E

MARINE ENVIRONMENT PROTECTION MEPC 80/4/12

COMMITTEE 28 April 2023
80th session Original: ENGLISH
Agenda item 4 Pre-session public release: ☒

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER

Clarification of the temporary storage of treated sewage and/or grey water

in the ballast tanks under the BWM Convention and proposal of guidelines

Submitted by IACS

SUMMARY

Executive summary: This document discusses concerns about the temporary storage of
treated sewage and grey water in the ballast tanks and provides a
draft guidance for temporarily storing treated sewage and/or grey
water in ballast tanks. The intent of the guidance is to establish a
uniform procedure for minimizing the impact on the environment.

Strategic direction,
1
if applicable:

Output: 1.25

Action to be taken: Paragraph 17

Related documents: MEPC 63/2/18, MEPC 63/23; MEPC 78/4, MEPC 78/4/13,
MEPC 78/WP.8; MEPC 79/4/8, MEPC 79/4/11 and MEPC 79/WP.6

Introduction

1 With the enforcement of the D-2 standard of the BWM Convention, the issue of
whether the grey water and treated sewage stored in the ballast tanks will contaminate the
ballast tank, resulting in the discharge of ballast water sequentially uploaded following sewage
discharge, which would not meet the D-2 standard, has also aroused increasing concern.
IACS has also identified a potential risk of discharging untreated or not fully compliant ballast
water if mixed with grey water and/or treated sewage stored in ballast tanks. At present, both
the BWM Convention and MARPOL Annex IV have no relevant provisions for the prohibition
of the storage of grey water or treated sewage in the ballast tanks. The industry has various
interpretations on this issue. Although IACS considers that the temporary use of the ballast
tanks for storage of grey water and/or treated sewage should not be encouraged on ships, a
clarification on this issue from the Committee to ensure the uniform implementation of the BWM
Convention and MARPOL Annex IV is deemed to be necessary.

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2 At MEPC 79, the Ballast Water Review Group (BWRG) was instructed to consider
whether, in the context of the BWM Convention, the temporary storage of grey water or treated
sewage in ballast tanks should be permitted. The BWRG recognized that this practice was not
prohibited by the BWM Convention (nor by MARPOL Annex IV) and, while recognizing also
that this did not necessarily mean that it had to be explicitly permitted, this was identified as a
factor supporting the view that it should be. However, the BWRG agreed that guidance should
be developed to ensure this practice was undertaken in an environmentally sound manner,
including to avoid contamination of the ballast tanks.

3 Based on the outcome of the discussions during the BWRG at MEPC 79, the
Committee endorsed the Group's view that the Convention does not preclude the temporary
storage of grey water or treated sewage in ballast tanks, and, furthermore, that this storage
should be permitted, and that guidance should be developed.

Discussion

4 More ports are imposing local discharge requirements for grey water and sewage
treated by a sewage treatment plant (STP) in accordance with regulation 9.1.1 of MARPOL
Annex IV, and, therefore, the temporary storage of grey water and treated sewage in the ballast
tanks is often considered as the "best" option for the industry since it is not regulated by the
MARPOL Convention.

5 Although the conclusion of the consideration of document MEPC 63/2/18 (Norway) at

MEPC 63 was that grey water and sewage on board ships should be handled in accordance
with MARPOL Annex IV, concern was expressed regarding how to avoid the contamination of
the ballast tanks of a ship by sewage and grey water after the BWM Convention enters into
force, especially when the D-2 standard is mandatory for that ship. Another view was
expressed that, once treated sewage is allowed to be stored in a ballast tank, that ballast tank
should also be regarded as a sewage holding tank, and then both the BWM Convention and
MARPOL Annex IV should be complied with.

6 The BWRG at MEPC 79 concluded, and the Committee endorsed, that this practice
was not prohibited by the Convention, that it was already taking place, and that it should be
permitted provided that guidance be developed to set out appropriate actions and uniform
procedures to ensure compliance with the BWM Convention, and in particular the D-2
standard, when the ballast tanks are returned to ballast water storage.

7 At MEPC 78, it was noted that some flag States provided specific guidance on this
matter to their ships, which could be useful as reference for development of guidance on this
matter. The Bahamas Maritime Authority (BMA) permits the use of ballast tanks as temporary
storage for "treated wastewater", sewage or sewage sludge subject to certain conditions. Such
conditions include that the ballast tank is to be temporarily isolated from the ballast system;
the ballast tank, pipes and pumps are adequately flushed prior to being returned to use for
ballast; the tank is verified gas-free if it is to be entered, and the temporary storage tank shall
not be located in hazardous areas of the ship.

8 At MEPC 78, the Committee also invited interested Member States and international
organizations to submit concrete proposals on additional aspects for guidance on the
temporary storage of treated sewage and grey water in ballast tanks under the
BWM Convention.

9 IACS recalls document MEPC 78/4/13 (India) which highlighted additional issues and
proposed additional measures to resolve the issues raised by IACS in document MEPC 78/4.
India was of the opinion that there is a requirement to provide clear guidance on this issue and

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suggested guidance on the temporary storage of grey water or treated sewage in ballast tanks
be issued as an MEPC circular for existing ships and that amendments to MARPOL Annex IV
be developed to reflect the permission for the temporary storage of grey water and treated
sewage for new ships. Such requirements that should be considered for new ships include
tank coatings, compatibility with treated sewage and grey water, non-contiguous bulkheads
with potable/freshwater tanks, placement of air vents, arrangements of pipelines and valves
both for inflow/outflow and segregation from the ballast system.

10 Document MEPC 79/4/8 (China) indicates that the temporary storage of grey water
and treated sewage in ballast tanks has become a global practice and that this practice is
acceptable provided that the ballast water discharge from the tank is conducted in accordance
with the BWM Convention, while the discharge of the temporarily stored treated sewage in the
ballast water tank should meet the requirements of MARPOL Annex IV, and the discharge of
the stored grey water should meet relevant requirements of the port State, if any.
Further, document MEPC 79/4/8 (China) provides the view that:

.1 For new ships, independent grey water/treated sewage holding tanks should
be provided. However, ships with limited spaces, such as scientific research
and fishing vessels, may have difficulty providing completely independent
grey water/treated sewage holding tanks with adequate capacity. For these
ships, the ballast tanks may be temporarily used as grey water/treated
sewage holding tanks. In this case, the appropriate technical and operational
measures should be conducted to avoid the contamination of ballast tanks.

.2 For existing ships, technical measures should be met as far as possible. If

technical measures are not feasible to be met, isolation means should at
least be met to ensure that the grey water/treated sewage system served to
the dual-purpose ballast tank when used for storage of grey water/treated
sewage is disconnected from the ballast system during navigation.

11 IACS notes document MEPC 79/4/11 (India et al.) in which the co-sponsors are of the
view that temporary storage of treated sewage and grey water in ballast water tanks under the
BWM Convention should be permitted. Using the principles set out in document MEPC 78/4,
the co-sponsors identified some points which would result in difficulties for existing ships in the
implementation, such as physical separation or isolation of the pumps and pipelines from those
of the ballast system. Considering the actual needs for temporary storage of treated
sewage/grey water in ballast tanks at specific ports and areas, the co-sponsors were of the
view that practical ways in addressing this issue should be pursued. In light of this, document
MEPC 79/4/11 (India et al.) provided a draft guidance for the temporary storage of treated
sewage and grey water in ballast water tanks in order to establish a uniform procedure that
minimizes the impact on the environment while ensuring practicability for existing ships.

12 IACS is of the view that temporary storage of grey water and/or treated sewage in the
ballast tanks, although not favoured, could provide an option for existing ships where the
quantities of grey water or treated sewage generated on that ship cannot be stored on board
and local port restrictions do not allow the discharge, based on an adequate justification by the
ship's managers.

13 Since ballast water mixed with grey water or treated sewage could affect the operation
of the ballast water management system (BWMS) and/or the subsequent ballast water
discharge can be considered as non-compliant with the D-2 standard, mixing of grey water
and/or treated sewage into ballast water should be avoided.

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14 IACS recalls that the draft guidance for the temporary storage of treated sewage and
grey water in ballast tanks provided in document MEPC 79/4/11 (India et al.) stated that the
ship is to discharge ballast water in the ballast tank in accordance with the criteria of regulation
D-2 of the BWM Convention and flush the ballast tank in accordance with the procedure of
ballast water exchange plus ballast water treatment (BWE+BWT). In this case, BWE is
required to follow regulation D-1 of the BWM Convention and the 2017 Guidelines (G6)
(resolution MEPC.288(71)). To reduce complexity, IACS is of the opinion that BWE+BWT
should not be included in the guidance and that only one type of water is to be stored in ballast
tanks at a time to prevent mixing of ballast water and treated sewage or grey water. Permanent
pumping and piping systems should be provided for the transfer of treated sewage and/or grey
water and should be separated or isolated physically from those of the ballast system. In case
the BWMS installed is capable of handling such mixture, common pump and piping systems
may be accepted when provided with changeover procedures and an alarm every time the
ballast water management system is bypassed when filling or emptying any ballast tank.

15 Remaining untreated or not fully treated ballast water or sediments in the ballast tank
when used for storage of treated sewage and/or grey water could lead to non-compliant
discharge and increased risk of spreading invasive species. Therefore, untreated or not fully
treated ballast water should be removed before the tank is used for temporary storage of
treated sewage or grey water. Any water used for flushing and which remains in the tank before
it is used for the storage of treated sewage or grey water should meet the D-2 standard.

Proposal

16 In light of the discussion in paragraphs 4 to 15 above, and documents MEPC 79/4/8

and MEPC 79/4/11, IACS has prepared draft technical and operational guidance regarding the
temporary storage of treated sewage and/or grey water in ballast tanks in the annex of this
document taking into consideration the comments from other delegations.

Action requested of the Committee

17 The Committee is invited to consider:

.1 the discussion in paragraphs 4 to 15;

.2 the proposal in paragraph 16 and the draft technical and operational

guidance regarding the temporary storage of treated sewage and/or grey
water in ballast tanks, set out in the annex to this document, with a view to
its issuance as a BWM circular; and

.3 take action, as appropriate.

***

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Annex, page 1

ANNEX

DRAFT GUIDANCE FOR THE TEMPORARY STORAGE OF TREATED SEWAGE AND/OR

GREY WATER IN BALLAST TANKS

Introduction

1 The purpose of this guidance is to provide a procedure for the temporary storage of
treated sewage and/or grey water in ballast tanks.

2 Considering the needs for storage of treated sewage and/or grey water in ballast
tanks, this guidance is developed for establishing a uniform procedure that minimizes the
impact on the environment while ensuring practicability on ships.

Definitions

3 "Treated sewage" means the sewage that is treated by a sewage treatment plant in
accordance with regulation 9.1.1 of MARPOL Annex IV. Treated sewage does not include the
comminuted and disinfected sewage by a sewage comminuting and disinfecting system in
accordance with regulation 9.1.2 of MARPOL Annex IV.

General matters for application

4 New ships should follow future guidelines or the amendment to MARPOL Annex IV,
such as to install a dedicated treated sewage and/or grey water tank(s) within a safe area of
the ship. However, new ships with limited spaces, such as scientific research and fishing
vessels, may have difficulty providing completely independent treated sewage and/or grey
water holding tanks with adequate capacity. For these ships, the ballast tanks may be
temporarily used as treated sewage/grey water holding tanks. In this case, the technical and
operational measures set out in paragraphs 7 to 16 should be conducted to avoid the
contamination of ballast tanks.

5 For existing ships that inevitably must temporarily store treated sewage and/or grey
water in ballast tanks, the technical and operational measures set out in paragraphs 7 to 16
should be conducted to avoid the contamination of ballast tanks.

6 The storage of untreated sewage, including comminuted and disinfected sewage

using a sewage comminuting and disinfecting system in accordance with regulation 9.1.2 of
MARPOL Annex IV, in a ballast tank is not permitted and is outside the scope of this guidance.

Technical and operational measures

7 Permanent pumping and piping systems should be provided for the transfer of treated
sewage/grey water and should be separated or isolated physically from those of the ballast
system to avoid any possible mixing of ballast water and treated sewage or grey water. In case
the BWMS installed is capable of handling such mixture, common pump and piping systems
may be accepted when provided with changeover procedures and an alarm every time the
ballast water management system is bypassed when filling or emptying any ballast tank.

8 Specific operational procedures are to be made available on board addressing the

tank content changeover procedures.

9 The hull strength and stability of the ship should not be compromised.

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10 Such operation and management method of the temporary storage of the grey water
and/or treated water in the ballast tank should be described in the Ballast Water Management
Plan of the ship.

11 To avoid possible spread of live organisms, prior to the transfer of treated

sewage/grey water into the ballast tanks, the ballast tank should be properly emptied using the
BWMS to remove any residual ballast water and sediments as far as practical (with reference
to paragraph 1.3.7 of Guidelines (G4) (resolution MEPC.127(53) as amended by
resolution MEPC.306(73)). If flushing is applied, the water should be ballast water meeting the
D-2 standard or the same water from the same location being used and discharged on the
same location.

12 The ballast tank should be fully emptied to remove any residual treated sewage or
grey water before being used as a ballast tank again.

13 During the period in which the ballast tank is holding treated sewage/grey water, the
Ballast Water Record Book should have an entry with the type of water being stored.
The following items should be recorded in the ship's Ballast Water Record Book as item
number 3.6 (additional operational procedure and general remarks):

.1 date, time and location of change of the use of a ballast tank;

.2 type of water to be stored after the change of use (e.g. treated sewage, grey
water or ballast water); and

.3 implemented procedure for the change of the use of a ballast tank (e.g. after
the discharge of treated ballast water, ballast tank was flushed in accordance
with the procedure described in the BWMP).

14 Special considerations should be made to the tank coatings while storing treated
sewage and grey water to prevent corrosion. Prolonged storage of treated sewage and grey
water and inadequate flushing can cause septic and generate hydrogen sulfide (H2S) gas.
Hence, consideration for location of air pipe outlets at a safe distance from air intakes in service
spaces and accommodation along with tank entry procedures should be provided.

15 The arrangements for the temporary storage of treated sewage or grey water in the
ballast tanks and operations of the discharge of ballast water and treated sewage/grey water
should adhere to the following principles:

.1 the discharge of ballast water and sediments should be in compliance with

the BWM Convention; and

.2 the discharge of treated sewage/grey water should adhere to local

requirements until the amendments of MARPOL Annex IV are revised to
regulate these discharges.

16 When failing to meet the above procedures, the port State, the flag State and the ship
should work together to agree on the most appropriate solution to allow for the discharge of
ballast water found to be non-compliant.

___________

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