By Wendy Laursen
A proposal from Norway and Singapore at the March IMO meeting to discuss the international ballast water management convention seemed a fairly minor consideration at the time. Some of the organisms used to test the efficacy of treatment systems for type approval were dying before the tests could be completed and these countries requested a protocol change. However, coupled with the news that equipment manufacturer Wilhelmsen Technical Systems had withdrawn their already type approved system from the market, the issue of type approval reached crisis point.
The Bahamas suggested there was a need to review the type approval guidelines and Tim Wilkins, environmental manager at Intertanko, was quick to support the move. Although keen to see an international solution rather than a regional response to the problem of invasive species carried in ballast water, Wilkins believes that there is a lack of industry confidence in the type approval process that should be addressed. Currently, the type approval guidelines are not perceived to reflect realistic water conditions worldwide. Only two salinity levels are expected to be tested and although certain levels of sediment and live organisms have been set, water temperatures are not specified.
DESMI highlighted the limited salinity testing done by the industry to date when they included fresh water testing in their type approval regime. Some very soft, freshwater species were unexpectedly passing through the filter and DESMI has since redesigned their system as a result.
There are more than 20 type approved ballast water treatment systems on the market and more are currently going through the approval process. Whether or not any changes at IMO will necessitate revisiting existing type approvals is not yet clear and the situation needs to be resolved, says Wilkins. “Let’s be logical about it. Let’s be practical about it.”
Another issue raised at the last IMO meeting relates to California’s no discharge zone for sewage. Although seemingly unrelated to ballast water, some vessels have chosen to store sewage in their aft peak ballast tank. “They are amending the piping and pumping arrangements and some are galvanizing the tanks,” says Wilkins. “The question was raised, if you are putting liquid into a ballast tank, is it defined as ballast water? On discharge, does it have to go through the ballast water treatment system?” It is unlikely that ballast water treatment equipment would be suitable for sewage processing so vessels considering this option would have to have dual piping arrangements.
Meanwhile, the California State Lands Commission is pushing ahead with their own evaluation of treatment systems. The Commission does not actually approve ballast water treatment systems for use in Californian waters; rather it has established performance standards for the discharge of ballast water. “Vessels have several options to comply with those standards including retaining all ballast water on board, the most protective management strategy, and using a ballast water treatment system,” says Nicole Dobroski, environmental program manager for California’s marine invasive species program.
So far only one system can claim to have met the more stringent Californian discharge requirements being enacted by California. The commission’s latest review, published in September 2011, states that Qingdao Headway’s system is the only one so far evaluated that demonstrated the potential to meet California’s standards 100 percent of the time during the shipboard trials conducted for the system’s type approval. Other manufacturers whose systems demonstrated the potential more than 50 percent of the time were Ecochlor, RWO, Severn Trent de Nora and Techcross.
Compliance checking is another issue that has failed to be resolved at IMO. David Tongue, director of regulatory affairs at the International Chamber of Shipping, successfully blocked the current proposal before IMO and he was supported by Panama, the Bahamas and Singapore. The protocol included indicative analysis where indirect measures rather than individual organism counts can be used as compliance tools. Tongue believes that this could involve different testing in different ports and therefore disadvantages shipowners.
California is preparing compliance testing protocols independently from IMO and has not included indicative analysis. The commission is, however, funding two research projects focused on such techniques and is closely tracking similar efforts at federal and international levels. “As indicative sampling methods become more robust and standardized across the scientific community, we will consider including them as part of the compliance assessment process,” says Dobroski.
The protocol developed by California involves collecting samples continuously over as much of the discharge process as possible in order to cover portions of the beginning, middle and end of deballasting. Some of the analysis will be able to be done within six hours but some could take several days. A vessel will be notified of non-compliance as soon as results are available.
Compliance checking systems are being developed around the world, not only for enforcement officers but also for operators wanting to be sure of their status. Hach has developed a portable Rapid Ballast Water Compliance Test Kit that measures living organisms 10 to 50 microns in size. In case of compliance problems or emergency situations, The Glosten Associates has developed an onboard emergency treatment dosing protocol in association with the US Geological Survey and National Parks. Cofely West Industrie has developed a barge-mounted treatment system suitable for ships arriving in port with ballast water of uncertain treatment status. Cofely has also developed a real-time bacteria detection system.
While the US Coast Guard and California continue with regulatory developments, ratification of the IMO ballast water convention is no longer expected this year. Ship repair and ballast water treatment specialist Goltens Green Technologies believes that shipowners that wait for ratification will face far greater costs. Acting early they will get cheaper system prices and cheaper engineering and installation costs, says Goltens.
Engineering company Instrumental Marine Services believes that on-voyage installation is a good option as lead times will be extended when 40,000 to 60,000 orders are placed in the lead up to regulatory mandates. Delayed component deliveries will have an insignificant impact on voyage but, in a shipyard, they can be significant and may lead to work having to be conducted at sea at a later stage and at premium prices.
Dr. Dale Neef, managing director of independent data management consulting company DNA Maritime, believes that electronic data management systems will soon figure more prominently in the ballast water treatment market. Equipment operation, either for ballast water exchange or treatment, needs to be reported to authorities, but there is also the potential for ship managers to make efficiency improvements to ballasting operations using data already available on board from ballast pumps, tank level indicators, valve flow sensors and treatment systems. Fleet management and condition based monitoring software suppliers will soon be able to offer improved functionality in this area, predicts Neef.
Recent type approvals include Westfalia’s BallastMaster ultraV and Siemens’ SeaCURE system. Some manufacturers, such as Mahle and RWO, are expanding their service offering by providing 3-D scanning to facilitate installation design for retrofits. Early entrants to the market, such as Ecochlor and Hyde Marine, continue to build their reference lists: Ecochlor, recently with the Buenos Aires, a bulk carrier owned by Sojitz Corporation, and Hyde Marine with two Aframax tankers being built by SPP Shipyard in South Korea for owner OSG. PG Marine has become Hyde Marine’s supplier for offshore support vessels and has so far secured orders for approximately 60 shipsets.
Severn Trent de Nora has installed three systems to date and has nine systems on order for a range of vessel types including LNG carriers, offshore barges and pipelay vessels. The company has also progressed through the US Coast Guard (USCG) and Californian evaluation process with SeaRiver Maritime’s tanker American Progress.
The USCG established the STEP program in 2004 to promote the development of alternatives to ballast water exchange and participation is available to all international and US domestic vessels subject to the USCG’s ballast water management regulations. Acceptance of the American Progress into the program is evidence of SeaRiver Maritime’s proactive approach to the problem, says Severn Trent de Nora.
In August 2010, American Progress was also authorized to discharge treated ballast water into California waters and it may continue to do so as long as it remains in the STEP program. California also considers the vessel to be in compliance with the state’s performance standards for a period not to exceed five years from the date that the interim performance standards are implemented for this vessel class on 1 January 2016.
With limited industry experience to call on, Wilkins has published a commentary on treatment system selection based on the experiences of Intertanko members that aims to assist others in their decision-making. Guidance on the Selection and Installation of Ballast Water Management Systems for Tankers was published this year and it includes information such as reminders that an often-overlooked aspect of the size of the installation is the additional footprint or space required for personnel to adequately maintain the system. At present, very few systems are estimated to be less than 20 cubic meters (700 cubic feet) and many weigh between 2,000 and 5,000 kg (2 to 5.5 tons). Additional strength reinforcement may be required.
Wilkins recommends that manufacturers and shipyards perform a HAZID assessment prior to both installation and installation and acceptance testing. He also recommends that a ballast water sample and test should be part of the pre-delivery procedures of a new installation. “You don’t just put a ballast water treatment system on board and merrily sail away,” he says.
Wendy Laursen is a freelance journalist based in Australia who has been writing for maritime and engineering magazines since 2004.