Hi everyone.
I’m trying to find some legislation that will state whether or not it is OK to discharge via an OWS while on DP. A few of us on board have been on vessels where classification societies allowed us to use the OWS while on DP as long as the current exceeded 2, sometimes 4 knots, but we can’t find anything written down anywhere. We are under the Isle of Man flag if this helps. Tried the IOM web site and regs4ships, but it’s like looking for a needle in a haystack!
: )
It will be IMO regs so sea area and how close to the coast
When you can taste bilge water in your fresh water… you know you weren’t going fast enough.
OWS discharge should be clean. If it isn’t clean, then you can’t discharge it, ever. The only mention of it I’ve seen was in our Vessel General Permit, and it doesn’t say anything at all about geographic restrictions. Obviously, if you’re in a zero discharge zone then you can’t discharge anything. I’ve never heard of any restrictions on discharges listed by operation.
This sounds more like someone trying to give the engineering staff a hard time about something they “heard.”
[QUOTE=fourdegreesc;73842]OWS discharge should be clean. If it isn’t clean, then you can’t discharge it, ever. The only mention of it I’ve seen was in our Vessel General Permit, and it doesn’t say anything at all about geographic restrictions. Obviously, if you’re in a zero discharge zone then you can’t discharge anything. I’ve never heard of any restrictions on discharges listed by operation.
This sounds more like someone trying to give the engineering staff a hard time about something they “heard.”[/QUOTE]
Vessel General Permit is EPA and has nothing to do with offshore waters where you would DP.
[QUOTE=dieseldoris;72826]Hi everyone.
I’m trying to find some legislation that will state whether or not it is OK to discharge via an OWS while on DP. A few of us on board have been on vessels where classification societies allowed us to use the OWS while on DP as long as the current exceeded 2, sometimes 4 knots, but we can’t find anything written down anywhere. We are under the Isle of Man flag if this helps. Tried the IOM web site and regs4ships, but it’s like looking for a needle in a haystack!
: )[/QUOTE]
First of all, oily water discharge is illegal; You are getting a few things mixed up. Marpol Annex IV is in reference to sewage discharge and sets an underway speed (along with pump volume) for raw sewage pumping. That can be an issue on DP. Having 15 ppm discharge going over the side from the OWS has no such requirement…that’s why it must be 15 ppm, but you have to log it all the same. Start/Stops/Locations/Amounts before & after…
The oily water discharge section is Marpol Annex I. If you read the oil record book that you should have onboard, page 1 gives a vague description of how to use the OWS. It even says you have to be (enroute) however, the word enroute is in different text than the rest of the paragraph. Leaving alot of discretion to the operator and inspector. If you have the same issue we do, meaning you stay offshore on DP for sometimes months at a time and never actually enroute, the law is very vague.
I will make this point if you have a 15 PPM OWS and it is calibrated according to your class society, you have the cert and the documentation for it, you should have no issues anywhere. We run our OWS everywhere, even at the dock. I know I have heard this argument made in every shape form and fashion there is. I have had ABS, Coast guard, DNV, FMEA inspectors, and about everyone else you can think of look through our oil record book. As long as you have the paper work in order on your OWS and you are not trying to hide something from them, we have had no issues from anybody. I have had coast guard inspectors notice the Lat and Long in the oil record book and mention, I see you are running your OWS at the dock. I gave a very nervous YES. His reply it is not illegal as long as your 15 PPM OWS is in proper working order and you have the correct documentation for it.
With all due respect, oil water discharge is legal, as long as it is within 15 PPM. MARPOL is the drivwer of this reg.
Anchorman was making a distinction between “oily water discharge” (pumping over oily water), which is illegal, and “oily water separator discharge” which is not oily water and thus legal.