Pollution caused by discharging the drainage (grey) waters.





In Ukraine, the activity of each commercial seaport is regulated by Obligatory Rules for Commercial Sea Ports. Obligatory rules for Ukrainian seaports, enacted and approved by the Ministry of Transport of Ukraine, provide strict requirements for ships calling at the ports in respect of their pollution control equipment and documentation.





Though Ukraine has ratified MARPOL regulations, which provide for strict definition of “sewage” (MARPOL 73/78 Annex IV) as drainage and other wastes from any form of toilets, urinals, WC scuppers, medical premises via wash basins, wash tubs and scuppers, kitchens, from spaces containing living animals or any other waste waters mixed with the above, and in accordance with Ukrainian law these regulations shall prevail over Ukrainian legislation should it be contradictory, in practice authorities exerting environmental control in ports (State Inspection for Protection of the Black Sea, Port State Control) only apply local regulations and imposed fine, depends of numbers of crew and period of ship’s staying at the port, is quite inevitable in case of discharge of any drainage (grey) waters from the vessel. Under the above obligatory rules and Ukrainian law, State Inspection for Protection of the Black Sea are entitled to board the vessel and inspect the ship’s pollution control equipment, pipe-lines of oil, sewage and bilge waters. The Harbor Master seals the vessel’s outlet valves and an appropriate act of sealing must be issued. Also the state ecological inspectors check the existence of MARPOL certificates and the Log book and Oil Records Book. Moreover under the Law the administrative fine often impose on Master and/or the Chief Engineer. Sometimes we have faced problems when despite the fact that the vessel had appropriate equipment for the purification and disinfection of sewage water in accordance with the Ukrainian National Regulations and requirements of International Convention For Prevention of Pollution (MARPOL 1973/78 with amendments) ecologists have imposed fines on the basis of local regulations. Usually Port Rules contains the following requirements for Prevention of Pollution of Environment:


Quote


Before entering Ukrainian territorial waters all stop valves (outlet valves, clinket gates, etc.) and devices (hatches, covers, driving gears, etc.) which are designed for special purposes such as discharge overboard of harmful substances, must be properly closed and sealed and appropriate entries made in the Log Book and Engine Room Log Book. After berthing, sealing operations for valves and devices should be made by Port State Control personnel in accordance with the duly approved scheme of sealing and issue of sealing report. A copy of the sealing report should be given to the Master, or the appointed crewmember. Upon arrival at the port all ship’s documents (certificates, schemes, all records books, plans) are to be shown and the vessel must prove full compliance with requirements of International Convention For Prevention of Pollution (MARPOL 1973/78 with amendments). Discharge overboard of any sewage (bilge) waters is prohibited.


Unquote


If some of the ship’s pollution control equipment is defective or non-compliances of documents is discovered, the state ecological inspectors issue the following documents:


• Protocol on violation of the environmental legislation of the Ukraine

• Calculation of damages

• Claim estimated on the basis of local regulations and period of ship’s stay in the port

• Resolution on imposition of an administrative fine on Master

• Resolution on imposition of an administrative fine on Chief Engineer.


It is obvious that Ukrainian Authorities now deal very severely with vessels which discharge even a small quantity of pollutant (grey or bilge waters) within Ukrainian territorial waters. Moreover authorities have powers for detention the vessels and they co-ordinate their steps when pollution incidents occur.



P&I Correspondents Recommendations



• Before entering Ukrainian territorial waters, all stop valves (outlet valves, clinket gates, etc.) and devices (hatches, covers, driving gears, etc.) which are designed for special purposes as discharge overboard of harmful substances must be properly closed and sealed, and appropriate entries made in the Log Book and Engine Room Log Book.


• Upon arrival at the Port, the vessel’s crew has to show all the ship’s document (certificates, schemes, all records books, plans) to the Authorities (Port State Control, Sanitary Inspection, State Ecological Inspectorate for the Protection of the Black Sea) and to prove that vessel is in full compliance with requirements of MARPOL 1973/78 with amendments and local environmental regulations.


• To prevent any discharge overboard of any sewage (grey, bilge) waters during ship’s stay at the port as well as any intact valves or leakage from the vessel’s sewage system.


• To prevent leakage from ships’ side: outlet valves, clinket gates, pipe-lines and connections. Thus, proper working of shipboard systems (to equip ships with special collectors for collecting sewage and bilge water during the ship’s stay at the port) reduces the risks of pollution by sewage and bilge water.


• To make all entries carefully in the Log Book, Oil Records Book, Engine Room Book, etc. and provide all the requested ship’s documents/extracts certified by ship’s stamp, if necessary to the ecological authorities.


• To approach local P&I surveyor for assistance in negotiation with the ecologists


• The vessel must be equipped by appropriate tanks (collectors) for collection of grey/sewage waters or all outlet valves must be sealed in closed position, arrange in order to prevent direct discharge overboard to. Alternatively the vessel should order port sewage collecting barge through the agent.