These plans are required to meet the requirements of IMO conventions such as MARPOL, SOLAS, and other local variant acts and regulations such as OPA-90. These plans include Vessel Response plans(VRP),(applicable in USA) SOPEP, SMPEP etc. These plans provide details of emergency procedures and options for support e.g spill management, damage stability, fire fighting and salvage etc.
VESSEL RESPONSE PLAN
As part of Emergency response plan a Vessel Response plan is needed when a vessel operates in USA. An important constituent of OPA-90 is the VRP. This plan is applicable upon all navigable waters of USA including the EEZ and adjoining shorelines of USA.
Vessels must be provided with the oil spill removal equipment and marine transportation related facility response plans such as salvage and marine fire fighting requirements. Vessels have to use new / latest response technologies and revise methods and procedures for oil spill response.
Vessel Response Plan holders must ensure dispersant service providers meet regulatory response requirements. The owner or operator of a vessel carrying petroleum products with pre authorization for dispersant use must identify in their response plan and ensure availability through contract of response resources capable of conducting dispersant operations in those areas.
Aerial tracking resources must be capable of reaching the site of discharge in advance of the arrival of response resources identified in the plan taking WORST CASE DISCHARGE into account. Setting up response timing requirement for each of the activity is an important component of VRP. VRP may vary as per law requirements from state to state in USA.
As part of VRP, vessels employ shore organisations to meet their obligations
Some of these companies are O”Briens, Hudson Marine etc based in USA. These companies must have an Qualified Individual(QI). From time to time the vessels are to perform and record drills including making contact with their QI’S.
OPA – 90
Applicable to Tankers operating in U.S waters and this act sets requirements to liability of freight of Oil in USA waters.
Whilst this law will have general interest for most, for Tanker operators it will be the governing instrument. Salient features of this Act include
- Vessel Response Plan should be provided for worst case discharge of oil.
- New Tankers ordered after 1990 which call US ports must have double hull. The single hull tankers will be phased out over 20 years period from 1995 to 2015
- Escort tugs to be provided for tankers in certain areas.
- Bridge watch – In certain designated areas, two licensed officers required on the bridge.
- Rest Period – More stringent tan STCW in many cases.
- Ship owner and operator jointly and severally responsible for cleaning up oil spills.
- Liability to pay damages unlimited if negligence or violation of regulation can be proved.
All vessels entering US waters are required to possess Certificate of Financial Responsibility.
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM – ( NPDES) PERMIT PROGRAM
The Clean Water Act of the USA requires waste water dischargers to have a permit establishing pollution limits and specify monitoring and reporting requirements. NPDES permits household, industrial wastes that are collected in sewers and treated in municipal treatment plants. More than 20000 sources are regulated by NPDES permits nationwide. Permits regulate discharges with the goals of 1) protecting public health and aquatic life 2) assuring that every facility treats waste water. To achieve these ends, permits include site specific limits and reporting procedures.
Conventional pollutants are contained in human waste, sink disposals and laundry and bath waters etc. and such conventional pollutants include faecal Coliform ( found in digestive tracts of humans. animals),oil and greases( in fats oils waxes, acids), toxic pollutants ( in PCBS, metals such as lead, mercury, copper, zinc etc). Non Conventional pollutants include nitrogen and phosphorus etc
On board ships, the discharge from all constituents that come as conventional/non conventional pollutants are generally collected in one tank ( may be a septic tank) and such discharges are retained on board during vessels stay in USA or discharged ashore after due permit and reporting .
Prior to entering within 3 miles of USA waters, vessels must be in possession of valid VGP( Vessel general permit) which is checked by authorities. Such VGP amongst other permits includes NPDES permit, compliance with Anti Fouling Convention ( to prevent release of TBT and other non compliant paints), compliance with Ballast Water convention( Transfer of pathogens through water etc)
Marine Pollution Prevention Plan
Operational Discharges & Best practices to protect coastal environment
The purpose of this PLAN is to provide for compliance with the U.S. Environmental Protection Agency (EPA) National Pollution Discharge Elimination System (NPDES) Vessel General Permit (VGP).
The EPA has identified 26 possible discharges from vessels that are covered by the General Permit which are listed below, as applicable, with our operational methods to protect US Territorial Sea and general Coastal waters wherever vessel operates. There are other discharges that are not covered by the General Permit but are regulated by other U.S. regulations.
The General Permit applies when the ship is operating within the U.S Territorial Sea (three mile limit).
Operational Discharges, control measures and Best Pracises for environmental protection are as listed below:
- Towards Deck Washdown, Runoff, and Above Water Line Hull Cleaning
Cargo debris, garbage, oil/grease residues may spill into deck wash down and runoff discharges. Deck scuppers with rubber gasket sealing arrangement should be available handy at location on deck to prevent debris finding access to port waters in the event of sudden rain or deck fire service water. All debris should be swept clean if fire water is required to be run for inspection of class societies or Port/Flag state Authorities. Machinery on deck must have coamings or drip pans to collect any oily water from machinery and prevent spills. The drip pan should have positive sealing plugs attached to the trays. Trays must be periodically wiped and cleaned. Application of disinfectant and dispersants, or surfactants must be minimized in ports and restricted waters. Deck washing should have prior approval of Master or Chief Officer in ports and restricted waters close to shore.
Maintenance work of descaling rust or old coating should be done with adequate care to prevent debris finding access to water and paint spraying in windy conditions or over application of paint should be avoided. Disposal of unused paint or allowing droplets of paint in maintenance work into waters are not permitted.
Furthermore, cleaners and detergents should not be caustic or only minimally caustic and should be biodegradable. Reference is to be made to product data sheet before application whether it is permitted to be used within 3km of territorial waters of the coast.
- Bilge water
All bilge water discharges must be in compliance with current MARPOL regulations. Use of dispersants, detergents, emulsifiers, chemicals or other substances in bilge waters is to be avoided and can seriously impair working efficiency of bilge oil separators.
Discharge of bilge water overboard should be minimized by curbing the production of bilge water and discharging into waters more than 3 nautical miles from shore and always through Bilge oil separator as regulated under Annex I of the International Convention for the Prevention of Pollution from Ships. All bilge water discharges must be documented in Oil Record Book.
- Discharges of Ballast Water
It is strongly advisable to solicit prior information from local agents of next port of call on requirements of ballast water discharge at port and quarantine requirements to ensure compliance. Reference is to be made to vessel specific ballast water management plan and safety limitations mentioned therein.
The officer -in-charge, and crew members who perform ballasting, ballast exchange and discharge of ballast water should be familiar with sequence of operation in order not to endanger stability and subject hull to undue stresses. All such operations should only be done as per plan worked out with due verification of stresses caused within allowable limits checked by loadicator program and within scope of vessel specific ballast water management plan.
Ensure adherence to good Ballast Water Management Practices as under:
Avoid the discharge of ballast water into waters that may directly affect marine sanctuaries, marine preserves, marine parks, shellfish beds, or coral reefs or other restricted waters
Minimize or avoid uptake of ballast water in the following areas and situations:
– Areas known to have infestations or populations of harmful organisms and pathogens (e.g., algal blooms).
– Areas near sewage outfalls.
– Areas near dredging operations.
– Areas where tidal flushing is poor or when a tidal stream is known to be more turbid.
– In darkness when bottom dwelling organisms may rise up in the water column.
– In shallow water or where propellers may stir up the sediment.
– Areas with pods of whales, convergence zones and boundaries of major currents
– Clean ballast tanks regularly to remove sediments in mid-ocean or under controlled arrangements in port, or at dry dock.
– No discharge of sediments from cleaning of ballast tanks near to coast
– Discharge only the minimal amount of ballast water essential for vessel operations while in the waters close to port.
– The exchange must occur in an area more than 200 nautical miles from any shore;
– The exchange must be commenced as early in the vessel voyage as possible, as long as the vessel is more than 200 nm from any shore.
- Gray water
Conscious effort must be made to minimize the discharge of grey water while in port. Following are few tips as how we can help reduce production of grey water and avoid effluent contaminated with toxic or caustic residues and oil / paraffin with grey water discharged in port or coastal waters
– minimize the discharge of gray water when the vessel is not underway by restricting washing of bedding/linen/clothes
– avoid washing of accommodation decks and flooring and apply dry sweeping / vacuum cleaning followed by wet mopping
– When cleaning dishes, remove as much food and oil residue as practicable before rinsing dishes. Use environmental friendly detergents
– Oils used in cooking shall not be added to the graywater system. Waste oils should be collected and handed over to engine room for safe disposal with waste oil.
– use phosphate free and non-toxic soaps and detergents for cleaning or disinfecting. These detergents must be free from toxic or bio-accumulative compounds and not lead to extreme shifts in receiving water pH. Refer product manual guide appended to this procedure for recommended products to ensure compliance.
– Grey Water production and discharge should be positively restricted while transiting nutrient impaired body of water, or a body of water that is impaired as a result of nutrient enrichment (such as waters listed as impaired for phosphorus, nitrogen, or for hypoxia or anoxia (low dissolved oxygen concentrations)
- Inspections, Monitoring, Reporting, and Recordkeeping.
Routine Visual Inspections
Conduct routine visual inspections of all areas addressed in this plant, including, but not limited to cargo holds, machinery spaces, storage areas, and other deck areas. Ensure these areas are clear of garbage, exposed raw materials, oil, any visible pollutant or constituent of concern that could be discharged in any waste stream, and that pollution prevention mechanisms are in proper working order. Routine inspections should be conducted on a schedule that coincides with other routine vessel inspections if feasible. At least once per week or per voyage, whichever is more frequent, you must conduct a visual inspection of all accessible areas where chemicals, oils, dry cargo or other materials are stored or used. Furthermore, the inspection should verify whether all monitoring, training, and inspections are logged. A ship’s watch must include visual monitoring of the water around and behind the vessel for visible sheens, dust, chemicals, abnormal discoloration or foaming, and other indicators of pollutants or constituents of concern originating from the vessel. Particular attention should be paid to deck runoff, ballast water, and bilge water . These inspections may be done concurrently with inspections done for compliance with management System routines.
At least once per quarter, random inspection of sample discharge of bilge water or grey water should be done for any signs of visible pollutants or constituents of concern, including discoloration, visible sheens, suspended solids, floating solids, foam, or changes to clarity. If you discover signs of concern exceeding the applicable effluent limit, you must record the steps you have taken to prevent the continued discharge of these pollutants or constituents of concern and what corrective actions were taken to remediate the problem(s). Sampling of readily visible discharges is not required, but is recommended if the inspector cannot easily view their discharge characteristics (such as clarity or discoloration, presence of oily sheens, presence of foams, etc.).
PARTICULARLY SENSITIVE SEA AREAS(PSSA)
A PSSA is an area that needs special protection through action by IMO because of its significance for recognized ecological, socio-economic or scientific attributes- where such attributes may be vulnerable to damage by international shipping activities.
At the time of designation of a PSSA, at least one associated protective measure(APM) which meets the requirements of the appropriate legal instrument establishing such measure, must have been approved or adopted by IMO to prevent, reduce or eliminate the threat to or the identified vulnerability of the PSSA.
IMO is the only international body responsible for assessing proposals for and designating areas as PSSAs and adopting measures applicable to international shipping. PSSA is not a legally binding document since it is not covered by any convention/code or protocol but is implemented only through action by IMO.
When an area is approved as a PSSA, specific measures can be used to control the maritime activities in that area, such as routeing measures, strict application of MARPOL discharge and equipment requirements for ships, such as oil tankers, and installation of Vessel Traffic Services(VTS).
Ships routeing measures to protect PSSAs
A PSSA can be protected by ships routeing measures- such as an area to be avoided :an area within defined limits in which either navigation is particularly hazardous or is exceptionally important to avoid casualties and which should be avoided by all ships or certain classes of ships.
LIST OF ADOPTED PSSAs WITH APM
- The Great Barrier Reef, Australia(designated in 1990) – IMO recommmended system of pilotage;mandatory ship reporting system
- The Sabana-Camaguey Archipelago in Cuba(1997)- Area to be avoided
- Malpelo Island, Colombia(2002)- Area to be avoided
- The sea around the Florida Keys, United States(2002)- Area to be avoided; mandatory no anchoring areas
- The Wadden Sea, Denmark, Germany, Netherlands(2002)- Mandatory deep water route
- Paracas National Reserve, Peru(2003)- Area to be avoided
- Western European Waters(2004)– Mandatory ship reporting system
- Extension of the existing Great Barrier Reef PSSA to include the Torres Strait(2005) – IMO recommended Australian system of pilotage; two way route
- Canary Islands, Spain(2005)-Areas to be avoided, recommended routes, mandatory ship reporting system
- The Galapagos Archipelogo, Ecuador(2005)- Areas to be avoided, mandatory ship reporting systems, recommended tracks
- The Black sea Area-, Denmark, Estonia, Finland, Germany, Latvia, Lithuania, Poland and Sweden(2005)—— Traffic separation schemes, deep water routes, areas to be avoided, mandatory ship reporting system, MARPOL Special Area: Marpol SECA
- NW Hawaiian Islands – Areas to be avoided; recommended /mandatory ship reporting systems
- Straait of Bonifaco——Recommendation on Navigation
- Saba Bank( Caribbean Island of Saba)——- Area to be avoided; Mandatory no anchoring area