Does anyone happen to know the CFR regarding pumping/educting cargo hold bilges? I thought normal practice was to educt them overboard (RORO), but I can’t find any info to back this up. I took a quick glance through 33 CFR part 155 but didn’t find anything useful.
Anyone have an idea where I should look? Something along the lines of water collected from non machinery spaces, or from clean engine room drains…
I’ve never worked RO/RO, so don’t treat this as gospel but, I believe that falls under MARPOL Annex V “Operational Waste” if I’m not mistaken.
Maybe Cargo Residue though:
“Cargo residues are defined as the remnants of any cargo which are not covered by other Annexes to the present Convention and which remain on deck or in holds following loading or unloading. They include loading and unloading excess or spillage, whether in wet or dry condition or entrained in wash water, but do not include cargo dust remaining on deck after sweeping or dust on the external surfaces of the ship (regulation 1.2 of Annex V). In addition to this definition, MARPOL Annex V also stipulates that only those cargo residues that cannot be recovered using commonly available methods for unloading could be considered for discharge.”
In my experience the water in the cargo hold bilges is almost always ship sweat, from time to time it might come from a leaky fire main. Assuming the holds are clean.
Either way it should be OK to pump if it’s clean water.
If it’s under 15 ppm oil than OK to pump, clean water is under 15ppm.
Here is MARPOL Practical Guide: Scroll down to page 54, this is likely posted somewhere.
In some cases water with cargo residue is permitted as is wash water with cleaning agents.
If clean water is pumped out when water with cargo residues or cleaning agents is permitted then clean water with neither residues or cleaning agents has to be permitted as well.
Consult your VGP paperwork as well. If it’s clean, shouldn’t be a problem but per the terms of VGP, should be done outside three miles in US waters—if that is relevant to your operating area.