Ballast water treatment does not have to take place on board a vessel, but choosing an alternative solution is dependent on location, purpose and regulation
Ballast water management systems (BWMS) are grabbing the headlines across the maritime press at present, largely due to the wave of vessels that require their installation before new regulations come into force in October. However, it is important to remember that alongside the many certified systems that can be placed on board a vessel, alternatives exist that do not require onboard installation.
At a recent Riviera Maritime Media webinar on the subject of ‘Alternatives to ship-board ballast water treatment systems’, industry experts Choice Ballast Solutions senior compliance engineer Debra DiCianna and Glosten director of research and development Kevin J Reynolds explained how these systems can bring multiple benefits to owners and operators struggling to determine the best options for their fleets.
Ms DiCianna began by emphasising the options available in the US market, where discharge from an installed BWMS is forbidden. She said water from a US water source can be used as a treatment option but noted the ability to take this route was very limited and highly dependent on volume, among other factors. She pointed out that while onshore treatment is a legitimate option, and that MEPC has developed guidelines for ballast water reception facilities, there are currently no onshore reception facilities for ballast water to be found anywhere in the world.
Further, she explained that in the US, ballast water treatment was not governed under federal law; rather such ‘add-on systems’ are covered by a local regulation. “Once waste is moved from a ship to another vehicle it is no longer under [US] Coast Guard (USCG) regulations.” She noted ongoing discussions to centralise the issue, which would “make it a little bit easier on the different locations around the country, so it isn’t a port-by-port issue that has to be overcome,” but added no consensus had yet been reached.
Another obstacle which any alternative to an onboard system must overcome involves the simple fact many vessels sail all over the world. With limited availability of shore- or port-based treatment units, coupled with a lack of standardised equipment, many owners and operators would rather invest in an onboard option that does not impact their sailing schedule.
Considering the alternatives
What then are the alternatives to onboard solutions? An interesting proposition stemming from India involves introducing ballast water treatment boats, situated in strategic ports, which would allow vessels to travel around certain regions without the need for an onboard BWMS.
Ms DiCianna also drew attention to the Damen InvaSave solution, which offers mobile or land-based treatment units at specific ports. At present, most of the Damen units are situated in the Netherlands and France, and while Ms DiCianna agreed the system could quickly establish a presence in Europe, she felt the option was not suitable for every port.
The Damen solution is currently certified in accordance with IMO guidelines by the Netherlands; it does not have USCG type-approval. However, Ms DiCianna noted it would not matter if Damen did have had USCG type-approval because the system takes waste from another ship, which means it then falls outside of US regulations. “[Damen] could get USCG type-approval but it wouldn’t mean that they could use the system as it’s designed to be used,” she explained. “They would still have to go through each of the different ports to get approved to use it.”
While alternatives exist to onboard BWMS, any transition away from an onboard unit would require a strong incentive, likely in the form of regulatory requirements.
One such driver may derive from the need for contingency solutions to be in place for onboard BWMS.
“We do have to look at alternatives because problems will occur and an effective ballast water management plan must include contingency measures,” said Ms DiCianna. “When a problem occurs in this area, the first thing the USCG asks is “Does the ballast water management system plan include contingency measures?” and most of the plans we have seen do not include such contingency.”
It is an opinion shared by Glosten’s Mr Reynolds. He emphasised the risks of trying to resolve issues that had not been documented. “At the end of the day, if you are not documenting your plans and your contingency measures, you are kind of stuck. You really do not want crew or shore personal trying to figure out what to do ‘on the fly’”.
Mr Reynolds explained that contingency measures and alternatives to onboard BWMS are essentially two sides of the same coin. “They are related,” he said. “Contingency is what you need when you run into an unexpected event, be that filter plugs, or low UVT alarms going off for example. Alternatives are more about planning. Is there an advantage in going with a fixed ballast water system so you don’t have to take ballast water on board a container ship? Can you convert an existing container ship to fixed-ballast only, or locked in freshwater? Do you have an old vessel or an infrequent discharging vessel where you’re willing to do some alternative that’s perhaps a little more expensive on a case-by-case basis, but you don’t have to install a very expensive and disruptive ballast water treatment system? Or perhaps you are on a reliable fixed run in the Netherlands and it’s worth refitting your vessel to pair up to the Damen system?”
It is these factors – alongside locked-in, fixed ballast water, discharging to a facility, or using municipal water – that Mr Reynolds cites as the main areas of focus when considering alternatives to shipboard ballast treatment systems. And it is concerns such as having to manually transfer ballast water to trucks and barges to be disposed of onshore or offshore that drove Gloston to develop its own oneTank ballast treatment system, capable of mobile deployment for contingency or as an alternative to an onboard unit and tested on several vessels in the US.
Referencing the concept of barge-based treatment – which Mr Reynolds explained was similar in nature to other barge-based solutions such as bunkering – as an influence, he explained oneTank removes the barge from the equation and puts the treatment system into a box which is transferred to the vessel when needed.
Shore-based or mobile BWMS like this require vessels to have short connection and pumping arrangements, which presents additional challenges. Mr Reynolds explained that Glosten had conducted a study in California which focused on the standard of care while making a transfer. “It’s the same standard of care as if we were taking bunkers or transferring petroleum from a tanker to another facility,” he said. “You can’t be leaking ballast water; you can’t have hoses that break and as we know, ballast pumps are not designed for providing a lot of pressure, so it is a major challenge.”
Mr Reynolds lamented the absence of an international standard for shore connections and noted the effort spent on establishing such a standard for electrical short connections for cold ironing or shore power. “There’s been huge amount of effort to come up with international standards in those areas,” he said. “For ballast water, we need a similar effort to devise an international connection and allow personnel to be trained on making that connection safely. “
This raises the issue of liability and Mr Reynolds was asked if, when using the oneTank system, liability lay with the manufacturer or the vessel? He explained that the system is a temporary installation of a type-approved BWMS on a vessel. “As such, it is no different than using a regular BWMS and as would be the case in any other circumstance, the vessel master is in charge of the vessel and the owner carries the liability.”
However, he noted that it becomes a very different situation when taking a barge-based approach because once water transfers off the vessel there needs to be an exchange of responsibility for that water. “It becomes the responsibility of the municipality and falls under local jurisdiction,” he said.
As the webinar drew to an end, Ms DiCianna reiterated the importance of adequate planning and ensuring a ballast water management plan covers contingency measures. “At the moment a ballast water management plan can easily be appended to include a contingency measure because it’s not a requirement by the convention or by flag,” she said. “We have provided this service for a lot of ships and it helps plan for what to do when ballast water exchange is no longer an option, or when an issue with the ballast water management system occurs.”
It was a view shared by Mr Reynolds who stressed how a well-designed plan should also factor in proper crew training and the timely provision of spares. “I hope everybody now understands,” he said, “Contingency is unplanned, when something goes wrong; an alternative is something that you plan for because it’s the right fit for you.”
He concluded by highlighting the range of vessels which would benefit from an external BWMS as an alternative to a costly onboard, permanent solution. “There are a lot of vessels out there that don’t need to install a permanent treatment system if a decent alternative is available. These are the vessels that don’t discharge very often or are old; the semi sub rigs that are relocating on a very periodic basis, or barges relocating theatres from time-to-time and need to treat their water only periodically.”
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