As environmental pressure mounts, performance testing of sewage treatment systems is likely to become a requirement for entry into many ports, especially those in areas with sensitive eco-systems. Kittiwake’s managing director, Martin Lucas, explores how regular testing can, not only safeguard against environmental deficiencies, but also save money by avoiding costly in-port delays.
As an inherently global industry, the opportunities for shipping are borderless. The same cannot, however, be said for regulation, which – although perhaps a necessary evil – is always going to present challenges. With Flag State and Port State Control requirements potentially differing, it is critical that MARPOL regulations are properly understood, monitored and adhered to. Deliberate violation of MARPOL requirements or deliberate falsification of records can result in both company management and seafarers being liable for criminal prosecution, large fines and possibly even imprisonment. But even if certification is up- to- date, original and valid, deficiencies found by Port State Control Officers are many and varied, so measures that reassure compliance and lessen the risk of prosecution and delay are surely to be sought out and welcomed.
As we are all only too aware, the environment is no longer the elephant in the room; it is now inescapable and pervades almost every aspect of our lives. And now that the green spotlight has turned to focus on shipping, pressure is mounting to demonstrate that, as an industry, we are capable of recalibrating to meet environmental obligations. One such motivator is the resolution MEPC.115(51) revision of MARPOL’s ANNEX IV, which came into force on 27 September 2008, regulating the environmental impact of ocean going vessels and specifying performance criteria for onboard sewage effluent treatment systems. New and existing ships engaged in international voyages, which are of 400 tons gross tonnage and above, or are certified to carry more than 15 persons, must have a Sewage Pollution Prevention Certificate before they can sail. To obtain this, a survey must be completed by the port/flag state and the sewage system on board must conform to certain performance test criteria, including COD, E.coli and pH.
This certificate is valid for five years, so – perhaps understandably – there is still a certain inertia to regular testing between certificates. However this could prove to be false economy. In line with Annex IV Prevention of Pollution by Sewage from Ships, sewage treatment plants should be kept in good condition, properly maintained, fully functional, with appropriate spares. Escalating environmental concern for oceans with sensitive ecosystems has lead to the introduction of additional performance testing of sewage treatment systems, which can constitute a pre-qualifier to port entry. This is already the case in Alaska and Canada, and as environmental pressure mounts, testing is likely to become a requirement for entry into many ports. A port authority can instruct a survey of the system at any time, and if the system is shown not to substantially comply – that is to perform to type approval – then the vessel can be held in port until repairs are completed (Regulation 4(5)).
It goes without saying that detention and the associated unscheduled delay incurs significant costs, so a growing number of vessels are monitoring the quality of discharges from the sewage treatment plant to ensure that any problems are spotted and can be rectified at an early stage. Proactively testing sewage effluent using a product such as Kittiwake’s Sewage Effluent Test Kit enables ships engineers to rapidly assess the performance of onboard treatment systems and demonstrate to port authorities that the effluent discharge is within the consent levels detailed in the MARPOL regulations. The test kit adheres to EPA approved methodologies enumerating C.O.D. and Coliforms/E.Coli and measures pH value and TSS.
While everyone is in agreement that we must work collaboratively to identify ways to reduce environmental impact, common sense dictates that this must be balanced with satisfying commercial demands. Using time, energy and resource without waste, and making assets work harder will directly impacts the bottom line and therefore must be given priority – let’s be realistic. Happily, many ‘environmental initiatives’ have a direct correlation with uptime and therefore revenue. Increasing operational profitability through preventative maintenance of critical equipment minimises repair costs and delays, and monitoring and alarm systems are the first means of defence in diagnosing problems with the ship.
The impact of successful troubleshooting using condition monitoring tools and technology can equate to millions of dollars in savings, negate the considerable costs and inconvenience associated with unscheduled delays, while also helping to meet environmental responsibilities. Those most adept at generating more from less, prolonging the life of assets and eliminating waste and delays are the ones who will not only become leaner, stronger and more profitable, but will also improve their environmental standing within the shipping community.
Marine Propulsion, July 2010