Decades of regulatory development have brought the industry to the point where ballast water treatment system implementation is well underway, but closure is still a long way off, said experts at Riviera’s What’s next for the ballast water sector? webinar
The webinar was sponsored by Atlantium Marine and by Netsco naval architecture and its associated company, Choice Ballast.
Ballast water treatment system provider Atlantium Technologies chief technical officer Ytzhak (Itzik) Rozenberg gave an overview from the manufacturer’s perspective on the installation timeline and the implementation of ballast water treatment regulations.
The timeline starts with the two to six months required to manufacture a UV-based or electrochemical ballast water treatment system. On the ship side, one to three months is required for concept, 3D scans and detailed drawings; with two to three months for the purchasing process and ancillary materials. Finally, there is the installation in drydock, which can be two to three weeks; with up to a month of training, commissioning and bedding in on the voyage.
The most pressing current issue is that the Covid-19 coronavirus pandemic has created delays.
“The US Coast Guard has realised this is an issue and is granting a one-year extension on request and an additional year if there is justification,” he said.
IMO will also grant a request for a delay from the flag state.
He noted that in 2020 there was another milestone for ballast water treatment, the requirement from 28 October 2020 for newbuildings to only be fitted with ballast water systems that meet the revised G8 guidelines or the stricter Ballast Water Management System Code (BWMS Code). Of those surveyed, 22% had difficulty in sourcing and fitment before the deadline but 78% had been able to meet the deadline.
Under D-2 testing, the water is sampled at the inlet and outlet, and these sampling points are provided in the Atlantium Purestream ballast water management system.
EnviroManagement vice president Marcie Merksamer noted that the ballast water treatment industry is now effectively in the implementation phase.
“We are seeing a lot of installations. Commissioning and operating the systems will be a normal practice. Another part of implementation is compliance monitoring. These aspects of implementation are very important because they lead us to experiences,” she said.
In a survey during the webinar, all respondents agreed that their vessels had undergone a Port State Control (PSC) inspection of the ballast water treatment system.
Ms Merksamer noted that in addition to stakeholders’ experiences, there will be new input from compliance testing and PSC testing.
“That is a really important next step, because where do we go from there? Hopefully, we make improvements to the regulations,” she said. “That is the purpose of the IMS experience building phase. It specifically says we are going to gather data, add that into the information loop and identify areas where the ballast water convention might need to be modified so that we can facilitate practical implementation,” said Ms Merksamer.
In the US, the Environmental Protection Agency has issued regulations for the US Coast Guard to follow. Under the US system, all stakeholders have an opportunity to comment on the regulations through their State Administrations. Ms Merksamer said, “I want to encourage all stakeholders, whether you’re a treatment system manufacturer, a shipowner, a scientist or installer, to put that information to your national administrations in the United States process.”
Ms Merksamer also tackled the confusion around Revised G8. “The differences between the revised G8 and the code is that the language that was “should” and “may” was converted to words like “shall” and “must”, she said.
Choice Ballast Solutions senior compliance engineer, Debra DiCianna noted that ballast water implementation was “the gift that keeps on giving.” In particular, the Covid-19 coronavirus pandemic has messed up installation deadlines, she said.
“We have heard of a few clients that, because of port restrictions, the ballast water management system equipment was just placed somewhere on the ship and nothing was connected,” she said.
But what Ms DiCianna wanted clients and operators in general to understand, was that compliance starts with the documentation. “The best way for you to have a compliant operation is to make sure the paperwork is in order. We have found that if the paperwork is not complete, when you get into an inspection, the officer will raise more questions.”
Returning to installations, Ms DiCianna noted that MEPC Resolution 372 required that all ballast water management systems installed on or after 28 October 2020 had to be approved according to the Code. What does ’installed’ mean? “The word installed means the actual date of delivery of the ballast water management system to the ship,” she said.
Those attending the webinar agreed that ballast water treatment installation has presented challenges. These ranged from serious challenges (5%), significant challenges (36%), and moderate challenges (32%) to low level challenges (23%) and the lucky few with no challenges (5%).
Those challenges are ongoing for the early movers who fitted ballast water treatment systems prior to the US Coast Guard giving type-approvals. These systems have been granted US Coast Guard alternate management systems (AMS) status, but the status does not last indefinitely. The systems are on a five-year lifespan from the vessels’ compliance dates, and some have been granted an extension for eight or nine years, but new AMS extensions are unlikely.
“Upgrading from a US Coast Guard accepted management system to US Coast Guard type-approval is not just a paper exercise. Upgrading will include new operating manuals, a nameplate that is provided by the manufacturer,” said Ms DiCianna. It does not mean, Ms DiCianna said, making up your own nameplate in the workshop.
The panel was asked when the US would clarify its stance on adding the MPN testing method to that of the stain test already in use by the US Coast Guard, and which the US Coast Guard in its draft policy letter to the Senate passing VIDA insists is the only viable method of testing ballast water. The panellists noted that in the US, the regulatory timeline can be loose, and the response is already around a year late. The US Coast Guard is responsible for the response, but do not expect anything soon, they said.
Taking a longer-term view of ballast water treatment, the panel was asked: what do you think will be the ballast water issues that will be discussed at MEPC in five years’ time?
Mr Rozenberg replied that, by that time, there will be a body of operational experience of ballast water treatment systems. He felt there would information gathered from the biological ability of the systems, which will allow assessment of the impact on the aquatic invasive species.
Ms DiCianna noted that a long-term issue surrounds the number of manufacturers left in the ballast water treatment sector. How will installed systems be upgraded if the manufacturer is no longer around or if the operator wants to change the filter system?
“That’s what I see is the longer a longer-term issue with systems,” she said.
Ms Merksamer noted that experience has shown that ballast water regulations develop very slowly. “Modifying a convention is a big deal. I do think that we will be working on this at IMO level for a while,” she said. That includes the monitoring process. “I also think that as we gain experience and PSC gains experience with compliance monitoring, we will see that topic utilised as input to the IMO,” she said.
As a takeaway, Mr Rozenberg offered the following: the industry is facing the immediate short-term issues of Covid-19, installations and commissioning but must not forget the long-term goal is to provide an efficient biological barrier.
Ms DiCianna noted that ballast water treatment is one of the most complex engineering challenges on a ship, and it is important to remain open to new ideas, to avoid repeating mistakes and to maintain dialogue with all parties involved in the process.
Ms Merksamer said the process needs to be looked at holistically and for owners to be especially mindful of crew training as the next phase is implementation. As more ships operate ballast water treatment systems, it is vitally important that the experience is communicated back to stakeholders, she said.
“It is so important that information is brought back to the regulatory community so that whatever the challenges are, we can work with the agencies to understand them, and how we can improve the regulation. Please take advantage of the opportunities to work with your national administrations and then use those public comment periods and opportunities to submit comments to the regulators,” she said.
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From left to right: Ytzhak Rozenberg (Atlantium Technologies), Debra DiCianna (Choice Ballast Solutions) and Marcie Merksamer (EnviroManagement): (Image: Riviera)