Shipowners may have a sense of relief that, at least for retrofits, decisions on which ballast water treatment systems to select are not quite so urgent following IMO’s decision to defer implementation to the first available drydocking and special survey. But deciding on which technology and system to select still poses difficult questions.
Peter Hinchliffe, secretary-general of the International Chamber of Shipping (ICS) said to Ballast Water Treatment Technology: “The biggest problem facing owners in selecting ballast water systems is how to have certainty that the system you buy will comply with the actual requirements of the convention and port state control (PSC) inspections. There is concern that some systems, although type-approved, may not meet the requirements in practice in some conditions.”
He said that ICS is arguing for a system of safeguards at IMO that will change the requirement for port state control testing so that it only happens where there are clear grounds to believe that ships are not compliant. “The uncertainty about enforcement and testing makes it difficult for owners who need to make decisions on what systems to select,” Mr Hinchliffe said.
He stressed that the onus for selecting systems remains with owners. “The only advice at present is that owners should look first at the list of systems that have been type-approved. Then look closely at the relevant type-approval parameters for those systems. Then they need to look closely at the operating conditions in which the system will be used on its vessels. Owners need to ensure that the system they select will meet the requirements in those operating conditions. As an extreme example, owners of ships operating in the Great Lakes should not select systems that do not meet the discharge standard. But, amid the current uncertainty of exactly how and when ballast water will be tested and how PSC will enforce the regulations, owners face difficult decisions.”
In its publication Understanding Ballast Water Management, Lloyd’s Register sets out a list of considerations that owners should take into account when selecting a BWT system. They include the physical and operating characteristics of the vessel such as ballasting and deballasting flow rates, capacity, space requirements such as footprint and ballast volume, and flexibility for locating system components. Power availability, effects on tank structures and coatings are also important. Operational aspects such as crew workload and training, safety, need for consumables, spares and servicing should also be considered. The final decision will also take into account capex and opex and the likely availability and delivery times for particular systems as demand increases closer to implementation deadlines.
BWT system options should be factored in when planning newbuild designs. For retrofits, owners need to consider what modifications might be necessary to install systems and where equipment and related pipework will be located.
Shipowners will need to find out from suppliers the system capacity, power consumption, any impact on ballast tank coatings, any chemicals required, estimates of the reduction in the vessel’s ballasting/deballasting rate following installation of the treatment system and a description of any mitigation measures, including pressure drops and the effect that the introduction of the treatment equipment will have on ballast pump suction and delivery performance.
This information will show whether additional generator capacity is needed: electrolytic, UV and advanced oxidation processes are likely to incur significant power requirements. Power requirements are the biggest operating costs for BWT systems, but LR warns that owners should be careful when interpreting and comparing cost information from suppliers and there are differences in how they are calculated.
It says that particular care should be taken when ships are likely to operate in fresh water that the system is capable of meeting the requirements and if additional services are needed to do so.
The US has attempted to address the uncertainty to some extent by requiring BWT systems to demonstrate that they meet the required discharge standard before gaining US type approval using the Environmental Technology Verification protocol. The problem for owners is that some systems that have been tested under this protocol have failed despite having previously gained IMO type-approval. Owners that have invested in these systems in good faith could therefore face a problem in future as their systems might not be accepted in the US and elsewhere.
Acknowledging this dilemma for owners, the US has agreed a five year waiver for IMO-type approved systems. But that does not necessarily help owners that have made, or need to make, major investment decisions for systems that are expected to be in operation for a great deal longer than five years.
A specific issue arising from the early testing in the US is that some UV systems that have been type-approved do not meet the discharge standard in actual operating conditions. Part of the problem is that while IMO requirements accept that UV treatment can make organisms unviable, the US rules go further and require that organisms are killed. This could mean that UV systems will have to be more powerful, with UV lamps upgraded and therefore more costly to gain US approval, giving owners a further decision to make when selecting a system.
Intertanko has said that this uncertainty over type-approved systems puts owners in difficulty when choosing a system. It is particularly concerned that those owners that have heeded advice to install systems early could be penalised if their systems do not meet the standard when testing starts in earnest. The message for owners is that IMO type-approval in itself does not guarantee that the system will meet the standard.
BWT system suppliers are aware of the challenges owners face in reaching decisions on which systems to select and when to go ahead. Darren Jacks, product manager of ballast water management systems at Wärtsilä said: “Our advice to owners is to make vessels [ready for] ballast water treatment now and then put the system in when it is required. This allows owners to spread the cost. We can do hot works on vessels during drydocking. The system can be installed later when the vessel is in service, with no downtime as the hot work will already have been done.”
The IMO amendment placing the installation date at the IOPP (pollution prevention) survey means that each vessel can be considered according to its own anniversary dates. In some cases this will allow part or full installation to be carried out during planned drydock schedules. The installation can be done without taking the ship out of the water, while alongside in port or at sea. Planning these projects in advance can save considerable time and money.
The uncertainty owners face is reflected in advice being offered to owners from various quarters. The UK P&I Club points out that BWM plans and systems must be ship-specific. Owners must consider not only the cost of the system itself but ancillary costs such as additional energy supplies, training, installation, drydocking and surveys.
“BWM systems complying with the convention standards may still fall foul of more stringent standards set in the US and other countries,” the club warned. “Shipowners who trade to these jurisdictions must, therefore, install systems that meet these more stringent standards.” BWTT
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