Sunday, June 6, 2010

MARPOL RULES FOR ANNEX 2 CHEMICAL TANKERS-- CAPT AJIT VADAKAYIL

                  

No tank washings containing chemicals can be discharged into the sea unless ---the ship’s speed is 7 knots, depth of water is greater than 25 metres, and distance from land is greater than 12 miles.

In Antartic ( south of 60S Lat )  categories X Y and Z cannot be discharged and it is the only special area after 1.1.07 .

For list of high volatile cargoes which can be vented see P&A manual. If VP > 5000 Pa @20C ( 50mb ) you can the vent the cargo off into the atmosphere.

MARPOL Annex II grades “noxious liquid substances carried in bulk” into 3 categories graded X Y Z, according to the hazard they present to marine resources, human health or amenities.

Every ship constructed on or after 1 January 2007 shall be provided with a pumping and piping arrangement to ensure that each tank certified for the carriage of substances in Category X, Y or Z does not retain a quantity of residue in excess of 75 litres in the tank and its associated piping

Ship details
Stripping requirements (in litres)
Category X
Category Y
Category Z
New Ships: keel laid after 01/01/2007
75
75
75
IBC ships until 01/01/2007
100 +50 tolerance
100 + 50 tolerance
300 + 50 tolerance
BCH ships
300 + 50 tolerance
300 + 50 tolerance
900 + 50 tolerance

Category X:

Noxious Liquid Substances which, if discharged into the sea from tank cleaning or deballasting operations, are deemed to present a major hazard to either marine resources or human health and, therefore, justify the prohibition of the discharge into the marine environment
 Examples are Acetone Cyanohydrin, Carbon Di Sulphide, Nonyl Phenol, Di Butyl Pthalate, Epichlorohydrin, Ethyl Acrylate Monomer, Vinyl Toluene, Butyl Benzyl Pthalate, Alpha Methyl Styrene, Calcium Naphthalate etc. Cumene has been down graded from 1st Jan 2007 from A to Y—however more stringent stripping is required.
You are not allowed to discharge Cat X washings into the sea. A tank from which a substance in Category X has been unloaded, shall be prewashed before the ship leaves the port of unloading.  The resulting residues shall be discharged to a reception facility until the concentration of the substance in the effluent is below 0.1% by weight.  When the required concentration level has been achieved, remaining tank washings shall continue to be discharged to the reception facility until the tank is empty.   See P&A manual for the water quantity and number of cycles.
The Govt Surveyors sign and stamp has to be endorsed on the Cargo record book entry. For prewash one cleaning cycle is defined as two consecutive identical rotations of 360 degrees . Any water subsequently introduced into the tank may be discharged into the sea in accordance with the discharge standards in regulation
When discharging Cat X cargoes superstrip is not mandatory as you are prewashing ashore till the tank is empty.
To find out how much water to use in prewash for 0.1% conc by weight—
Find out how many m3 of water is ejected in one cycle.  At 13 m3 /hr and 7.5 min for one cycle, it is 1.63 m3 ( 13/60 X 7.5 )
1.63 X no of cycles X no of machines ( as per P&A manual )
The residual quantity of pre-wash tank washings in:--
1) Volume of water to use ( CuM )
2) Duration of wash in minutes
is tabled in the P&A manual for each cargo tank .

Both tables will have the value K on the X axis and the ships cargo tanks on the Y axis.
k =          a factor having values as follows:
Category X, non-Solidifying, Low-Viscosity Substance,   k = 1.2
Category X, Solidifying or High-Viscosity Substance,      k = 2.4
Category Y, non-Solidifying, Low-Viscosity Substance    k = 0.5
Category Y, Solidifying or High-Viscosity Substance       k = 1.0

Typical pre-wash volumes in CuM / times  in minutes---------- for a SS tank of 1500 cum with portable machines (15 cum/ hour ) would be:--

Proforma--- K/ Volume in CuM / Duration in Minutes

0.5/ 1.02 / 4.1
1.0/ 2.03 / 8.1
1.2/ 2.44 / 9.8
2.4/ 4.88 / 19.5

A cleaning machine cycle is defined as the period between two consecutive identical orientations of the machine (rotation through 360°).
After washing, the cleaning machine(s) shall be kept operating long enough to flush the pipeline, pump and filter,and discharge to shore reception facilities shall be continues until the tank is empty.
Number of cleaning machine cycles to be used in each location
Category of substance
Number of cleaning machine cycles
Non-Solidifying Substances
Solidifying Substances
Category X
1
2
Category Y
1/2
1


Prewash procedures for non-Solidifying Substances : Tanks shall be washed by means of a rotary water jet, operated at sufficiently high water pressure. In the case of Category X substances cleaning machines shall be operated in such locations that all tank surfaces are washed. In the case of Category Y substances only one location need be used.
Prewash entries in Oil record book –Annex 2:
Identify port---Identify tank(s), substance(s), category(ies) discharged ashore---Have tank(s), pump(s), and piping system(s) been emptied?---Has a prewash in accordance with the ship’s procedures and arrangements manual been carried out?---Have tank washings resulting from the prewash been discharged ashore and is the tank empty?---An exemption has been granted from mandatory prewash---Reasons for exemption----Name and signature of authorized surveyor.----Organization, company, government agency for which surveyor works.

Category Y

WHENEVER YOU CARRY VEG OILS OF CATEGORY Y-  ASK FOR THE VISCOCITY IN mPa.S AT 20 DEG C AND MP --IN THE SHIPPING DOCUMENT OR B/LADING.    IT DOES NOT MATTER IF THE VEG OIL IS DRYING OR SEMI DRYING.
Noxious Liquid Substances which, if discharged into the sea from tank cleaning or deballasting operations, are deemed to present a hazard to either marine resources or human health or cause harm to amenities or other legitimate uses of the sea and therefore justify a limitation on the quality and quantity of the discharge into the marine environment;
Examples are Acrylonitrile, Biodiesels, Carbon Tetrachloride, Caustic coda , Ethylene di Chloride , MDI, Lub Additives, Phenol, Sulphuric acid, Benzene, Toluene, Xylene, Ethylene Glycol , Methanol, Lard, Palm Oils, All VEG OILS and FATS, Hexane, Vinyl acetate   etc.
For High-Viscosity or Solidifying Substances in Category Y the following shall apply ( note –the values are given in the cargo list of P&A manual ) :

1              a prewash procedure shall be applied;
2              the residue/water mixture generated during the prewash shall be discharged to a reception
                facility until the tank is empty; and
.3            any water subsequently introduced into the tank may be discharged into the sea
High-Viscosity Substance means a noxious liquid substance in Category X or Y with a viscosity equal to or greater than 50 mPa.s at the unloading temperature.
Solidifying Substances and substances with viscosity equal to or greater than 50 mPa.s at 20°C shall be washed with hot water (temperature at least 60°C) when water is used as the washing medium, unless the properties of such substances make the washing less effective.

Only solidifying and viscous Category Y cargoes need to be prewashed ashore (with >60 deg C water) prior departure discharge port.
Solidifying means –---if MP > 15C and dischg temp of cargo is within 10 deg C /  if MP < 15C and dischg temp of cargo is within 5 deg C.
Prewash procedures for Solidifying Substances
1 Tanks shall be washed as soon as possible after unloading. If possible tanks shall be heated prior to washing.
2 Residues in hatches and manholes shall preferably be removed prior to the prewash.
3 Tanks shall be washed by means of a rotary water jet operated at sufficiently high water pressure and in locations to ensure that all tank surfaces are washed.
4 During washing the amount of water in the tank shall be minimized by pumping out slops continuously and promoting flow to the suction point (positive list and trim). If this condition cannot be met, the washing procedure shall be repeated three times with thorough stripping of the tank between washings.
5 Tanks shall be washed with hot water (temperature at least 60°C) unless the properties of such substances make the washing less effective.
6 The number of cycles of the cleaning machine used shall not be less than that specified in table 6-1. A cleaning machine cycle is defined as the period between two consecutive identical orientations of the machine (rotation through 360°).
7 After washing, the cleaning machine(s) shall be kept operating long enough to flush the pipeline, pump and filter,and discharge to shore reception facilities shall be continues until the tank is empty.
Table 6-1 -- Number of cleaning machine cycles to be used in each location
Category of substance
Number of cleaning machine cycles
Non-Solidifying Substances
Solidifying Substances
Category X
1
2
Category Y
1/2
1

Those substances which have a viscosity equal to or greater than 50 mPa.s at 20°C shall be washed with hot water (temperature at least 60°C), unless the properties of such substances make the washing less effective.

Prewash procedures for non-Solidifying Substances : Tanks shall be washed by means of a rotary water jet, operated at sufficiently high water pressure. In the case of Category X substances cleaning machines shall be operated in such locations that all tank surfaces are washed. In the case of Category Y substances only one location need be used.

Recycled medium prewash—Can be adopted for washing more than one tank. The cargo concentration in the water / medium 5% based on stripping test quantities of the P&A manual.

Every ship constructed on or after 1 July 1986 but before 1 January 2007 shall be provided with a pumping and piping arrangement to ensure that each tank certified for the carriage of substances in Category X or Y does not retain a quantity of residue in excess of 100 litres in the tank and its associated piping

The definition of high viscosity in the revised Annex II would mean that a lot of vegetable oils (primarily the soft oils) could be required to be prewashed.
It has been suggested that for certain oils, such as Soyabean oil, the discharge temperature could be raised slightly to bring the product out of the high viscosity range, thus obviating the need for a prewash, and the vegetable oil industry has been considering the issue. FEDIOL (the European refiners association) have, however, recently advised that they are not prepared to alter the heating instructions in respect of vegetable oils. This will mean that a prewash is inevitable for a number of oils.
It should be noted that the revised Annex II requires that the prewash and discharge ashore should be carried out in the port of unloading unless a port that the vessel is due to call at later has confirmed in writing that it has a reception facility available that is adequate for the purpose. The unloaded tank must be neither washed nor ballasted at sea before the prewash can be carried out.
Prudent masters must ensure  the availability of shore reception facilities, till all are familiar will the new regulations.

Regarding the DH ( discharge temperature ), --for solidifying or high viscosity cargoes which have been identified as being required to be a certain minimum temperature during unloading--  If  P-Xylene was discharged at temperature of 17°C,  the tank cleaning slop of the cargo should be discharged to a reception facility because it is a solidifying cargo defined as Solidifying substance.

It means --in case of substances with melting points less than 15°C, is at a temperature, at the time of unloading, of less than 5°C above its melting point. 
  
Therefore the P-Xylene(melting point:13°C) with temperature of  more than18°C(13+5)  has   to be unloaded and then the tank cleaning slop of the cargo can be discharged into sea.

 
Category Z

Noxious Liquid Substances which, if discharged into the sea from tank cleaning or deballasting operations, are deemed to present a minor hazard to either marine resources or human health and therefore justify less stringent restrictions on the quality and quantity of the discharge into the marine environment;
Examples are  Acetone, Acetic acid, Dodecyl Benzene , Methyl Ethyl Ketone, MTBE, Phosphoric acid , Urea  etc.

For ships constructed before 1 January 2007 the discharge into the sea of residues of substances in Category Z or of those provisionally assessed as such or ballast water, tank washings or other mixtures containing such substances below the waterline is not mandatory.

If the unloading of a substance of Category Y or Z is not carried out in accordance with the Manual, a prewash shall be carried out before the ship leaves the port of unloading. Remember this relates to unpumpables due to heating breakdown ( cold interface etc ) and excess ROB due to use of PORTABLE FRAMO etc. The resulting tank washings of the prewash shall be discharged to a reception facility at the port of unloading or another port with a suitable reception facility provided that it has been confirmed in writing that a reception facility at that port is available and is adequate for such a purpose.

Every ship constructed on or after 1 July 1986 but before 1 January 2007 shall be provided with a pumping and piping arrangement to ensure that each tank certified for the carriage of substances in Category Z does not retain a quantity of residue in excess of 300 litres in the tank and its associated piping. If the stripping has failed or portable framo has been used for discharge due to deepwell pump failure , then the subject tanks have to be prewashed ( extended one ).

For a ship other than a chemical tanker constructed before 1 January 2007 which cannot meet the requirements for the pumping and piping arrangements for substances in Category Z referred to in paragraphs 1 and 2 of this regulation no quantity requirement shall apply. Compliance is deemed to be reached if the tank is emptied to the most practicable extent.  

Ships certified to carry substances of Category X, Y or Z shall have an underwater discharge outlet (or outlets).
For ships constructed before 1 January 2007 and certified to carry substances in Category Z an underwater discharge outlet is not mandatory.

          O    Other Substances:
                  Substances indicated as OS (Other Substances) in the pollution category column of chapter 18 of the International Bulk Chemical Code which have been evaluated and found to fall outside Category X, Y or Z because they are, at present, considered to present no harm to marine resources, human health, amenities or other legitimate uses of the sea when discharged into the sea from tank cleaning of deballasting operations. The discharge of bilge or ballast water or other residues or mixtures containing only substances referred to as “Other Substances” shall not be subject to any requirements of the Annex. The fourth category, OS (Other Substances), contains only 8 harmless products (apple juice, clay slurry, coal slurry, dextrose solution, glucose solution, kaoline slurry, molasses, water).

The revised annex includes a number of other significant changes. Improvements in ship technology, such as efficient stripping techniques, has made possible significantly lower permitted discharge levels of certain products which have been incorporated into Annex II. For ships constructed on or after 1 January 2007 the maximum permitted residue in the tank and its associated piping left after discharge will be set at a maximum of 75 litres for products in categories X, Y and Z - compared with previous limits which set a maximum of 100 or 300 litres (with 50 litres tolerance ), depending on the product category.

After 1st January 2007, all vegetable oils which is being currently listed in Chapter 18 of the IBC code ( meaning that they can be carried in normal product tankers with NLS certificate) can only be carried on type 2 chemical tankers. This means these cargoes will be transferred from Chapter 18 to Chapter 17.
Depth of water means the charted depth.

En route means that the ship is under way at sea on a course or courses, including deviation from the shortest direct route, which as far as practicable for navigational purposes, will cause any discharge to be spread over as great an area of the sea as is reasonable and practicable.

Liquid substances are those having a vapour pressure not exceeding 0.28 MPa absolute at a temperature of 37.8°C.
Nearest land. The term “from the nearest land” means from the baseline from which the territorial sea in question is established in accordance with international law

Noxious Liquid Substance means any substance indicated in the Pollution Category column of chapter 17 or 18 of the International Bulk Chemical Code or provisionally assessed under the provisions of regulation 6.3 as falling into Category X, Y or Z.

PPM means ml/m3.
Residue means any noxious liquid substance which remains for disposal.
Residue/water mixture means residue to which water has been added for any purpose

The discharge requirements of this Annex shall not apply to the discharge into the sea of Noxious Liquid Substances or mixtures containing such substances when such a discharge:
                  is necessary for the purpose of safety of a ship or saving life at sea; or
results from damage to a ship or its equipment:
provided that all reasonable precautions have been taken after the occurrence of the damage or discovery of the discharge for the purpose of preventing or minimizing the discharge; and
except if the owner or the master acted either with intent to cause damage, or recklessly and with knowledge that damage would probably result; or 
is approved by the Administration, when being used for the purpose of combating specific pollution incidents in order to minimize the damage from pollution. Any such discharge shall be subject to the approval of any Government in whose jurisdiction it is contemplated the discharge will occur.

Where the provisions in this regulation allow the discharge into the sea of residues of substances in Category X, Y or Z or of those provisionally assessed as such or ballast water, tank washings or other mixtures containing such substances the following discharge standards shall apply:
1              the ship is proceeding en route at a speed of at least 7 knots in the case of self-propelled ships or at least 4 knots in the case of ships which are not self-propelled;
2              the discharge is made below the waterline through the underwater discharge outlet(s) not exceeding the maximum rate for which the underwater discharge outlet(s) is (are) designed; ( use of UW discharge is not mandatory for category Z residues and tankwashings )
3              the discharge is made at a distance of not less than 12 nautical miles from the nearest land in a depth of water of not less than 25 metres.
4        Remark: the thing to note is that the discharge PPM is unrestricted after 1.1.07

For ships constructed before 1 January 2007 the discharge into the sea of residues of substances in Category Z or of those provisionally assessed as such or ballast water, tank washings or other mixtures containing such substances below the waterline is not mandatory.
For Category Z, regarding the distance of not less than 12 nautical miles from the nearest land for ships solely engaged in voyages within waters subject to the sovereignty or jurisdiction of the State the flag, of which, the ship is entitled to fly.

On request of the ship’s master an exemption for a prewash may be granted by the Government of the receiving Party, where it is satisfied that:
1              the unloaded tank is to be reloaded with the same substance or another substance compatible with the previous one and that the tank will not be washed or ballasted prior to loading; or
2              the unloaded tank is neither washed nor ballasted at sea. The prewash in accordance with the applicable paragraph of this regulation shall be carried out at another port provided that it has been confirmed in writing that a reception facility at that port is available and is adequate for such a purpose; or
3              the cargo residues will be removed by a ventilation procedure approved by the Administration
When a washing medium other than water, such as mineral oil or chlorinated solvent, is used instead of water to wash a tank, its discharge shall be governed by the provisions of either Annex I or Annex II, which would apply to the medium had it been carried as cargo.  Tank washing procedures involving the use of such a medium shall be set out in the Manual and be approved by the Administration.
When small amounts of cleaning additives (detergent products) are added to water in order to facilitate tank washing, no additives containing Pollution Category X components shall be used except those components that are readily biodegradable and present in a total concentration of less than 10% of the cleaning additive. No restrictions additional to those applicable to the tank due to the previous cargo shall apply.

Ballast introduced into a cargo tank which has been washed to such an extent that the ballast contains less than 1 ppm of the substance previously carried, may be discharged into the sea without regard to the discharge rate, ship’s speed and discharge outlet location, provided that the ship is not less than 12 miles from the nearest land and in water that is not less than 25 metres deep.

Cargo record book
After completion of any operation it shall be promptly recorded in the Cargo Record Book. In the event of an accidental discharge of a noxious liquid substance  an entry in ENGLISH  shall be made in the Cargo Record Book stating the circumstances of, and the reason for, the discharge.

Each entry shall be signed by the officer or officers in charge of the operation concerned and each page shall be signed by the master of the ship. The Cargo Record Book shall be kept in such a place as to be readily available for inspection .. It shall be retained for a period of three years after the last entry has been made.  The competent authority of the Government may inspect the Cargo Record Book on board any ship to which this Annex applies while the ship is in its port, and may make a copy of any entry in that book and may require the master of the ship to certify that the copy is a true copy of such entry. Any copy so made which has been certified by the master of the ship as a true copy of an entry in the ship’s Cargo Record Book shall be made admissible in any judicial proceedings as evidence of the facts stated in the entry.  The inspection of a Cargo Record Book and the taking of a certified copy by the competent authority under this paragraph shall be performed as expeditiously as possible without causing the ship to be unduly delayed.

The Government of each Party to the Convention shall appoint or authorize surveyors for the purpose of implementing this regulation. When a surveyor appointed or authorized by the Government of the Party to the Convention has verified that an operation has been carried out in accordance with the requirements of the Manual, or has granted an exemption for a prewash, then that surveyor shall make an appropriate entry in the Cargo Record Book.
 Where it is impracticable to measure the concentration of the substance in the effluent without causing undue delay to the ship,  the alternative procedure is for the surveyor to certify in the Cargo Record Book that:
1              the tank, its pump and piping systems have been emptied; and
2              the prewash has been carried out in accordance with the provisions of appendix 6 of this Annex; and
3              the tank washing resulting from such prewash have been discharged to a reception facility and the tank is empty.

Minimum quantity of water to be used in a prewash
The minimum quantity of water to be used in a prewash is determined by the residual quantity of noxious liquid substance in the tank, the tank size, the cargo properties, the permitted concentration in any subsequent wash water effluent, and the area of operation. The minimum quantity is given by the following formula:
Q=k(15r0.8 + 5r0.7 x V/1000)
                  where Q = the required minimum quantity in m3
                                     r =      the residual quantity per tank in m3. The value of r shall be the value demonstrated in the actual stripping efficiency test, but shall not be taken lower than 0.100 m3 for a tank volume of 500 m3 and above and 0.040 m3 for a tank volume of 100 m3 and below. For tank sizes between 100 m3 and 500 m3 the minimum value of r allowed to be used in the calculations is obtained by linear interpolation.
For Category X substances the value of r shall either be determined based on stripping tests according to the Manual, observing the lower limits as given above, or be taken to be 0.9 m3.
                                     V =    tank volume in m3
k =          a factor having values as follows:
Category X, non-Solidifying, Low-Viscosity Substance, k = 1.2
Category X, Solidifying or High-Viscosity Substance, k = 2.4
Category Y, non-Solidifying, Low-Viscosity Substance  k = 0.5
Category Y, Solidifying or High-Viscosity Substance, k = 1.0

The table below is calculated using the formula with a k factor of 1 and may be used as an easy reference.
Stripping quantity (m3)

Tank volume (m3)

100
500
3000
<0.04
1.2
2.9
5.4
.10
2.5
2.9
5.4
.30
5.9
6.8
12.2
.90
14.3
16.1
27.7

 Verification testing for approval of prewash volumes lower than those given in paragraph 20 may be carried out to the satisfaction of the Administration to prove that the requirements of regulation 13 are met, taking into account the substances the ship is certified to carry.  The prewash volume so verified shall be adjusted for other prewash conditions by application of the factor k as defined in paragraph.

               Ventilation of cargo residues from a tank :
High Volatile Cargoes with a VP>5000 Pa @ 20 deg c ( 50 mb @ 20 deg c ) that can be removed by ventilation.

                  1            the pipelines shall be drained and further cleared of liquid by means of ventilation equipment;
2              the list and trim shall be adjusted to the minimum levels possible so that evaporation of residues in the tank is enhanced;
3              ventilation equipment producing an airjet which can reach the tank bottom shall be used. Figure 7-1 could be used to evaluate the adequacy of ventilation equipment used for ventilating a tank of a given depth;
4              ventilation equipment shall be placed in the tank opening closest to the tank sump or suction point;
5              ventilation equipment shall, when practicable, be positioned so that the airjet is directed at the tank sump or suction point and impingement of the airjet on tank structural members is to be avoided as much as possible; and
6              ventilation shall continue until no visible remains of liquid can be observed in the tank. This shall be verified by a visual examination or an equivalent method.

The graph with inlet jet penetration depth in metres on X axis and minimum flow for each cargo tank in CUM/ min on Y axid is given in P&A manual—read off flow rate against linear lines for various inlet diameters

CARGO RECORD BOOK:--

Every chemical tanker is required to maintain a Cargo Record Book. This book must be upto date at all times.

In some ports (like in Algeria) the harbour master takes the cargo record book away while the ship is alongside and returns it just prior sailing . This is not allowed as per the regulations. Many ships are not familiar with  how to make correct entries in the Cargo Record Book .

Entries in the Cargo Record Book are required only for operations involving Categories X,Y,Z substances.  Other Substances carried in bulk are not subject to the provisions of this Annex as they are not in the Pollution Category column of chapters 17 of IBC Code and it is NOT necessary to enter in the Cargo Record Book (i.e.  Molasses, Clay slurry , Apple juice etc)

1.       The Cargo Record Book shall be completed, on a tank-to-tank basis, whenever any of the following operations
         with respect to a noxious liquid substance take place in the ship:

a). loading of cargo
b). internal transfer of cargo
c). unloading of cargo
d). cleaning of cargo tank
e). ballasting of cargo tanks
f). discharge of ballast from cargo tanks
g). disposal of residues to reception facilities
f). discharge into the sea or removal by ventilation of residues in accordance with regulation 5 of thisAnnex.  

2.       Each operation shall be fully recorded without delay in the Cargo Record Book so that all the entries in the book appropriate to that operation are completed as and when it happened.

3.       When making entries in the Cargo Record Book, the date, operational code and item number shall be inserted in the appropriate columns and the required particulars shall be recorded chronologically in the blank spaces without leaving blank spaces between last operation records and next operation records. 
 
4.        Each completed entry shall be signed by the officer in charge ( xxx ships Chief Officer ) and each completed page shall be countersigned by the master of the ship as soon as it is complete.

5.        Entries shall not be altered, erased, or cut in any case.  If correction has to be made, two lines shall be run through such entry, leaving the corrected part in legible state, with the signature of the officer affixed. No tipex white fluid corrector can be used.

6.       The cargo record book shall be retained for a period of three years after the last entry has been made.

Recapitulation:
Revised MARPOL & IBC Discharge & Stripping Requirements
Category
BCH Ships Constructed before 31/7/1986
Existing IBC Constructed from 31/7/1986 but before 1/1/2007
New Buildings Constructed from 1/1/2007
Ships Other than Chemical Tankers constructed before 1/1/2007
X
Pre Wash Strip to 350 Litres 12 mile 25m water depth 7 knots, en-route
Pre Wash Strip to 150 Litres 12 mile 25m water depth 7 knots, en-route
Pre Wash Strip to 75 Litres 12 mile 25m water depth 7 knots, en-route
Carriage Prohibited
Y
Pre Wash for solidifying for high viscosity substances Strip to 350 Litres 12 mile 25m water depth 7 knots, en-route
Pre Wash for solidifying for high viscosity substances Strip to 150 Litres 12 mile 25m water depth 7 knots, en-route
Pre Wash for solidifying for high viscosity substances Strip to 75 Litres 12 mile 25m water depth 7 knots, en-route
Carriage Prohibited
Z
Strip to 950 Litres 12 mile 25m water depth 7 knots, en-route
Strip to 350 Litres 12 mile 25m water depth 7 knots, en-route
Prewash if stripping not in accordance with P&A manual.
Strip to 75 Litres 12 mile 25m water depth 7 knots, en-route
Prewash if stripping not in accordance with P&A manual.
Strip to Maximum Extent 12 mile 25m water depth 7 knots, en-route
OS
No carriage Requirements
No Carriage Requirements
No Carriage Requirements

Underwater Discharge Required
Only X and Y cargoes
Only X and Y cargoes
X,Y and Z cargoes
Only X and Y cargoes


-------CAPT AJIT VADAKAYIL ( 28 YEARS IN COMMAND )--Rules as on end 2009

34 comments:

  1. Dear Captain Vadakayil,

    I have a doubt about the tank washings after an Annex-I cargo on a chemical tankers. I've noted this practice on many vessels.

    A chemcial tanker carries out a quick wash (30 mins) after discharging a cargo of lub oil (Annex-I), and collects the tank washings in a slop tank. The vessel then washes all her cargo tanks with hot water and pumps out the tank washings directly overboard.

    Q:
    1. Is this procedure legal? If yes, where can I find the information?
    2. What entries are required in the oil record book?

    Thanks/Best regards

    ReplyDelete
    Replies
    1. Mr. Tajbar plz do post the answer for your query.. tht was a good one and still a mystery... if you had already got the answer plz do send it to the following email address: leomrtn3@gmail.com... thanks in advance.

      Delete
    2. hi lm and t,

      annex 1 washings of tank and pipeline flushings can NEVER EVER be pumped directly overboard.

      they have to pass through the ODMCS .

      the annex 1 washing has to be CLOSED CYCLE WASH.

      punch into google search-

      ANNEX 1 CLOSED CYCLE WASH ON CHEMICAL TANKERS VADAKAYIL

      ODMCS is used for decanting slops only.

      punch into google search-
      ODMCS DECANTING OF ANNEX 1 SLOPS ON CHEMICAL TANKERS VADAKAYIL

      the closed cycle wash using slops can NEVER involve cleaning chemicals.

      reputed annex 2 time charterers fit DECK TANKS to hold the annex 1 slops so that they can dispose it off later at cheaper places. no times if lost before loading.

      i have regularly discharged high heat viscous LUB OILS in brazil / argentina and back loaded ethanol/ veg oils . if pipeline flushing is neglected you fail the first foot.

      capt ajit vadakayil
      ..

      Delete
  2. i have 2 questions but they do not belong to this article sorry

    1 - if i there are very toxic cargo which require ventilation during voyage , Is this legal to let the vapours out to atmosphere ?
    2 - if there are an inert gas above cargo in tank and this cargo needs ventilation , how can i do this without losing the nitrogen blanket ?

    thanks in advance Capt.

    ReplyDelete
  3. hi mehmoud,

    in the chemical business at sea, there are NO toxic cargoes whicg require ventilation during voyage.

    if there is nitrogen pad , and the oxygen content of tank rises due to leak, the this has to be replenished by padding at sea, using nitrogen cylinders or plant.

    capt ajit vadakayil
    ..

    ReplyDelete
  4. i have 1 question

    how to dispose cargo sample of annex II cargo , inhibited ,self reactive or solidifiying ones

    ReplyDelete
  5. Sir, please throw some light on this question which is failing a lot of us in orals. Why marpol annex II has been named under control of pollution...... while other aneexes has been named under prevention of pollution.....

    ReplyDelete
    Replies
    1. hi bf,

      can you pump out ANNEX ONE mineral oils overboard?
      NO !!


      can you pump out ANNEX 2 chemicals overboard ?

      YES -- but within limits depending on pollution category XYZ .

      capt ajit vadakayil
      ..

      Delete
  6. sir have you done diploma in shipbuilding engineering?

    ReplyDelete
  7. Good day sir ... One small query....It may sound stupid but just asking for the sake of gaining knowledge...
    After calculating the minimum prewash quantity from the P&A manual (correct me if i'm wrong) is it possible to introduce more water during prewash to bring down the concentration or it is not a big deal tht it can be disposed as it is ? And is it the caorgo surveyor or The Port captian who supervises the prewash.

    ReplyDelete
    Replies
    1. hi lm,

      prewash has to be WITNESSED and the endorsement in the annex 2 cargo record book , signed by a GOVT surveyor.

      you can introduce MORE water than the MIN stipulated in the P&A manual.

      nothing is free-- you have to pay for the shore tank or the barge .

      capt ajit vadakayil
      ..

      Delete
  8. sir kindly edify me on the marpol nearest land definition ... can an isolated land or a group of rocks in mid sea be considered as nearest land... or is it like nearest land should be of human existance orpossible human existance... your reply would be a greathelp to me sir...

    ReplyDelete
    Replies
    1. hi lm,

      marpol is a law.

      read it and understand it.

      so interpretation on HINDSIGHT is allowed.

      MARPOL maps are available .

      capt ajit vadakayil
      ..

      Delete
  9. Sir,

    What name do we enter in cargo record book for the Substance carried: Product name or Shipping name??

    ReplyDelete
    Replies
    1. hi id,

      tell your company to send to you the IBC CODE SHIPPING DOCUMENT.

      BOTH ARE REQUIRED-

      -------- CARGO NAME AS PER BL

      ---------- PRODUCT NAME AS PER IBC CODE.( OR MEPC 2 CIRCULAR ).

      i have stopped taking academic questions .

      capt ajit vadakayil
      ..

      Delete
  10. I HAVE ONE QUESTION
    is palm olein a marine pollutant ? ACCORDING TO THE IMO REGULATIONS ?

    ReplyDelete
    Replies
    1. hi mmaa,

      get the specs for MP and viscocity.

      capt ajit vadakayil
      ..

      Delete
  11. Sir , Please explain what categories of chemical cargo ( X,Y,Z & OS ) can be carried on Type 1 ,2 & 3 tankers ? plz explain with examples. Thanks.

    ReplyDelete
  12. sir

    After carriage of X category cargo a ship has pre washed the tanks till the effluent concentration is 0.1% which is equivalent to 1000 ppm .Marol is not saying to do pre wash and discharge to shore till concentration is 0 ppm and 1000 ppm is fairly a good concentration . so can we clean the tank further and and discharge washing to sea is it allowed ? if the charter says to clean the tank further after leaving port what to do in that case . Pls note that it is a cat x cargo and basic criterion of cat X is not to discharge any washing to sea .Kindly help to clear this confusion

    ReplyDelete
    Replies
    1. FOLLOW MARPOL RULES -EVERY TIME .

      IF YOU HAVE A PROBLEM BECAUSE OF PRE-CONCEIVED NOTIONS-- ASK YOUR COOK TO INTERPRET THE RULES

      Delete
    2. sorry to get this reply from such a highly respected source of knowledge like you sir . Thank you

      Delete
    3. hi rp,

      AT SEA WHEN I WANTED RULES TO BE INTERPRETED

      I TOLD MY WIFE TO INTERPRET IT FOR ME.

      SO THAT MY PRECONCEIVED NOTIONS DO NOT BLUR MY JUDGEMENT

      MARPOL RULES MUST BE FOLLOWED.

      THERE IS NO PAST PRACTISE WHEN IT COMES TO POLLUTION RULES . ALL THESE PAST PRACTICES ADOPED BY GREEDY CHARTERERS , ARE WRONG 99.99% OF THE TIME.

      THE US COAST GUARD HAD ONCE APPROACHED ME FOR INTERPRETATION OF MARPOL ANNEX 2 RULES . I JUST TOLD THEM "FOLLOW THE MARPOL RULES"

      I PERSONALLY HAVE USED SOLAS RULES TO SCREW MY BOSSES ASHORE.

      MANY TIMES CHARTERES HAVE TRIED TO SEND WHITE SUPERCARGOES TO LEARN HOW I CHANGE OVER ROM HIGH VISCOCITY LUB OILS TO POTABLE ETHANOL--

      I SAID NO !

      capt ajit vadakayil
      ..

      Delete
  13. Hi, quick question please. I had loaded annex 2 , solvent waste, cat y in 4 tanks, other 6 tanks i have waste oil, annex 1. After discharging of this 4 tanks a2 should i make a prewash in order to load a1 cargo again? As per marpol and p&a manual is like that, and residues disch to shore facility. Pls let me know asap. Respect, Alex

    ReplyDelete
  14. Sir,is t possible to pump out pure annex 1 cargo through ODMCS?

    ReplyDelete
    Replies
    1. hi j,

      http://ajitvadakayil.blogspot.in/2012/05/odmcs-decanting-of-annex-1-slops-on.html

      http://ajitvadakayil.blogspot.in/2010/11/annex-1-closed-cycle-wash-on-chemical.html

      capt ajit vadakayil
      ..

      Delete
  15. sir, why annex 2 is only control of pollution while all others are prevention

    ReplyDelete
  16. Good day Cap. First of all I'd like to say many thanks for very interesting forum. Dear Sir I'm interesting about Heating of cargo category Y. Possible or not,if cargo Temperature will be kept according cargo heating instruction (for example Palm-Oil Heating min/max, voyage 25/30 C. Heating min/max, discharging 40/45 C.) avoid Pre-wash and begin tank cleaning and discharge cargo residue according Marpol Discharge standards( 7 knots,12 miles,25 meters) If yes how can I find information about cargoes which doesn't require Pre-wash?

    Many Thanks in advance

    ReplyDelete
    Replies
    1. FOLLOW MARPOL RULES

      SHIPPERS HAVE TO DECLARE VOYAGE HEAT AND DISCHG HEAT IN WRITING.

      http://ajitvadakayil.blogspot.in/2010/11/vegetable-oils-and-fats-on-chemical.html

      http://ajitvadakayil.blogspot.in/2011/09/high-melting-point-cargoes-on-chemical.html

      Delete
  17. STOP PRESS:

    SOMETIMES MY READERS WONDER HOW I GET SO MUCH OF UNKNOWN INFORMATION..

    A CHUNK OF IT CAME BY "SHAKING DOWN " PEOPLE.

    MAKE SOMEONE FEEL THAT IF HE DOES NOT CONFESS- HE WILL GO TO JAIL-- AND I HAVE THE POWER TO DO IT.

    THIS IS WHO I CAME TO KNOW SECRETS OF "INDIAN SHIP MANAGEMENT COMPANIES "

    EXAMPLE?

    ONCE I WAS PUT IN A HOTEL ROOM WITH SAME SEROUS DEFICIENCIES --SAY THE ROOM DID NOT HAVE A WINDOW

    I WOULD CALL FOR THE TOP MANAGER AND SHAKE HIM DOWN.

    BUT HEY--

    BUT I MAY RE-CONSIDER , IF HE TELLS ME HOW MUCH KICK BACK PERCENTAGE HE GIVES TO THE MANNING OFFICE WHO PUTS SHIP OFFICERS IN HIS HOTEL.

    PAT- THE ANSWER WILL COME-- 40 %

    THIS MEANS IN A HOTEL ROOM COSTING 5000 BUCKS A DAY 2000 BUCKS GOES TO THE POCKET OF OWNER/ MANAGER OF THE MANNING OFFICE.

    I HAVE SHAKEN DOWN SHIPPING ACCOUNTANTS IN FOREIGN NATIONS . NOBODY LIKES JAIL

    I HAVE COME TO KNOW OF SLIMY SHIP MAMANGEMENT INDIAN COMPANIES WHO PAY AN OFFICER 6000 DOLLARS A MONTH-- BUT THEY FORGE THE WHOLE SIGNED SHEET AGAIN ( ENTIRE CREW ) IN THE OFFICE , AND CHARGE THE JAPANESE SHIP OWNER 30% EXTRA.

    THAT MEANS IF THE ACTUAL WAGES GIVEN ARE 2 LAKHS DOLLARS PER MONTH 60,000 DOLLARS ARE SKIMMED OFF BY THE INDIAN SHIPMANAGEMENT COMPANY--WITHOUT THE CREW OR THE JAP SHIPOWNER KNOWING.

    OFFICERS AND CREW ARE MADE TO PAY FOR THE "FLAG DOCUMENTATION" SAY--PANAMA/ MONROVIA ETC SAY 800 DOLLARS-- BUT THEY COLLECT THIS MONEY FROM THE JAP OWNERS TOO--

    FLAG DOCUMENTATION-- CERTIFICATE OF COMPETENCY, CDC, SPECIAL VERTIFICATES LIKE OIL / CHEMICAL/ GAS ADVANCED COURSEs ETC

    I HAVE THE POWER TO JAIL SEVERAL HIGH FLYING MAHA MERUS WITH PROOF. I HAVE REVEALED JUST 2%.

    SOME OF THEM ARE IMMORAL SONS OF BITCHES-- THEY WILL SELL THEIR OWN MOTHERS TO WHORE HOUSES.

    WELL THEY WILL READ THIS TODAY--AND ALL WILL SHIT IN THEIR LANGOTS AND SPEND SEVERAL SLEEPLESS NIGHTS

    capt ajit vadakayil
    ..


    Capt. Ajit VadakayilFebruary 26, 2016 at 2:31 PM
    SOMEBODY CALLED –

    ASKED ME CAN YOU REVEAL SOME MORE ABOUT THESE BASTARDS RUNNING INDIAN SHIP MANAGEMENT COMPANIES—

    OK— TWO MORE

    AAA- MONTHLY ALLOTMENTS TO HOME BANK REACHING LATE.
    ##################################

    LET US SAY THAT I SENT 15000 USD AS MONTHLY ALLOTMENT TO MY WIFE

    IT WILL REACH MY HOME ONLY AFTER 20 DAYS

    THE FIRST 20 DAYS , THEY MILK OFF THE INTEREST ( HUGE AMOUNT FOR THE WHOLE CREW ) IN SOME BANK.

    AS A BONUS TO THESE BASTARDS I WILL NOT REVEAL THEIR FCNR / NRE MONEY CHANNELING VIA THE MAURITIUS ROUTE OR WHATEVER -- FERA - AS OF NOW


    BBB- A LOT OF COMPANIES DEMAND THE FIRST MONTHs SALARY AS BRIBE.
    ######################################

    I STOPPED THIS WHEN I CAME TO KNOW ABOUT THIS.

    EXAMPLE: I HAD A BANGLADESI OFFICER WHO HAD TO PAY HIS RECRUITING MANNING AGENT ( A SHORE CAPTAIN ) AT DHAKA , HIS FIRST MONTHs SALARY- BEFORE BOARDING THE SHIP.

    THIS MEANS YOU WORK THE FIRST MONTH WITHOUT SALARY.

    I CALLED UP THE TOP HONCHO IN DENMARK ( MY DIEHARD FAN ) AND STOPPED THIS NONSENSE , THAT VERY MINUTE.

    Capt ajit vadakayil
    ..

    ReplyDelete
  18. This comment has been removed by the author.

    ReplyDelete