Even though Covid has slowed down some regulatory and compliance aspects of the ballast water treatment world, the fundamentally stronger simple innovation of a practical, no filter, certified, “in tank” BWTS is realised with Scienco/FAST’s Scienco InTank BWTS
Involved with Ballast Water Treatment since 2002, Giles Candy, Executive Business Development (Ballast Water Division), Scienco/FAST – a subsidiary of BioMicrobics, Inc., worked with the inventor of the Venturi Oxygen Stripping (VOS) BWTS, Peter McNulty. After a discussion in Giles’s office, Mr. McNulty announced he had a great idea for a Ballast Water Treatment System (BWTS). Being a project manager at a terrestrial water treatment company, this statement at the time meant nothing to Giles. How things change…
“I remember Peter’s call in 2004, “The Convention is Final” and went to work for his N.E.I. Treatment Systems in 2006. N.E.I.’s VOS is a valid no filter BWTS, it was the first BWTS to be “IMO” Type Approved in 2007,” said Candy. Since then, there are literally dozens of electro chlorination, UV or chemical addition BWTS that have come to market, all of them inline systems and most with 20-40um filters, often placing significant burdens on the vessel and crew during combined in port ballast treatment and cargo operations.
By 2016 with the Convention STILL not ratified, Giles had almost transitioned out of ballast completely -- almost. However, the first press release by Envirocleanse for the InTank BWTS caught his eye. Based on the description, InTank was a new, innovative approach that Mr. Candy appreciated and he wanted to be involved. The fundamental simplicity, robust operational and compliance advantages of an InTank BWTS meant, through testing, the Type Approval is accepted. Mr. Candy remain involved during and after the acquisition of InTank by a well-suited, marine-focused company, Scienco/FAST, and newly minting it as Scienco® InTank™ BWTS (www.intankballast.com).
If a vessel usually spends more than 36hrs in ballast, an “in tank” ballast treatment system treating during the voyage offers several fundamental advantages over an in line ballast water treatment system. The vessel gets to complete all its port operations as normal – during ballasting and deballasting; no worries about power, or water quality, or filters, or if will neutralization happen and be recorded correctly, will the tide change affect BWT, and on and on. Fundamentally treating in the tank during the voyage brings operational control to the vessel. Scienco InTank is not a silver bullet; the work still needs to be done but it is done at sea where there is less stress on time and resources.
As well as bringing control over treatment operations to the vessel, treating in the tank also brings complete control over BW compliance to the vessel. Neutralization is completed in the tank before discharge, so “technical compliance” is achieved and recorded before discharge. No worries about TRO levels or UV performance during discharge – it can even gravity discharge. Additionally, the vessel can choose when to treat. If at sea, or anchor for weeks or months treating at a time close to discharge eliminates the risk of regrowth, bringing control over biological compliance to the vessel.
Scienco InTank automatically monitors the treatment process brining dosing control to the vessel. Clean Caribbean waters will probably not need additional TRO, but Mississippi mud is a whole different story. Treating in the tank is not “one shot and done” like in line systems, it will automatically account for challenging water without compromising treatment time or dosing compliance.
The fundamentally stronger simple innovation of a practical, no filter, certified, “in tank” BWTS is realized with Scienco/FAST’s Scienco InTank BWTS. To find out more join the companies InTank Webinar on July 15th:
With our Ballast Water Expert, Giles Candy, and our Marine Engineer, Ben Swann, the training program will cover the basics and understanding of the new concerns with ballasting activities and latest information on regulatory challenges; technologies that offer simple, robust BWMS solutions.
REGISTER TO ATTEND
Executive Business Development (Ballast Water Division), Scienco/FAST
Benjamin (Ben) Swann
Marine Engineer, Scienco/FAST
Timetable to “Compliance” is set but…:
When the IMO’s BW Convention was finally ratified in late 2016 the BWTS installation schedule was still effectively three years away from starting. What had been a progressive ten-year installation schedule ending in 2019 has become a busy five-year schedule starting in 2019. Effectively this five-year schedule is further concentrated to 2021-23 by the “decoupling” exercise so many went through. How the last 18 months of COVID may further confuse this picture, we will have to see. However, through this winding road each vessel now as a date by which it must technically “comply” with the IMO’s BW Convention.
For most vessels’ this “compliance” means retrofitting a BWTS during a drydock. For a significant minority of vessels, it means using a BWTS which was installed years ago but has been rarely if ever used or even maintained. There are exceptions to this obviously, but the impact to vessel operations of using a BWTS during every ballasting event, as the timetable for “compliance” passes vessels by, is proving to be a challenge for many.
Why is “Compliance” in inverted commas?
The IMO’s BW Convention is best known for its Regulation D2, or D2 discharge standards. Indeed, once applicable, a vessel must declare it is sailing under D2 (treatment) standards not the D1 (exchange) standard. D2 is the biological discharge standard applying to all ballast discharged from a vessel, it is a VERY high standard. One of the three D2 criteria is organisms >50 microns – generally zooplankton. The standard is <10 per cubic meter (m3) of discharged ballast. Consider it is not unusual for ballast to have over a million zooplankton per m3, and a vessel may ballast at 5,000 or 6,000 m3 per hour in all sorts of water conditions, you can see how hard a BWTS must work to achieve D2 biological compliance.
However, the prospect of any meaningful enforcement of D2 compliance is years away. Today the mechanism which is in place to ensure “compliance” is that a vessel must carry an endorsed International Certificate of Ballast Water Management. This Certificate means the vessel has an approved BWTS installed and will operate to the requirements of its Administration approved Ballast Water Management Plan. In June of 2022 a vessel it will also have to prove the BWTS installation has been successfully commissioned to receive the International Certificate and be in “compliance”.
Enforcement of “compliance” remains technical and is only just beginning to happen. Questions, such as, “Was the BWTS operated correctly during all ballasting events?” will be asked as part of the arrival port check. Today the vast majority of ballasting events are not “policed” let alone measured against what is the intended purpose of the BW Convention in the first place, implementation of the environmentally protective D2 standard. So “compliance” remains in inverted commas.
Despite technical departments spending tens of thousands of hours reviewing different BWTS, generally (but certainly not always) selecting the least expensive most expedient type of BWTS is the chosen path. For well over a decade where systems have been installed this approach served the vessel well enough. There is a technical “compliance” tick in the box ahead of time, the BWTS does not have to be used, and there is a sense of “we’re ahead of the game”. As the operational realities of using BWTS during every ballasting event begin to challenge more and more vessels, the difficulties of achieving just technical “compliance” are anecdotally becoming apparent. Ballast water treatment is hard, not just on vessel operations but as a treatment exercise in of itself, and not all systems are equal.
Where there are publicly available studies of technical and biological compliance of treated ballast discharges the story is grim. Consistently 25-35% of discharges are out of compliance either technically, biologically or both. This is workable during a time of “compliance” but a fundamental problem for owners when compliance is enforced.
Ballast Water Issues Pushed from MEPC 76 to MEPC 77:
Recognizing a ballast water treatment system is a high-performance piece of equipment and successfully operating them on a vessel, operating in many different water qualities, is a difficult thing, the IMO implemented the Experience Building Phase (EBP). In short a “no harm no foul” phase of “compliance” - as long as you tried. IMO’s review of findings from the EBP was not scheduled at MEPC 76. The future review of the EBP should lead to enforcement guidelines for the D2 standard and The Convention in general.
However, MEPC 76 was going to begin to hear about the expansion of the practice of vessels declaring their option to execute a ballast water “Contingency Measure” per their Administration approved Ballast Water Management Plan. Written into The Convention to allow a vessel experiencing a very extreme condition to continue operations and comply with The Convention, the rapid expansion of these practices is turning the backdoor into the front door. Allowing less capable BWTS to declare they are challenged on a chronic basis, undermining the intent of The Convention. Delay of this discussion at IMO will not help stake holders in the long run and may prolong the introduction of what will become compliance guidelines or practices.
The Innovation of Scienco InTank Offers the Least Impact to Operations with the Most Confidence of Compliance:
It will be twenty years after the IMO’s BW Convention was Final before meaningful compliance enforcement of the D2 standard is in place. For well over a decade the shipping industry has considered BWT must be in line and probably should have a filter, because that is all that has been available. The operational and compliance weaknesses of some of these systems is beginning to come to light, but there was nothing fundamentally better or different available.
Now there is:
The Type Approved Scienco InTank BWTS is filterless and effective in all types of water, using liquid sodium hypochlorite (NaOCl) solution as the Active Substance. The NaOCl is generated or stored on board. InTank offers simple BWT operations during the voyage with complete control over compliance. It is effective for all ballast water qualities for 24-hour TRO residence times, and marine and brackish water for TRO residence times between 24 and 60 hours.
The Scienco InTank allows normal ballasting and deballasting, no filtration or treatment during uptake or discharge. Treatment occurs during the voyage as ballast water is pumped from one ballast tank at a time, passed through the Dosing Module (DM), and returned to the same ballast water tank through in-tank nozzles. This circulation loop provides the means of adding TRO (NaOCl) to the ballast tank and mixing to achieve target TRO levels. Treatment happens over time and maybe adjusted for challenging waters. Neutralization is completed using the same circulation loop prior to discharge.
In conclusion, since the treatment and neutralization happen in the tank, a vessel can use The Convention’s A.3-5 Exception for same location ballast operations, a huge operational advantage for semi-submersible vessels – many Scienco/FAST customers own semi-submersibles. While the Scienco InTank does require some voyage time and a circulation piping loop, where the voyage time is available (36hrs + generally). It offers far more operational control than any typical in line BWTS. If there is an issue with the system you are at sea, it can be fixed with no impact to the schedule. The vessel retains complete control over BW compliance while never having to use the BWTS in port. Simply a better, more robust way for a commercial vessel to achieve BW compliance.
Installation footprint is small: An EC cell and DeChlorination Module, installed anywhere in the machinery space or a house. And a Dosing Module with circulation pump close to the ballast line / in the pump room.