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STARBULK S.A.

Safety Management System Manual


Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 1 of 26

Chapter 7.6
PROTECTION OF THE ENVIRONMENT


CONTENTS

7.6. Protection of the environment....................................................................................... 2
7.6.1. General ............................................................................................................................ 2
7.6.2. Purpose ........................................................................................................................... 2
7.6.3. Responsibilities .............................................................................................................. 2
7.6.4. Procedure........................................................................................................................ 3
7.6.4.1. General requirements....................................................................................................... 3
7.6.5. Compliance with the requirements of Annex I of MARPOL 73/78.............................. 4
7.6.5.1. Bunker Tanks Cleaning .................................................................................................... 4
7.6.5.2. Disposal of Oil................................................................................................................... 4
7.6.5.3. Handling of oily mixtures and sludges in the Engine department ..................................... 5
7.6.6. Ballast handling............................................................................................................ 10
7.6.6.1. Purpose .......................................................................................................................... 10
7.6.6.2. Responsibilities............................................................................................................... 10
7.6.6.3. Procedure ....................................................................................................................... 11
7.6.7. Compliance with Annex V of MARPOL 73/78 Garbage management ................... 12
7.6.7.1. Garbage handling ........................................................................................................... 12
7.6.7.2. Disposal of waste to reception facilities .......................................................................... 13
7.6.8. Compliance with Annex IV of MARPOL 73/78 Sewage management ................... 14
7.6.8.1. Purpose .......................................................................................................................... 14
7.6.8.2. Responsibilities............................................................................................................... 14
7.6.8.3. Procedure ....................................................................................................................... 14
7.6.8.4. Sewage treatment plant operation and maintenance ..................................................... 15
7.6.8.5. Sewage Holding Tank..................................................................................................... 15
7.6.9. Measures for the limitation of air pollution MARPOL 73/78 Annex VI .................. 15
7.6.9.1. Purpose .......................................................................................................................... 16
7.6.9.2. Responsibilities............................................................................................................... 16
7.6.9.3. General Procedures........................................................................................................ 16
7.6.9.4. Reduction of NOx emissions .......................................................................................... 16
7.6.9.5. Engine certification and survey requirements................................................................. 18
7.6.9.6. Procedure for engine new installations or replacements ................................................ 19
7.6.9.7. Maintaining the engines according to NOx regulation requirements .............................. 19
7.6.9.8. Reduction of SOx emissions........................................................................................... 19
7.6.9.9. Bunker Handling ............................................................................................................. 21
7.6.9.10. Control of emissions produced by shipboard waste and garbage incineration.............. 21
7.6.9.11. Control of emissions of shipboard Ozone Depleting Substances (ODS)....................... 22
7.6.9.12. Emission free discharge - Funnel smoke....................................................................... 23
7.6.10. Miscellaneous pollution sources ................................................................................ 23
7.6.10.1. Hull or bulkhead failure.................................................................................................. 23
7.6.10.2. Machinery operations .................................................................................................... 23
7.6.10.3. Hull anti fouling systems................................................................................................ 24
7.6.10.4. Saving of fresh water ..................................................................................................... 24
7.6.10.5. Decommissioning / Ship recycling................................................................................. 24
7.6.10.6. Energy conservation policy............................................................................................ 25
7.6.11. Other instructions for the prevention of pollution .................................................... 25
STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 2 of 26

7.6. Protection of the environment

7.6.1. General

The aim of the following procedures is to provide a proactive approach to environmental
management that includes identification of sources of marine and atmospheric pollution, and
measures for the reduction of potential impacts both onboard and ashore.

The Company is voluntary committed in continually improving its environmental performance, by
adopting an Environmental Management System (EMS, which is part of the SMS), by which all
aspects of its activities with significant environmental impact are identified, addressed, and
monitored.

7.6.2. Purpose

To assist the Senior Officers and the shore Management to carry out a full review of the ships
environmental protection capability, in order to identify potential problems before they impact on
the ships operation and on the Companys activities, and to ensure that:
- Interaction of the shipboard activities with the environment is in accordance with the applicable
rules and regulations.
- Shipboard wastes and emissions to the sea, air and land are controlled, monitored and in
accordance with the Companys policies and procedures.
- Environmental objectives and reduction targets to minimise discharge of pollutants are
established.
- Operational controls aiming to achieve the environmental objectives are established,
maintained and monitored.

Moreover, this section provides the minimum environmental requirements which must be complied
with at all times.

7.6.3. Responsibilities

The DPA is responsible to monitor the Companys and vessels compliance with all relevant
requirements and ensuring that all relevant forms are forwarded to the Company at the
recommended intervals and duly kept. He is also responsible to coordinate the Management (and
Environmental) Review Committee meetings and record their results. He is also responsible to
record and monitor the implementation of the Companys Environmental programs.

The Management (and Environmental) Review Committee members are responsible to identify
the environmental impacts of the Companys activities, and propose solutions and action plans so
as to minimise these impacts.

All shore staff, Superintendent Engineers, Port Captains, etc., having routine involvement in
any aspect of the vessels operations, maintenance and repairs shall report to the DPA any
information related to the vessels or crew's inability to comply with the SMS and any other marine
environmental protection requirement. This may include but not be limited to:
- Any information obtained from reviewing, ordering or purchasing lub oils, spare parts ordered
for pollution prevention equipment, equipment having oil to sea interfaces, etc.
STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 3 of 26

- The need for additional cleaning crews.
- The need for machinery space piping replacement, etc.

Furthermore, they are responsible to report information related to environmental releases or
inadequate performance of environmental pollution protection equipment, excessive waste
development and leaking equipment with oil-to-sea interfaces, etc. All notifications, in addition to
any corrective actions taken, will be made to and tracked by the DPA.

The Master is responsible for the proper implementation of this procedure onboard, in cooperation
with the C/E. These procedures also involve all Officers and ratings.

7.6.4. Procedure

The Company has established, implements and maintains the following procedures to
systematically identify and assess all environmental aspects of its ships and shore-based
operations, defined within the scope of the SMS, taking into account planned or new developments
or new or modified activities and services:
- Minimising adverse environmental impacts and waste generation and ensuring the safe and
responsible disposal of wastes.
- Reporting arrangements for all pollution incidents or near-miss occurrences which could have
resulted in pollution.

7.6.4.1. General requirements
All Companys ships are equipped so that they can comply with MARPOL and other applicable
regulations. Additional requirements may be imposed by the National Authority with which the ship
is registered and/or by the Administration within whose territorial jurisdiction is intended to operate.

This section provides details of the Company's minimum requirements which must be complied
with at all times. More specific requirements and information will be found in instructions and
publications which are referred to in this Manual.

1. Sorbent Materials and Tools
During all bunker handling operations, the oil spill response kit, containing sorbent materials,
must be deployed on each side of the ship. Many countries do not allow chemicals to be used in
port areas. Clarification should be sought from the port authorities before utilising these products.

2. Scuppers
Scuppers must be effectively plugged during all bunker handling operations, and at all other times
when in port. In the event of rain, there will inevitably be a build up of water on deck, which will
nearly always have sheen of oil on it, as the result of grease run off from exposed wires, winch
gears, etc. Never let this water builds up to a level where it might flow over the ship side plate. Use
the portable emergency transfer pump or the scupper drain system to transfer the water to a
suitable tank. Where the ship is fitted with a scupper drain system, this must be checked prior to
arrival in port, to ensure that the lines are clear and the valves operate correctly.

Scupper drain system valves must be clearly identified.

3. Emergency preparedness and Oil Spill Response Plan
The Company has made every effort to identify potential emergency situations which have an
adverse impact to life and the environment. As a result, the Company has developed various
STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 4 of 26

contingency plans included in the SMSM which, along with the vessels SOPEP, the non-tank VRP
(as applicable), etc. aim to minimise the impacts of an accident to life and the environment.
All Officers and crewmembers are expected to be familiar with the reporting requirements and with
the duties delineated in these plans.
The Master and the DPA must review these plans regularly in order to verify that they remain
relevant. Should any changes be deemed necessary, the DPA should be advised.

4. Oil spill response drills
The Masters must ensure that the emergency oil spill response drills are held at least every 3
months.

7.6.5. Compliance with the requirements of Annex I of MARPOL 73/78

This section presents instructions concerning:
- The arrangements and operation procedures for handling oily mixtures in the Engine
department, in accordance with the requirements of Annex I of MARPOL.
- The arrangements and procedures for handling oil sludges and bilges.
- The requirements for discharge within and outside of special areas.
- The completion of the Oil Record Book.

The Companys ships must always carry out handling of oil residues and bilge waters according to
the following procedures and in line with the requirements of Annex I of MARPOL. Bilge water
volume may be reduced by the use of the Oil Water Separator (OWS), discharging water with less
than 15ppm into the sea, wherever this is permitted by International and National regulations. In
areas where discharge of bilge water is prohibited, the latter as well as any oil residues
accumulated onboard will be delivered to the port reception facilities. Records of all operations,
including receipts from the shore receiving companies, will be kept together with the ORB.

7.6.5.1. Bunker Tanks Cleaning
Bunker Tanks cleaning must not be carried out within Port limits, unless permission has been
obtained from Port Authorities. It must be carried out in such a manner that prevents emissions of
hydrocarbon vapours to the atmosphere. If tank vapours have to be vented for operational
reasons, then prior to doing so, permission must be obtained from Port Authorities. An entry is to
be recorded in the Bridge logbook of such permission being granted, along with the actual times of
venting.

7.6.5.2. Disposal of Oil
Any discharge overboard shall be in accordance with Annex I of MARPOL and local requirements.
Bilge water from the Engine bilge spaces is transferred to the waste holding tanks or bilge tanks.
The bilges may be discharged at sea only if separated/filtered through the OWS, ensuring an oil
content of 15 ppm or less. The operation of the OWS and incinerator should be in accordance with
the manufacturers instructions.

STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 5 of 26

7.6.5.3. Handling of oily mixtures and sludges in the Engine department

1. Purpose
To describe the way to handle oily mixtures and sludges in the Engine department, so that the
requirements of Annex I, MARPOL 73/78 and National legislation are complied with.

2. Responsibilities
Master: He is jointly responsible with the C/E to apply these instructions, and avoid any illegal
overboard discharges.
C/E: It is his responsibility to adhere to the efficient application of these instructions and inform the
personnel working in the Engine department accordingly. He is responsible for all bilge pumping
operations, and these operations must never be carried out without his personal approval. Written
instructions relating to bilge operations must be drawn up by the C/E. These must be posted in the
Engine department, adjacent to the OWS and in the Engine Control Room (ECR) and must be
signed by all Engine Officers. He is also responsible for properly maintaining the ORB.

3. Terminology
The following terminology is used in order to describe this procedure:
Oily mixtures: It is the quantity of dirty water collected in the Engine department bilges.
Sludges are resulting from the purification of fuel and lubrication oil.
Waste oils:
a. Drain and leakage oil, which means oil resulting from drainages and leakages in machinery
spaces.
b. Dirty oils, which means used lubricating oil.
Sludge tank: It is the tank or tanks used for the collection of oil sludges.
Waste oils tank: It is the tank or tanks used for the collection of waste oils.
Holding tank for the retention of oily mixtures: It is the tank which is going to be used entirely
for the retention of oily mixtures.

Oily mixtures can be handled in two ways:
- Collection of oily mixtures in the holding tank and subsequent discharge to the shore reception
facilities through the standard connection. Collection and discharge is carried out by a
designated bilge pump or by an independent pump used exclusively for that purpose.
- Separation of oily mixtures using the OWS. The supply of equipment is carried out using its
integral pump. The suction of this pump is connected directly to the bilge lines or the holding
tank.
Any discharge of oily mixtures into the sea without the use of the OWS constitutes an
infringement of the requirements of MARPOL.

4. Engine department bilge and sludge management record keeping.
The system of records regarding Engine department bilge and sludge management, and the
persons responsible for record keeping are described in this paragraph. The purpose of the
following records is to facilitate monitoring of the bilge and sludge quantities generated, transferred
and processed onboard as well as the quantities transferred ashore.

STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 6 of 26

4.1. Oil Record Book (Part I)
The identification of all tanks associated with the handling of Engine department bilges must be
listed in the Oil Record Book (ORB), with all the same designations and capacities, as mentioned
in the supplement to the International Oil Pollution Prevention (IOPP) Certificate.

Details of all bunker and Engine department sludge and bilge handling operations must be
recorded in the ORB. Entries shall include the quantity and type of any oily mixture burnt into the
incinerator. It must be noted that entries under code C are weekly at all times, whether at sea or
in port, but never more than once a week, and should only include all sludge tanks mentioned in
the supplement to the IOPP Cert. Cleaning, testing and maintenance of the OWS should also be
reported under code I. It must be ensured at all times that quantities and positions are accurately
entered, where these are required. The ORB constitutes for the Company very significant evidence
in order to ensure that the ship complies with these instructions and the operational requirements
of MARPOL.

The C/E is responsible for maintaining the ORB. Entries shall be made by the C/E in accordance
with the MARPOL requirements and the instructions provided inside the book. All entries shall be
made in ink. Corrections shall be carried out by striking through. The strike through shall not
degrade the readability of the wrong entry. No corrector fluids are allowed. Each page of the ORB
shall be signed by the C/E and the Master.

4.2. Tank soundings
The maximum capacity and the associated sounding and ullage of each tank used for bilge waste
or sludge must be clearly posted in the Engine department or the ECR. If any of these tanks are
fitted with a high level alarm or indicator, then the sounding and capacity at which this alarm or
indicator is activated must be clearly identified.

4.3. Bilge Alarm test log
Engine department bilge alarms weekly tests must be recorded in the form M 027 (see Chapter
10). Each entry must be signed by the certified engineer carrying out the tests.

4.4 Bilge and Sludge receipts
Whenever bilge and sludge quantities are delivered to shore reception facilities, a receipt must be
requested by the Master, stating the date and time of the transfer and the quantities delivered
ashore. These receipts must be kept with the ORB, and may aid the Master in proving that the ship
was not involved in an alleged pollution incident.

5. Procedures for discharge of oil and oily mixtures to the sea

5.1. Discharge of oil and oily mixtures into the sea while the ship is within special areas
Discharge shall be prohibited, except when all the following conditions are satisfied:
- The ship is proceeding en route.
- The oil content of the effluent without dilution does not exceed 15 ppm.
- The oily mixture in the Engine department is being treated through the OWS.
- The OWS is equipped with a stopping device, which will ensure that the discharge is
automatically stopped when the oil content of the effluent, without dilution, exceeds 15ppm.
- Discharge to be duly inserted in the ORB.
Any discharge of oil or oily mixtures into the Antarctic area shall be prohibited.
STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 7 of 26


5.2. Discharge of oil and oily mixtures into the sea outside special areas
Any discharge of oily mixtures into the sea outside of special areas shall be prohibited except when
all following conditions are complied with:
- The ship is proceeding en route.
- The oil content of the effluent without dilution does not exceed 15 ppm.
- The oily mixture in the Engine department is being treated through the OWS.
- Discharge to be duly inserted in the ORB.
Any ship of 10,000 tons GT and above shall be provided with automatically
stopping device in order to discharge oily mixtures outside special areas.

6. Engine department bilge and sludge management

6.1 Bilge main cross-connections
The use of cross connections between the bilge suction piping from Engine department bilge
wells/bilge tanks and the suction of Engine pumps, other than the dedicated bilge pump, is strictly
prohibited.

Connection of the bilge suction piping to the fire, general service, sea water cooling and ballast
pumps via existing permanent piping and valves or via temporary hose connections can facilitate
the overboard discharge of bilge oily water through overboard valves. This is an illegal practice,
equivalent to by-passing the OWS, and it is strictly prohibited.

6.2 Emergency bilge suctions
Dedicated emergency bilge suction valves shall be painted brightly. A brightly colored sign shall be
permanently fixed nearby and read: Emergency Bilge Suction Emergency Use Only.

6.3 Blank & spectacle flanges.
All blank and spectacle flanges isolating the bilge from the sludge system and both from sea water
systems shall be permanently secured.

6.4 Oil to sea interfaces management
Shipboard systems in which lub oil or hydraulic oil is isolated from sea water by a single
diaphragm, tubing or rubber seals are generally included in the oil to sea interface category. In
such machinery there is always a certain risk of lub oil or hydraulic oil leakage to the Engine
department sea water system or directly to sea, in case of damage to the isolating arrangement.

Such systems include oil lubricated stern tubes, bow or stern thrusters, stabilizers, hydraulically
operated controllable pitch propellers, lub oil or hydraulic oil coolers, etc., whereby the leakage of a
sealing component may cause a loss of operating medium into the surrounding waters of the
vessel. Any replenishment of oil into the head tanks, operating systems reservoirs or other
receivers associated with this equipment shall be logged in the Engine logbook, regardless of
quantity. When known, signed explanation of the loss shall be also provided, along with dates and
time.

Routine stern tube lub oil loss must be logged and reported to the DPA immediately. The Company
recognizes that in certain cases, such as leakage from sterntube aft seals, it is difficult or even
impossible to permanently rectify the leakage without taking the ship to a drydock. In such cases,
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Safety Management System Manual
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PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


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and depending on the time interval up to the scheduled drydocking, leakage minimization
measures shall be planned by the C/E, in consultation with the ships Superintendent.

In extreme cases where the leakage cannot be fixed, causes serious breach of MARPOL
regulations and jeopardizes the ships safety, the Companys Management shall take necessary
corrective actions, including the ship stoppage and arrangements for afloat or drydocking repairs.

6.5. Handling of oil sludges
Oil sludges can be discharged to reception facilities through the standard discharge connections.
According to Annex I of MARPOL 73/78, it is forbidden for any piping to and
from sludge tanks to have direct connection overboard.
Therefore, there should be no interconnection between the sludge tank and any bilge pump with a
direct overboard connection. The sludge pump should be independent, suitable for liquids with high
viscosity, and with no interconnection with any other pump or tank. Except from the sludge
discharge to the reception facilities, these are allowed to be burnt in an approved type incinerator
or a suitable combustion boiler.

6.6. Further guidance for operating the OWS
The C/E is to be personally responsible for the operation of the pumping out of Engine department
bilges through the OWS. Delegation of this task can be assigned to another Engineer Officer, only
when the following conditions are met:
- The Engineer Officer is thoroughly conversant with the operation of the equipment, including
the alarms, indications, system line up, layout and functioning of the system.
- The Engineer Officer has understood the relevant requirements of MARPOL and the SMSM.
- The C/E and the Engineer Officer have conducted one to one training.
- At least one operation has been conducted under the supervision of the C/E. After that, an
entry has been made in the Engine logbook to state that The Engineer Officer (name) has
been trained in the operation of handling Engine department residues and associated
systems. He has been found competent to conduct the operation independently.
- The Engineer Officer has understood and signed the C/E's instructions relating to the handling
of bilges.

Bilge water from the Engine department bilge spaces is transferred to the waste holding tanks or
bilge tanks. The bilges may be discharged at sea only if separated / filtered through the OWS,
ensuring an oil content without dilution of 15 ppm or less.

Routine overboard discharges are prohibited except:
- During daylight hours.
- Under the direct supervision of an Engineer Officer.
- Via the appropriate 15 ppm equipment.
- Ship is en-route and proceeding on passage. The automatic stop on the 15 ppm equipment
must be working.
- Ship is more than 12 miles from nearest land.

Prior to commencing the operation:
- The OOBW must be advised and the position of the ship relative to land must be ascertained.
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Safety Management System Manual
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- The OOEW must record the ship's position in the ORB.
- Interlock system (which does not permit starting of the 15 ppm equipment, unless the OOEW
puts the switch to the ON position) if fitted, should be used.
- The OOEW makes sure that the interlock system, if fitted, which prevents the initiation of the
opening of the discharge valve or the operation of other equivalent arrangements before the
OWS is fully operational, is operable.

During the operation of pumping out bilges through the 15 ppm monitor, the following checks are to
be carried out:
- Check for the correct operation of the equipment. If in doubt, stop and investigate.
- Every half hour, effluent sample through the monitor to be visually checked for clarity.
- Relevant entries in the ORB should include the time and date, and be initialled by the Officer in
charge of the bilge operations.
- At least every half hour, the OOBW should check aft for any signs of pollution (oil/soot).

On completion of the operation:
- Stop the pump and secure all valves.
- Inform the OOBW and take the ship's position.
- The OOEW must record the ship's position in the ORB.

The final residues which remain must be incinerated or discharged to a shore reception facility.
The Master shall inform the Company in due time of the need to discharge any waste oil to
reception facilities ashore. Waste oil must be treated as Companys property and its disposal shall
be carefully documented. The C/E is responsible to record any shore disposal process in the ORB.
Additionally, the signed receipt for waste oil disposal is to be attached to the ORB.

It is noted that local regulations may apply in the process of oil mixture disposal. It is the Masters
and C/Es responsibility to be prepared and comply with them accordingly.

Prior to arrival in port, the level in the bilge holding tanks should be lowered in accordance with the
instructions in this section. This is to make space for bilges that may be generated during port stay.
Any pump which can be connected to the bilge piping system and used for the emergency
discharge of the Engine department bilges must be clearly identified. Its starter box must be clearly
marked with the instruction: This pump can only be connected to the bilge system when duly
authorised by the C/E.

All bilge pump overboard valves should be kept closed and sealed with a strip of wire which will
break when the valve is operated. This seal should be clearly marked with a "Do not Operate" tag.
All such valves must be clearly marked with the instruction This valve can only be opened when
duly authorised by the C/E. In addition a placard "Discharge of Oil Prohibited" should be located at
the overboard valve.

The main emergency bilge suction valve must be opened up for inspection and overhauled as
necessary during major repairs period.
ote 1: In an emergency situation, ships staff must be able to pump from the bilges directly
overboard, as provided for by SOLAS and MARPOL. Such overboard valves must be sealed
but not locked.
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Safety Management System Manual
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6. PROTECTION OF THE ENVIRONMENT


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ote 2: Any malfunction and/or operating problem encountered in the OWS should be
immediately reported to the Company.
ote 3: The OWS should never be left operating when the vessel is transmitting from manned
Engine department mode to UMS mode.
On UMS ships, where the bilge pump is operating in automatic mode, the level in the tanks should
be checked during the final inspection of the Engine department each day. There must be sufficient
space for any volume likely to be pumped during the night.

The sample line from the OWS discharge connection to the sample/flush line control valve should
be painted with a bright color, to distinguish it from other tubing and piping in the area. The line
must be routed so it is clearly visible to the extent possible for its entire length.

The Oil Content Meter (OCM) requires a sample flow for a normal operation and control. Any OCM
that allows the OWS to function normally without sample flow is prohibited, unless all valves from
the OWS discharge to the sample / flush line control valve are removed.

Furthermore, in most of the Companys vessels, the OWS is configured to be capable of being fully
operationally tested in port with the overboard valve closed.

Monthly operational tests of the OWS and OCM must be carried out. The C/E must witness and
certify the test by signature in the ORB. The test must document the performance of the OWS and
OCM without dilution at the OWS inlet, storage tank or tricking of the OCM.

The OCM must be calibrated every 3 years. Certificate of calibrations shall be retained onboard the
vessel and a copy shall be kept in the Office.

Cleaning of the OWS in a 6-months basis is also required, and this should be recorded in the ORB.

Cleaning of the OWS source tank and removing of any accumulated oil must be carried out every 3
years.


7.6.6. Ballast handling

In order to ensure that ballasting/deballasting procedures will be carried out according to National
and International requirements, the Company has developed and follows an individual Water
Ballast Management Plan (WBMP) for each vessel.

7.6.6.1. Purpose
To describe the procedures that should be followed during ballasting/deballasting, so that the
safety and environment protection measures are maintained.

7.6.6.2. Responsibilities
Master: It is the Masters responsibility to inform Officers and crew of these instructions and to
ensure their efficient implementation. He is responsible to ensure that the vessels specific WBMP
is properly implemented. He is also responsible to comply with any National requirements of the
ports of calls.

C/O: He is responsible to prepare the ballast plan in co-operation with the Master, and to conduct
all ballast operations, taking into account the stability and stress of the ship. He is also responsible
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for the correct position and operation of the sea and overboard valves. He may delegate their
routine monitoring to the deck W.

The Master and deck officers must be familiar with the procedures for ballast water exchange for
the particular ship, in order to carry out the ballast exchange in an efficient way, while ensuring the
safety of the ship from the longitudinal strength and stability aspect. The Master and deck officers
must also be familiar with:
- the ships ballast pumping and piping arrangements, positions of associated air and sounding
pipes, positions of all compartment and tank suctions and pipelines connecting them to ballast
pumps and, in the case of use of the flow-through method of ballast water exchange, the
openings used for release of water from the top of the tank together with overboard discharge
arrangements;
- the method of ensuring that sounding pipes are clear, and that air pipes and their non-return
devices are in good order;
- the different times required to undertake the various ballast water exchange operations,
including the time to complete individual tanks;
- the method(s) in use for ballast water exchange at sea, if applicable, with particular reference to
required safety precautions;
- the need to continually monitor ballast water exchange operations; and
- the reporting procedures required to be presented to the Port States.

7.6.6.3. Procedure
Ballast operations must always be carried out in accordance with a pre-planned written Plan,
prepared by the C/O and approved by the Master. This Plan must be discussed with and be clearly
understood by all Officers dealing with the operation.
a) Measures before the ballasting procedure
- Control ballast valves/overboard valves in closed position.
- Draining of ballast lines using stripping means.
- Operating pump in low speed. Control of suction pipe to ensure that no positive pressure exists.
- Open sea valve and increase the speed of pump gradually.

b) Measures during the ballasting procedures
- The C/O is responsible to ensure that loading and discharging of ballast is carried out in
compliance with his directions and under the direct supervision of a responsible mate.
- The C/O determines which tanks shall be used for ballast, and the ullage to which ballast is to
be taken on.
- The C/O shall ensure that the valves in the Engine department and on deck are correctly set.
- Watch shall be kept on deck at all times during ballasting.
- The pumping of ballast into a tank shall be carried out with great care and by measuring
ullages, so that an overflow or an overpressure condition will be avoided.
- The tanks should be filled to 98% capacity only, for safety reasons and in order any possible
damage to bulkheads to be avoided.
- Prior to the commencement of ballasting, the ships stresses for intermediate and final ballast
condition will have to be checked using the vessels approved loading instrument.

The following measures must be complied with to prevent any pollution during ballast operations:
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- On vessels over 10 years of age, during major repairs period, a thorough internal and external
examination of the ballast lines is to be carried out where these pass through cargo hold.
- Cargo holds, when possible, are to be checked for water no later than two days prior to arrival
at the loading port, to detect ballast line/bulkhead leak during the ballast passage.
- The (de)ballasting operations should be commenced/re-started in the presence of the OOEW or
the C/O.
- Sea valves must be secured at all times other than when (de)ballasting operation is in progress.

Despite the ballast being clean and pumps and lines properly washed, rust and/or mud often
discolour water lying in pumps and lines for any period of time. On occasions, ships have been
penalised for pollution when discharging such discoloured water. In order to avoid any such
penalty, it is not only necessary to ensure that the ballast water is clean, but also that all pipelines
and pumps are completely free of discoloured water. Deballasting by gravity alone may not
achieve this objective. It is essential that in addition, deballasting be effected for a short period
shortly before arrival at the loading port. This should ensure that all lines and pumps are
completely clean when deballasting starts in port.

c) Ballast water exchange
Ships carrying ballast water are advised to implement precautionary measures to minimize the
translocation of non-native organisms, unless it can be demonstrated that the risk of translocation
of non-native organisms in the ballast water and sediments is minimal. As a minimum,
precautionary measures to minimize the translocation of non-native organisms include:
1. Minimizing the uptake of aquatic organisms, pathogens and sediments during ballasting, by
limiting (or minimizing) ballasting in situations where the numbers of aquatic organisms are likely to
be increased locally. For example:
- In darkness, when bottomdwelling organisms may rise up the water column.
- In very shallow water.
- Where propellers may stir up sediment.
- In areas specified by the port state for avoidance or restriction of ballasting.
2. Monitoring of sediment build up and, where practical, routine cleaning of ballast tanks to remove
sediments.
3. Planning uptake and discharge of ballast water, such that where ballast needs to be taken on
and discharged in the same port, discharge of ballast loaded in another port is to be avoided,
where practicable.


7.6.7. Compliance with Annex V of MARPOL 73/78 Garbage management

The purpose of these instructions is to describe the procedures that should be followed for the
handling and disposal of garbage, in compliance with the requirements of Annex V of MARPOL, as
well as for the disposal of oily waste to reception facilities.

7.6.7.1. Garbage handling
Every ship shall carry a Garbage Management Plan (GMP), which provides instructions for
collecting, segregating, storing, processing and disposing of garbage, including the use of the
equipment on board. The procedures cover all garbage generated during normal ship operation,
including cargo residues and cargo associated wastes, waste oil, paint and painting materials,
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medical wastes, large metal objects such as oil drums and old machinery components, ropes
made of wire synthetic or natural fibre, rust / scale debris, etc.

The Companys policy on this matter is fully aligned with the MARPOL, Annex V requirements and
any applicable National regulations. Separate garbage categories must be stored in separate
containers onboard, and disposal carried out as per the Annex V requirements.

A designated person onboard shall be in charge of carrying the GMP. All crew shall provide
support which is necessary in the collection, separation and processing of the garbage.
Furthermore, display placards are positioned to notify the crew of the disposal requirements
prescribed in Annex V for garbage disposal within and outside special areas.

A Garbage Record Book (GRB) must also be maintained onboard. Each discharge operation or
completed incineration shall be recorded in this Book, and signed on the date of the incineration or
discharge by the Officer on charge. The Master shall sign each completed page of the GRB.

7.6.7.2. Disposal of waste to reception facilities
The Master is responsible for the disposal of oily waste and garbage to reception facilities. In case
of lack or inadequacy of reception facilities, it is under his responsibility to inform the Company and
report to the port authority accordingly.

The C/E is responsible for the disposal of oily mixtures and sludges generated in the Engine
department.

The C/O is the designated person onboard responsible for the disposal of garbage and in charge
of carrying out the GMP. He shall ensure that the procedures within the GMP are implemented,
which include:
- Display placards are positioned to notify all onboard of the disposal requirements prescribed in
Regulations 3 and 5 of Annex V for garbage disposal within and outside special areas.
- The prescribed entries for each discharge operation or completed incineration are made in the
GRB.

All personnel onboard shall provide necessary support in the collection, separation and processing
of garbage, to ensure that the onboard procedures are carried out in accordance with this GMP.
Support staff representatives from Deck, Engine and catering departments are the Bosun, 2
nd

Engineer and Chief Cook/Steward respectively.

Where disposal of garbage to shore facilities or to other ship is required, a signed receipt with the
estimate amount of the garbage transferred should be received and kept together with the GRB.

As far as the disposal of Oily Waste, the following guidance is applied:
- The C/E will decide for the disposal of oily mixtures and sludges generated in the Engine
department, taking into account the capacity of relevant tanks and the daily generation of oily
mixtures-sludges.
- The disposal of oily waste is carried out from the relevant tanks (holding tank and sludge tank)
and never directly from the bilge well. Only in cases that the ship is under repair, the disposal
directly from the bilge well may be permitted.
- The disposal shall take place only through the international standard connections.
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- The disposal of oily waste shall take place only to authorised reception facilities. The disposal is
to be carefully documented, with signed receipts obtained from the person responsible of the
reception facilities. The signed receipt is to be attached to the relevant page in the ORB.
- The use of hoses with a direct suction from the relevant tanks is not permitted.


7.6.8. Compliance with Annex IV of MARPOL 73/78 Sewage management

Sewage from ships shall be treated and disposed in accordance with the provisions of MARPOL,
Annex IV. The Companys vessels sewage discharge equipment and procedures are in full
compliance with Annex IV and any applicable National requirements.

7.6.8.1. Purpose
To describe the procedures for sewage treatment that should be followed.

7.6.8.2. Responsibilities
Master: It is his responsibility to ensure that the sewage treatment is performed in accordance with
these instructions. He is also responsible to comply with the criteria defined in Annex IV referring to
the discharge of sewage into the sea.

The C/E is responsible for the efficient operation and maintenanace of the sewage treatment plan,
as per makers instructions.

7.6.8.3. Procedure
Sewage refers to:
- Drainage and other wastes from any form of toilets, urinals and WC scuppers.
- Drainage from medical premises via wash basins, wash tubs and scuppers.
- Other waste waters, when mixed with the drainages defined above.

Sewage can only be discharged into the sea if the Sewage Teatment Plant is in use. In case of
Plant failure, sewage must be retained onboard and collected in the Sewage Holding Tank, and
only discharged to sea if the ship is more than 12 miles from the nearest land, and ships speed is
consistent with the discharge rate that has been approved by the Administration. The maximum
permissible discharge rate must be 1/200,000 (or one 200,000th part) of swept volume (ships
breadth x draft x distance travelled), as follows:

DR
max
= 0.00926 V D B
Where:
DRmax is maximum permissible discharge rate (m3/h)
V is ships average speed (knots) over the period
D is the vessels Draft (m)
B is the vessels Breadth (m)

The maximum permissible discharge rate specified above refers to the average rate as calculated
over any 24 hour period, or the period of discharge if that is less, and may be exceeded by no
more that 20% when measured on an hourly basis.

According to some National requirements, the discharge of sewage is not allowed when the ship is
in their port or within their territorial waters. In this case, National regulations shall be followed.
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When the sewage is mixed with wastes or waste water having different discharge requirements,
the more stringent requirement shall apply. MARPOL Annex IV, Reg. 8 stipulates the provisions for
discharge of sewage into the sea.

To enable pipes of reception to be connected with the ships discharge pipeline, both shall be fitted
with a standard discharge connection, in accordance with Reg. 11.

The following table summarises the MARPOL requirements concerning discharges of sewage:

Requirements for Sewage Discharge
SEWAGE STATUS
DISTANCE
FROMLAND
SHIPS SPEED
DISCHARGE POSSIBILITY OR
CAPACITY
Sewage not comminuted or
disinfected from a holding tank
12 miles
>4knots
(Moderate rate)
Approved by Vessels Flag State
Sewage comminuted and
disinfected from a holding tank
3 miles >4knots Approved by Vessels Flag State
From holding tank and a sewage
approved treatment plant
No restrictions No restrictions No restrictions

7.6.8.4. Sewage treatment plant operation and maintenance
The sewage treatment plant must be operated and maintained according to the manufacturers
instructions. Records of maintenance and/or repair are to be maintained. The manufacturers
restriction on materials which may be disposed of throught the sewage treatment system are to be
clearly displayed at each input point. The disinfectant dosing points must be readily accessible.

7.6.8.5. Sewage Holding Tank
In case the vessel is equipped with a sewage holding tank in lieu of the treatment plant, the former
must be of sufficient capacity to hold the generated black and/or grey water for the maximum time
the vessel is normally expected to sail within the limits where discharge is prohibited.

The holding tank must be equipped with a high level alarm and flushing line or other equipment,
according to the requirements of the vessels Flag State. The tank must also be connected with a
pump capable of delivering the tank contents to a shore connection, and subsequently to shore
reception facilities.

The C/E must keep records of discharge at sea operations and the receipts for discharging to
shore facilities.

7.6.9. Measures for the limitation of air pollution MARPOL 73/78 Annex VI

The Company has developed a proactive approach to environmental management that includes
the systematic identification and assessment of all sources of marine and atmospheric pollution
and measures for the reduction of potential impacts. These sources include aerial emissions (NOx,
SOx), garbage incineration exhaust, etc.

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All ships are required to minimise pollution to the atmosphere. The scope of these procedures is to
ensure that all effluents shall be within permitted levels (refer to MARPOL and National/regional
limitations e.g. EU or US limits).

7.6.9.1. Purpose
To describe the procedures that should be followed for the control of aerial emissions and the
limitation of air pollution.
7.6.9.2. Responsibilities
The C/E is responsible for the proper maintenance of main engines and auxiliary machinery
equipment in order to improve their performance and therefore to reduce air pollution. He is also
responsible to train the Engine personnel on the proper operation and maintenance procedures for
diesel engines with an output subject to MARPOL Annex VI regulations. Shipboard incinerators are
also subject to this Annex.

7.6.9.3. General Procedures
The Company is aware of the importance, from the financial and environmental point of view, to
reduce as far as possible the fuel consumption of ships. The Engineers should closely monitor the
engine exhaust by ensuring:
- Optimum burn of fuels.
- The vessels plant is operated to minimise emission of smoke.
For that purpose the following should be complied with:
- All internal combustion engines should be made to function, as far as possible, under a load
corresponding to peak efficiency.
- Before leaving the port for a new voyage, the Master should define the speed so that
unnecessary fuel consumption will be avoided.
- The C/E shall monitor the performance of the main and auxiliary engines and make all
necessary adjustments so as to minimise their emissions to the air.
- For each voyage, the Technical Department should calculate the fuel consumption and
compare the new values with the old ones, in order to ascertain the possible need for hull
cleaning.
- Soot blowing should be done prior arrival and avoided in port.
- When initially starting the main engine, a watch should be kept and the Engine department
notified if smoke or sparks are evident.
- If an occasion arises where an unavoidable emission of dark smoke is foreseen, prior notice
should be given to the Port Authorities, whenever possible.

7.6.9.4. Reduction of NOx emissions
The purpose of these procedures is to ensure compliance with MARPOL Annex VI, Reg. 13
(hereinafter called the NOx regulation), regarding the operation of the diesel engines onboard
vessels. All vessels with engines installed onboard on or after 1/1/2000 with power output more
than 130kW have to comply with the NOx regulation. This regulation applies also on older engines,
installed onboard prior to 1/1/2000, but which undergo a major conversion after this date. A major
conversion is any conversion involving modification of engine systems and components that affect
the engines NOx emissions, or increase the engine MCR more than 10%.

These requirements do not apply to engines installed onboard and used solely in case of an
emergency (emergency generator, lifeboat engines, etc). For engines affected by the NOx
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regulation, there are NOx emission limits imposed, calculated as the total weighed emission of
NOx, dependent on the engine crankshaft RPM, as follows:
- 17.0 g/kWh when RPM are less than 130.
- 45.0 x n(-0.2) g/kWh, when RPM are between 130 and 2000.
- 9.8 g/kWh, when RPM are more than 2000.
Engine components affecting NOx emissions are engine dependent, however common
components included are the following:

1. Components and settings that affect the compression ratio and/or the combustion chamber:
- Connecting rods, piston rods.
- Piston skirts and crowns.
- Cylinder Heads and seams between the head and the engine body.
- Piston travel.

2. Components and settings that affect the injection:
- Fuel Pumps and pressure settings.
- Fuel Injectors, their Nozzles and injection pressure settings.

3. Components that affect the engine timing:
- Inlet and Exhaust valve cams and their positioning.
- Fuel pump cams and their positioning.

4. Components that affect the charge air:
- Turbocharger and all main internal components (compressor and turbine, nozzle ring, etc).
- Charge air cooler.
- Auxiliary Blower.

5. Equipment added to the engine for implementing various NOx reduction techniques:
- Water Injection type.
- Emulsified Fuel type.
- Exhaust gas recirculation type.

Such additional equipment, if fitted must:
- Be arranged so that failure will not prevent continued and safe operation of the engine.
- Be operated in accordance with the manufacturers instructions.
- Provide easy access for their inspection and maintenance.
- Be instrumented to record and maintain significant exhaust gas parameters regarding NOx
emissions.
- Be maintained regularly according to the manufacturers instructions. Essential components
maintenance intervals must be incorporated to the PMS to ensure regular monitoring.

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7.6.9.5. Engine certification and survey requirements
Each engine installed onboard after the 1/1/2000, and required to comply with the NOx Technical
Code, shall be certified by an Engine International Air Pollution Prevention Certificate (EIAPP),
issued by the ships Class or the Flag Administration, and provided by the engine manufacturer.

This Certificate is a statement of compliance supplemented by the engine Technical File, which is
also provided by the manufacturer and approved by the ships Class or the Flag Administration.
The engine Technical File contains the identification of all originally installed components and
settings which affect NOx emissions. The Technical File for all engines affected by MARPOL
Annex VI Reg.13, must remain onboard the vessel throughout their operating life.

Whenever engine components or settings mentioned in the Technical File are replaced or
adjusted, this action including spares particulars and settings values must be recorded in the
Record Book of Engine Parameters, attached to the engine Technical File.

Each vessel is also provided with an International Air Pollution Prevention Certificate (IAPP), which
remains valid only if the engine compliance with NOx regulation is validated at every IAPP survey.
The vessels IAPP Certificate is endorsed at special (quadrennial), intermediate (2.5 years) and
annual surveys. To ensure engines compliance with the NOx regulation, an inspection method is
employed by the Class surveyors, as prescribed in the NOx Technical Code. The method
employed is the Engine Parameter Check method, which is based on checking the following:
- The EIAPP certificate is available for each engine.
- The engine NOx emission affecting components, as detailed in the Technical File, are
maintained in good condition.
- Components replacement complies with the Technical File requirements and is recorded in the
Record Book of Engine Parameters.
- The engine settings affecting NOx emissions are maintained within the limits detailed in the
Technical File, and any adjustments are recorded in the Record Book of Engine Parameters.
- Inspection of engine components is included in the Technical File, as per the Onboard
Verification Procedure attached to the Technical File. This means that engine stripping down
will be required to the extent prescribed by the Onboard Verification Procedure and the
surveyors requirements.

Since the Engine Parameter Check is an indirect method (as opposed to direct methods which
involve direct measurements of engine NOx emissions during operation), the surveyor will
supplement it by examining the following:
- Engine logbook parameter records (mainly exhaust gas temperatures, but also fuel, lub oil,
cooling water and charge air temperatures and pressures).
- Records / diagrams of compression and combustion pressures.

To summarize, each engine subject to the NOx regulation must comply with the emission limits
imposed throughout the operating life. Therefore engine components and settings, prescribed in
the Technical File, cannot be arbitrarily changed during maintenance. Any changes to components
and/or settings shall conform to the specifications of the engines approved Technical File, to
ensure continuous compliance of the engine emissions with the NOx regulation limits.

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7.6.9.6. Procedure for engine new installations or replacements
The following procedures present the basic steps to be followed for ensuring compliance with the
NOx regulation, when new engines are installed onboard, or existing engines arer completely
replaced by other units:
- Assess if the engine characteristics (power, RPM, intended duty) fall within the NOx emissions
requirements. Remember that the NOx regulation applies to engines more than 130kW, which
are not solely used in emergency situations.
- During the engine selection process ensure that the manufacturer provides the EIAPP
Certificate for the models considered.
- Verify that the engine will comply with the NOx regulation when delivered, without the need for
modification or installation of additional components or systems at a later stage.
- Verify that the EIAPP provided is acceptable by the vessels Class Society.
- During the final installation process verify that the components installed correspond to the
specifications presented in the Technical File. Correct components can be identified by the ID
numbers carved on them and written in the Technical File. These shall be identical.

7.6.9.7. Maintaining the engines according to NOx regulation requirements
Since the engine compliance is verified according to the Engine Parameter Check method, it shall
be ensured that engine components and settings comply with the Technical File prescription. This
is the condition that must be satisfied and that indirectly guarantees the engine compliance with the
NOx emission limits.
- The C/E must ensure that operational parameters logged at regular intervals (temperatures
and pressures) are within the manufacturers specified limits. Whenever sudden changes
arise, he must identify the cause of the change and rectify the malfunctions. In case of a
complicated problem he must inform the Company and ask for external assistance. Basic
critical parameters indicating deviations from normal operation are exhaust gas temperatures,
charge air temperature and pressure, compression and combustion pressures.
- Whenever replacement of components specified in the Technical File is carried out, the C/E
must ensure that original components are used and their ID numbers recorded in the Record
Book of Engine Parameters. In case of component repair or maintenance, the C/E must
ensure that the manufacturers instructions are followed and the final calibration of
components is within specified range. Every intervention to components specified in the
Technical File must be recorded to the Record Book of Engine Parameters.
- Whenever adjustments are carried out to engine settings specified in the Technical File, the
C/E must ensure that these are within the specified range and recorded in the Record Book of
Engine Parameters.
- The engines Technical File and the EIAPP must always be onboard and maintained in an
excellent condition.

Any changes recorded in the engine logbook parameters must be signed by the responsible
workshop representative or the C/E, as applicable.

7.6.9.8. Reduction of SOx emissions
The purpose of these procedures is to ensure that vessels operations will fully comply with the
MARPOL Annex VI requirements regarding SOx emissions, both inside and outside SOx Emission
Control Areas (SECAs).

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The fuel oil received and consumed must satisfy the Annex VI maximum sulphur content limit of
4.5%. The C/E should ensure this by verifying that the sulphur content is written on the Bunker
Delivery Note (BDN), and that it is not above the limit stated.

In case the vessel trading patterns include SOx Emission Control Areas (SECAs), then the vessel
must be provided with 1.5% sulphur content, in addition to the normal sulphur content fuel oil.
The low sulphur fuel oil must be stored in the separate bunker tank(s) designated for this purpose.
Under no circumstances should the low sulphur fuel be stored or mixed in a normal 4.5% fuel
bunker tank.

Low sulphur fuel oil quantities will be subject to inspection by the port authorities. The latter, by
checking the low sulphur fuel available onboard, and comparing this with the entries in the
rerlevant Companys Logs and the BDN(s), will try to verify whether only low sulphur fuel has been
consumed while the vessel sails within the SECAs.

Prior to entering a SECA, the vessel must begin a fuel oil change over procedure from the normal
sulphur to low sulphur fuel oil burning. The change over procedure must be commenced enough
time prior to entering the SECA, to ensure that upon crossing the SECA border the fuel oil system
of the main engine and/or diesel generators has been fully flushed with the low sulphur fuel, i.e.
that low sulphur fuel is already at the engines injectors. The time required for fully flushing the fuel
system depends upon several parameters, which are mentioned below:
- The existence of separate service and settling tanks for low and normal sulphur fuel.
- The volume of the service and settling tank, in case these are common for the two fuel types.
- The existence of separate purifiers, heaters, etc. for the two fuel types.
- Requirements for gradual adjustments of the F.O. temperature and viscosity, if applicable.

In general, the less the segregation of the two fuel oil systems between the bunker tanks and the
diesel engines fuel pumps, the greater will be the time interval required for the change over. It is
the responsibility of the C/E to assess the time interval required, in order to ensure that upon
crossing the SECA border, the low sulphur fuel will be already present at the engine injectors.

In case of a common system of fuel oil service and settling tanks, the C/E must assess the time for
transfer to the settling tank, settling and purification of low sulphur fuel and then transfer to the
service tank. The service tank must have the minimum allowable quantity of normal sulphur fuel at
the time of low sulphur purified oil transfer. Then he must assess (depending on the engine
consumption rate) the additional time required to fully flush the fuel system from the service tank
suction to the engine injectors, including the time for the consumption of the small quantity of
mixed low and normal sulphur fuel in the service tank. The time for temperature and viscosity
adjustments must be also considered.

In case the settling and service tanks are designed for daily consumption, it is expected that the
transfer and filling of low sulphur fuel to the settling tank will have to be carried out at least 24
hours prior to entry in the SECA.

Appropriate fuel temperature adjustment to the specified viscosity and changes to the cylinder oil
consumption in case of 2-stroke engines will also have to be done to compensate for the reduction
of combustion gas sulphuric acid. For these procedures the engine manufacturers instructions
must be consulted.

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Records of the change-over operation must be kept onboard when entering and leaving the SECA,
and will be subject to inspection by the PSC authorities and Class Surveyors. The change-over
time and the position and the volume of low sulphur bunkers in each tank available onboard at the
time the change-over procedure is completed must be recorded. Regarding the volume of low
sulphur fuel in bunker tanks, the corrected volume at 15
0
C must be recorded at all times, so that
the measurements are consistent and easily compared.

The above records should be kept in an official logbook prescribed by the Flag Administration,
otherwise the Companys forms (see Chapter 7.4) should be used for logging the information
required. Reference of the change over procedure should be also made in the Engine logbook.

The Company strictly monitors the quality of bunkers by engaging an independent recognized
organization, providing petroleum analysis services, to collect samples and conduct chemical
analysis. As regards the check of fuel oil sulphur content, the recognized organization should
preferably use the ISO 8754 test method or an equivalent national standard.

7.6.9.9. Bunker Handling
- All personnel engaged in Bunkering operations must wear personal H
2
S monitors when
outside accommodation block.
- When H
2
S content on deck exceeds 5 ppm, CABA must be worn.
- The max. level of H
2
S acceptable in bunkers is 100 ppm in vapour space in shore tanks.
Arrangements have been made in certain ports to pre-analyse the H
2
S level in vapour space
in shore tanks.
- n completion of bunkering, the vessels are to measure H
2
S in vapour space. If it exceeds 5
ppm, then the ships Superintendent must be informed.
- If bunkers are loaded on top, the vapour space must be tested for H
2
S before and after loading
bunkers.

7.6.9.10. Control of emissions produced by shipboard waste and garbage incineration
The purpose of these procedures is to provide guidance to the shipboard personnel to ensure that
the requirements of MARPOL Annex VI, Reg. 18 are complied with. For detailed information on the
maintenance and proper and safe use of the shipboard incinerator, reference to the equipment
manufacturers instructions should be made. Incineration of the following substances is strictly
prohibited for avoiding the pollution of air:
- Polychlorinated biphenyls (PCBs) which are mainly liquid substances used as coolants and
lubricators in electrical apparatus like transformers. Trade names are Aroclor (USA), Clophen
(Germany) and Kanechlor (Japan).
- Garbage as per Annex V of MARPOL, when containing more than traces of heavy metals.
- Polyvinyl Chlorides (PVCs), unless the incinerator is IMO type approved for burning these
category of substances. Check that the incinerator Certificate states approval as per the
MEPC 59(33) or MEPC 76(40) specifications prior to processing PVCs.

Shipboard incineration of sewage and oil sludge is permitted, but shall not take place in ports,
harbours and estuaries. Incineration of these substances is permitted also in the power plant and
boilers, if suitably equipped. Shipboard incineration is only allowed in Class approved incinerators
specially built for the type(s) of waste intended to be incinerated.

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6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 22 of 26

Shipboard incinerator operation must strictly follow the manufacturers procedures. The persons
responsible for the operation must be trained and records of the training must be kept.

Regarding documentation to be kept onboard for shipboard incinerator operation, the following
should be recorded in the Garbage Record Book:
- Incineration operations documentation (date and time of starting/stopping of the operation,
position of vessel, type and amount of garbage in m3).
- Exhaust gas temperature of incinerator should also be monitored and recorded, together with
the amount of garbage. According to Annex VI operating limits, flue gas temperature should be
between 850 and 1200
0
C.

7.6.9.11. Control of emissions of shipboard Ozone Depleting Substances (ODS)
The following procedures provide guidance for handling and maintaining equipment that contain
ODS, in accordance with the requirements of MARPOL Annex VI, Reg. 12.
During installation, maintenance and final disposal of equipment containing ODS, the deliberate
emission of these substances to the air is strictly prohibited. ODS must be recovered and disposed
to appropriate shore reception facilities for further treatment. ODS commonly encountered onboard
ships (as refrigerants or fire fighting substances) include the following:
- Halons 1211, 1301, 2402.
- CFC 11, 12, 113, 114, 115.
- HCFC 21, 22, 31, 122, 123.
The use of CFCs and Halons onboard the ship is prohibited. Halons are prohibited both for
refrigerant and fire fighting applications. Use of HCFCs in existing installations is permitted until
1/1/2020. However, there are more substances subject to restriction of emissions to the
atmosphere. Therefore, in case of maintenance by the shipboard personnel, if in doubt that a
substance is subject to emission restrictions, the C/E must contact the Company for advice.
Equipment containing ODS include but may not be limited to the following:
- Central provision refrigeration units.
- Central air conditioning systems.
- Accommodation local refrigerator and air conditioning appliances.

During maintenance and disposal of central refrigeration and air conditioning equipment
components by external workshop teams, the latter must use appropriate equipment for recovering
the refrigerant. The refrigeration system should ideally be designed so that the compressor may be
used for collecting the refrigerant into an existing liquid receiver. Alternatively, recovery units may
be used, evacuating the refrigerant into cylinders dedicated for this purpose.

In case the maintenance needs to be done by the shipboard personnel, the C/E must ensure the
recovery of the refrigerant and, as far as practicable, not allow emissions to the atmosphere. The
refrigerant can be collected in the condenser by closing the condenser discharge valve and
operating the compressor until stopping by low suction trip.

The annual refrigerant leakage rate for each refrigerant system must be lower than 10% of the total
charge. For monitoring purposes, records must be maintained covering:
- Refrigerant quantities added to each system.
STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 23 of 26

- Refrigerant leak incidents, including remedial actions.
- Recovered refrigerants quantities and storage or disposal details (shore company details, etc).
- In case of disposal of the installation, the recovered refrigerant should be transferred by
special equipment to special containers, both provided by shore disposal companies.
- During disposal of household air conditioning units, these must be dismantled by personnel
provided by shore companies, having the special equipment required for the recovery of the
ODS refrigerants.
- Disposal of appliances that do not require special dismantling, like household refrigerators,
must be done to shore reception facilities without any deliberate or accidental dismantling or
damage to the refrigerant system, at least until these leave the vessel.
The Technical Department must closely monitor and restrict the vessel orders for refrigerants, and
ensure the provision of all necessary technical support and equipment to the vessel, as this is
required for minimizing ODS emissions.

7.6.9.12. Emission free discharge - Funnel smoke
In many ports, the discharge of smoke from the funnel is prohibited. All plant machinery must be
operated so as to minimise this type of emission. Crew members should immediately inform the
deck OOW and the Engine department if smoke is noticed coming out from the funnel, and
immediate action must be taken to rectify the situation.

7.6.10. Miscellaneous pollution sources

7.6.10.1. Hull or bulkhead failure
During bunker operations all personnel should regularly monitor the water alongside the ship for
any indication of hull leaks.

Whilst at sea, the OOBW should monitor the sea astern of the ship for any indication of hull leaks.
Particular attention should be paid to this requirement during and after periods of heavy weather.

During all loaded and ballast passages, all empty spaces must be sounded on a daily basis in
order to detect any internal leaks at an early stage.

Every opportunity should be taken, either when alongside a jetty or from boats, to visually examine
the external hull for any sign of leaks or potential defects.

7.6.10.2. Machinery operations
It is not just the E/R bilge handling which have the potential to cause oil pollution. Routine
machinery operations can also cause pollution. The concept of slight pollution is unacceptable.
Obviously, all ships are different and it is not possible to mention every item or equipment.
However, the following problems might arise on most of the ships:
- Many coolers or heat exchangers, particularly those cooling lub oil, would cause pollution, if
there is any internal leakage of lub oil into the water stream.
- Stern tubes are always a potential source of pollution as a result of lub oil leakage.
- Poor combustion in the boilers could result in pollution via the blow-down system.
- Cylinder liner leakage could result in contamination of the main engine and diesel generator
cooling systems.

STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 24 of 26

This list is not comprehensive. Engine department staff should be thoroughly familiar with all
machinery, and should be alert to the possibility of oil pollution in the event of any internal
equipment or system failures. Close monitoring of all such equipment and systems are essential, if
any such leakage is to be detected.

Any unusual consumption of lubricating or bunker oils must be investigated immediately.
Anticipated or metered usage should be compared against measurements based upon tank
soundings, in order to identify abnormal usage.

7.6.10.3. Hull anti fouling systems
Anti-fouling paint is applied to the hull in order to prevent the build up of marine growth, which
would otherwise reduce the speed of the ship and increase the fuel consumption. Certain types of
anti-fouling paints that include tri-butyl-tin (TBT) compounds can create adverse impacts on the
marine environment and human health. TBT or Tri-Butyl-Tins or Tri-organotins are chemical
compounds, containing at least 3 bonds between carbon and tin. These paints slowly leach out
organotin compounds, which act as biocides against certain marine organisms.

Vessels will therefore need proof of compliance and this will be in the form of an International Anti-
Fouling System Certificate. These certificates will be issued by the Flag Administration or an
Organisation duly authorised by it. In addition, the Flag Administration will require a Declaration
signed by the Owner/Manager, stating that the coating is compliant with the International Anti-
Fouling Convention, along with the types of coating and the date of application.

A Deck Officer should be responsible for supervision of the hull and underwater painting. Painting
shall be carried out in accordance with the suppliers' suggestions and recommended painting
schemes. Areas requiring blasting are decided by the attending Superintendent. Particular
attention should be paid to the following:
- Environmental conditions (especially important prior to first primer coating application).
- Proper thickness of successive coatings.
- Application of antifouling paint at a proper time prior to undocking.
- No antifouling paint shall be admitted without -Free antifouling Certificate issued or
approved by the vessels Class.

7.6.10.4. Saving of fresh water
Saving of FW may be achieved in both individual and technological basis. Saving in individual
basis consists of:
- Avoiding of any useless flow relating to each ones competent duties (i.e. turning off the hose
supply when cleaning deck and windscreens on any job pause).
- Avoiding of any useless flow relating to each ones personal consumption (i.e. turning off the
supply when brushing teeth and turning on for rinsing out tooth-brush).
Saving in technological basis consists of:
- Upgrading existing energy consumption practices.
- Attempting to utilize any thermal losses, aiming to spare energy for desalting processes
(osmosis systems and boilers).

7.6.10.5. Decommissioning / Ship recycling
Eventually, a ship will come to the end of her economical service and will require being
decommissioned. In general, ships are not scrapped but are recycled, and in this process, almost
STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 25 of 26

nothing goes to waste. Steel is reprocessed, generators are reused ashore, batteries find their way
into the local economy, oils onboard become reclaimed oil products for use in rolling mills and
fittings can be reused on land. Recycling makes a positive contribution to the global conservation
of energy and resources.

7.6.10.6. Energy conservation policy
The Company recognises that the burning of fossil fuels, such as diesel and heavy fuel oil, can
result in many environmental impacts. When fuel is combusted, pollutants such as the oxides of
Carbon, Nitrogen and Sulphur are emitted to the atmosphere. These can contribute to the effects
of greenhouse gases and acid rain. The Company is committed to environmental training and
awareness including energy conservation. The prime way in reducing the effects of the above
emissions is to efficiently control and conserve energy, wherever possible. This can be done by
ensuring that:
- The main and auxiliary engines are operated according to the manufacturers instructions.
- The main and auxiliary engines are properly maintained, as per the manufacturers instructions
and the vessels PMS.
- Funnel exhaust is correctly monitored, to ensure efficient combustion.
- Speed is correctly adjusted to avoid excess fuel consumption, whilst staying within the
parameters of the charterers requirements for speed and ETAs.
- Speed is reduced in heavy weather, to avoid excess pounding and consumption.
- The automatic pilot is correctly adjusted, to avoid frequent and excess helm movements.
- The condition of the ships bottom is regularly inspected for signs of fouling or damage to
coating.
- The condition of the ships propeller is regularly inspected for signs of damage.
- Ancillary systems, including lighting, ventilation systems, galley ranges, steam supplies, etc.
are turned off when not required.


7.6.11. Other instructions for the prevention of pollution

There is a number of other sources of oil pollution, many of which individual action can address
successfully.

Oily or greasy rags or other such material must always be placed in a container for incineration or
disposal ashore, and must NEVER be thrown overboard.

When draining or collecting waste oil from any equipment, it must always be returned to a
designated tank or container for later disposal. It must NEVER be disposed off overboard and must
NEVER be flushed down in toilets or sinks.

Never over grease or over lubricate machinery, particularly deck machinery, as the excess will
simply run off and be a potential source of pollution.

Residues removed from a bunker tank prior to repairs must NEVER be disposed off overboard.
They must be stored in drums onboard for later return to the tank or disposal to a shore reception
facility. This applies equally to the small amounts accumulated during onboard repairs, or the large
volumes collected prior to shipyard repairs.

Hydraulic oil can cause pollution and personnel must be alert to the possibility of leaks.

STARBULK S.A.
Safety Management System Manual
Chapt er 7
PLANS ANDINSTRUCTIONS FOR KEY SHIPBOARDOPERATIONS
6. PROTECTION OF THE ENVIRONMENT


Issue No. / Date: 2 / 18.01.09 Revision No. / Date: 0 / 18.01.09 Page 26 of 26

Whenever machinery oil is changed, e.g. winch gear case oil, the old oil must be pumped into a
drum or container and must never be discharged into the sea. Whenever any maintenance is being
carried out, which might result in the spillage or release of oil, always ensure that sorbent materials
are readily available. Spilled oil should always be cleaned up immediately.

When in port or at anchor, the area in the vicinity of the ship should be carefully monitored for signs
of oil on the water, which might drift towards the ship. In such cases, the local authorities should be
advised, and an appropriate entry made in the Bridge logbook. Similar action should be taken if
signs of oil are encountered during coastal passages, river transits, etc.