1 Approval of a ship's bilge water and oil residues
(sludge) handling system should in the main be based upon how to ensure
compliance with MARPOL requirements in the daily operation of the
ship.
2 Consideration should be given to the system
layout so that there are no operational constraints to personnel,
to facilitate compliance with MARPOL Annex
I requirements,
3 The ability to discharge oil or an oily mixture
into the sea, which may be necessary for emergency purposes (cf. regulation 4 of MARPOL Annex I), should
continue to be an integral part of the approval of a ship's bilge
water and oil residues (sludge) handling system.
4 Plan approval by Administrations must include
a specific element of verification of compliance with the technical
and operative requirements of MARPOL Annex
I in relation to engine-room operations.
5 Outlined below are some of the most important
aspects which should be verified:
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.1 as this verification comprises, amongst others,
calculation of required oil residues (sludge) tank capacity with consideration
to Unified Interpretation 15.1, it follows that there is, albeit implicit
so, a necessity to determine which tanks are in fact oil residues
(sludge) tanks listed in table 3.1 of the Supplement to the IOPP Certificate);
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.2 at this plan approval stage, it should also
be recommended to issue a draft Supplement to the IOPP Certificate
containing all the information available at plan approval stage pertaining
to the Supplement to the IOPP Certificate. This draft Supplement should
ensure consistency between the plan approval and the supplement to
the IOPP certificate as issued by the Administration at completion
of the initial survey;
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.3 the Administration should give consideration to
the unified interpretations pertaining to regulations 12 and 14, UI 15 to UI 21, including their subparagraphs, and in
particular Unified Interpretation 17.1.3, which prohibits common
bilge water and sludge piping other than the common discharge pipe leading to the
shore connections manifold as required by regulation 13 of Annex I. This UI is, for instance, violated
when using the common discharge pipe as an internal sludge transfer pipe between
sludge tanks;
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.4 the Administration should verify that bilge
pumps cannot take suction from oil residue (sludge) tanks;
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.5 the Administration should verify that sludge
pumps cannot discharge to bilge water holding tanks;
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.6 the Administration should verify that the effluent
from oily water separator systems cannot be intentionally diluted
at any point upstream of the oil content monitor in these systems.
In this context, the need for installation of pipes depending on the
design of the system used for cleaning and filling of the oily water
separator and zero adjusting of 15 ppm alarm, should also be considered
taking in account the design requirement and paragraph 4.2.10.2 in
the Revised guidelines and specifications for pollution prevention
equipment for machinery bilges of ships (resolution
MEPC.107(49)); and
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.7 the Administration should verify that no part
of the engine-room bilge water system forms part of any direct operational
bilge water discharge system, such as cargo hold bilge discharge or
anchor chain locker discharge. In this respect the Administration
should take into account SOLAS chapter II-1, regulation 21 (Bilge pumping arrangements).