part 1, Chapter 1, Section 7.

11
Reference of Statutory Legislation and LR Rules
in Contracts

• In building specifications
• Date of contract of construction, Keel-laying
  date, estimated Delivery date
• To specify additional requests which do not
  covered by the applicable legislation applicable
  by those dates above
• In contracts signed with Lloyds Register
• Clear statement of three key days or estimated
  ones
• To specify additional requests which need to have
  additional assessment and/or statement of
  compliance issued by Lloyds Register.

12
Part IIRevised MARPOL Annex I (1)

• Revised Annex I is adopted by MEPC. 117(52) on 15
  October 2004
• MEPC. 117(52) Deemed to have been accepted on 1
  July 2006 but to enter into force on 1 January
  2007
• Application
• Building contract placed on or after 1 January
  2007
• In the absence of building contract, the keel of
  which are laid or which are at a similar stage of
  construction on or after 1 July 2007
• Delivery of which is on or after 1 January
  2010
• Undergo major conversion.

13
Revised MARPOL Annex I (2)

• Main New Requirements
• Regulation 22 Pump-room Protection
• IMO unified interpretations adopted by MEPC 54
  (March 2006) Applicable to cargo pump-room and
  ballast lines are acceptable in DB spaces
• Regulation 23 Accidental Oil Outflow
  Performance
• Alternative solution
• Software developing, current Aids and NAPA SCM in
  future
• Regulation 37(4) All oil tankers of 5,000 tons
  deadweight or more shall have prompt access to
  computerised, shore-based damage stability and
  residual strength calculation program.
• Lloyds Register services of SERS

14
Revised MARPOL Annex I (3)Regulation 12A -
Protection of Fuel Oil Tanks (1)

• Adopted by MEPC.141(54) on 24 March 2006
• used to be called as Regulation 13A but being
  renumbered to avoid confusion with current
  Regulation 13A.
• Application
• Building contract placed on or after 1 August
  2007
• In the absence of building contract, the keel of
  which are laid or which are at a similar stage of
  construction on or after 1 February 2008
• Delivery of which is on or after 1 August 2010
• Undergo major conversion.

15
Revised MARPOL Annex I (4)Regulation 12A -
Protection of Fuel Oil Tanks (2)

• Apply to all ships with an aggregate oil fuel
  capacity of 600 m3.
• Apply to all oil fuel tanks except small oil fuel
  tanks (not greater than 30 m3) but excluding
  those tanks which would not contain oil fuel in
  normal operation, such as overflow tanks.
• Individual oil fuel tank not to be more than
  2,500 m3.
• any oil fuel tanks that do not border the outer
  shell plating shall be located minimum h from
  the bottom shell plate and at least w from side
  shell plating.
• Alternative arrangement to comply with accidental
  oil fuel outflow performance standard.
• Influence piping design as well.

16
Revised MARPOL Annex I (5)Regulation 12A -
Protection of Fuel Oil Tanks (3)

• Arrangement of fuel tanks on different types of
  ships.
• Container Ships, RoRo Vessels, Multi-purpose
  Vessels, Bulk Carriers, Tankers
• Safe carriage of cargoes.
• One BC Code cargo - Ammonium Nitrate Fertilizers,
  Type B (UN. No. 2071) (not a dangerous goods)
• Away from all sources of heat. Away from any tank
  or double bottom containing fuel oil immediately
  adjacent to the cargo space if heated to more
  than 50C.
• Certificate of Compliance.
• Dangerous Goods. Operational matter.
• Document of Compliance for Reg.II-2/19 or 54.
• Discussions of arrangement and installations
  underway.

17
Part IIIRevised MARPOL Annex II and IBC Code

• Revised MARPOL Annex II adopted by MEPC. 118(52)
  on 15 October 2004 and Revised IBC Code adopted
  by MSC. 176(79) on 10 December 2004
• Enter into force both on 1 January 2007.
• Applicable to
• New ships constructed on and after 1 January
  2007
• Existing ships converted to chemical tankers on
  and after 1 January 2007
• Existing ships due to re-categorisation of
  chemicals.
• Issue of certificates
• NLS certificate for MARPOL Annex II.
• Certificate of Fitness for IBC code.

18
Revised MARPOL Annex II and IBC Code
(2)Re-categorization of Chemicals

• New four-category system of category X, Y, Z and
  OS (other substances).
• Replacing previous five-category system of
  category A, B, C, D and III (other substance in
  Appendix III).
• Some chemicals may not be categorised yet because
  of lack of essential data for evaluation.
• Without being at least provisionally assessed,
  they will not be able to be carried after 1
  January 2007.
• Will not to be listed on new certificate of
  fitness or NLS certificate.
• Could be added in an addendum if there is
  provisional assessment/evaluation.
• The work is estimated to be complete by 1 January
  2009.

19
Revised MARPOL Annex II and IBC Code (3)Carriage
of Particular Cargoes

• Vegetable Oils
• Most of vegetable oils (previously in Chapter 18)
  have been upgraded during re-categorization due
  to environmental threat.
• Most of then have been now put in Chapter 17 of
  the revised IBC Code and shall be carried on ship
  type 2 chemical tankers.
• Special consideration/exemption for carriage on
  ship type 3 chemical tanker. Note the 3 000 m3
  problem
• Carriage on dry cargo ship on specific trades
  after 1 January 2007. To see MEPC.120(52).
• Oil-like substances
• To be only carried on full chemical tankers after
  1 January 2007.
• Any residues must be discharge as for chemical
  substance.
• Bio-fuels (e.g. bio diesel)
• Not yet categorised Tri-partied agreements

20
Revised MARPOL Annex II and IBC Code (4)Major
Technical Requirement Changes
21
Revised MARPOL Annex II and IBC Code (3)Type of
Vessel

• NLS carried on Offshore Supply Vessels
• Resolution A.673 (16) Guidelines of the
  transport and handling of limited amounts of NLS
  in bulk on Offshore Support Vessel
• The resolution is being revised by IMO in light
  of 2007 amendments to MARPOL Annex II and the IBC
  Code.
• Remember your mud-tanks

22
Revised MARPOL Annex II and IBC Code (5)LR
Services

• Assessment based on current record of a ship to
  determine which cargoes could be carried after 1
  January 2007.
• can be undertaken for non-LR ships upon request.
• Analysis proposed changes and modifications to
  enable carriage of additional cargoes.
• Issuing new Certificate of Fitness and NLS
  certificates including new list of cargoes.
• Guide and approval of revised PA Manuals and
  SMPEPs.

23
Part IVMARPOL Annex VI (1)

• This annex was original adopted at MEPC 40 on 26
  September 1997 and was ratified by enough flag
  states on 18 May 2004
• Entered into force on 19 May 2005 (one year after
  18 May 2004)
• Application
• All ships and fixed and floating drilling rigs
  and other platform
• Issue of Certificates
• International Air Pollution Prevention (IAPP)
  Certificate or
• Certificate or Statement of Compliance

24
MARPOL Annex VI (2)

• To control what
• Ozone Depleting Substances (ODSs)
• Nitrogen Oxides (NOx)
• Sulphur Oxides (SOx)
• Volatile Organic Compounds (VOCs) (Tankers only
  and if VEC system fitted)
• SOx Emission Control Area (SECA) (1.5 m/m
  sulphur content)
• the Baltic Sea
• the North Sea
• Amendments adopted by MEPC.132(53) on 22 July
  2005
• from 22 November 2007 ships entering the North sea

25
MARPOL Annex VI (3)

• To check what
• Main Engines (NOx Code) by EIAPP Certificate
• Other Diesel Engines with a power output of 130
  kW, except those intended solely for emergency
  use (NOx Code) by EIAPP Certificate
• Incinerators (MEPC. 76 (40)) by Type Approval
  Certificate
• Fire Fighting Systems (free of ODSs) by Statement
• Refrigeration Systems (free of ODSs) by Statement
• VECS (VOCs) by Plan Approval DAD
• Fuel Oil Quality (SOx) by Bunker Delivery Note
  Sample

26
MARPOL Annex VI (4)Discussion and Development

• To reduce pollution during operating at sea
• Discussion of limit use of residual oils
• Discussion of use lower sulphur fuel oil 1.5
  and 0.5 or even less (0.1)
• To reduce pollution during berthing at a port
• Port regulations EU, California (USA), Vancouver
  (Canada)
• Discussion of on-shore power supply. It is also
  called Alternative Marine Power (AMP) or
  Cold-ironing.
• Technical developing by working group from
  ISO/IEC
• Ports cost effective study and test
  projects/scheme
• Facilities at quay
• Facilities on board
• Wash water from SOx scrubbers (and from Inertgas
  plants!)

27
Part VBallast Water Management

• International Convention for the Control and
  Management of Ships Ballast Water and Sediments
• adopted on 13 February 2004
• Not entered into force yet but will be 12 month
  after ratification by 30 States (6 currently),
  representing 35 per cent (0.62 currently) of
  world merchant shipping tonnage.
• Target to enter into force on 1 January 2008.
• But many states and areas ask for ballast water
  management plan of approved or examined format.
  For example,
• Brazil (approved) (by 30 June 2006 and extended
  to 30 December 2006)
• Canada (examined) (by 8 December 2006)

28
Ballast Water Management (2)

• Obtaining a statement of compliance with the
  convention will assist in compliance with those
  national requirement and will ensure that the
  ship.
• Ballast Water Management Plan shall be examined
  to compliance with
• Reg. B-1 of the convention and IMO Resolution
  MSC.127(53) Guidelines for Ballast Water
  Management and the development of ballast water
  management plan, or
• LR ShipRight Procedure Assessment of Ballast
  Water Management Plans on the basis of IMO
  Resolution A. 868 (20) Guidelines for the
  control and management of ships ballast water to
  minimize the transfer of harmful aquatic
  organisms and pathogens.

29
Ballast Water Management (3)

• LR custom-made, well-structured systematic
  procedure and user-friendly Model Plan
• Offices in this region authorized to provide the
  services
• Piraeus, Copenhagen, Madrid and Rotterdam
• Exchange Method
• Sequential Method
• Flow Through Method
• Dilution Method
• Additional piping system and pumps.
• Few ships

30
Ballast Water Management (4)Treatment Method

• A certificate or letter of acceptance of the
  ships ballast water treatment system issued by
  at least one Port State Authority within whose
  territorial jurisdiction it is intended to
  operate is required.
• No approved system currently on the market. But
  the convention does allow the use of prototype
  systems provided they are installed and used in
  accordance with a scheme run in conjunction with
  the flag administration.
• USCG STEP (Shipboard Technology Evaluation
  Program) programme.
• http//www.uscg.mil/hq/gm/mso/step.htm
• First fully approved ballast water treatment
  system with certification might be completed in
  mid of 2007.

31
Part VIAnti-fouling Systems

• IMO International Convention on the Control of
  Harmful Anti-fouling Systems on Ships (AFS
  Convention), 2001
• Adopted on 5 October 2001
• Not entered into force yet but will be 12 month
  after ratification by 25 States (17 currently),
  representing 25 per cent (15.72 currently) of
  world merchant shipping tonnage.
• EU AFS Regulation, EC No.782/2003.
• Applicable to all ships of 400 GT and above
  engaged on international voyages
• From 1 January 2008, to remove organotin
  anti-fouling systems from the hull or apply a
  sealer coat.

32
Anti-fouling Systems (2)LR Services

• Anti-fouling paint identification, sampling and
  testing
• LR recognized anti-fouling paint list
• Anti-fouling system survey and certification
• International Anti-fouling System Certificate, or
  
• Anti-fouling System Certificate of Compliance
  (EU)
• Both with a copy of record of anti-fouling
  system.

33
Anti-fouling Systems (3)Certification Flow Chart
34
Part VIIShip Recycling and Green Passport

• IMO Guidelines on Ship Recycling, A.952(23)
• adopted on 5 December 2003
• Green Passport is a document that contains an
  inventory of materials onboard a ship which may
  be hazardous to human health or to the
  environmental.
• Certificate (Document of Compliance) Inventory
• to be maintained throughout the ships
  operational life. At the end of a ships life,
  the Green Passport can be used to assist safer
  and more environmentally sound dismantling of the
  ship.
• Life cycle Design Construction, through-life
  operation and end of life.

35
Ship Recycling and Green Passport (2)Benefits to
the Owners

• Provides formal summary of hazards, thus
  promoting better hazard management, enhancing
  onboard safety and enabling better long term
  liability planning
• Assists financial planning through better
  awareness of changing value of assets (on account
  of enhanced dismantling requirements) and onboard
  hazard liabilities
• Promotes better environmental awareness and
  planning
• Enhances Owner reputation through compliance with
  (currently) voluntary initiative
• Provides measurable and achievable objective(s)
  for ISO 14001 certified companies

36
Ship Recycling and Green Passport (3)LR Services

• LR service covers the approval and verification
  of Green Passports for accuracy and compliance
  with the IMO Guidelines
• LR do not compile Green Passports
• For new ships, the yard should prepare the
  hazardous materials inventory and for existing
  ships, Owners/crews will need to compile
  inventory.
• LR supply a Guide to the Green Passport, Rev.
  July 2006 and supply an electronic template to
  assist preparation
• World-wide service net with well trained
  surveyors
• Singapore, Yokohama, Piraeus, Rotterdam, London,
  Miami and Korea

37
First Green Passport forShell LNG Tanker,
GRANATINA LR 9253105
38
Ship Recycling and Green Passport (5)
Document of Compliance with IMO Guidelines on
Ship Recycling under Lloyds Registers own
authority
39
Ship Recycling and Green Passport (6)Completing
the Inventory (1)

• Part 1 Potentially hazardous materials in the
  ships structure and Equipment
• 11 categories of hazardous materials, 1A1K
• covering Asbestos, Paint, Plastic Rubber
  materials, Materials containing PCBs/PCTs/PBBs,
  ...
• Part 2 Operationally generated wastes and Part
  3 Stores
• Do not need to be completed until the ship is
  being prepared for recycling.

40
Ship Recycling and Green Passport (7)Completing
the Inventory (2)

• In case where testing would be required in order
  to establish whether a hazard exists, the owner
  have the option not to test, but to declare the
  material a probable or presumed hazard.
• Proper safety and environmental hazard management
  systems must exist for all noted probable,
  possible, presumed or actual hazards.
• These systems are not part of the Green Passport
  since they are covered by the ISM code. However,
  the Green Passport will be available to ISM
  auditors and may be used as a source of reference
  during the audit.

41
Ship Recycling and Green Passport (7)Latest
Development

• New legally binding Instrument on Ship Recycling
  agreed IMO MEPC, July 2005 for adoption
  2008-2009
• New instrument to set out mandatory requirements
  governing
• Ship design and construction, operation and
  maintenance, preparation for recycling
• Requirements for recycling facilities
• Enforcement mechanisms
• Draft International Convention for the Safe and
  Environmentally Sound Recycling of Ships, March
  2006
• Consistent, but additional aspects
  prohibition/restriction of materials Technical
  Group

42
Part VIIILR Rules on Environmental Protection

• Development History
• First launched in May 1998 as provisional Rules
• Incorporated in Ship Rules in January 2001
• Amended in 2002/2003/2006
• Current Ships Rules, Part 7, Chapter 11
  Arrangement and Equipment for Environmental
  Protection.
• Covers major areas of concern with regard to
  operational pollution from shipping.

43
EP Notation (2)Benefits

• Demonstrates environmental responsibility
• Improves environmental performance
• Mitigates risk of fines, etc. from environmental
  infringements
• Helps future proof your ship
• Rules on EP aim to predict where legislation may
  be introduced in the future and thus compliance
  with these minimises risk of future legislative
  compliance problem

44
EP Notation (3)General (Prerequisite)
Requirements

• Comply with all relevant Annexes of MARPOL.
• Possess valid ISM certificates, Document of
  Compliance for the company and Safety Management
  Certificate (SMC) for the ship.
• Enrol in LRs Ship Emergency Response Service, or
  an equivalent scheme by an IACS member.

45
EP Notation (4)

• Basic notation EP
• Supplementary Characters
• A - Hull anti-fouling
• B Ballast Water Management
• G Grey Water
• N NOx Emissions
• O Oily Bilge Water
• P Protected Oil Tanks
• R Refrigeration System
• S SOx Emissions
• V Vapour Emission Control Systems Vc and Vp

46
EP Notation (5)Basic EP Notation (1)

• NOx emissions
• Emission limits are the same as those specified
  in Regulation VI/13 to MARPOL
• SOx emissions
• Max fuel sulphur content 3.5 S
• Max fuel sulphur content 1.5 S in SOx Emission
  Control Area
• Refrigeration systems
• Free of Chlorofluorocarbons (CFC)
• System design, operation maintenance to
  minimise refrigerant gas leakage. Max allowable
  leakage 10
• Leakage detection system for monitoring
  continuously the spaces into which the
  refrigerant could be leak shall be provided and
  the alarm shall be given in a permanently manned
  station

47
EP Notation (6)Basic EP Notation (2)

• Fire-fighting system
• Free of halon or halo-carbons.
• Oil pollution Prevention
• Oil water separator 15 ppm. Type approval
• Separate tanks for sludge and waste oil. Combined
  tank acceptable when operating on distillate fuel
  only
• Collection and recovery any oil spilled on deck
• Garbage handling and disposal
• Garbage management plan. More details specified
• Incinerator, if fitted. Type approval operation
  to following Regulation VI/16 to MARPOL

48
EP Notation (7)Basic EP Notation (3)

• Sewage treatment
• Treat Black water only Minimum capacity of
  115/15 litres/person/day for conventional
  flushing system/ vacuum system
• Treat both black and grey water the above
  additional allowance of 135 litres/person/day.
• Type approved sewage treatment system.
• Ventilation pipes from treatment system to be
  independent of others.
• Hull anti-fouling systems
• Free of TBT from 1 January 2003.
• Up to 1 January 2008, TBT leaching rate not
  exceeding 4 µm/cm2/day.
• Ballast water
• Precautionary measures

49
EP Notation (8)More Stringent Requirements for
SCs (1)

• A - Hull anti-fouling
• Antifouling system to be non-biocidal. Silicone
  based paints acceptable.
• B Ballast Water Management
• BWMP to be approved
• G Grey Water
• To install plant for the treatment of grey water
• The effluent
• faecal coliforms content not to exceed 250/100 ml
  M.P.N. (most probable number)
• Suspended solids test on shore/board not to
  exceed 50/100 mg/l
• Biochemical Oxygen Demand (BOD5) test on
  shore/board not to exceed 50/100 mg/l
• If re-used or recycled, to meet potable water
  quality standard

50
EP Notation (9)More Stringent Requirements for
SCs (2)

• N NOx Emissions
• Not exceeding 80 of the limits specified in
  Regulation VI/13 to MARPOL
• O Oily Bilge Water
• Oil water separator 5 ppm
• P Protected Oil Tanks
• The same as new Regulation I/12A to MARPOL
• R Refrigeration System
• Refrigerant gases restricted to those
• Ozone Depleting Potential (ODP) 0
• Global Warming Potential (GWP) lt 1950

51
EP Notation (10)More Stringent Requirements for
SCs (3)

• S SOx Emissions
• Maxi allowable fuel S content
• Gas oil 0.2 m/m
• Fuel oil 1.5 m/m
• V Vapour Emission Control Systems
• Vc VECS to be fitted and to comply with USCG 46
  CFR 39 or IMO MSC/Circ. 585
• Vp to fit a self-contained system to prevent
  vapour emission formation during loading
• LR type approved type with reduce vapour emission
  formation by at least 75 v/v.

52
EP Notation (11)
53
EP Notation (12)LR Services

• Type approval of equipment/system
• Plan approval
• Initial survey and audit
• Period survey and audit
• Change of Company
• Notation will be suspended when a ship changing
  company.
• Re-assign after successful completion.

54
Part IX Introduce some new concepts

• Integrated Bilge Water Treatment Systems (IBTS)

55
Integrated Bilge Water Treatment System (IBTS)

• MEPC.1/Circ.511 - Revised guidelines for systems
  for handling oily waters in machinery spaces of
  ships adopted on 18 April 2006
• Previously MEPC/Circ.235 adopted on 13 December
  1990 (applicable to ships constructed on or after
  1 January 1992)
• Improvement has been made on pollution prevention
  equipment for machinery spaces bilge by
  MEPC.107(49). But the treatment process of oily
  bilge water with the improved equipment and the
  engineers load is basically unchanged and the
  amount of oily bilge water generated in ships has
  not been reduced.
• Approved the concept of an Integrated Bilge Water
  Treatment Systems (IBTS)
• Incorporates the means to reduce the amount of
  oily bilge water and process the oily bilge water
  and oil residue (sludge) in a holistic manner.

56
Integrated Bilge Water Treatment System
(2)Concept

• IBTS is a system to minimize the amount of the
  oily bilge water generated in machinery spaces by
  means to treat the leaked water and oil
  separately. It is also provides integrated means
  to process the oily bilge water and oil residue
  (sludge).
• Outline of IBTS
• Collection of drains
• Pre-treatment of oily bilge water
• Discharge of oily bilge water
• Discharge of clean drains
• Treatment of oil residue (sludge)

57
IBTS (3)
Typical Flow Diagram of IBTS
58
Integrated Bilge Water Treatment System
(4)Additional Installation of IBTS (1)

• Drainage System
• Drip trays or coamings for equipment used for oil
  such as diesel engines, burners, pumps, heaters,
  filters and tanks to keep spillage of oil.
• Drip trays or coamings for equipment used for
  water such as pumps, heaters, coolers, filters,
  tanks, condensers and boilers to keep spillage of
  water.
• Pre-treatment unit for oil separation
• Bilge primary tank with construction of cascade,
  which is able to separate oil from oily bilge
  water by gravity with drainage facilities of the
  oil on the top as primary separation of oily
  bilge water.

59
Integrated Bilge Water Treatment System
(5)Additional Installation of IBTS (2)

• Storage tanks
• Clean drain tank Tank for the retention of clear
  drains.
• Bilge water holding tank Tank for the retention
  of oily bilge water.
• Waste oil tank tank for preparation of oil
  residue (sludge) for incineration.
• Discharge arrangement of clean drains
• The discharge arrangement of clean drains to
  overboard should be independent from the system
  for oily bilge water.
• Exclusive pump for the oil filtering equipment
• It is preferable to be provided with an excusive
  pump to transfer the pre-treated bilge water from
  bilge water holding tank to the oil filtering
  equipment so as not to mix the pre-treated bilge
  water and untreated oil bilge water.
• Heating Arrangement
• To the bilge primary tank to facilitate
  separation of oil
• To the waste oil tank to vaporize water and
  facilitate incineration.

60
One last thing

• The shipowner is the one who are
• Going to court (with the captain and perhaps the
  crew)
• To pay for any damages and fines imposed
• Getting the bad publicity
• Paying the bill for everybody else involved
• Is the only one responsible for the Safety,
  Security and Environmental Condition of the ship
• Class as an RO are acting on behalf of the
  flag state administration in order help the
  shipowner to comply with statutory regulations.

61
Thank you very much for your attention For more
information, please contact Copenhagen Design
Support Center Denmark London Design Support
Office External Affairs Department United
Kingdom Lloyds Register EMEA