Wei Chen, Ph.D.
process engineer, environmental expert/advisor/consultant
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I am glad to have the opportunity to speak at this important event. In my talk, I will compare the different regulatory and technical approaches taken by the other industries to address our society's biosecurity concerns, and what they could mean to maritime industry.I encourage maritime policymakers, port authorities, national biosecurity authorities, and biosecurity professionals of different industries to take an interest in the discussions. #biosecurity #EFSA #port #Veolia #UFSA #BPA #APHIS #ballastwater #biofouling #foodwaste
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Wei Chen, Ph.D.
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I am pleased to be attending SMM next week for a few days. You can find me with Hamann team who are fully committed to their successful sewage treatment products and services. They are continuously raising awareness on important technical and regulatory topics and sharing their experiences for the benefit of the customers. Come and talk to us on improving investment efficiencies and leading future-proofing solutions. https://lnkd.in/ebq-wSSK.
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Wei Chen, Ph.D.
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See AlsoWei Chen, Ph.D. on LinkedIn: I am pleased to be attending SMM next week for a few days. You can find me…Ram Govindasamy on LinkedIn: #marpol #doesnt #engineroom #ukmcaInternational Convention on Load Lines, 1966Oil–water separator - Wikiwand articlesAccess this content and more in the LinkedIn app
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Wei Chen, Ph.D.
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Wei Chen, Ph.D.
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The operating temperature of sewage treatment plants (STPs) in Arctic watersWith more ships exploring the Northern Sea Route https://lnkd.in/eUVQwFuq, it can be helpful to understand the potential operational challenges and practicalities for the STPs (even though they may be the last thing on people's mind, I know).The temperature of ships’ black and grey water is influenced by factors such as the ambient temperature of living quarters and plant rooms, holding tank design and operations, and potential heat sources during storage and treatment, such as the use of blowers for mixing or aeration, etc. There is a scarcity of STP temperature data taken during Arctic voyages in the public domain. To address this gap, I initiated polls to gather the first of such data on cargo and passenger ships: https://lnkd.in/e7xVR4N2 https://lnkd.in/emjiqXf8. I appreciate the contributions of those who wish to share their knowledge and findings. Various instruments, such as a temperature gun or a pH or conductivity probe, can be used to take a reading on the surface or a water sample of a duty STP. Please feel free to provide further details in the comment section.#ship #cruise #Arctic #environment
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Wei Chen, Ph.D.
process engineer, environmental expert/advisor/consultant
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30% of ships are found to have Oily Water Separators (OWS) that do not raise an alarm when there is no sample flowing through the Oil Content Monitor (OCM) https://lnkd.in/eVEC9Dmp. Certificates become the licences to pollute. These type-approved equipment are non-compliant with MARPOL Annex I https://lnkd.in/d4qf5HY3. Is the approval of a technology failing to meet the regulatory requirements legal? A pollhttps://lnkd.in/e4yQF8E9 showed that 24% said it is legal, 68% said illegal, and 7% said unsure. The majority disapproved the approval. AMSA believes this failure represents non-compliance with the Guidelines https://lnkd.in/ecVg-gJW. The Working Group on the case (MEPC 79/WP.1, screenshot below) seems to suggest the failure complies with Annex I and its Guidelines, and it is the Guidelines that are at fault, which need to be revised to accommodate a flow switch. But hold on, MARPOL Annex I (Regulation 14.7) stipulates that for ships of 10,000+ GT, an OWS ‘... shall be provided with alarm arrangements to indicate when this level cannot be maintained. The system shall also be provided with arrangements to ensure that any discharge of oily mixtures is automatically stopped when the oil content of the effluent exceeds 15 ppm’. This requirement is a law in 150+ signatory Member States. So, after half a century, when these type-approved arrangements are found not 'to indicate' when the effluent exceeds 15 ppm nor 'to ensure' the discharge is automatically stopped, how come they are considered compliant, considering reputable OWSs have built-in flow switch to comply with Annex I for a long time? Under the type-approval regimes, no provisions exist for reporting, reviewing, acknowledging or correcting the approved mistakes under the MARPOL Convention. I have followed up on this case with interest because, to me, the issue is not just visible, but also current, and telling. #OWS #OCM #IMO #environment #shipping #ships-------------------------------------------------------------------EN Decision page: https://lnkd.in/eb4g5w-M
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Wei Chen, Ph.D.
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Port Reception Facilities (PRFs)Ships’ operational wastes, such as bilge water, black and grey water, sewage sludge, food waste, and ballast water, can be managed onboard for safe discharge to sea and/or received by the PRFs under national regulations. Onboard solutions type-approved for consistent and universal operations are often found to be inadequate. The operational difficulties and poor performances have resulted in illegal dumping and discharge bans. The industry has learned to live with the bans by shifting its reliance to PRFs, sometimes encouraged through local investments, no-special fees, and compulsory offloading https://lnkd.in/du64Tu-n.However, matching the requirements of international marine regulations with the diversified and fluid national rules for compliant and sustainable waste reception can be as challenging as onboard solutions. For example,- PRFs and waste handlers receiving HME cargo hold wash water may not have assigned it a suitable waste category or demonstrated any subsequent removal of its perceived harmful impacts. - Ships’ sewage, sewage sludge, and food waste can readily exceed the maximum allowable concentrations for local sewers https://lnkd.in/e5x5S_yw https://lnkd.in/eu7A2sr3. Untreated sewage from international ships can also spread diseases.- Ships’ food waste can overload local infrastructures, esp. those serving smaller towns and communities https://lnkd.in/eVhHqKa8.- Ships’ biosecurity wastes, such as international food waste, ballast water and sediments, and hull cleaning residuals, need to be assigned with suitable categories under the international marine regulations so that relevant national authorities can align (or develop) and implement their national biosecurity laws https://lnkd.in/et2xrmha https://lnkd.in/em6pV7bx. The shipping industry needs to satisfy its extended producer responsibility by having transparent, compliant, and sustainable disposal routes for its waste landed ashore https://lnkd.in/ehaMuekM. Some believe our society should invest twice, on ships and on land, for the same waste. This is happening. In time, the industry can start to tell whether this approach will strengthen or weaken the two solutions with some evidence-based reviews. But first of all, both solutions need to be compliant.
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Wei Chen, Ph.D.
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Legal or illegal? A short story of the approved Oil Content Monitor (OCM)In the 1970s, to address the pollution from ships’ oily bilge water discharges, Annex I of the IMO’s MARPOL Convention mandated the use of oil filtering equipment, which ‘shall be provided with alarm arrangements to indicate when this level (15 ppm) cannot be maintained. The system shall also be provided with arrangements to ensure that any discharge of oily mixtures is automatically stopped when the oil content of the effluent exceeds 15 ppm’ (Regulation 14.7). In 1983, MARPOL Annex I entered into force. Today, over 150 signatory countries incorporate the requirements into their national laws. In between, Guidelines were introduced in 1977, 1992, and 2003, detailing the testing protocols, including OCM sample flow and pressures https://lnkd.in/eahfirhU https://lnkd.in/eJMNRrCc https://lnkd.in/ePytsY6C.In 2021, a study revealed that many approved products do not raise the alarm when there is no sample flow through the OCMs (MEPC 77/14/2) https://lnkd.in/eVEC9Dmp. So, ships can potentially discharge oily bilge water exceeding the limit without any alarm. 30% of the ships surveyed are affected. Having been type-tested, approved, and inspected, these products are compliant for serving the industry, and yet, they are unfit to ‘ensure that any discharge of oily mixtures is automatically stopped when the oil content of the effluent exceeds 15 ppm’, as demanded by the laws of the contracting countries. So we have products approved to meet the rules actually approved to break the rules. Does this mean the approvals are illegal? I created poll to see the collective understanding of maritime professionals https://lnkd.in/e4yQF8E9The latest initiative by AMSA is relevant and timely https://lnkd.in/ecVg-gJW
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Wei Chen, Ph.D.
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Wei Chen, Ph.D.
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Ships' speed when discharging untreated sewage (Part II)I thank the dozens of maritime professionals who have commented and participated in the polls in Part I https://lnkd.in/ewckaFpy. The inconsistency of the rules, which was well described in a comment https://lnkd.in/eHeEXZK7, has caused uncertainties that can only be resolved by evidence-based rulemaking.Ships' speed is only part of the problem. The discharge rate can also be impractical to implement. These issues will affect potential future rules on sewage sludge discharge rate and sewage record book (PPR 11/12). Approach your company, NGO, Class, or Flag if the issues affect you.My observations started from a different perspective:Treated and untreated sewage of the world's population largely ends up in the sea. Sewage can be treated to remove 30% to 90+% of pollutants. Untreated sewage from over half of the world population is often screened to remove large objects prior to discharge. These treated/untreated discharges are a pollution needing assimilation by nature, a process helped by initial dilution, or a 'mixing zone', at the point of discharge. This is because sewage cannot be viably treated to meet the so called Water Quality Standards (WQS) of our aqua environment (try to use car exhaust as an example to understand this point). So, dilution and natural assimilation of sewage is accepted by our society https://lnkd.in/ejNSyiHk. Coastal discharges often have an outfall pipe extending into the sea to increase dilution https://lnkd.in/effv3UgY. A sea outfall serving a large cityhttps://lnkd.in/ehsjaJ3K can have an impact 100,000 times of a discharging ship drifting without SWT, or 1,000,000,000 times of a ship having a swept volume. Not many maritime professionals know that the 'swept volume' was created for the largest animal carrier, to make its discharge of 'undiluted' and untreated sewage, equivalent to that from 350,000 people or 10,000 cargo ships, comply with MARPOL Annex IV. A cargo ship is burdened by the same requirement as that of an animal carrier, and further penalised for flushing toilets when the phrase 'undiluted sewage' was lost in translation. Yet, all the while, animal carriers may have never complied, for not having a sewage holding tank or washing down the animal pens 24/7. The debates on speed and rate can continue. But to me, removing sewage screenings and macroplastics from ships' sewage discharges outside 12 nm https://lnkd.in/ejWCM2PP, regulating greywater inside 12 nm https://lnkd.in/eFffzQTn, and stopping the notorious dilution machines as certified 'green technologies' can be low-hanging fruits for aligning shipping industry with the expectations of the rest of our society. But with the maritime environmental aspirations soaring high, who needs low hanging fruits? -----------------------------------------------------------------------EN Decision page: https://lnkd.in/eb4g5w-M
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