ILIA

Oil filtering equipment shall also be provided with arrangements to ensure that any discharge of oily mixtures is automatically stopped when the oil content of the effluent exceeds 15ppm. In considering the design of such equipment and approvals, the administration shall have regard to the specification recommended by the Organization. To avoid willful manipulation of 15ppm bilge alarms, the 15ppm bilge alarms should be so constructed that the alarm is always activated whenever clean water is used for cleaning or zeroing purposes. Port State Control Officers (PSCOs) identified faulty solenoid valve stuck in the open position on the fresh waterline to the Oil Content Meter (OCM). During operational tests, the fresh water diluted the sample reading to zero PPM with open solenoid valve. The three-way valve remained in the open position, with no alarm activation, to overboard despite the OCM being actively flushed with fresh water for over twenty minutes. In its current condition, the OCM is unable to detect the oil concentration in the discharge effluent and does not prevent overboard discharge when the OCM is utilizing fresh water for cleaning or zeroing purposes. MARPOL I/14.7 MEPC.107(49)

Each operation described in paragraph 2 of this regulation shall be fully recorded without delay in the Oil Record Book Part I (ORB), so that all entries in the book appropriate to the operation are completed. Each completed operation shall be signed by the officer or officers in charge of the operations concerned and each completed page shall be signed by the master of the ship. The ORB presented to the PSCOs had multiple discrepancies. Approximately eight additional cubic meters of bilge water was observed on board by PSCOs through soundings during the exam. According to the ORB entry on 20NOV2019 there was 9.2 m3 and the PSCOs observed soundings of 17.3 m3. Additionally, on 05NOV2019 the ORB entry sounding for the bilge tank was 10.6 m3 while the company provided daily tank sounding log states it was 6.3 m3. It was determined through crew statements and sounding logs that the presented ORB is not a true account of the handling of oily waste and bilge water on the ship. MARPOL I/17.4

The company should ensure that the (safety and environmental) policy is implemented and maintained at all levels of the organization, both ship-based and shore-based. PSCOs found several entries in the ORB that contradicted sounding logs (SMS - 7.4.5.3.7) and violated company environmental protection policy. The ship’s last operation of OWS was on 12NOV19 at 1630 to 0352. Company policy on OWS operation (SMS - 7.6.6.5.7) clearly states that routine overboard discharges are prohibited except during daylight hours. That same policy also states prior to commencing the operation the Officer Of the Watch (OOW) must be advised and the position of the ship relative to land must be ascertained; the OOW is to record the position in the deck logbook. There were no entries of this operation recorded in the deck logbook. Furthermore, the operating instructions for the OWS do not specify proper valve alignment and checks to prevent pollution. As delineated in deficiencies #1 and #2 and in review of the ship’s records, vessel has failed to fully implement functional requirements of a safety and environmental-protection policy. An external audit of the Safety Management System is required with a focus on environmental protection policies. 74 SOLAS (14) IX/3.1 ISM Code 2.2

Oil residue (sludge) tanks shall be provided and shall have no discharge connections to the bilge system, oily bilge water holding tanks, tank top or oily water separators, except that the sludge tank discharge piping and bilge-water piping may be connected to a common piping leading to the standard discharge connection referred to in regulation 13; the connection of both systems to the possible common piping leading to the standard discharge connection referred to in regulation 13 shall not allow for the transfer of sludge to the bilge system. Discharge piping from the sludge pump to the standard discharge connection is hard piped to allow for transfer of sludge and waste oil into the bilge holding tank. Piping does not have check valves or visual inspection means to prevent the accumulation of waste oil and sludge in the bilge tank. Crew has performed transfers from the waste oil tank to the bilge holding tank via sludge pump multiple times in recent months. MARPOL I/12.3.3.2

Where penetrations of watertight bulkheads and internal decks are necessary for access, piping, ventilation, electrical cables, etc., arrangements are to be made to maintain watertight integrity. Piping on top of the waste oil tank on the double bottom of the engine room is no longer watertight. Hard piping has been removed and replaced with flexible hose to allow for drainage from the start air receivers. No arrangements exist to ensure watertight integrity of the waste oil tank. 74 SOLAS (14) II-1/13-1.1