One of the main sources of operational pollutio n of maritime environment by ships is propulsion machinery and all ships are concerned, as all of them use fuel

oil for propulsion. In the past this was hidden by the o perational pollution from tankers especially large ta nkers using cargo tanks alternatively for cargo and for ballast, in order to sail in safety conditions for hull stresses and keeping propeller correctly immersed.

These procedures are discontinued as most of the vessels concerned have been sent to scrap since the beginning o f years 2000 or even converted into floating storage for offshore oilfields.



## ENGINES COMPARTMENT: THE PROPULSION ENGINE.

This type of economic engine replaced the turbi nes installations of our old oil tankers from the Sevent ies, less demanding on quality of fuel simply burned t o provide vapor, but consuming 120t per day in same condit ions.

THE FUEL.

To be used, fuel delivered on board must be in conformity with the engine builder's specifications, of t ype 380 centistoke and grade RMG35 as specified in the report hereafter. Sampling operations are conducted throughout bu nkering and one average sample is sent to laboratory +f or analysis in order to know injection parameters.

Here is a concrete example of analysis report :

To be noted: 0,2% of water, density 0,963, metals, sulf ur,... and the temperature of injection to the engine 131° C. Return to the menu 

# Oily waste management onboard of vessels
September 2006 update

(page optimized for a full screen display, with control accessible by the main menu)

Our colleague, captain LE CALVEZ, gave a lecture to ai r spotters cadets on training course with CEDRE, in orde r to explain them the origin of the oily effluents onboard ships, the means and rules of pro cessing and storage of these products. This lecture was also given during the seminar on maritim e pollution fighting by ships (AGIS), organized in Bre st by the Gendarmerie Maritime for European lawyers, police officers, customs officers, and ge ndarmes.

The fuel used in vessels propulsion engines is a pr oduct from end of distillation of crude oil, directly unusable. This fuel requires purification by centrifugation, in order to eliminate water and abra sive particles of heavy metals (vanadium, nickel) sediments and others. This operation h as to be carried out by the vessel and generates approximately 1% of residues which have to be either unloaded periodically, or incinerated progressively, but i n no case dumped overboard. The logical alternative to make the poor sailor's life easier would be to carry out this operation industrially ashore, at ref ining exit, but unfortunately, this residue generated has a commercial value in some coun tries of southSaharan Africa and in China. It concerns very little our developed countries, which prefer to delegate to the vessels the management of these undesirable goods.

Some figures to give an idea of the vessels consumption :

Here is the B&W engine, 7 cylinders in line, of a 300.000 tons oil tanker , on the construction and test bench in a Japan shipyard, wit h the following

characteristics :

 Nominal power: 30.000 HP at 82 rpm.

 Dimensions: breadth 9.50 m, length 14 m, height 17 m, weight 996 T

 Lubrication oil load : 30m 3

.

The operation average consumption is 90 to 100 tons per day at 76 rpm that is to say about at 25.000 Hp and includes the generator se ts consumption. Type of ship Power

engine Speed Daily

consumption Generated

waste

Cargo liner 20.000 T 7.500 HP 12 kts 20 tons/day 0,25 m 3 /day

Gas 35.000 m 3 10.000 HP 17 kts 35 tons/day 0,4 m 3 /day

Tanker 300.000 T 30.000 HP 15 kts 95 tons/day 1 m 3 /day

Large container ship 50.000 HP 25 kts 180 tons/day 2m 3 /day

Fuel Sample Nom du navire

VLC Log No. F040850119

Date 08/02/04

Bunk. Port and Date SINGAPORE - 07/25/04

Place and Date Sent SINGA - 07/29/04

Supplier SINGAPORE PETROLEUM

Date Received at VLC 08/02/04

Sample Type per Customer IFO 380

Grade RMG35 SPECIFIED PARAMETERS FOR RMG35

Density @ 15 deg C 963,2 kg/m 3 (991,0 Max)

API Grade 15,32 ( 11,20 Min)

Viscosity @ 50 deg C 298,50 cSt (380,00 Max)

Viscosity @ 100 deg C 30,9 cSt ( 35,0 Max)

Upper Pour Point 19 deg C ( 30 Max)

Carbon Residue 8.89 % wt. (18,00 Max)

Ash 0,013 % wt. ( 0,150 Max)

Water 0,20 % vol. ( 1,00 Max) ADDITIONAL PARAMETERS

Si 2 ppm

Al < 1 ppm

Na 15 ppm

Ca 11 ppm

Fe 2 ppm

Pb < 1 ppm

Ni 6 ppm

P < 1 ppm 

## Page 1 of 12 Oily waste management onboard of vessels

7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlGRADE CONFORMANCE

The fuel sample tested conforms to grade RMG35. Temperature for injection viscosity 10 is 143° C. Temperature for injection viscosity 15 is 125° C.

POUR POINT

Observation: Heat and store this fuel at 10°C above the measured pou r point temperature.

PERCENTAGE WATER

Observation: Presence of water noted. Ensure water removal through settling and purification

.

SULFUR Observation: This fuel has high sulfur. High Sulfur can cause low temperature corrosion in comb ustion gas passages. Avoid temperature below dew point. Achieve this by maintaining higher temperatures and pr eventing moisture accumulation in scavenge spaces by keepin g drains open. Avoid running engine at low speed for prolonged time.

OVERALL QUALITY: Engine Friendliness Number (EFN) is a unique bench-mark of fuel quality evaluated by VISWA LAB from the point of view of engine wear and tear resulting from the use of this fuel. Based on EFN, which is calculated f rom the analysis results listed in this report, the qua lity of this fuel is good.

NOTE: The conformance of this fuel to the contracted specificatio ns may have no relationship to the evaluation of this fue l based on EFN.



## PRINCIPLE OF OPERATION.

Simplified schema of the principle of operation of a m arine engine.

Internal combustion 2 strokes engine :

The fuel injection is carried out at each passage of the piston at the upper part, and the gas renewa l is done with air overfed at the passage at low positio n, with

Tamper Proof 0216963 : Sealed

Customer furnished data: Density 963,5 kg/m 3
Quantity 3000 M. Tons Sulfur 3,57 % wt. ( 5,00 Max)

Sediment 0,01 % wt. ( 0,10 Max)

vanadium 27 wt. ppm ( 300 Max)

Al + Si 3 ppm ( 80 Max)

Flash Point > 65 deg C ( 60 Min) Zn < 1 ppm

CCAI 827

Calorific value 40,43 MJ/kg

Minimum Transfer Temperature 39 deg C

Injection Temperature (For 13 cSt Viscosity) 131 deg C

Engine Friendliness N° (EFN: 1-100) 70 

## Page 2 of 12 Oily waste management onboard of vessels

7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlthe exhaust valve opening at this moment. The smoke produc ed by the engine get away towards the exhaust gas economis er and the funnel through the turbo

charger turbine, which compressor stage supplies with air the combustion chamber after passage through the air co oler. The fuel is settled in the bunker tanks, is centrifuged, and stored in a buffer tank, before bein g heated for injection into the engine at approximate ly 130°C.



## FUEL RESIDUES.

Between 0.8 and 1.5% of residues are generated by c entrifugation of fuel , that is to say about 1 ton per day (for our example).

lubricating between lining and piston is done by a continuous lost injection of about 800 liters of cy linder oil per day . The cylinder oil drainage,

cumulated with ashes and soot in the lower chambers of t he pistons, (vaults), the filtering and centrifugation o f movement oil generate about hundred litres of oily residues per day.

All these residues, after transit through small int ermediate capacities, are stored in a sludge tank 8 5m 3 capacity (for our example). This volume is calculated before construction according to the type of voyage that is to say 2,5 months.

This low part of piston (named vaults and scavenging manifold) requires a monthl y cleaning during an interruption period. This operati on generates from 200 to 300 litres of solid oily waste

.



## SLUDGE PROCESSING.

For the elimination of this liquid sludge from the sludge tank several possibilities exist. It shall be noted that there should be no piping for direct dumpi ng to the

sea.

The discharge in port of call, but more, it is necessary t o find facilities or a barge able to receive this sludge , for a financial contribution of course.

The onboard incineration.

The transfer to the cargo slop tank (residues tank) is an option applicable only to tankers, but however with co mmercial constraints, and thus not always possible.

Incineration of the engine oily sludge.

A slow operation, which requires in our exampl e the care of an engineer every day :

to burn 1m3 in 12 hours at a rate of 80 liters per ho ur, from 7 a.m. to 7 p.m.

for daily transfer to the incinerator tank of 1m3 at th e end of the day.

for the warming up during the night, in order to fa cilitate the combustion of the product and the decanta tion of water towards the bilge waters storage tank i n the morning.

The incineration is time consuming even when t he device works properly, it matches with difficulty the r esidue production, especially when the bunkers quality is poor or difficult to treat. The solution is sometime s a compromise between incinerating as much as possible, an d discharging this sludge in some ports able to take delivery by barge, as in Rotterdam, Gibraltar, Sin gapore, in China or in Fujairah (Arab Emirates) with the flow rate of the small transfer pump (7 to 10 m 3 per 

## Page 3 of 12 Oily waste management onboard of vessels

7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlhour) after reheating at 80° C, or alongside as in t he ports of North Sea, with the example of Mongstad in Norway, where the discharge of sludge is free. But the

problem is to pump out the residues at 150 meters from the engine room exit, in the middle of the ship, by th e cargo piping, before beginning the commercial operations.

Some oil tankers companies currently have all-in c ontracts for sludge removal in Fujairah, a small bunker ing port located at the entrance of the Arab Gulf, provided that the operation is carried out quickly. This requires the transfer of the sludge the previous day a t 8 m 3 per hour, after reheating, towards cargo capacities, then the use of the reciprocating stripping pump at 200 m 3 per hour to pump towards the barge during a little half an hour. The cost of the operation is the mobilization time of the reception barge, because for everybody, time is money.

Solid oily waste

Two solutions to process the oily solid waste prod uction from the vaults and the engine scavenging manifold : The periodic discharge in 200 litres drums, which is a good drill for administrative correspondence and pap erwork, or the incineration, a more economic operation but rather difficult, dangerous, and not very clean.



## Management of oily water from engine room bildge :

Note: the domestic waste water is not considered, being matter of a statutory specific processing.

Since the end of era of wooden vessels, despite t he mechanical seals of the pumps and other propeller sha fts watertight systems of our beautiful steel ships, we always pump engine bilge water, stored in a capacity l ocated, like the sludge tank in the double bottom of the engine room compartment, which contains, in theory, contrary to its neighbor, a lot of water with a little oil on the surface.

On board a vessel in good condition, this daily w ater production comes mainly from condensation of atmosp here humidity from the air-conditioning plants

, and especially from the air cooler of the main engine and of diesel gen erator sets , where the atmospheric air is compressed in the turbo-ch argers, then cooled down by the passage in the air cooler. According to the h ygrometry of the geographical zone, this production is ab out 20 to 30m 3 per day in our example. Note: Being able to contain some compressors lubricant, the conde nsations dumping of air-conditioning in the bildge tan k is mandatory.

If this production of limpid fresh condensation water does not create any difficulty for pumping to sea through the statutory oily water separator at 15 cm 3 per m 3 (15 ppm) , the following occasional maintenance opera tions will complicate this task.

The monthly periodic washing of the aerial part of the air coolers carried out during the port stops of the main engine, dumps there 1 to 2 m 3 of water which contains a chemical specific to this type of cleaning, a nd gives to this water an appearance of whitish emulsion

.

The monthly periodic washing of the exhaust gas eco nomiser smoke element , carried out during these same stops, may at each operati on pour there

2 to 3m 3 of dark water despite the passage through the decantat ion soots tank.

The wash water from the workshop wash-hand basin an d the washing of the engine floors pour there a dirty water not necessarily oily.

The various maintenance and cleansing operations of the condensers and sea water exchangers carried out when stopped in ports give some quantity of seldom limpid harbor water and almost alwa ys unacceptable for the 15ppm separator sampler.

During harbour stay the damages to mechanical seals of the pumps caused by muddy water of some rivers can bring in a non-oily and muddy water unacceptable by the sampler.

Engine bilge waters separator 15ppm. 

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7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlVarious models of equipment, whose principle of operation is the following :

A 5m 3 /h bilge pump pumps water from the bilge tank to the stilling tank. Inside this tank the oil is separated from the water and an hydrocarbon detector

connected to an electric valve drains the oil to the slud ge tank, the water below the oil flows through filter s where solid particles are retained and through the 1 5ppm sampler detector, which actuates a 3 way valve, to the se a. From experience, this system has limited capacities, red uced to light oils or gas oil, with fuel oil you get quickly into trouble by oil plugging of various elements.

On recently tested devices : The principle of op eration of the approved detection device, on a vessel la unched from a shipyard in 2001, is based only on opacit y and a photoelectric cell, and not on an hydrocarbon dete ctor by light diffraction or other technical principles ( chromatography...). This system which does not accept dirty and whitish non-oily washing water, and the water pumped in ports, brings the user to defy the interdi ct by misleading the detection system with a clear fresh water injection. Equipment unable to differentiate hydrocarbon from dirty water...! The periodic cleansing of the bilge separator filters i n the engine room brings the collected dirt back to the sludge tank and is r ecycled again...!

Hereafter, the standard management cycle of eng ine oily residues in application of MARPOL regulation :

Daily production of 1m 3 of oily sludge and 40 m 3 of bilge water.

Daily transfer at day's end of 1m 3 towards the incinerator & reheating tank.

Decantation in the morning of water towards bilge w ater tank

Incineration of the sludge during 12 to 14 hours per day

§ Pumping of bildges through the 15ppm separator duri ng 8 hours in authorized zone.

Regarding the problems encountered due to the lack of reliability of this separator, everyone has his method of bilge water management! photo P. Le Calvez 

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7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlIt is thus better to avoid oil introduction into the bildge separator , and therefore into the storage tank, which everyone w ill keep clean. It will never be fully

drained in order to maintain the possible oily layer on the liquid surface.

According to the structure configuration of each vessel, an additional decantation system may be installed upstream of the bilge water tank. Th e interest is to

have a good decantation capacity, little influenced by d ynamic movements of the vessel, with great height a nd small sections in length and breadth (large and long vertical pipe), which is not the case of the bildge tanks located in the double bottom.

The evaporation before incineration , is another solution whose cycle becomes the following after the installation of a second storage tank :

1m 3 oily Sludge production and 40 m 3 bilge water per day.

Daily transfer at day beginning of 1 m 3 from the evaporation tank towards the incinerator ta nk.

Continuous sludge incineration, 24h/24h

Filling up of the 3 m 3 evaporation tank and heating.

Pumping of the bildges through the 15ppm separator d uring 8 hours

With inertia, some ship-owners conscious of this pr oblem, install, in line with oily water separator, a n ew more efficient equipment available on the market. Others ask their crews not to dump bilge waters in the “ watched zones”...! Some coasters have instructions from their s hip-owner not to use the bilge water separator, and to discharge these waters at port.

Equipments of engine bildge separators brought into service in year 2005 have difficulties to produce waters with hydrocarbon content lower than 200ppm.

Regulation and Recordings.

In order to facilitate to the various internat ional administrations the control of the proper uses in compliance with the international rules of pollution prevention of the maritime environment, we find on all vessels the mai n documents and recordings as follows :

The up to date document of MARPOL regulations (mariti me pollution convention).

IOPP (International Oil Pollution Prevention) certi ficate of compliance with MARPOL rules for processing plan ts of the engine sludge, and water bildges for all vessels. Are reported there the volumes of the tanks and the characteristics of the incinerator.

An additional part to the certificate (IOPP) of compli ance with the MARPOL rules for the washing and treatm ent plants of the cargo compartments and hydrocarbon discharge for the vessels carrying oil, hydrocarbo ns, and chemicals.

The Oil Record Book N°1 for engine room for all vessel s, in which every day and in a coded way are recorded al l the main operations of bunkers and ecological pumping, incineration and discharge to shore plants with written certificate from the receiver.

The Oil Record Book N°2 for the cargo capacities for ve ssels carrying oil and other pollutant products, in which a re recorded in a coded way all these commercial operations of transfer, washing, water balla sting operations, and discharge relating to freight cap acities.

An O.D.M.E. (Oil Discharge Monitor Equipment) device fo r analysing and recording the hydrocarbon dumpings from t he cargo capacities for vessels carrying PPM : Part Per Million, figure without dimension, which uses numbers of same nature (weight or volume). 1 ppm = 1 g per ton or 1 cm 3 per m 3 and not grams per

cubic meter or cm 3

per ton. 

## Page 6 of 12 Oily waste management onboard of vessels

7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlpotentially pollutant products. These recording strips must be kept onboard for 5 years. Informations recorded : date, GMT time, geographical positions (on

some models), speed, flow rates, and dumping rates must b e in compliance with the records of the N°2 Oil Record Book.

A Ship Oil Pollution Emergency Plan (SOPEP) for fight ing against accidental pollution, approved by the auth orities. This plan has a worldwide application except in the USA, where it is replaced by the OPA90 (O il Pollution Act of 1990).

In this plan we find, the inventory of statutory antipol lution equipment, the worldwide phone call list of t he companies and local authorities, the ship's plans, and a blank form of assistance and towing contract.

A register for garbage bins management on which are re corded daily the dumping to sea from galley and biodegr adable waste, the incineration of solid oily waste (greasy rags), the periodic discharge of the plast ics with the certificate issued by the receiver.

Various pollution insurances certificates, civil liability (CLC), P&I, and others...



## OILY DUMPINGS CAUSED BY EQUIPMENT DAMAGES.

Contamination of the ballast water tanks by hydraul ic leaks



## COLOURED SPECIAL OPERATIONS NOT POLLUTING.

Soot tank draining.

Due to the main engine economizer periodical wa shing, the contents of the soot storage tank will be dr ained in open sea after the port of call, using a sea water ejector device on the fire collector. This operation may generate a black trail, transitory, with an oily appear ance in the ship's wake. This normal operation is applicable to all the trading ships. It is not consider ed as pollutant because not mentioned in the Marpol pr otocols.

Contamination of the harbor water by the washing to wer of the inert gas generator. Propeller shaft sealing

It happens periodically to all vessels some worries with this sealing system for propeller shaft, due to fouling with nets for example, the ship has a continuous leak of a small quantity of oil.

To repair afloat this damage, requires the sealing replacement, bring out from the water the propeller shaft hub, and thus the unloading of the ship combined with a ballast movement to trim by

the head.

Oil coolers

Leaks caused by corrosion or constraint movement of the ship's structure on the sea water oil coolers may be the source of continuous or episodic lubricant leakages by this mechanism.

The operation of the seawater valves of ballast w ater tanks is usually hydraulic. On some ships without duct- keel, pipings and valves actuators are located directly in the ballast water tanks and may perspire, even leak episodically or continuously some oil, due to corrosion, loose connections, or constraints caused by the localized def ormation of the ship's structure normal

work.

Some vessels may be equipped with immersed ba llast pumps hydraulically driven (FRAMO standard) with same risks of potential leakages. Damages b eing able to cause an unforeseeable and uncontrolled dumpings to the sea, of transmission lu bricant, during full ballast water draining, even congregated to the sludge mud. Situation and even t which may happen to all vessels (and even to good crews). 

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7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlUnusual, but, identical to the soot effects, t he oil tankers processing the smoke of the boilers by washin g with sea water before injection into cargo capacities,

may encounter this misadventure in the event of temporar y bad combustion with an important smoke production, r esulting in a black and transitory contamination of the harbor water very similar to a pollution effect of heavy petroleum product.

Operational management of the Ballast. 

## Page 8 of 12 Oily waste management onboard of vessels

7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlP. Le Calvez photograph

The pumping of ballast water in some river port s (the Loire, the Gironde, the Mersey, the Yang-tseu- kiang...) overloads the ship with mud, sometimes black , which it is necessary to quickly remove before decantation, this as soon as in open sea. This operation may leave a coloured trail in the ship's wake. Example: The ballast water mud charge of a 300.000 t VLCC in Donge s harbor is about 200 tons. 

## Page 9 of 12 Oily waste management onboard of vessels

7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlThese sludges and muds pumped in from harbours m ay contain and congregate together various oily waste of unspecified origins (dumpings from other ships,

15ppm outflows from refineries, harbour facilities, und erground pipes leakages, or organic triturations in decom position inside muds...). From experience of manoeuvres in some ports, the propeller movements pushes u p oily irisations with the mud to the surface of the wa ter.

Regulation management of Ballast Water (B. W. M.) :

In order to avoid the contamination of the ecosyst ems in some ports as in the USA, by live species carried from other ports of the planet, it is imperative to renew the ballast water in open sea before calling in these ports.

Various cargo dumpings during the cargo holds clean ing :

Some ore vessels, due to commercial reasons of prod ucts changes, have to clean their decks and cargo spaces after unloading. Coal, iron ore, bauxite, animal feed flours generate beautiful coloured trails.



## DUMPINGS FROM OIL TANKERS AND CHEMICAL CARRIERS.

For commercial reasons of products changes, of clean ing operations before repairs, of water ballasting o perations for bad weather condition, the vessels carrying crude oils, hydrocarbons, and chemical products, w hen proceeding, may have to dump their decantation wat er or ballast water (from cargo capacities) in open seas authorized zones at more than 50 miles from t he shore, with an oily flow rate not exceeding 30 lit ers per nautical miles. The total dumped quantity for each voyage must not exceed the 1/30.000 of the volume p reviously loaded, that is to say 10 tons for a former 3 00.000 t oil tanker. It should be noted that the sampling equipment for the dumpings is a chromatograph y hydrocarbon detector independently of the water opa city.

These recordings and written traces can be found again in the N°2 Oil Record Book and on the dumpings d etector paper strips. AFCAN photograph AFCAN photograph

The discovery last year, with a media coverage, of carbonaceous blackish releases on the beaches of th e south western part of France, considered at the beginning as pollution by hydrocarbon, made me think about a voyage on a gas transport vessel, from Gijon in Spain towards the North Sea, during which we had to wash the decks and superstru ctures after a rather long call in this port with i nopportune loading, by the wind, of a remarkable quantity of coal dust from the next quay. This oper ation generated a beautiful blackish trail on calm sea. 

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7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmldouble

- hull oil tankers from years 2000.

P. Le Calvez photograph Having experience of crude oil transport for the last 35 years, the VLCC with double- hull is, today, very ecological operationally compared to old structures with simple hull and ballasting operations in the cargo capacities, Clean Ballast Tanks (C.B.T. ) and segregated ballast tanks (S.B.T. ). The sea water transfers in cargo capacities of double- hull vessels are unusual and exceptional, the contamination possibilities of ballast tanks by pipings damages impossible because there is no passage of ballast pipings in the cargo and conversely.

Moreover, the various crude oils are liquid ores m ore or less viscous according to the origin, and loaded at temperatures between 30 and 45°C. They are transported throughout the planet during 2 to 5 week s, and sometimes discharged in winter zones. The products, cooled down by the heat exchange of the hull in contact with the ocean, become thicker, adhere to bulkheads and structures, settles on the handrails, and sometimes are difficult to pump at low temperature. Th is phenomenon always applies to single hull existing

vessels.

The handrails and structures of the double hul l vessels are mainly localized in the ballast water tanks sections.The plane surface areas of the cargo capacities, bulkheads and floors, do not offer any more hiding pla ces to the viscous elements, and a washing of the bottoms with light crude incomparably minimizes the residues remaining onboard at the end of the discharge. Moreove r the empty double- hull limits the heat exchange with the 

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7/25/2011 http://www.afcan.org/dossiers_techniques/gestion_dech_huileux2_gb.htmlThis type of ship is thus not inevitably the ideal remed y for accidental big pollutions.



## Air surveillance and repression of the ships dumpin gs :

Comments from a sailor in conclusion of this presen tation.

I perceive this initiative of our political lead ers well covered by the medias like an univocal contribution to the other international maritime authorities, in order to give a sense of responsibility to the various in tervening parties in sea transportation on improvin g cleanliness of the oceans.

However, at the era of evidence by DNA in crimin ology, where at few meters the sight of a simple red sta in (of painting) does not conclude inevitably to a murder, I deeply think with many reserves that the visual o bservation at few hundred meters, without other relia ble technical means, of a coloured trail in a ship's wake, does not mean necessarily the effective evide nce of a pollution offense , with risks of disproportionate sentences and fine, revise d at increase after every maritime catastrophe.

The delocalization of legal follow-up of these pollution cases with a mediatic din towards countries of great maritime vocation seems beneficial to me. It will allow in the medium term, I hope, to get back to a r easonable and more objective processing of these cases. The systematic sampling of the punishable dumpings,
in order to know the nature and thus the source of the pollutant, seems essential to me to leave this present cont ext of inculpation by presumption of culpability

, and give possibility to reconsider the accidental dumpings (mistake or lack of luck) and to discriminate the illusions of pollution. Not rely on the judgment of God after sentence by all...! Being overflown by one of your planes, during the l iquid gas carrier deck washing to remove the coal d ust as per my previously quoted anecdote, I think retrospectively that I pro bably should have been diverted to Brest, and sould have been accused of pollution for hydrocarbon dumpings (with lack of cadaver), and this, due to t he necessary analysis time to establish the true na ture of this carbonaceous residues collected directly on sand during this “false” beach pollution of the Basque coast last year.

I finish this presentation with some news of one and not the least of these maritime world interveni ng parties which is the I.M.O.

The International Maritime Organization re-examined during year 2003 the certification requirements of the engine bilge water separation and dumpings equipments, for the ships which construction started after january 1 st 2005. By establishing a new test procedure of separation in workshop laboratory, and modifying the dumpings analysis device , which becomes similar to the cargo dumpings chromatograp hic detection device of the oil tankers, with recording paper strip to be kept 18 months for poten tial check by authorities, and with impossibility of misle ading or blocking the rinsing sequences of the measuring

cell.

However , during the IMO 2006 spring session, the German and Indian delegations appeal for revisi on of this new resolution MEPC.107 (49) of July 18th, 2003, Germany proposing additions to the homologation tests procedu res to approach the reality on board. And more realistic India, informing that today's systems for process of used oils from engines are i nappropriate , and asking for improvements in efficiency, flow rate, and quality, arguing that equipment designers and those who lay down the rules do not seem to understand the real conditions of movements, of heat , of moisture, of various emulsified residues generated on board of vessels, which explain why, even the new installed material in accordance with the year 2003 rules is still unsuitable for onboard requested use. Difference between quietude of a laboratory and t he open sea... Also indexed to this proposal: the insufficient ves sels incineration capacity always calculated too short, the bunkered fuel quality, th e time spent by the crews to operate and maintain t hese equipments in good condition, the inadequacy of reception facilities at a reasonable price, and request to the MARPOL 73/78 signatories countries t o take concrete measures to provide in their ports reception facilities easily accessible at a reasona ble price, rather than to engage procedures against the sailors.

Do we have to be surprised that in a democratic co untry, passionate for justice, we do not seek better fo r the guilty? In comparison with the life expectancy of the ships currently operating, equipped with the ir origin separator, we cannot hope for an improvem ent of the engine bilge water dumpings quality only beyond the year 2036 in the legislation presen t state.

Captain Patrick LE CALVEZ

Return to the menu P. Le Calvez photograph sea during the voyage,vessel loaded. For example: Loaded at 42°C in Saudi Arabia, the product is delive red
at more than 30°C in Saint- John, Canada, in February after 35 days at sea by the Cape of Good Hope, for 10 to 15°C on a voyage with a single hull.

The disadvantage of these vessels is, at sea, the very difficult paintings maintenance of ballast water tan ks, because of the access, of containment, of moisture, of heat, of mud accumulation, and the paintings drying tim e, especially if they were not perfectly succesful during construction. These paintings of ballast water tanks are applied at the shipyard at 98% in open air before assembling the various elements. After the assembly, only are remaining the weldings to be covered, this in good conditions. To note: The stop periodicity for the careenage of these types of vessels is only about ten days every 5 years. 

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