These days, a friend sent KR's advisory to me and asked: Has Nantong MSA imposed any fines? How should ocean-going vessels handle domestic sewage when berthing at various ports along the Yangtze River?

Here is the information communicated by KR: On 10 February, during a PSC inspection of a KR-classed vessel, Nantong PSC detected that the vessel’s domestic sewage had been directly discharged into the sea and issued a deficiency. KR reminds all vessels to pay close attention to this matter when berthing at ports in the Yangtze River Basin.

In fact, I have talked about domestic sewage issues on many occasions. Those who still get fined are simply harboring a fluke mentality and taking it lightly, so such penalties are totally justified.

I checked the Tokyo MOU official website and found that Nantong PSC did inspect a vessel on 10 May, identifying 5 deficiencies without detaining the vessel.

Among these 5 deficiencies, one was coded as 14499 - POLLUTION PREVENTION - MARPOL ANNEX IV (Other (MARPOL Annex IV)), which means a violation of MARPOL Annex IV, i.e., the requirements governing domestic sewage discharge.

Based on the deficiency code and KR’s circular, the vessel in question should have directly discharged domestic sewage into the port while alongside. It is possible but highly unlikely that the sewage had been treated by the domestic sewage treatment plant prior to discharge.

From the handling advice of this deficiency code, I could see it was not Code 30, meaning the vessel was not detained. No fine record was found on the official website either. It’s clear that PSC went easy on the vessel—this shouldn’t have happened!

Typically, such direct discharge into the Yangtze River warrants both detention and a fine.

Fines start at 100,000 yuan and go up to a maximum of 1,000,000 yuan!

I’ve explained the current domestic sewage discharge policies on many occasions.

In brief:

1) In accordance with MARPOL Convention requirements, water treated by the domestic sewage treatment plant may be directly discharged into the sea whether the vessel is in port or at anchor.

2) In compliance with China’s GB 3552-2018 requirements, treated domestic sewage can only be discharged when the vessel is underway; discharge is prohibited while alongside or at anchor.

3) For comminuted domestic sewage, discharge is permitted only when the vessel is in waters at least 3 nautical miles from the nearest land and sailing at a speed of not less than 4 knots.

Many still confuse the concept of "nearest land". In fact, it refers to waters within the territorial sea baseline, not land in the traditional sense! For example, the Bohai Sea and the Yangtze River are both within the territorial sea baseline, falling under the scope of "nearest land"—even comminuted domestic sewage cannot be discharged there.

I emphasize again: "Nearest land" refers to waters within the territorial sea baseline, not land in the traditional sense!

Once the rationale above is understood, vessels entering waters within China’s territorial sea baseline have two reliable options for domestic sewage management:

1. Discharge domestic sewage into the temporary storage tank. Zero discharge is certainly the safest option.

2. Treat sewage via the domestic sewage treatment plant and discharge it only while underway. When at anchor or alongside the berth, lock down the treatment plant, retain all sewage on board for shore reception, and crew shall use shore-based toilets.

You can review my previous posts: Complete Guide to Domestic Sewage Treatment (All-season Collection).

Some may argue: "This is nonsense! When our vessel berthed at XX Port last time, we directly discharged treated domestic sewage into the sea and weren’t fined by XX MSA. Neither was the vessel in your Nantong case fined, right?"

Not being fined was just luck. All I know is this is what the regulations mandate!

Never take luck for exemption or harbor a fluke mentality.

Pursuant to the Marine Environmental Protection Law of the People’s Republic of China (MEPL), current fines for domestic sewage violations fall into two categories:

1.    Fines for incorrect domestic sewage records;

2. Fines for actual discharge of non-compliant domestic sewage.

For Category 1 (incorrect records):

Under Article 87 of the old MEPL, the fine ranged from 0 to 20,000 yuan.

Note: Since the new MEPL took effect on 1 January 2024, incorrect domestic sewage discharge records carry a maximum fine of 100,000 yuan under Article 110.

For Category 2 (discharge of non-compliant sewage):

Under Article 72 of the old MEPL, the fine ranged from 20,000 to 100,000 yuan.

Note: Since the new MEPL took effect on 1 January 2024, illegal discharge of non-compliant sewage incurs a minimum fine of 100,000 yuan and maximum of 1,000,000 yuan under Article 93.

The easiest and safest solution is installing a temporary domestic sewage storage tank.

However, adding a tank on board requires drawing modifications, which is cumbersome. A more convenient and efficient option now is converting a ballast tank for dedicated domestic sewage storage. Critical notes: Prior to use, modify the pipelines, update the Ballast Water Management Plan, revise the ISPP Certificate, and record the operation under Item H in the Ballast Water Record Book.

--------------------------------------------Reprinted from PSCReady