Ballast water treatment system implementation: 'the gift that keeps on giving'

Decades of regulatory development has brought the industry to the point where ballast water treatment system implementation is well underway, but closure is still a long way off. Speaking at a Riviera webinar, Choice Ballast Solutions (NETSCO) senior compliance engineer Debra DiCianna noted that ballast water treatment system 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 to understand is 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 (35%), 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 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.

Another of the many issues facing owners and operators looking to retrofit ballast water treatment systems is timing. Classification society ClassNK strongly recommends owners and operators do not leave the retrofit of ballast water management systems (BWMS) to the last minute. Its analysis shows an uncomfortable number of retrofit installations are due in 2022. As of the end of November 2020, 7,220 of the 9,159 ships registered with ClassNK are obligated to install ballast water treatment systems in accordance with the Ballast Water Management Convention. Among these, 3,982 ships have completed the installation of ballast water treatment systems, leaving 3,238 ships that still require BWMS to be installed.

Although the number of ships without ballast water treatment systems has decreased by 1,280 since August 2019, the installation deadline for these ships remains largely concentrated in 2022. As difficulties are expected in the installation of ballast water treatment systems if owners around the world wait until 2022, ClassNK recommends installing them well in advance.

In addition, plan approval applications are also expected to concentrate during this period, therefore early application is strongly recommended. “It is very important to plan in advance and provide constant updates to get everyone involved in the project. Everyone needs to know how to mitigate any delays,” said BioMarine Services director John Loaiza. “Communication is the key” he said.

These project management elements have become especially important during the coronavirus pandemic. In a survey, more than three-quarters of those polled agreed or strongly agreed they had delayed the execution of projects from start to end.

Crew training is another important aspect and does not have to be left until the installation is complete. “Start the crew training early – get them involved. They need to understand the maintenance of the system. They will be the ones operating it at sea,” said Mr Loaiza. He offered the following advice: before the commission testing, make sure the ballast water pipes are flushed and the tanks are clean.

Maersk Line project manager Shobhit Agarwal has been the ballast water treatment project manager for the group for the last three years. He said that a project starts “10 to 12 months before the start of the implementation of the project. We need to make sure all the drawings are class-approved, the specifications required by the shipyards are ready and all the technical clarifications with the shipyard are done,” he said.

The planning should also include the days and time required for superintendents to be on site. One of the first tasks is to assess the condition of the existing ballast water system – are the pumps, gauges, pipework and tanks pressure-tested and in good order? The commissioning engineer needs to track paperwork, including customs clearances and alert the commission testing laboratory in good time.

Before installation, any prefabricated parts should be accompanied by their certification: material, welding, pressure-testing and non-destructive testing certification. In a survey, nearly everyone (98%) agreed that prefabrication of piping and associated foundation materials for the BWMS is critical to a timely and efficient retrofit.

When the vessel arrives at the shipyard, the supervisor plays a critical role in preventing delays and ensuring the timeline is met. Mr Agarwal advised that some items can be forgotten. “Take into account the commissioning time for the ballast water treatment system – we have noticed this is not always taken into consideration while planning the job. It differs from maker to maker and a suitable time should be made available for commissioning, training crew and sufficient time to take the sample,” he said.