Ballast Water Treatment: A “headache” for Ship Owners - Carbon Positive

Posted - May 10, 2013 -   Carbon Positive - RSS: Hellenic Shipping News Worldwide

Since the major technical concerns and the big challenge of harmonization between the performance standards for type approved systems and the procedures for testing, sampling and monitoring by Port State Control (PSC) have been overcome, the IMO BWM Convention is close to being ratified, maybe before the end of this
year.
IMO Convention
The global transportation of untreated ballast water causes significant ecological damage and is considered as one of the four major threats to the marine environment alongside oil pollution, over-exploitation of the sea and climate change. The IMO introduced relevant regulations in 2004 and provided two standards, the exchange standard D1 (sequential, flow through and dilution method) and the performance standard D2 (Ballast Water Treatments). The implementation dates as they stand today are summarized in the diagram below.
The BWM Convention is not yet in force and the timetable is subject to the ratification of the Convention. By March 2013 it had been ratified by 36 countries which represent 29% of the world’s GT. The minimum required is 30 countries, representing 35% of the world’s GT. When the remaining 6% of gross tonnage sign (e.g. Panama or some others with smaller tonnage) then the BWM Convention will become mandatory worldwide 12 months later. According to estimations, about 68,000 vessels will implement the BW treatment system worldwide until the end of the decade. At present, it is expected that there will be about 45 certified manufacturers by the end of 2013, making about 70 different systems available. Since nobody is sure if a bottleneck can be avoided (especially between 2016 and 2018), there is currently an on-going discussion within IMO about lengthening the implementation dates for existing vessels (eg. change the implementation dates for fleet in service to the first renewal survey after 2016 or change the date on which a vessel is considered to “exist” to the date of the “entry into force of the convention”). The proposal to move the IMO application dates forward would create a harmonization issue with dates already set by USCG.
Forthcoming regulatory developments
The technology is not yet fully developed or implemented (especially for sampling). It seems that implemented regulations are in some cases ahead of technology. In this respect many parties within the shipping community addressed the need for revision of the guidelines for approval of the ballast water management system (G8), to improve transparency and harmonization with sampling procedures, however it was decided that any revision of the G8 guidelines should take place after ratification of the convention. In the IMO sub-committee meeting for Bulk Liquids and Gases (BLG 17), which was held from 4 - 8th February, it was agreed to undertake a trial period of two years for port state control sampling and analysis once the IMO Convention has entered into force. Within this period a vessel may not be detained for non compliance with the BWMC standards. After this period the IMO will conduct a review and amend the sampling and analysis protocol as necessary. The aforementioned arrangements are expected to be adopted during the next MEPC 65 meeting taking place from 13-17 May.
National Regulations in USA
On the other hand US regulations on ballast water management and regular removal of hull fouling and sediment already entered into force on 21 July 2012.
All ships calling at US ports and intending to discharge ballast water are required to use an approved ballast water treatment system meeting the US ballast water discharge standard, which is similar to the IMO D-2 standard. The compliance date is 01/12/2013 for new ships, the first scheduled dry docking after 01/01/2014 for ships constructed before 01/12/2013 with ballast water between 1500 and 5000 cub.m and the first scheduled dry docking after 01/01/2016 for the rest.
All BWT systems installed on vessels calling at US ports have to be approved by a test facility accepted by USCG. For the time being none of the systems which have already been approved through the IMO process has gained USCG approval. The reason for this is that several test facilities are reported to be seeking acceptance by USCG. It seems that the first USCG type approved BWTS will not enter the market before 2015.
Alternatively, a BWTS with an approved certificate (by Flag or Classification Society) might be accepted for use in US waters, after a USCG review, with a grace period of five years, while the manufacturers seek type approval from the US. These systems are called Alternate Management Systems (AMS) and it is the manufacturers’ responsibility to apply to the USCG for this temporary designation while the systems undergo approval testing. By mid April 2013 nine BWTS had been accepted as AMS by USCG.
In addition the new US VGP will enter into force on 19/12/2013 and generally will be in line with USCG ballast water requirements. Further requirements for calibration of sensors, sampling, testing, functioning, monitoring, recording, training and permitted level of sediment, must be taken into account by the owners in the new US VGP.
The new US federal rules will not prevent individual states (such as California or New York) from implementing even tougher ballast water standards in the future.
Selection of a BWT system
Owners are advised to investigate this matter carefully with the support of technical advisors, get independent operational references and spend time choosing the right system in a quite young & emerging market.
The decision about a BWT system is not an easy one, due to the complexity of the problem, although some BWT system suppliers make the whole procedure seem simple at the quotation stage. At least the following parameters should be carefully considered:
•    Ship routing (country, ports, rivers, temperature, salinity, turbidity, sediments disposal etc)
•    Ship type, size & age (incl. operational issues, ballast capacity and max. ballast rate)
•    Tank coating (certification & testing reports by manufacturers / suppliers)
•    Installation of the BWT system on board (arrangement, footprint, volume, weight, available space on board, modularity, extent of structural, piping, electrical, automation, monitoring, sampling connections, etc)
•    Design and operational safety requirements (restrictions in hazardous areas, cargo pump rooms, APT in tankers, etc)
•    Storage of chemicals, neutralizing agents, by-products, residuals, etc
•    Treatment steps (during uptake, at discharge or both) & removal of sediments
•    Pressure loss (varies from 0.3 to 3.5 bars) & reduction of nominal flow
•    Energy consumption (spare power, load balance, when the power is needed)
•    Holding time (how often the BW is discharged)
•    Efficiency and effectiveness
•    Ability of BWTS to comply with even stricter requirements in the future, designation as Alternate Management System (AMS) by USCG, planning for USCG Type Approval
•    Maintenance (availability of consumables, maintenance intervals, easy handling by the crew, after sales service and global support)
•    Experience of manufacturers in maritime technology, financial stability
•    Cost (purchase, installation, operational, maintenance, training)
GL approval scheme
The GL approval scheme for BWMS includes the following steps:
1) Type Approval Certificate by RO (for compliance with IMO) shall be provided by the manufacturers. The environmental acceptance of process for active substances (basic & final approval) is given exclusively by IMO.
2) Type approval by GL certifies components and functions like pressure vessels, plastics, vibrations, temperatures, software tools, electro magnetic compatibility (EMC) etc. EMC must be taken into consideration especially for high voltage systems. This step is optional.
3) Plans of the treatment plant showing its connection with existing on board systems (structural, piping, electrical, monitoring, automation, safety systems, etc) shall be submitted to GL for approval prior to installation.
4) An approved Ballast Water Management Plan and Ballast Water Record Book shall be kept on board.
5) After a successful survey and reporting, GL issues either a STATEMENT OF COMPLIANCE with the BWM Convention or an INTERNATIONAL BALLAST WATER MANAGEMENT CERTIFICATE or a DOCUMENT OF COMPLIANCE depending on whether the convention has been ratified and the flag is party to it.
Source: GL Academy

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