Restrictions on Shipboard Incinerator Use


#1

My understanding is the incinerator can not legally be used to burn solid waste without proper approval. We only burn oil waste and we’ve had a couple PSC inspectors ask to see the approval paper work and have no problems.

However I’ve not yet found regs to support the view burning solid waste is prohibited. Anyone have any info on this?

Annex VI- Regulations for the Prevention of Air Pollution from Ships


#2

I’ve read this over a few times but still not clear to me. I know of no IMO / MARPOL regulation that prohibits that.

If the incinerator was designed to burn solid waste and you have a type certificate for it, there is no restriction on burning solid waste as long as long as that waste does not contain certain specific substances - see Annex VI Regulation 16.1

Of course port states and even localities can make up their own local rules pertaining to incinerator operation in their ports or even waters in some cases just to make life interesting. We just don’t use the incinerator in port - except to test it for PSC inspectors of course.

The all purpose warning applies - when operated in accordance with the manufacturers instructions.


#3

Yep. In Brazil, we just LO&TO the unit due to the regulations there. There are also certain restrictions in the CFRs for units engaged on the OCS. This falls under the same MOU between the USCG and EPA, similar to the low sulfur diesel requirements being enforceable through this mechanism to the extent of the EEZ. I’m not sure what those requirements are off the top of my head; it doesnt become an issue due to the OSV support most offshore units have. So, you have a good waste stream. We only burn sludge.
Just as restrictive is the water quality requirements now days. We are now required to static sheen test ballast water believe it or not, before discharge.


#4

Yes, I think I have been making the wrong assumptions about burning solid waste. Now that I think about it we also burn oily rags which are classifieds as solid waste.


#5

Amazing. Maybe if you installed one of these systems http://www.clean-exhaust.com/ you could get away with it. It looks like these folks have found a way to use a Joy bottle without annoying the CG or the EPA.

“The specifically formulated ecoBrew emulsifier neutralizes contaminates, particulates, and product from incomplete burn.” “Incomplete burn”? We used to call that a diesel fuel sheen.

Go figure.


#6

It doesn’t make any sense to me, to static sheen test ballast water discharge from a close loop system, just because you are under NPDES on the OCS. This does not apply in any other case. You do have an exception for running the OWS, you don’t need to be making way. So, being connected to a well head is no issue in this case, which makes sense.

pg.141 (you basically have two options when discharging ballast on the OCS), visually check discharge during daylight hours, or static sheen test at night since you cannot see. I’m being told that it must be a static sheen test no matter, since this is the EPA approved test method. To get a sample is not indicative of a discharge anyhow. The only possible way for sampling is via the petcock on the pump itself. What does this small sample prove or disprove when pumping out 2500m3 of seawater? Not a damn thing.


#7

It proves the regulator is regulating and since he is regulating he is justifying his salary and all the regulations he creates. Reality or value to the user or environment has little if anything to do with the process.


#8

Beyond the ballast water vector a few countries are serious about biofouling on the hull.

Had these Guys clean our hull before we could enter NZ waters a while ago. Quite the machine. The recovered water and matter flows over what looks like a shale shaker. The solids get swept into a super sack for disposal ashore. The liquid passes through what amounts to a BWTS (filter stage and UV stage) and overboard in the designated cleaning anchorage.

Thing was all cobbled together on a work barge with a small workboat ala American style of doing things.

If the market is there one could see purpose built small vessels with better material handling, diving support features, etc. Hell give Norway a chance and it will have an x-bow, Hilton accommodations and Michelin star quality food. But I digress.

Aside from the IMO guidelines some places have actual laws / regulation in place. Which is what got us.

Right now it means the chief mate and I have yet another record book to keep up and more inspections added to the CMMS system.

Don’t get me wrong invasive species are a threat with economic consequences but yet another patchwork approach and unrealistic goals without supporting technology or methods but all the consequences for shipboard folk is getting wearisome.