1. Page 1 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
A Presentation at MEPC68, IMO Headquarters, London, May 2015
Co-sponsored by FOEI and WWF
Dr Wei Chen, Wartsila Water Systems Ltd
MARINE WASTEWATER POLLUTION:
- CONFRONTING GREY WATER
- IMPLEMENTING ANNEX IV EFFECTIVELY

2. Page 2 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
CONFRONTING GREY WATER

3. Page 3 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Grey Water – What Is It?
‘Grey water means drainage from dishwater, shower,
laundry, bath and washbasin drains…’ MECP.227(64)
Galley
grey water
Laundry
grey water
Sanitary
grey water
Overboard
Black
water
Sewage Treatment Plant
Collection
system
Overboard
Very simplified black & grey
water systems on-board a ship.

4. Page 4 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Grey Water Characteristics
Parameters
MEPC159(55)
standards
Faecal coliform
(MPN/100ml)
100
BOD5 (mg/l) 25
COD (mg/l) 125
TSS (mg/l) 35
US EPA (2008), Cruise Ship Discharge Assessment Report.
Sanitary
grey water
Laundry
grey water
Galley
grey water
37,000,000 80,000 29,000,000
260 84 1,490
723 257 1,830
207 37 877

5. Page 5 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Greater Environmental Impact Than Sewage
Black water Grey water
AmountofBOD5
Grey water also has:
 Grease, oil and fat
 Food particles
 High/low pH
 Spreading agent
Design loading rates (Meyer Werft, 2012)
Grey water has higher flow

6. Page 6 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Proactive Steps Taken by Many
 Land: widely regulated over the world,
across all industry sectors, for decades...
 Marine: regional rules
 Technologies available
 Greener class notations
 Ship owners’ - led by the cruise sector
 Alaska 33CFR159 subpart E
 US waters EPA Vessel General Permit (2013)
 European Inland Waterways 2012/49/EU
 No Discharge Zones (Great Barrier Reef, etc.)

7. Page 7 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Challenges
 Image
 Moving away from universal rule.
 NDZ – holding vs. solutions on-board
 Impact to BWM MEPC63/2/18, MEPC 64/7/7
 No guidelines led to violations.
Effluent
STP
Untreated
grey water
Black water
Sewage Treatment Plant
X

8. Page 8 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Confronting Grey Water
Should grey water be regulated?
 To address a major pollution source.
 To address concerns in sensitive areas MEPC 68/INF.37
 To facilitate effective implementation of Annex IV.
 To fulfil our obligations, as does the rest of the society.
We request that IMO Member States and other
recognized entities submit relevant information on grey
water to MEPC69, with a view to considering addressing
this significant source of pollution through IMO
processes/procedures.

9. Page 9 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
IMPLEMENTING ANNEX IV EFFECTIVELY

10. Page 10 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Effective Implementation - What Is It?
 Success on land
 Regulatory Cycle
Legislation
(Revision)
Permitting
Compliance
Monitoring
Compliance
assessment
Enforcement
Evaluation &
Feedback
Policy/
Objectives
Adapted from IMPEL (2010)
!!

11. Page 11 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Legislation
Type
Approval
Compliance
monitoring
Compliance
assessment
Enforcement
Evaluation &
Feedback
Annex IV – An Overview
 Long history
 Superior targets
 No Regulatory Cycle
 Realities…
Policy/
Objectives
!!

12. Page 12 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Realities
 ‘…the large ship data (2000) shows that none of the
treatment systems were functioning properly…‘ Alaska DEC
(2002).
 ‘…a vast majority of the equipment did not meet the
existing sewage treatment standards…’ MEPC 64/23; MEPC
67/8/1.
 ‘…legal, treated sewage discharges contain fecal bacteria
concentrations that are many times higher than the state
water quality standards…’ Washington State (2013): Draft Petition to
Designate the Waters of Puget Sound as a No Discharge Zone

13. Page 13 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Realities – STP Performance Status
0
100
200
300
400
500
600
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
BOD5(mg/l)
BOD5 Concentration - Average

14. Page 14 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Realities – STP Performance Status
1
10
100
1,000
10,000
100,000
1,000,000
10,000,000
100,000,000
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
F.Coli(counts/100ml)
Faecal Coliform – Geometric Mean

15. Page 15 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
 A lack of visibility.
 Regulatory Cycle – incomplete !
 Annex IV NOT effective, the gap between rules and
realities is widening.
 “A convention that just gathers dust on a shelf offers
no benefit to anyone” - IMO Secretary General Koji
Sekimizu
 Effective implementation – possible?
Challenges

16. Page 16 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Alaskan Experience
1
10
100
1,000
10,000
100,000
1,000,000
10,000,000
100,000,000
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
F.Coli(counts/100ml)
Faecal Coliform – Geometric Mean
 Alaskan law - CPVEC program!
 Cruise industry’s commitment led to great success.

17. Page 17 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Alaskan Experience
0
100
200
300
400
500
600
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
BOD5(mg/l)
BOD5 Concentration - Average
 Grey water rule makes CPVEC more feasible.
 Permitting under CPVEC vs. Type Approval

18. Page 18 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Effective Implementation – It benefits
 Benefits industry.
 Level playing field.
 Reality check for 'aspirations'.
 Science-based, practicable and sustainable rules.
 Benefits the regulators by making rules fit for purpose.
 Benefits the environment.

19. Page 19 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
The Way Forward
 Regulation should be building confidence in the society.
 Regulatory Cycle is key !
 Annex IV should be, and can be, made effective.
We request that Member States and other recognized
entities consider the presented information with a view
to addressing the requirements of Annex IV adequately.

20. Page 20 Marine Wastewater Pollution: Confronting Grey Water and Implementing Annex IV Effectively, at MEPC68, London, May 2015, by Dr Wei Chen
Any Questions
Contact:
John Kaltenstein, IMO Coordinator at FOEI.
JKaltenstein@foe.org
Dr Simon Walmsley, Marine Manager at WWF International.
SWalmsley@wwf.org.uk
Dr Wei Chen, Future Program Development Manager at
Wartsila Water Systems Ltd. wei.chen2@Wartsila.com