Ballast Water Treatment Technology 2016

Approval

2016 A supplement to Marine Propulsion & Auxiliary Machinery

“There is no system that a shipowner can use to comply everywhere. For a global industry, that is a big problem.” John Butler, president and CEO, World Shipping Council, see page 54

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contents2016

For more articles visit www.ballastwatermanagement.co.uk Ballast Water Treatment Technology 2016

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Comment5 Is there life after BWMC?

Best of the web6 Ballast water convention may not need more ratifications; No change to US

ballast discharge rules before 2018; BWMC: just 0.18 per cent now needed

7 Cathelco ditches MPN analysis for USCG tests; Four BWMS makers lodge

USCG appeals; BWMS makers launch campaign to oppose USCG’s testing

stance; US type-approval costs halt BWMS development; USCG ruling has

made class societies cautious

Regulation9 Twelve years old and counting

11 US rules in place but troubled waters ahead

12 Supreme Court dilemma for EPA

Environment15 It is not too late to make a difference

16 Fouling is fair game for travelling aliens

17 Fishing for answers

Operators forum20 Operators look for the right solutions

22 Owners choose systems to suit their specific requirements

Port state control25 Port states are unsure on testing methods

26 Case study: Orkney Islands are clear about ballast discharges; Orkney’s

legal basis for ballast control

Suppliers forum29 Managing turbulence in ballast water treatment; Suppliers gear

up for ratification

30 Enquiries surge as IMO target nears; USCG has set the global standard

31 In it for the long haul

contents

Disclaimer: Although every effort has been made to ensure that the information in this publication is correct, the Author and Publisher accept no liability to any party for any inaccuracies that may occur. Any third party material included with the publication is supplied in good faith and the Publisher accepts no liability in respect of content. All rights reserved. No part of this publication may be reproduced, reprinted or stored in any electronic medium or transmitted in any form or by any means without prior written permission of the copyright owner.

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Published April 2016

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Ballast Water Treatment Technology 2016 For more articles visit www.ballastwatermanagement.co.uk

Technology35 A rough ride for UV

38 Innovation is in short supply

39 Taking care over components

System selection40 US stance adds to owners’ difficult choices

Case studies45 US type-approval: getting the testing done

46 Installation tested yard’s project management

49 Coping with challenging environments

50 OceanSaver provides a retrofit for Provalys

Opinion53 It is time to choose your BWMS

54 Shipowners are caught between politics and science

USCG type-approval56 What to expect during USCG type-approval tests

57 Buyer beware; Auditing the auditors

After-sales service58 Tips for good service

Containerised systems61 BWC brings boxed ballast to barges; containerised BWMS simplifies

installation; Ballast connector heralds ‘a new era’ of BWMS

62 Shipboard tests needed for port solution

Costs and benefits64 Counting the cost of ballast treatment

65 Manufacturers worry over mounting costs

Directory67 A digest of available systems and their type-approval status


‘Few owners would want to fit systems that they knew prevented them from entering US waters’

Paul Gunton, Editor

approval of BWMSs have been amended before and changes to them now being drafted will bring IMO’s requirements closer to the USCG’s. It remains to be seen whether systems that hold type-approvals to IMO’s standards will be able to retain them when the goal posts have moved. What shipowner would fit a system that might not be acceptable anywhere?

Meanwhile, USCG’s stance on the ‘most probable number’ (MPN) analysis technique put a halt to the only three USCG type-approvals currently in progress and prompted many manufacturers of UV-based systems to rethink their testing strategy. At least one has given a guarantee that it will have secured USCG type-approval by the end of 2017 as a pre-condition in a big fleet contract, but its chief executive declined to detail the terms of that guarantee.

If BWMC does reach its tonnage target during MEPC 69, it will come into force in April 2017. If the revisions are then sped through, a revised convention might be in place in 2018. That is the year by when the EPA must update its rules on ballast water discharges, in response to a ruling in October 2015 by the 2nd US Circuit Court of Appeals in New York that the EPA had acted “arbitrarily and capriciously” in setting the terms of its 2013 Vessel General Permit (VGP) – specifically that it had not considered shore-based treatment solutions.

Some in the industry have long thought that shore-based systems would be the best option, and I have heard a growing number of positive views recently about that prospect. Therefore, if the EPA eventually makes that a regulatory reality, we will enter a very different arena: one in which owners need not fit BWMSs that are compliant everywhere, since they can use shore-based equipment to meet local standards where necessary. Or not fit BWMSs at all.

If that is the outcome of IMO revising BWMC and a court case in the US, much of what we have assumed about ballast water management goes overboard. BWTT

I am writing these remarks in late March, a few weeks before IMO’s Marine Environment Protection Committee (MEPC) gathers for its 69th meeting in

April. It may become a pivotal gathering. The Ballast Water Management Convention (BWMC) stands just 0.18 per cent of the world fleet short of its 35 per cent threshold and any states planning to ratify it may choose MEPC to grab their moment, pushing it over the line.

Even if MEPC does not inspire more ratifications, the convention could drift into force, since IMO is now reviewing flag states’ tonnages every month – instead of annually – so everyday changes in registered tonnage could ease the total to 35 per cent.

Then what happens? Suppliers will finally ramp up production and hope for a return on their long and expensive investments; shipowners will scramble for yard berths to retrofit ballast water management systems (BWMSs); and, finally, flag states that have been reluctant to ratify will fall into line and sign up. And that’s that.

Not quite. Most accept that the BWMC will never be the global standard. That has been set by the US, with its more stringent standards, drawn up by both its Environmental Protection Agency (EPA) and the US Coast Guard (USCG). While there may be a small market for systems that are BWMC-compliant but which do not meet USCG requirements, few owners would want to fit systems that they knew prevented them from entering US waters.

Of course, BWMC’s shortcomings are being addressed. Because of the way IMO conventions work, although MEPC could approve amendments, they can only be adopted once it has come into force. There is a lot of work being done on preparing for that moment so that the convention can be amended quickly and effectively.

Guidelines do not have to wait until then to be amended. The G8 guidelines covering

IS THERE LIFE AFTER BWMC?

COMMENT | 5


6 | BEST OF THE WEB

BEST OF THE WEB ballastwatermanagement.co.uk

BWTT WEB NEWS COVERS CRUCIAL CHANGES

Ballast water convention may not need more ratifications

IMO’s Ballast Water Management Convention (BWMC) could enter into force with no further flag state ratifications, IMO’s secretariat confirmed to BWTT.

In a break from its normal procedures, it is now updating its database of flag state fleets every month, instead of at the end of each year. As a result, it is possible that – due to the normal daily variations in flag state tonnages – the percentage covered by states that have ratified the BWMC could pass the 35 per cent threshold as a result of an end-month reappraisal of its existing parties.

The policy affects all IMO conventions, although none is as sensitive to small changes in the data as the BWMC.

http://bit.ly/BWTT-numbers

No change to US ballast discharge rules before 2018

No changes will be made to US rules on discharging ballast water until 2018, despite a US federal court ruling in early October that the US Environmental Protection Agency (EPA) had acted “arbitrarily and capriciously” in setting the terms of its 2013 Vessel General Permit (VGP). A spokesman for the EPA told BWTT: “We expect to renew the VGP when it expires in 2018.”

The 2nd US Circuit Court of Appeals in New York said that the EPA had been wrong to follow an international standard governing the discharge of harmful organisms, although technology was available to adopt a higher standard – specifically that it had not considered shore-based treatment solutions. It ordered the EPA to issue a new Vessel General Permit (VGP) but allowed the existing VGP to remain “until the issuance of a new VGP,” without setting a deadline.

http://bit.ly/BWTT-EPA2018

BWMC: just 0.18 per cent now needed

IMO’s Ballast Water Management Convention (BWMC) is now just 0.18 per cent short of its 35 per cent target to trigger its entry into force. Belgium became the 48th state to ratify the convention on 7 March when its UK ambassador, Guy Trouveroy, handed over the instruments of accession during a meeting with IMO secretary-general Kitack Lim at the ambassador’s residence in London.

This brought the total tonnage represented by states that have ratified the convention to 34.82 per cent of the world fleet.

The next day, Fiji also ratified the convention. This brought the number of ratifications to 49 but, since the country has no registered tonnage, Fiji’s ratification did not move the convention any closer to its threshold.

http://bit.ly/BWTT-Belgiumhttp://bit.ly/BWTT-Fiji

Since the 2015 edition of Ballast Water Treatment Technology, a dedicated website has been launched providing up-to-date news, a monthly newsletter and free access to industry white papers on a wide range of topics relevant to ballast water treatment (www.ballastwatermanagement.co.uk).

From its launch in July last year, its coverage has often led the debate around many of the technical, commercial and

regulatory developments during what some see as the most significant period in the run-up to the anticipated entry-into-force of IMO’s Ballast Water Management Convention (BWMC).

These pages highlight some of the themes that have featured on the website in the past few months. BWTT’s editor, Paul Gunton, said: “We have aimed to get behind the headlines to see their real significance for our readers.”

Fiji’s high commissioner to the UK, Jitoko Tikolevu (right), delivered the instruments of accession for BWMC to IMO secretary-general Kitack Lim in March (credit: IMO)


Charles Haas (Drexel University): “MPN assay has been used in microbiology for well over a century” (credit: Drexel University)

Cathelco ditches MPN analysis for USCG tests

BWMS manufacturer Cathelco has submitted a letter of intent to the US Coast Guard (USCG) to confirm it plans to begin testing its ballast water management system (BWMS) for USCG type-approval for its UV-based system.

It has chosen not to use the ‘most probable number’ (MPN) analysis technique used for some other UV-based systems – and which Cathelco itself used for its IMO type-approval tests – because of the USCG’s rejection of that technique in December. Instead, its tests will be carried out using the FDA/CMFDA methodology, which tests whether organisms are alive or not.

A spokesman for Cathelco told BWTT the USCG’s decision had been an important factor in opting for a different method for these tests. “We wanted a system that would be accepted everywhere,” he said.

http://bit.ly/BWTT-Cathelco

Panama’s register supports BWMC

Panama’s ship register has recommended to the country’s parliament that it should ratify IMO’s Ballast Water Management Convention. Speaking to BWTT in late March, the country’s ambassador to IMO, Arsenio Dominguez, said that the proposal had been presented to parliament earlier that month but no date had been set for a debate. “Approval of ratification is expected,” he said.

The register first made this proposal in January, when Mr Dominguez said that it normally takes two or three months to complete all the parliamentary stages for ratification to be completed.

Four years ago the country was also preparing to ratify the convention but wanted clarification on testing guidelines. “That has changed,” Mr Dominguez said.

http://bit.ly/BWTT-Panamahttp://bit.ly/BWTT-Panama2

Suppliers differ over UV power requirements

High-powered UV lights “make the biggest difference” in determining how effective ballast water management systems that use this technique can be in dealing with organisms, the chief executive of Optimarin, Tore Andersen, told BWTT in November.

Its system consists of individual chambers, each with a 35kW light and a throughput of 167 m3/h. That is about four times as much power as some other systems for similar throughputs.

At about the same time, Panasia completed land-based USCG type-approval tests in sea water for its UV-based GloEn Patrol. This refutes “the misunderstanding that UV technology is able to meet USCG requirements only with high power consumption,” it said in a statement provided to BWTT .

http://bit.ly/BWTT-UVHighhttp://bit.ly/BWTT-UVLow

Four BWMS makers lodge USCG appeals

Four ballast water management system manufacturers that use UV treatment technology have lodged appeals against the US Coast Guard’s (USCG’s) decision to reject the ‘most probable number’ (MPN) analysis method.

Three of the companies had completed all their preparatory work and applied for type-approval on the basis of MPN data.

The four companies – Trojan Marinex, Alfa Laval, Desmi Ocean Guard and Hyde Marine – supplied more than 7,000 pages of documentation as part of their appeal process, along with a number of support letters, including one from Charles Haas, head of the Department of Civil, Architectural and Environmental Engineering at Drexel University’s College of Engineering in Philadelphia.

He wrote: “MPN assay has been used in microbiology for well over a century. It can be reliably carried out by technicians with only a small degree of training, and is able to detect low concentrations of viable micro-organisms.”

http://bit.ly/BWTT-Appeals

USCG ruling has made class societies cautious

Since the US Coast Guard (USCG) decided in December not to accept the ‘most probable number’ (MPN) method of testing the effectiveness of ballast water management systems (BWMSs), classification societies “are not as keen to go on the record to explain the situation,” said Tore Andersen, chief executive of BWMS manufacturer Optimarin in January.

This caution was reflected in a statement from Optimarin in which he quoted an environmental solutions expert “at one of the world’s leading classification societies” who, he said, had agreed to speak “only on the condition of anonymity.”

Hitherto, class societies have published substantial amounts of information and advice about all aspects of ballast water treatment and testing but, since the USCG decision, “we have a feeling that class societies are a little afraid now to take [a view] on whether MPN is right or not,” Mr Andersen said.

One society that has not been afraid to express a view is DNV GL, which said in a statement on 22 December: “The MPN method is the most relevant method and is a reliable way of evaluating the performance of UV technologies.”

http://bit.ly/BWTT-Cautious


REGULATION | 9

TWELVE YEARS OLD AND COUNTINGThe Ballast Water Management Convention is approaching its teenage years as entry into force nears

I n February this year, the IMO’s Ballast Water Management

Convention celebrated its 12th anniversary. Celebrated is perhaps the wrong word since the convention has not yet come into force and, even before it has, negotiations are underway to amend its terms and definitions.

In the US, where similar but different rules already apply, changes are also on the agenda and still no system has achieved type-approval under existing regulations. Towards the end of 2015, a ruling by the US Coast Guard suggested that many systems already approved under IMO guidelines would not be acceptable under US rules. The way was left open for a challenge and this is being pursued by four of the affected manufacturers.

Before the November 2015 IMO Assembly meeting, the status of the IMO convention had stood at 44 states accounting for 32.86 per cent of the world fleet by gross tonnage, relying on fleet figures issued in February 2015 and based on end-December 2014 data. The addition of three more signatories in November – Indonesia, Morocco and Ghana – looked almost certain to have triggered the coming into effect after a long 11 year wait.

According to another set of data – prepared in mid-2015 for the purpose of calculating flag states’ financial contributions to IMO and not for assessing the status of conventions – it appeared that these three were sufficient to take it past its 35 per cent target.

So the then IMO secretary general Koji Sekimizu – who had pushed for full ratification of the BWMC throughout his tenure – called for a recalculation to determine the state of the world fleet as at

24 November: the day when Indonesia had ratified the BWMC. This was a matter of a few weeks before the annual end-year analysis was due.

By mid-January, IMO announced that the best that could be hoped for was that the 47 states accounted for 34.56 per cent of the world fleet, later reduced to 34.35 per cent when the analysis was completed.

Since then, on 7 March, Belgium has ratified the convention, taking it to 34.82 per cent, followed the next day by Fiji, which has no registered tonnage to its name.

Belgium had been one of at least three nations that had at one time or another been rumoured to be ready to sign. Its signature, or either one of India or Finland, was expected to be sufficient, yet the reality of Belgium’s ratification still left the convention 0.18 per cent short. In a change from tradition, that figure was based on global fleet data for end-February and IMO’s secretariat advised BWTT: “due to the unusual situation with BWMC, we are getting monthly updates” on the world fleet from its data supplier, IHS Maritime & Trade.

This means that, each month, the status of the convention’s ratifications will be reassessed and the percentage is likely to change – up or down – as a result. There is thus the possibility that its entry into force will be triggered not by a specific flag state’s ratification but by one month’s normal variations in flag states’ registered tonnage.

At the time the November recount was in progress, Panama’s ship register authorities appeared ready to sign and submitted a proposal to the country’s parliament. With around 20 per cent of the world fleet under its flag, ratification by the largest open register would mean that the convention had all

IMO secretary-general Kitack Lim (left) received the instruments of accession to the BWMC from Guy Trouveroy, ambassador of Belgium to the United Kingdom (credit: IMO)


10 | REGULATION

the support it needs and will enter in to force within a year. At the time of writing, in early March, Panama has not ratified the convention.

It would seem that Panama’s intention to sign has some caveats that need to be resolved before pen is put to paper. Among the concerns are the ongoing issues relating to the G8 type-approval process, the status of systems that have been installed before any changes to the type-approval process is put into effect and progress on aligning the IMO’s BWMC requirements with those of the US authorities.

This latter point is one that may be impossible to settle in the short term because the US rules themselves have been called in to question on two fronts. With regard to the other potential sticking points, it may be that some progress will be made at the 69th meeting of IMO’s Marine Environment Protection Committee (MEPC) which was scheduled for 18-22

April, after this publication had gone to press.

Of course with so little of the convention’s gross tonnage condition to be satisfied, it may well be that a flag state among the majority of IMO members that have yet to sign will fire the starting gun at that gathering.

Should that happen there could well be some dissent from industry bodies for it is clear that the distrust over the robustness of the regulations is growing in many quarters. The problems that the US authorities are facing are covered elsewhere in this issue but IMO is far from clear in what it requires. At MEPC 69, the Correspondence Group tasked with re-examining the G8 type-approval guidelines was scheduled to present its report.

That report is a 56-page document but, while there are many issues that it suggests could be adopted at the April meeting, it also has an annex that identifies no fewer than 24 items

that require further work. Those 24 items recommend deciding on how best to incorporate testing in different salinities and temperatures, the possibility of limiting type-approval to situations that a specific system has been demonstrated to operate in successfully, a new definition of ‘viability’ as applied to organisms, reconsidering the problems caused by suspended solids in ballast water and standardising testing methods and protocols, including making tests more aligned to practical operating conditions.

As can be seen from the US Coast Guard’s Alternate Management System (AMS) status given to numerous systems, the majority are not approved for use in fresh water. If the idea of approving systems also for only certain temperature ranges is adopted, some say this will lead to a confusing and chaotic situation: they question what remedial action

might be taken if a ship takes ballast in conditions that its treatment system is not type-approved for. Another question concerns who is responsible for confirming the ambient conditions at the time, particularly as a ship working in a tidal environment might experience several changes of conditions while ballasting.

It would seem that there is much still to be done before the current situation is seen as being workable and fair by the industry and by flag states. However, the fact remains that, according to IMO protocols, it is impossible to change the wording of the convention until it has been ratified. The fear for the industry is that even if all the needed changes were agreed beforehand, there is no guarantee that states will allow them to be made once the convention comes into force.

Port states that feel a need to protect their interests and which have a distrust of the efficacy of treatment systems may take action, as Iran did recently. Because of a cholera outbreak in Iraq, it required all ships coming from there to exchange ballast 50 miles offshore and remain at anchor until ballast water testing could be carried out. It was perhaps a sensible precaution, but it was one that should not be necessary if treatment systems work as they are supposed to. If that experience is repeated often enough after the convention takes effect, shipowners might wonder why they have laid out millions of dollars on something that is not trusted.

Whenever the IMO convention is finally ratified, there is a 12-month period before it comes into force and, depending upon a ship’s age and ballast capacity, potentially a further 12 months after that when the ship’s International Oil Pollution Prevention Certificate must be renewed. BWTT

The moment some thought brought the BWMC into force: Indonesia’s minister of transport, Ignasius Jonan, delivers its instrument of acceptance to the then IMO secretary general Koji Sekimizu (credit: IMO)


REGULATION | 11

US rules in place but troubled waters ahead

I n complete contrast to the situation in the rest of the world, the US has a functioning regulatory system in place

but currently not a single treatment system has successfully navigated the full type-approval process.

Under the US regulations, ships with ballast capacities of between 1,500m3 and 5,000m3 have had to comply since 1 January 2014 and all newbuildings have had to comply since 1 December 2013. After that, the system used must be US Coast Guard type-approved, which could involve installing a new BWMS.

As a consequence of the lack of approved systems, the USCG has needed to implement an interim Alternate Management System (AMS) regime that allows treatment systems approved under IMO rules to be used for a period of five years. Granting AMS status is not automatic as each system has to be judged on its merits before the approval is issued. Approvals are generally granted to manufacturers, but it is possible for individual ships to apply as well.

Up to the end of January 2016, the

USCG had granted AMS status to 52 systems of all types. Each approval covers specified variants of each system but if the maker later switches to different components or if an original component is changed for something not included in the initial specification, the AMS must either be amended or it becomes invalid.

Because some electrochemical systems do not function well in every marine environment, the AMS approval is valid only for those environments where it should operate without problem. There are three categories – fresh, brackish and marine – representing the increasing salinity levels to be expected.

Only 13 systems (or 14, if the EX version of Alfa Laval’s PureBallast 3.0 system is counted separately from the basic variant) have been accepted for use in fresh water. Of the 13 systems, six use UV, three have electrochemical processes and the other four use either chemical dosing or mechanical treatment methods.

The breakdown of the different methods of operation for the systems accepted for use in freshwater is

interesting in light of the ruling recently issued by the USCG that many UV systems are unlikely to succeed in the US type-approval process. This is because of a fine distinction in the different terminologies of the IMO and US rules regarding the desired outcome of UV irradiation of organisms and the method used by some type-approval bodies.

At issue is something that has been seen as a stumbling block for some time and it seems remarkable that a definitive ruling was not made much earlier. Measuring the effectiveness of a ballast treatment system should be a simple case of every sample of treated ballast being tested for the presence of surviving organisms. The problem has arisen because many type-approval bodies have been using a method known as the ‘most probable number’ (MPN) for calculating survival rates whereas the US authorities currently only accept an alternative known as the ‘vital stain’ method.

The MPN method measures the number of viable phytoplankton cells in a sample, via their ability to reproduce. It is a formal mathematical calculation based on binary scoring data from a set of dilutions, and replicates from a sample.

In US ballast water management regulations, the current requirement for analysis of the organisms in the 10-50μm size class requires categorisation of organisms as being “living” or “dead,” rather than ‘viable’.

The Environmental Technology Verification (ETV) Staining Method (or ‘vital stain’ method) uses a combination of two fluorescein-based stains (known as FDA and CMFDA) to evaluate the status of organisms in the ballast water samples.

The stains will penetrate into organisms, where functional esterases (a specific type of enzyme) will convert them into fluorescent products that are retained by cellular membranes. Using epifluorescent microscopy, fluorescing organisms are enumerated as ‘living’

Evoqua’s SeaCure BWMS – seen here undergoing USCG tests last year – is one of 13 AMS-approved systems accepted for use in fresh water (credit: Evoqua)


12 | REGULATION

individuals. Any motile organisms observed are also counted as ‘living’.

In December 2015, the USCG publicly announced its decision that, following due consideration, it had decided the MPN method is not equivalent to the prescribed test as it “does not measure the efficacy of the BWMS to the performance standard required by the regulations.” However, while the decision has been made to disallow the MPN method, the USCG stated that this ruling of the Marine Safety Center is subject to appeal by manufacturers.

The decision has been criticised by those manufacturers that were relying on the MPN method during US type-approval. Some of them have joined forces to orchestrate a campaign to get the ruling changed and have established a website, http://mpnballastwaterfacts.com, publicising the problem. They have won support from academic institutions and the Chamber of Shipping of America and have appealed the USCG ruling.

The campaign has been criticised by some long-time opponents of UV systems and, while not necessarily criticising it, some other UV system makers – including two that are well advanced in the US type-approval process making use of the recognised vital stain test method – have not offered their support.

Solving the UV issue is not the only fly in the ointment with regard to ballast water regulation in the US. Last October a decision taken in the federal appeals court in New York in a case brought by a number of US non-governmental agencies against the Environmental Protection Agency (EPA) has major implications for future regulation in US waters.

The Natural Resources Defense Council, National Wildlife Federation, Center for Biological Diversity and Northwest

Environmental Advocates had sued the EPA over its 2013 “Vessel General Permit” governing ships’ releases of ballast water. The organisations argued that the current regulations are not sufficiently stringent and do not accord with the provisions of the Clean Water Act.

The ruling said that EPA had acted “arbitrarily and capriciously” when it decided in 2013 to follow the IMO standard governing the discharge of harmful organisms, though technology was available to adopt a higher standard.

The decision throws a huge spanner in the wheels of the US ballast treatment rules and processes and requires EPA to reconsider the whole issue from scratch.

While it does so, the current VGP rules can remain in place but these are due to expire at the end of 2018 so there is a degree of urgency needed. EPA has told BWTT that it will meet that deadline.

In line with the ruling, EPA is obliged to take into account its previous decision to set the technology-based effluent limitations (TBELs) at the IMO standard; its failure to consider onshore treatment for ballast water discharges; its decision to exempt pre-2009 Lakers from the TBELS in the 2013 VGP; its narrative standard for water quality-based effluent limitations (WQBELs) and monitoring and reporting requirements established by EPA for WQBELs.

Supporters of the MPN analysis method have established a campaigning website, http://mpnballastwaterfacts.com

The US Environmental Protection Agency (EPA) could seek a Supreme Court review of the appeal court’s decision. Such a course of action would be interesting because, although the EPA is more used to taking on industrial and commercial opponents such as mining and oil companies and has been encouraged in this by the current US administration, it may be uncomfortable in opposing environmentalists.

The possibility is made more intriguing because the death in February of Antonin Scalia, one of the nine Justices that decide Supreme Court cases, leaves the remaining eight split equally between conservative and liberal groupings. If President Obama is able to appoint a replacement

for Scalia – who was a conservative – it will likely be a liberal and would mean that the EPA on this occasion would probably be defeated.

The Republican party on the other hand believes that the appointment should be in the gift of the next president and have promised to oppose Obama’s likely choice.

Without a ninth justice, the split is likely to be 4-4 and would leave the current appeal court ruling in place. So it would seem that whatever course EPA takes, the current rules will remain to be followed but with the very real possibility that they could be reversed at some point in the not too distant future. BWTT

Supreme Court dilemma for EPA

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ENVIRONMENT | 15

IT IS NOT TOO LATE TO MAKE A DIFFERENCEALIEN SPECIES HAVE CAUSED ENORMOUS ENVIRONMENTAL DAMAGE, BUT BALLAST WATER TREATMENT CAN YET HAVE A POSITIVE IMPACT ON THE PROBLEM

by Stevie Knight

Is the transmission of marine species inevitable? Yes. So, is there any reason to keep pushing on with ballast water treatment systems? Yes, again. In fact, there is very good reason to be hopeful that it will be effective – even if that is

tempered by realism.What turns a visitor into an invasion is “largely a matter of scale”

explained Whitman Miller, a senior ecologist at the Smithsonian Environmental Research Center in the US. Although a single organism cannot usually take a new area by storm, he said, a number of larger or repeated releases may tip the balance.

Adnan Awad, director of the South African branch of the International Ocean Institute (IOI), offered such an example. “Looking at recent genetic studies it seems there were at least two introductions of the green shore crab into South Africa, and probably more than that, before it got a foothold,” he said.

Because of this, it is not a question of reducing the numbers of invasions to zero, but getting them down to a level where the native environment has a chance to adapt, Dr Miller said. “There’s biological push-back from the native community, competition or predation. The more undisturbed the habitat, probably the greater resilience.”

But discovering exactly how new species arrived is not always easy, although some, such as the zebra mussels that have wreaked havoc in the Great Lakes, are more obviously linked to ballast tanks.

“You are rarely watching an area to see the first invaders,” said Dr Miller. Initially low densities make trend analysis difficult for the obvious reason that the smaller the organisms are, the harder they are to spot, unless they are present in huge numbers. So by the time anyone notices them they are already established and deciding how they got there is often only ‘a best guess’ based on lifecycle and habits, he said.

This matters because they may have come in through circumstances that could have been avoided, explained Mr Awad.

Occasionally it can be nailed down. For example, a persistently reoccurring, local algal bloom was causing issues in Saldanha in South Africa. Since algae cysts are very robust and easy to pick up, ballast water fell under suspicion. But local scientists were

very reluctant to pin it on vessel movements so Mr Awad and his colleagues carried out detailed research.

They found that this algae was of a strain previously located only in US waters. Further, when the shipping routes were examined there were two vessels coming into the bay from the US. Tellingly, their logs showed that they had taken on water in the US algae bloom locations.

However he wasn’t doing this for the satisfaction of proving a point: he was more interested in highlighting the fact that ballast water issues were not just a problem for someone else, “but were relevant locally.” Further, armed with this knowledge, the response was specific and simple: “All that was needed was to tell the ships not to pick up ballast water in those particular places.”

While numbers are very difficult to track, “one thing that is becoming more obvious year to year is the increasing numbers of those that go on to become successful invaders across the globe,” Mr Awad said.

In fact, Dr Miller pointed out that the US National Exotic Marine and Estuarine Species Information System (NEMESIS) database has 450 invertebrate and algae non-indigenous species (NIS) documented with established populations in its tidal waters. This is a big jump from the 298 NIS that were reported by Ruiz et al in 2000. Further, these are only the reported ones: the real levels are probably much higher.

This was specifically a US study, but he believes that the trends are not limited to North America, although in less developed areas background data can be missing. Not only are emerging economies short on experience and resources, they are also in the firing line: as newly burgeoning areas start to attract big ships on new routes, faster transits with larger ballast tanks that hold more oxygen will help organisms survive the journey. “We are seeing the results of

The infamous zebra mussel causes several billion dollars worth of damage in Canada alone (credit: D Jude, University of Michigan)


16 | ENVIRONMENT

that already,” Mr Awad said.Dr Miller also pointed out that developing regions with high

levels of export or import activity warrant significant attention because of their potential for species transfer: bulk carriers coming in and out of oil, ore and forestry export points will often be discharging large amounts of ballast. A recent study by him and Gregory Ruiz – a zoologist at the Smithsonian Environmental Research Center in the US – also showed the Arctic may be vulnerable, because of melting sea ice, increased traffic and new corridors connecting the northern Atlantic and northern Pacific.

Although some areas have expressed concern about the resources needed to police the new regulations – something that Mr Awad said has made a number of developing regions wary of signing up to IMO’s Ballast Water Management Convention (BWMC) – information can help. The IOI is collecting data on technology, routes and trading partners for map-based databases using the geographic information system (GIS) protocol. These are tied into an easy-to-use system that helps port inspectors in places such as Africa, South East Asia and South America target their visits, rather than relying on visiting each vessel.

It is driven by a “three cylinder engine” explained Mr Awad. The first ‘cylinder’ is the ‘eco region’, which notes environmental similarity between calls. The second is the shipping information. This tells the inspector how long the voyage has taken, how frequent the ship’s calls are and if it is coming from the same place each week, plus how much ballast it is carrying. The greater the volume of ballast, the more problematic it will be and “one week away is riskier than four weeks’ sailing time,” he said.

The third ‘cylinder’ details where existing invasive species are. If there are established invaders in waters where the ship has ballasted, it raises the ship’s risk profile, he explained. “What is then shown is the risk from that ship’s ballast water in a range from 1 to 5, but it is also easy to drill down: you can look at the GIS map or the data behind it.”

Some areas seem to be doing better than others: some spots on the US West Coast – San Francisco for example – are interesting because they are bucking the trend. Although it has a long history of attack by non-indigenous species, “these appear to have plateaued – for example we haven’t seen many new planktonic invaders since 2005,” said Dr Miller, “so it’s possible that the ballast water exchanges that started taking place in the late 1990s are having an effect.”

Open ocean ballast water exchange works by swapping coastal

ballast (and coastal organisms) for open ocean water (and some pelagic organisms), setting up a habitat mismatch, so in theory exchanging coastal water and related biota for open ocean water and vice versa should hold visitors back from making themselves at home.

He admitted that “the scientific evidence is yet to confirm it” and that he does not yet have a large enough data set to verify the claim, but he said: “San Francisco is giving hints that ballast water exchange is working.”

Yet even that might have consequences. Mr Awad explained that although it is “hard to say exactly how much weight” should be attributed to them, some studies say ballast exchange may be sending coastal water into mid-ocean and helping create algae blooms where none existed before, while others point out that the narrowness of shipping lanes means that in some cases a vessel could be picking up the discharge from a ship ahead of it.

Both agree that ballast water exchange should be seen as just an interim measure, albeit one that is surprisingly effective in some circumstances: onboard treatment is now the only practical way forward.

Dr Miller is, generally, hopeful that this will produce results. It is a big problem, he agreed, but believes that it can be controlled. “If you treat ballast water, you will reduce the invasions. If you do something this big, you have to commit to it. But here we have a solution that isn’t particularly complicated, and – unlike many issues – we have the luxury of tackling it with engineering.”

Hull fouling is the next source of alien species to be put under the spotlight. Some say that the problem stems from when TBT antifouling was banned: at present, there is nothing around quite so good at killing off hitchhikers, they claim.

By and large, hull biofouling has not had the attention it probably deserves, despite clear evidence that this is a major driver of new incursions and on a par with ballast water.

“A variety of invertebrates and algae can cling to the hulls of vessels or in their interstices, like tunicates, bivalves, bryozoans, barnacles and, in some circumstances, even crabs and fish,” explained Whitman Miller, a senior ecologist at the Smithsonian Environmental Research Center in the US.

Again the numbers are tricky: while 12.5 per cent of non-indigenous species (NIS) in the US are said to be

‘almost certainly’ attributable to hull biofouling, (with ballast water accounting for 10 per cent of species invasions) both were possible vectors for an additional 77.5 per cent of them.

Only recently has there been some effort to focus on managing hull fouling invasions. Hull husbandry checks are being introduced in some places. California’s authorities, for example, already ask ships

when they last gave their bottom a once-over.

But the guidelines from IMO are voluntary and the path or rate for implementation of management and policies on biofouling are uncertain, according to Dr Miller. It seems that the difference in how seriously we are treating the two pathways is more about earlier political decisions than the vector’s ability to carry invasive species. BWTT

Fouling is fair game for travelling aliens

Whitman Miller (Smithsonian Environmental Research Center): “You are rarely watching an area to see the first invaders” (credit: SERC)


ENVIRONMENT | 17

A quaculture is especially sensitive to alien marine invasions said Adnan Awad, director of the South

African branch of the International Ocean Institute (IOI). Its impact is direct, and often irreversible, he explained.

While there are indications that some farms have moved or gone out of business, others are finding ways to adapt their methods. He cited some mussel farms located near a deepwater port, which found that tunicate seasquirt started to attach themselves onto their bivalves, out-competing them for food and holding back their development. They discovered a surprisingly simple remedy: pull the

ropes out of the water for a couple of hours a day and let the seasquirts die.

“It does take more manpower,” Mr Awad admitted, “but it reflects a trend: we have to accept we are now faced with living with alien species.”

However, assuming a geographic or market shift in favour of a geographical or trade direction could be misleading: crossovers can and do happen. For example, the comb jelly (ctenophore) mnemiopsis leidy caused the devastation of local fisheries when it hitched a lift from its native America to the Black and Caspian Seas in the 1980s.

As a return favour, a large predatory

FISHING FOR ANSWERS

The comb jelly devasted fisheries in the Black Sea when it arrived from North America in the 1980s (credit: A Vidar/Wikimedia)

ALIEN SPECIES POSE A PARTICULAR RISK FOR THE FISH FARMING INDUSTRY, SOMETIMES WITH DEVASTATING RESULTS


marine snail, rapana venosa, has (probably also via ballast water) returned from that region to Chesapeake Bay to feast on oysters and hard clams. It is not overwhelming yet, “but the Bay area fisheries are beginning to feel the impact,” said Whitman Miller, a senior ecologist at the Smithsonian Environmental Research Center in the US.

These impacts “can be quirky and not direct predation or competition,” explained Mr Awad. Take an algae bloom issue faced by South African aquaculture, for example: “The algae decreased the available oxygen so the oysters opened up more to breathe. This gave a parasitic worm a better chance of getting into them – it didn’t kill the oysters but it meant that they couldn’t be exported to the EU countries,” he explained.

Trying to hold back – let alone reverse – a trend ranges from ‘not easy’ to ‘nearly impossible’ and rearguard action is rarely effective.

But there are occasional eradication success stories. Dr Miller pointed to a bay in Australia where a small non-indigenous bivalve was caught in the act of setting up home: the authorities were able to close off the marina, use poison “and basically nuke it” into oblivion, he said.

But most attempts are not so successful. Mr Awad explained that the South African authorities recently spent a lot of money on seeing if trapping green shore crabs could dent their numbers: “The study, rightly, queried whether it was worthwhile to attempt a full eradication. The answer was that the population proved too resilient for this to be realistic or feasible.”

Smaller invaders can have truly devastating effects for aquaculture and fisheries. ‘Red tide’ – an algal bloom caused by pfiesteria piscicida, one of the more noxious dinoflagellates – does not just cause marine life to die: there have been human fatalities from ingesting

shellfish poisoned by it. However, some of the worst infiltrators

are invisible to the naked eye: viruses could be described as the nanobots of the biological world and can be extremely hard to deal with. Some experts believe that ballast water may have helped transfer viral hemorrhagic septicemia virus (VHSV) and infectious salmon anemia virus (ISAV) between regions.

This last especially can have overwhelming consequences for farmed salmon: the disease, first reported in Norway back in the 1980s, has found its way to Canada, Scotland, the Faroe Islands, Chile and the US; in fact some US farms hit by the virus have lost 70 per cent or more of their fish in recent decades.

Given all this, it’s no surprise then that the fishing fleet is beginning to be put under the spotlight. Trawlers can be large – and consequently the scale of their ballast tanks places them firmly in the same regulatory regime as other vessels, explained Tore Andersen, chief executive of ballast water management system manufacturer Optimarin. At the time of writing, in February, the company was installing its first UV-based BWMS on a new 80m fishing boat that will operate in the North Pacific, Gulf of Alaska and Bering Sea regions from its US home. “These vessels can travel quite a distance,” Mr Andersen said.

More intensive aquaculture processes can create a breeding ground for diseases that then infect the wild fish population. Studies on wild sockeye salmon have shown that they are now being hit by the highly infectious ISAV and the blame is being laid at the door of fishfarms, which have acted as the breeding ground for different, virulent strains of the disease.

However, alongside the farms themselves, aquaculture support vessels are also being implicated: in 2002 a study called Shipping and the Spread of Infectious Salmon Anemia in Scottish Aquaculture demonstrated a link between vessel visits and farm contamination, indicating that ballasting adjacent to fish processing plant or harvesting stations could be responsible for the spread of ISAV. Although infected detritus may also have remained in the fish holds or pipework, the study is unequivocal that these pathogens “are abundant in ballast water” and that “extensive ship traffic and lack of regulation increase the risk of spreading disease to animals raised for aquaculture and to other animals in marine environments.” BWTT

18 | ENVIRONMENT

‘Red tide’ algae bloom, such as this in Japan, kills marine life and can create toxins are fatal for humans (credit: Marufish)

THERE HAVE BEEN HUMAN FATALITIES FROM INGESTING SHELLFISH POISONED BY ‘RED TIDE’

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OPERATORS LOOK FOR THE RIGHT SOLUTIONSMany vessel owners are installing or planning ballast treatment systems, but few are using them to their full potential

by Steve Matthews

F urther delay in implementation of the Ballast Water Management Convention (BWMC) and continuing

uncertainty over enforcement of US rules, combined with the severe financial pressures on most shipowners and operators, means that many operators are continuing to put off making decisions on which ballast water treatment system they are going to install.

Most newbuildings now being delivered and ordered either have systems installed or have made provision for the space ready for the equipment and associated pipework. Together with those retrofit projects that are taking place, this means that the number of vessels with operable ballast water management systems (BWMS) installed onboard is slowly rising, though it is still only a small proportion of those that will ultimately have to use one.

Even so – and despite that fact that fuel costs have fallen significantly – the fine margins on which many ships are operating mean that owners are pursuing every possible saving in operating costs. The result is that, unless they are obliged to do so, for example by local regulations, ship operators are not routinely using ballast water treatment systems and thereby avoiding the additional costs from the energy that they consume. They are mostly only being activated for testing, maintenance and crew training purposes.

The key issue of whether systems will ultimately meet the operational requirements and satisfy port state control regimes around the world remains an area of doubt that worries ship operators, as they study the range of systems on offer and decide the most appropriate ones for each of their vessels.

Despite the ongoing regulatory uncertainty about technology approvals and implementation, Maersk Maritime Technology (MMT), part of the AP Møller-Maersk Group responsible for technical management of its huge and

diverse fleet, is well advanced in its preparations to ensure that it is fully prepared when the BWMS does come into force. The company is investing about US$500 million over six to seven years to achieve compliance.

Niels Bjørn Mortensen, head of regulatory affairs at MMT, said: “The major problem the shipping industry is facing in this context is that US Coast Guard (USCG) has not yet approved any equipment. A number of makers are being tested, but it is unknown when the first piece of US type-approved equipment will be available on the market.”

Maersk installed its first BWMS as long ago as 2010 and since 2012 its larger newbuildings have been equipped with BWMSs. Maersk said that so far it has installed about 30 systems on six different ship types. MMT is doing the groundwork in evaluating the technical possibilities and informing Maersk business units such as Maersk Line and Maersk Tankers what decisions to take.

Palle Wredstrøm, head of engines and propulsion at MMT and its technical lead in ballast water management initiatives, said that the system it has used is IMO type-approved, but, as with all other BWMSs, not yet USCG approved. He acknowledged that this means that it might end up in a situation where these ships, or at least some of them, will be banned from trading to the US unless the BWMS are replaced.

“We are using a UV-based system, which we will continue to install on newbuilds, but we are concerned about the pending stringent USCG approval. Our strategy for the installation on newbuilds is to install BWMS where we have a commitment from the supplier that it expects to obtain USCG approval. Considering the installation cost of US$2 million per ship, we would like to be able to expect that such a system fulfils all requirements,” Mr Wredstrøm said.

He added that the process is even more challenging when considering

Niels Bjørn Mortensen (Maersk): The major problem the shipping industry is facing in this context is that US Coast Guard has not yet approved any equipment (credit: MMT)


OPERATORS FORUM | 21

retrofits on older, existing vessels. “We have seen on a newbuild how it can be a challenge to integrate a BWMS into the ship’s control system. It will be an even bigger challenge on a retrofit,” he said.

Mr Wredstrøm said that the operator tends to favour larger suppliers because of their superior global service provision. “With ships drydocking at different yards, we need to be sure to have functional service in place and based on the experience with newbuilds, the demand for service will be even higher.”

Another dilemma facing a diverse owner such as Maersk is that different rules will apply to different types and sizes of ships, so that each must be considered individually. Examples are the offshore support vessels (OSVs) and tugs that are operated by Maersk Supply Service and Svitzer, respectively. These vessels might be able to make use of the exemption clause known as ‘same location’, which states that vessels operating within a confined geographical area are exempt from the BWMC and thus do not have to install any BWMS.

However, the definition of what area will qualify and how it will be interpreted around the world remains uncertain. According to Maersk, the US rules are

quite clear on what can be considered ‘same location’, but in the BWMC it is left to individual member states to agree internally. For example, Maersk believes that all Danish waters will be considered as ‘same location’ and that the same will apply to Brazilian waters, which is crucial for OSVs, in particular.

But, Mr Mortensen warned: “The challenge comes when several littoral states share the same water. For example, on ferry routes between Denmark and Germany some are only 10-15 miles long and ferries have been plying the waters for more than a century, yet the administrations cannot yet agree to designating it as the ‘same location.”

As a major shipowner and operator, Maersk says that it is committed to complying with whatever regulations are finally decided and implemented. But it is keen to ensure that the regulations are enforced consistently and that there is a level playing field in the industry so that Maersk and other similarly committed operators are not the only ones making the effort to comply.

Among recent BWMS contracts placed by Maersk Line is with Desmi Ocean Guard for 14 RayClean ballast water treatment systems for a series of new

container vessels to be built at Cosco Zhoushan shipyard in China.

The order is for seven vessels each equipped with two RayClean 500 BWTS, with options for two additional vessels and it is expected that the ballast water treatment systems will be delivered during 2016 and 2017.

The RayClean system uses low pressure UV, which Desmi says has low power consumption. Its system is automatic and can be integrated into existing ship automation systems.

The Desmi Ocean Guard system has passed all the required testing for USCG type approval, and a full type approval application was submitted to the USCG earlier this year.

Michael Heimann from Maersk Line said: “We are comfortable that Desmi Ocean Guard can deliver the right system for this project.”

Rasmus Folsø, chief executive of Desmi Ocean Guard, commented: “Total cost of ownership analyses have shown us that the RayClean system will provide considerable operational cost savings to Maersk Line compared to competing systems, due to the low power consumption and long lifetime of the UV lamps.” BWTT

Maersk Maritime Technology is advising decision making for the Danish shipping group (credit: MMT)


22 | OPERATORS FORUM

Owners choose systems to suit their specific requirements

I n the cruise ship sector Royal Caribbean Cruises (RCCL) is to retrofit seven of its cruise vessels with Hyde Marine’s Guardian Gold BWMS. Hyde has already retrofitted at least

10 RCCL ships. It has also supplied systems for RCCL newbuilds, bringing the total number of installations to 27. The latest retrofits will be timed to ensure that each vessel meets its respective compliance date.

Michael Jones, vice president for supply chain management at RCCL, said: “Hyde Marine has been a valuable partner in assisting us as we navigate the new regulatory requirements for ballast water treatment. Our crews are pleased with how easily and reliably the system operates, and with how seamlessly they integrate with existing automation systems.”

Large car carriers pose particular challenges with regard to BWMS and recent casualties that have been attributed to errors or malfunctions in ballast water systems have highlighted the sensitivity of these vessels’ stability to efficient ballast water management. Installing an appropriate BWMS can therefore be crucial to the overall efficient and safe operation of car carriers.

Norwegian Car Carriers (NOCC) has recently ordered Optimarin systems for two newbuild 6,500 car capacity ships under construction at Hyundai Samho Heavy Industries in South Korea for delivery in late 2016 and early 2017. The vessels are fitted with heavy capacity, 150-tonne, ramps with a 12-deck configuration enabling them to carry a range of high and heavy items.

Among the deciding factors for this choice is that NOCC wanted a system with the capacity it required on such large ships but with a small footprint; the modular characteristic makes it relatively easy to install by the shipyard.

Another recent order for Optimarin, for a different ship type, is for 10 systems on board chemical tankers owned by Atlantis

Tankers, comprising two newbuilds and eight retrofits. Lorenz Weinstabl, Atlantis Tankers’ group chairman, said: “We

offer customers reliability, flexibility and the very highest service standards. We wanted a BWMS supplier that could provide those same values. Optimarin’s track record in the industry is second to none. The technology is established, their expertise is unique and, with their engineering partners, their ability to quickly install and commission solutions worldwide is proven. What’s more, the upcoming USCG approval delivers the peace of mind we need and the flexibility of operation our customers demand.”

The systems are scheduled for installation in the newbuilds Atlantis Augusta and Atlantis Alicante in 2016, with the eight retrofit systems set for delivery in 2019. Installation on the existing fleet will take place during special survey dry dockings in 2019 and 2020.

Bernhard Schulte is retrofitting 11 of its container ships with Wärtsilä Aquarius BWMSs. The owner said that this decision followed the successful implementation of BWMSs on its newbuildings delivered since 2012 along with two pilot retrofits on older tonnage. In total, Bernhard Schulte is planning to retrofit 38 ships with the Wärtsilä Aquarius UV systems during a five-year period.

The 11-vessel project involves container ships from 2,600 teu up to 5,600 teu that are managed by Bernhard Schulte Shipmanagement, which is currently stepping up its management of container ships from third parties. The retrofit project is due to be completed in 2017. The owner said that, following the initial installations, it has built up an important working relationship with the supplier and has confidence that Wärtsilä has the required capabilities and resources to provide the necessary support throughout what is a major project. BWTT

Bernhard Schulte is retrofitting 11 container ships (credit: Bernhard Schulte Shipmanagement)

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Port states are very much playing the waiting game when deciding on possible action in anticipation

of IMO’s Ballast Water Management Convention (BWMC) finally entering into force.

It provides for sampling of ships’ ballast water during port state inspections but few, if any, states have sampling equipment in place. It is also still far from clear how such sampling could be carried out or what the benchmarks might be. IMO’s Marine Environment Protection Committee (MEPC) meeting No 68 in May 2015 suggested that indicative analysis could be performed using fluorescent diacetate (FDA) but further details were awaited at MEPC 69 in April, as this issue went to press.

Two major problems with indicative analysis are that ships carry huge volumes of ballast water and organisms are not likely to be evenly distributed, so any small sample is hardly likely to be representative. In addition, the limited experience so far of BWMS operation suggests that not all so-called ‘approved’ systems may function consistently. Sea conditions, temperature and salinity are all factors that can affect BWMS operation.

Shipowner organisations see this as a potential source of confusion. BIMCO, for one, recognises that the G8 guidelines for the approval of BWMSs are not robust enough to ensure that acquired systems are certain to be fit for worldwide use and will offer compliant performance under real ship operating conditions.

Port state testing is likely to fall somewhat short of the detailed analysis required under IMO guidelines and, in BIMCO’s view, should only be used as a

means of screening, to indicate whether a more stringent and comprehensive analysis is needed to ensure that the particular ship is in compliance.

Furthermore, BIMCO believes that port states should be able to accept the ship’s International BWM Certificate as evidence that its equipment fulfils the requirements of the convention, similar to current US practice.

Various studies have indicated that it should be possible to set thresholds that will enable port state authorities to determine compliance, but this will depend on actual samples taken from ships in operation, during the initial stages of introduction of the convention. According to DNV GL’s marine environmental expert Ralf Plump, “today’s lack of operational experience is a disadvantage. Most relatively new ships already equipped with BWMSs do not actually run the systems, as this is not yet required.”

Classification societies are finding themselves in a difficult position: they are expected to advise clients on best practices while still unsure themselves of the practicalities. “Sampling and indicative testing is a challenge that is relevant to port state control, as is education and training of the staff,” Mr Plump said. And there is also the question of what should be done if testing shows negative results or if the treatment system malfunctions. “Most ships do not have two systems on board or ballast water manifolds on deck for alternative disposal methods,” he pointed out.

At least the USA seems to be following the documentation trail in determining compliance with US Coast Guard (USCG) ballast water rules, which are already in

operation. Inconsistencies between IMO guidelines and USCG standards (mainly because the former sets limits for ‘viable’ organisms while the UCSG rules apply to those that are ‘living’) are seen by BIMCO as something that has to be addressed.

DNV GL, however, does not see this as the biggest problem. “Our experience shows that in practice there will be a balance of requirements, and the higher requirement counts,” suggests Plump.

So, for US compliance, owners will have to acquaint themselves fully with the extensive USCG rules and ensure that all relevant certificates and records are in place. Internationally, the jury is still out on how port states will take and test samples. BWTT

PORT STATE CONTROL | 25

Port states are unsure on testing methodsIMO’s BWMC sets discharge limits but port states are uncertain how to check for compliance

by Bill Thomson

If ballast water fails a port state control test, there is no alternative discharge option (credit: NEI Treatment Systems)


26 | PORT STATE CONTROL case study

Orkney Islands is clear about ballast dischargesBalancing the water quality for which Scapa Flow is famous with the commercial needs of tanker operators required clarity about its requirements

Off the UK’s northern coast lie Scotland’s Orkney Islands, where the clear and sheltered waters of Scapa Flow have been used for ship-to-ship (STS) transfers of crude oil since 1980. New legislation in 2012 required

the islands’ Harbour Authority to obtain a licence for this activity from the UK’s Maritime and Coastguard Agency (MCA), which it obtained in March 2015.

Transfers can involve ships of up to VLCC size, which have to discharge ballast so, although the UK has not yet ratified IMO’s Ballast Water Management Convention (BWMC), it was essential to have a policy on ballast discharges. It applies to all ship types.

David Sawkins is one of two deputy harbour masters at the Harbour Authority, which is part of Orkney Islands Council’s Marine Services department. He told delegates at a Green Shipping seminar during the Oceanology International exhibition in London in March about the water’s clarity, describing images from 32m deep that were made “in virtual natural daylight.” As he explained: “We do not want 40,000 tonnes of dirty water” to spoil that.

A consultant, Intertek, was tasked with making the policy practical and the director of its Energy and Water Consultancy Services, Chris Mooij, confirmed to BWTT that Orkney’s concerns

were aesthetic as well as biological. If a ship had loaded ballast containing dissolved iron, for example, the islanders would not want that red water discharged into Scapa Flow, he said.

Orkney Islands’ policy can be summed up as ‘exchange and treat’: ships must carry out ballast water exchange before arriving and any with ballast water management systems must also use those. The BWMC allows for local requirements such as this, Mr Mooij explained.

Ships planning to offload ballast are monitored long before they arrive so that their ballast loading port and water exchange area are known. On arrival at one of four STS locations, they are visited by Harbour Authority and Intertek staff and samples are taken for later analysis.

Marine non-native species monitoring surveys are carried out annually at specific locations in Scapa Flow. This began in 2013 with a baseline study and ongoing monitoring started in 2014. The results so far indicate that there has been no introduction of new non-native species since then, Mr Mooij told the seminar. In developing its plan, Orkney “is a leader,” he told BWTT.

• Read the Orkney Islands’ ballast discharge policy via www.tinyurl.com/ORKNEY-BW

Taking ballast water sampling on a semi-submersible accommodation vessel

(credit: Orkney Islands Harbour Authority)

Orkney’s legal basis for ballast controlSupporting Orkney’s ballast water management strategy is the status of its Harbour Authority, which was established by Act of Parliament.

Orkney’s plans were submitted to the UK’s Maritime and Coastguard Agency (MCA), to the shipping industry and all port and statutory consultees before approval. There was also an extensive consultation

with the islands’ residents. Shipowners have been supportive, David Sawkins, one of its two deputy harbour masters, said.

If a ship were to discharge contaminated ballast, the harbour authority’s statutory status gives it the authority to take cases to court, but he indicated to BWTT that this would be a rare event. “The only time we would prosecute

is if a ship discharged and we had told them they must not,” he said. Otherwise, it would be down to the MCA, as the national authority, to take matters further.

The harbour authority’s main sanction, however, is more practical: the ship would not be allowed to return and its ability to trade could be significantly affected as a result. BWTT

www.evoqua.com/seacure [email protected]

© 2016 Evoqua Water Technologies LLC

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SUPPLIERS FORUM | 29

Managing turbulence in ballast water treatment

Ballast water management system (BWMS) suppliers have had a turbulent few months, buffeted by uncertainty over when IMO’s Ballast Water Management Convention (BWMC) will come into force; what changes will be made to the convention once it has come into force; the cost of gaining US Coast Guard (USCG) type-approval; whether their preferred test method will be acceptable to the USCG; and, finally, whether the US rules will change in the next few years.

With those concerns blowing around their heads, they have to keep their feet on the ground: in anticipation of a rush of orders once the BWMC does reach its target tonnage, should they invest in new facilities? Should they take on more staff ? Will they eventually make any money from their investment in research and development?

BWTT contacted all the major BWMS suppliers to gauge their mood at this critical time, and the feedback on these pages is a short summary of their views. More details of the insights on which it is based can be found on BWTT’s website, ballastwatermanagement.co.uk

SUPPLIERS GEAR UP FOR THE RUSHSUPPLIERS ARE FACING DECISIONS OVER WHETHER AND WHEN TO INVEST IN NEW FACILITIES AND ADDITIONAL STAFF, BUT GETTING THE TIMING RIGHT IS TRICKY

B allast water management system (BWMS) suppliers have some tricky investment decisions to take. On the basis of reports to BWTT for this article, they are seeing increased enquiries, but not yet experiencing the rush of orders that must follow

once IMO’s Ballast Water Management Convention (BWMC) enters into force.When that rush comes, they may need to expand their production capacity and their

workforce, but neither can be done overnight or at zero cost. Some manufacturers have taken the plunge and announced significant investments.

Last October, for example, Techcross opened what it believes is the biggest factory in the world for making BWMSs and has recruited additional staff. It expects to make more than 1,000 systems each year at the new facilities, located on a 42,479m2 site in the Sinho industrial complex, near Busan, South Korea.

In Denmark, Desmi Ocean Guard is moving in a similar direction. “We have ready-to-execute ramp-up plans including staff recruitment [and] increasing manufacturing facilities,” said its chief executive, Rasmus Folsø.

Filter maker Filtersafe is gearing up to supply components for all these additional systems and has doubled the size of its manufacturing plant in Israel to 4,000m2 in readiness. It has also recruited more staff there and at its other factory, in Hong Kong, from where it supplies yards in China and South Korea.

Filtersafe’s investment will allow it to double its output but, like its BWMS manufacturer customers, it has no forecast of when that output will be reached. The company “will produce to meet demand as it arises,” a Filtersafe spokesman told BWTT in late February.

Many BWMS manufacturers are reviewing their staffing, and Coldharbour Marine in the UK made a public statement in January to coincide with a recruitment drive. It quoted the company’s chief executive, Andrew Marshall, as saying: “Once the convention becomes active, owners will have to comply and fit systems. We are expanding our engineering teams in anticipation.”

This growth is not only on the factory floor. Research and development engineers,

Techcross has opened the world’s largest BWMS factory (credit: Techcross)


30 | SUPPLIERS FORUM

quality control experts and system designers are all needed and this intake “will be a crucial element underpinning the next stage of the company’s growth plans,” the company said.

Recruitment on its own is not sufficient, said Matt Granitto, business manager at Evoqua Water Technologies. The company is actively looking for more staff, he said, but more important than that is ensuring good customer support by supplementing internal expertise. For that purpose, he said, Evoqua has partnered with a number of organisations, such as Damen in The Netherlands, Drew Marine in 900 ports worldwide, and Krosys in South Korea. “Our goal is to be fully trained and ready before the retrofit boom hits,” Mr Granitto said.

Some manufacturers are already part of large organisations with large networks and can make use of those as well as using external contacts. At Alfa Laval, for example, Stephen Westerling Greer, its global business manager for its PureBallast BWMS, said: “Externally, we are training partners to be ready for the retrofit boom. Internally, we are building and maintaining an organisation of dedicated service engineers globally.”

Optimarin’s chief executive, Tore Andersen, spoke of growth that is “carefully managed and according to our pre-determined business plan.” It is a strategy based around “a mixture of optimism, realism and the caution that 12 years of awaiting ratification naturally dictates.”

Filtersafe has expanded its facilities in Israel and recruited staff there and in Hong Kong (credit: Filtersafe)

With the US setting – and now implementing – its own ballast water management requirements, suppliers are faced with a number of issues. Will there be a market for equipment that meets IMO’s standards but not USCG’s, and are the US Coast Guard standards effectively the global benchmark? BWTT put those points to suppliers and received a spectrum of views.

Joe Thomas, managing director of Wärtsilä Water Systems and director of its Ballast Water Management Systems, suggested that there will be a market. The two performance standards have the same numeric values, he said, and “shipowners not trading in US waters have no need to purchase equipment that fulfils USCG-specific requirements,” he added.

Matt Granitto, business manager at Evoqua Water Technologies, also believes there is a potential market for IMO-only type-approved systems on vessels that are purpose built and will never enter US waters. However, “the challenge will be for how long these systems will be acceptable,” he said.

Revisions that are being discussed to modify the G8 guidelines for approval of ballast water management systems once BWMC enters into force, “seek to harmonise the IMO testing with that of the more stringent USCG testing,” he said, and a spokesman for Cathelco agreed: “There may be a small market for BWMSs that meet [only] the IMO’s standard … depending on the extent to which the revised G8 guidelines harmonise with the USCG’s.” In the main, however, “the USCG standard will set the level for the international standard,” the Cathelco spokesman predicted.

At Trojan Marinex, its managers suggested that it was not as simple as this. “There are some shipowners who need a USCG type-approved system, some who simply want [one], and then the majority who only need an IMO type-approved system,” their feedback notes said. They also offered a more nuanced assessment of progress on the G8 revisions, saying that, although the current review appears to be narrowing the gap between IMO and USCG standards, “the USCG’s preliminary decision on the MPN method has added a significant obstacle in this process.” ›››

USCG has set the global standard

Enquiries surge as IMO target nears

As this issue of BWTT goes to press, IMO’s Ballast Water Management Convention (BWMC) is just 0.18 per cent short of its 35 per cent trigger that will fire the gun for its entry into force a year later. Shipowners now appear to believe that it is inevitable that it will reach that target, and suppliers have seen a boost in enquiries. Orders, however, have not yet caught up.

John Dooley, president of Choice Ballast Solutions, reported a common experience: “We saw an increase in proposal activity in the fourth quarter of 2015 but, then, with the USCG rejection of the ‘most probable number’ (MPN) method and insufficient tonnage for ratification, many proposals were put on hold.”

That activity, in the latter part of the year, was related to the expectation that Indonesia’s ratification would bring the BWMC over its threshold, some suppliers believe. “Shipping companies were alerted

and interested in the final decision of ratification. News spread quickly,” said a spokeswoman for Erma First.

But the impact was short-lived, said Rasmus Folsø, chief executive of Desmi Ocean Guard. “We saw increased interest and activity. The news that the BWMC is in fact still not ratified has, however, returned interest and activity to the same level as before November 2015.”

One company, however, has seen a number of definite orders. Tore Andersen, chief executive of Optimarin, said: “Towards the end of 2015 and into 2016, business has really taken off.” Fleet agreements, in particular, “have been a real area of success for us,” he said. But at least one of those orders – from Carisbrooke Shipping – was backed by a guarantee that Optimarin’s UV-based system would achieve USCG type-approval by the end of 2017.


SUPPLIERS FORUM | 31

In it for the long haul

››› Tore Andersen, chief executive of Optimarin, is quite firm in his view that “USCG has set the de facto standard for BWMSs.” There may be a market for IMO-only systems based on MPN analysis, he said, but if shipowners want the flexibility of trading in US waters, “they must choose a USCG-compliant system. Full stop.”

Despite this, some equipment suppliers “insist that USCG testing is something that they are not going to look at,” said Andrew Marshall, chief executive of Coldharbour Marine. “But the reality is that having two different certification schemes, both enforceable, is unworkable if the requirements remain as diverged as they currently are,” he said.

A Techcross spokesman reminded BWTT that some UV-based system makers have challenged USCG’s rejection of MPN analysis. He nonetheless echoed the overwhelming view when he said: “If the USCG does not accept their appeals, a possible market for the UV-based system relying on the MPN method will be limited.”

The USCG has set the standard for ballast water quality (credit: USCG)

There are 91 systems from 75 suppliers listed in the directory section of this edition of BWTT. Few other equipment types can boast as wide a choice as this and no one contacted for this report expects all of those to remain in business once the initial retrofit rush has passed.

Most of those who took part in BWTT’s research did not put specific figures to their expectations, but among those who did was Matt Granitto, business manager at Evoqua Water Technologies.

He believes the shakeout has already begun, as companies that copied existing technologies drop away while ratification of IMO’s convention drags on. “We expect 20-30 companies to survive and service the retrofit market,” Mr Granitto said, after which another contraction will leave 10-15 suppliers to service the newbuild and re-retrofit market. The same estimate came from Andrew Marshall, chief executive of Coldharbour Marine.

Tore Andersen, chief executive of Optimarin, has similar expectations. “Somewhere close to 10, with enough manufacturers to provide healthy competition across all ship sizes, segments and geographical locations,” he said. But Rasmus Folsø, chief executive of Desmi Ocean Guard, expects to be able to count the survivors on his fingers: between five and 10 companies, he said.

There will be market consolidation and the number of BWMS vendors will reduce, predicted Joe Thomas, managing director of Wärtsilä Water Systems and director of its Ballast Water Management Systems. “Wärtsilä firmly intends to be in the BWMS market for the long term,” he said.

An important factor in staying in the market will be after-sales service, feedback from Erma First indicated. And that will pose difficulties as suppliers pull out, its spokesman said, which should be an important aspect in the initial selection, he suggested.

Stephen Westerling Greer, Alfa Laval’s global business manager for its PureBallast BWMS, agreed. Although the number of manufacturers is hard to foresee, those that can “offer global services over the long-term, past the retrofit boom, will certainly be present,” he said.

Reviewing the feedback, BWTT’s editor, Paul Gunton, remarked on the low numbers of long-term providers predicted by those who offered an estimate. Their various predictions are mostly fewer than the number of companies who responded to BWTT’s survey, he pointed out. Yet they all expect to be among the survivors. BWTT

Joe Thomas (Wärtsilä Water Systems): “Wärtsilä firmly intends to be in the BWMS market for the long-term”

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DID YOU KNOW?In 1983, KraftPowercon Sweden was the first in the world to introduce new Switch Mode DC-rectifiers (SMPS) for high current applications.

KraftPowercon is able to deliver standard DC rectifiers in Switch Mode design (SMPS) up to 48,000 Ampere and voltages up to 90,000 Volts.

DID YOU KNOW?

Soon, very soon perhaps, the IMO Ballast Water Convention will come into force and ship operators will be obliged to install a ballast water treatment system.

Because of the long delay, we know there will be a big rush to fit a system in time to meet the deadlines. That could be a problem for everyone from shipyards to system suppliers but Swedish international manufacturer KraftPowercon is already gearing up its production facilities to meet the anticipated large demand for certified power supplies needed to ensure ballast treatment systems can operate without interruption. As well as our own production and assembly lines, KraftPowercon has also taken the necessary steps to ensure that all necessary components from sub-suppliers have been secured.

KraftPowercon’s production area in Sweden has all the space necessary to scale up production immediately it is needed with fully trained personnel ready to man the new production lines. Furthermore, if even more production is needed, KraftPowercon’s ISO 9001certified facility in Shanghai is also available to meet the demands of the local and international market. “We have all we need for meeting the wave of ballast orders”, says production Manager Sefedin Harbas, “Modern factories, trained staff, a lean and flexible production and an effective traceability system,” he added.

KraftPowercon is a long established company which celebrated its 80th anniversary in 2015. Drawing on this long experience, KraftPowercon has developed its FlexKraft range of rectifiers to provide the vital reliable and quality current that is essential for any electro-chemical ballast water treatment system. Without a constant DC supply to the electrolyser of such systems, production of the disinfectant cannot take place and the system will not function. The reliability of KraftPowercon’s rectifiers has been proven in many different applications in other industries and their first class reputation has attracted ballast treatment makers such as DeNora Water Technologies, ErmaFirst, OceanSaver and RWO to select them for their systems. Discussions with other system makers are also underway.

Lennart Hansson, Business Sector Leader at KraftPowercon Sweden, says “Ship operators may be looking at treatment systems from many suppliers but it is essen-tial that they recognise that key components must be reliable and easy to source in case of need”.

The FlexKraft rectifiers have many advantages over traditional systems as Lennart Hansson explains, “It is a compact modular system designed and built around a

single standard module that can be arranged like Lego blocks into stacks and levels that can be adapted to almost any configuration, keeping the footprint as

small as possible.” Hansson says that the modules can be re-configured and added to in or-

der to meet any new or changed demands from type-approval bodies. Most importantly they have a built-in redundancy feature that ensures that in the event of a problem with any individual module, the system will con-tinue to deliver current to allow ballast treatment to be finalised.

The FlexKraft modules intended for ballast water applications are ma-rinised versions of an established reliable system. In the type approval process for the ballast treatment systems it has already been supplied to and independently, the FlexKraft modular system has been tested and approved according to the marine standards of DNV-GL, LR, KR and meets IACS E10 and IMO G8 requirements.

“As a consequence of the other uses for the FlexKraft system, KraftPowercon has established our own service centres at strategic

locations and we have an expanding global network of partners,” says Hansson. “However, although we are always on hand for assistance

and advice, the beauty of the system is that changing individual modules is so easy it can be done by an electrician on board in a matter of minutes. We have a

movie on YouTube that demonstrates exactly that,” he said

Lennart [email protected]+46 706 97 97 29

Artcile two page.indd 1 2016-03-31 15:12

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DID YOU KNOW?

DID YOU KNOW?In 1983, KraftPowercon Sweden was the first in the world to introduce new Switch Mode DC-rectifiers (SMPS) for high current applications.

KraftPowercon is able to deliver standard DC rectifiers in Switch Mode design (SMPS) up to 48,000 Ampere and voltages up to 90,000 Volts.

DID YOU KNOW?

Soon, very soon perhaps, the IMO Ballast Water Convention will come into force and ship operators will be obliged to install a ballast water treatment system.

Because of the long delay, we know there will be a big rush to fit a system in time to meet the deadlines. That could be a problem for everyone from shipyards to system suppliers but Swedish international manufacturer KraftPowercon is already gearing up its production facilities to meet the anticipated large demand for certified power supplies needed to ensure ballast treatment systems can operate without interruption. As well as our own production and assembly lines, KraftPowercon has also taken the necessary steps to ensure that all necessary components from sub-suppliers have been secured.

KraftPowercon’s production area in Sweden has all the space necessary to scale up production immediately it is needed with fully trained personnel ready to man the new production lines. Furthermore, if even more production is needed, KraftPowercon’s ISO 9001certified facility in Shanghai is also available to meet the demands of the local and international market. “We have all we need for meeting the wave of ballast orders”, says production Manager Sefedin Harbas, “Modern factories, trained staff, a lean and flexible production and an effective traceability system,” he added.

KraftPowercon is a long established company which celebrated its 80th anniversary in 2015. Drawing on this long experience, KraftPowercon has developed its FlexKraft range of rectifiers to provide the vital reliable and quality current that is essential for any electro-chemical ballast water treatment system. Without a constant DC supply to the electrolyser of such systems, production of the disinfectant cannot take place and the system will not function. The reliability of KraftPowercon’s rectifiers has been proven in many different applications in other industries and their first class reputation has attracted ballast treatment makers such as DeNora Water Technologies, ErmaFirst, OceanSaver and RWO to select them for their systems. Discussions with other system makers are also underway.

Lennart Hansson, Business Sector Leader at KraftPowercon Sweden, says “Ship operators may be looking at treatment systems from many suppliers but it is essen-tial that they recognise that key components must be reliable and easy to source in case of need”.

The FlexKraft rectifiers have many advantages over traditional systems as Lennart Hansson explains, “It is a compact modular system designed and built around a

single standard module that can be arranged like Lego blocks into stacks and levels that can be adapted to almost any configuration, keeping the footprint as

small as possible.” Hansson says that the modules can be re-configured and added to in or-

der to meet any new or changed demands from type-approval bodies. Most importantly they have a built-in redundancy feature that ensures that in the event of a problem with any individual module, the system will con-tinue to deliver current to allow ballast treatment to be finalised.

The FlexKraft modules intended for ballast water applications are ma-rinised versions of an established reliable system. In the type approval process for the ballast treatment systems it has already been supplied to and independently, the FlexKraft modular system has been tested and approved according to the marine standards of DNV-GL, LR, KR and meets IACS E10 and IMO G8 requirements.

“As a consequence of the other uses for the FlexKraft system, KraftPowercon has established our own service centres at strategic

locations and we have an expanding global network of partners,” says Hansson. “However, although we are always on hand for assistance

and advice, the beauty of the system is that changing individual modules is so easy it can be done by an electrician on board in a matter of minutes. We have a

movie on YouTube that demonstrates exactly that,” he said

Lennart [email protected]+46 706 97 97 29

Artcile two page.indd 1 2016-03-31 15:12


A ROUGH RIDE FOR UV

B allast treatment systems that employ ultraviolet (UV) irradiation as the primary means of

disinfectant have not had the smoothest path in the time since shipping’s international regulatory bodies decided that something had to be done to solve the problem of invasive species.

While the current preoccupation is with meeting the requirements of the IMO Ballast Water Management Convention (BWMC) of 2004 and/or the US regulations under the joint control of the country’s Environmental Protection Agency (EPA) and the US Coast Guard, the problem and attempts at solutions predate both regulations by several years. IMO began working on the problem in 1988 and around the world various countries began imposing national requirements in the

late 1980s – and still are, while there is no international standard in place.

UV has been at the forefront of these developments and Norwegian system maker Optimarin claims the distinction of installing the first type-approved system (although obviously not to the G8 guidelines) four years before the 2004 convention was adopted. Optimarin is still a leading player in the wider ballast treatment sector and especially in the UV system segment.

UV systems account for more than half of all type-approved systems but UV is not a single technology, with variants differing in their theoretical effectiveness as much as in practice.

In the early days of gaining approval under IMO rules, several makers of UV systems followed the G9 active

substance approval route while others were granted full type-approval under the G8 process. The G9 route was considered necessary because the systems produced hydroxyl radicals that aided the disinfection but existed for just milliseconds. Since 2010, almost all systems employing UV have opted for the G8 route and all but three have also gained type-approval.

UV works by destroying or disrupting the DNA of organisms but, except in a small number of systems, it is not intended to go the extra step and kill organisms outright. This difference is the reason why many observers have argued that UV systems will never win approval under US rules.

However, UV systems are definitely capable of fulfilling the kill requirement

TECHNOLOGY | 35

UV light destroys organisms’ DNA (credit: Trojan Marinex)


36 | TECHNOLOGY

as Optimarin is at pains to point out. Its system has passed most of the US tests and, importantly, it has done so using the vital stain or FDA/CMFDA test process rather than the ‘most probable number’ (MPN) test that is accepted under IMO rules but not by the US.

Optimarin says its system is able to achieve success because it makes use of high power UV lamps that have a maximum power of 35kW and a ballast throughput of 167 m3/h although under optimum water conditions it is possible to operate at half of the UV output for the same flow rate.

By contrast, many rival system makers have opted to develop and promote the energy-saving aspect of their UV systems and the consequential benefit of enabling a more compact and lighter system. Taking a random example, the Alfa Laval PureBallast 3.0 system of comparable size to an Optimarin 167 m3/h model has a maximum power of 20kW and can operate at 11kW under optimal conditions.

To improve their earlier systems, most makers of UV types have been compelled to alter the flow characteristics and to incorporate lamp cleaning to maintain the intensity of radiation. In some instances it is claimed that improved lamp technology,

in particular the glass casing, allows for greater UV transmittance.

Customers have to take these claims on trust, but type-approval certification should be a reliable indicator and the fact that it has been called into question partly as a result of the testing method dispute and partly because in practice some installed systems have apparently failed to live up to expectations, “is a sorry state of affairs,” one ballast water commentator remarked to BWTT. IMO is engaged in attempting to resolve this issue “but until that is done, all systems will be treated as being suspect and, when a client could be paying up to US$5 million, the reluctance to install any of them is understandable,” he said.

Some manufacturers say that it is not the case that only a system employing high power can achieve the kill criteria of the US rules and it may be that other system makers that have relied on the MPN method may also be capable of passing the FDA/CMFDA tests.

At least one maker is convinced this is possible: Panasia announced in late 2015 that it had completed land-based USCG type-approval tests in sea water for its GloEn-Patrol filter and UV-based ballast water management system.

In passing the tests, carried out in

conjunction with DNV GL, samples were checked using both techniques and all were able to satisfy the respective requirements, the company said.

Nevertheless, four system makers – three of which had applied for USCG type-approval – decided in February to challenge the USCG ruling that the MPN test is not equivalent to the FDA/CMFDA test.

It remains to be seen whether they will be successful but in their favour is the fact that in the US and in other places around the world, other water treatment processes – both for potable and waste water – are increasingly using UV disinfection rather than methods that use chemical agents such as chlorine, chlorine dioxide or ozone. In such cases UV is seen as being cleaner and, unlike the alternatives, does not produce any disinfection by-products.

Beyond the dispute over the testing method employed for UV systems, the fact that EPA’s regulations have been successfully challenged in a court should be of concern to all system makers. While that case was more concerned with ensuring ballast water was effectively sterile, it was brought by environmental organisations that are also interested in the overall effect of ballast operations on local species.

In mid-2015, reports of a study on electro-chemical treatments were published in the journal Environmental Science and Technology. Scientists at Helmholtz Zentrum München who carried out the study in tandem with the University of Maryland in the US suggested that only filtration should be considered as a ballast treatment method.

The reason for this conclusion is that using high-resolution mass spectrometry, the scientists discovered that electrochemical treatments led to the formation of 462 new, diverse compounds known as brominated disinfection byproducts (BDBs), some of which had not previously been described as disinfection products or been structurally categorised.

One of the authors of the study said: “In future studies, we want to find out what influence the BDBs have on coastal ecosystems.” The study concluded: “Our results clearly demonstrate that electrochemical and potentially direct chlorination of ballast water in estuarine and marine systems should be approached with caution and the concentrations, fate, and toxicity of BDPs need to be further characterised. BWTT

Panasia’s GloEn-Patrol meets USCG standards whichever test method is used, the company reports (credit: Panasia)

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Innovation is in short supplyThere are many systems available to choose from, but they all share just a few core technologies

S purred on by the prospect of a market that could consist of more than 50,000 installations, makers of ballast treatment systems have explored many technologies in their bid to

produce systems that meet IMO and US requirements. The pace at which new systems are being brought to commercialisation has slowed somewhat over the past year or two but has not dried up completely.

There are now more than 90 systems that have been developed although a few have dropped by the wayside for various reasons usually connected with either an operational issue or the system maker’s reluctance to sink more capital into projects that have been frustrated by the delay in ratification of IMO’s Ballast Water Management Convention (BWMC).

Last year five systems achieved their first type-approval allowing them to be commercialised and there are now around 30 systems that have not yet reached this stage. The numbers do grow, as the latest version of the table of systems shows (see pages 67-72), but not all of these are newcomers: some have previously been omitted because a system that has been approved has not been promoted or because the state where the maker is based has neglected to inform IMO of the system’s existence.

There are other manufacturers that are at early stages of developing a system believing that the market will be able to accommodate more. Whether that is true or not remains to be seen and one observer commented to BWTT: “most seem to be a reinvention of the wheel and bring little if any innovation to the table.”

However, one system that is a little different from most is still in its early stages and has so far received little attention. The system is being developed by Norway-based Ulmatec Pyro and uses waste heat from the engine with the ballast being used as cooling water. The water is then itself cooled before being returned to the ballast tanks. Ulmatec’s expertise in waste heat systems is extensive and it claims that the system can actually be very economic since it involves just valves, piping and heat exchangers.

Ulmatec Pyro’s managing director, Jan Petter Urke, told BWTT that although the system has been patented there are no immediate plans for it to be commercialised. He said that the system is ready for type-approval testing according to both USCG and IMO rules “when they decide to harmonise or when future rules are agreed upon.”

A closer study of the list of type-approved systems highlights that more than half make use of UV, either alone or in conjunction with some other treatment. The same is not true of those yet

NK has applied for basic approval at IMO’s Marine Environment Protection Committee for its NK-Cl BlueBallast system (credit: NK)


TECHNOLOGY | 39

to be approved, among which only three systems make use of UV. It is hard to say if this shows a decline in popularity of UV systems – which might be understandable, given some adverse reaction from the US – or whether it reflects the fact that UV systems are generally not required to obtain approval for active substances and so do not come to public attention as early in their development as systems using other technologies.

At IMO’s Marine Environment Protection Committee (MEPC) meeting No 69 in April – after this issue went to press – there were no systems listed as seeking basic approval under the G9 route, according to the meeting’s agenda in mid-February. Three systems were proposed for final approval – Techcross’ ECS-Hychlor, NK’s NK-Cl BlueBallast (both from South Korea) and the APTS-Blue system from Panasonic of Japan.

All have been recommended for final approval by the UN’s multi-agency Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), but their status as listed in this issue’s table does not assume that they will have passed that milestone at MEPC, since final approval has been withheld in the past for other systems for various reasons.

An area where there is more potential activity is in the development of shore-based systems. The idea that it is better to treat ballast water in a large plant in each port rather than with systems on board individual ships is compelling, although it is not suitable under all circumstances.

There is work going on in this area in India, where IRClass has been promoting such a solution, and in the Netherlands where Damen and Uniballast are both active. Uniballast’s system is not proprietary; it can use any maker’s system, mounted in a container with fittings to connect it to a ship’s ballast system.

There may also be similar work in the US, following an Appeal Court’s ruling against the US Environmental Protection Agency on the basis that it did not consider such systems when it developed its requirements.

A shore-based facility can readily deal with simple deballasting alongside but it is more difficult to understand how it might work when, for instance, a ship needs to deballast outside a port to clear a bar and reballast to bring its air draught down to load cargo or to pass under bridges.

Relying on shore facilities may also mean that if they break down or become unavailable for any reason, ships may be delayed from entering or sailing from a port. However, their provision would mean that vessels would be saved the cost of installing systems and enable them to undertake ballast operations if their own systems failed.

A schematic diagram of a Uniballast layout to fit a BWMS into a container (credit: Uniballast)

When IMO’s Ballast Water Management Convention (BWMC) finally becomes effective and shipowners begin the search for a suitable ballast treatment system, most will be concerned with finding one that allows compliance, matches the ship’s trading area and method of operation, is relatively affordable and which can be made available and installed in the appropriate time frame.

What many will not do is take the time to fully study the system and all its component parts except in so far as modularisation allows for them to be installed where space permits.

Ballast treatment systems, whether they be UV or electrochemical, are almost entirely a collection of parts from component suppliers. With few exceptions the system makers are not known for producing filters, pumps, UV lamps, piping, control electronics or electrical power supplies. However, type-approval and the USCG’s alternate management system (AMS) status is conferred on the whole system and if one of the components were switched for a different part, the approval could become invalid.

With a UV system it is obviously the lamps that are the key component and in an electrochemical system the power supply and any dosing units need to be considered. Electrochemical systems will need a reliable DC supply and this implies that rectifiers will be needed at some point. If at any point the rectifiers fail, then ballast treatment will have to be suspended. That is not an ideal situation at any time and especially not when the ballasting operation is taking place to allow for continuous cargo operations alongside or when taking on ballast to clear an overhead obstruction.

One company that supplies rectifiers to a number of ballast system makers and is in negotiation with others in Asia and Europe, is Gothenburg-based KraftPowercon. Lennart Hansson, business sector leader for ballast water treatment-high current solutions at KraftPowercon highlighted the problem that shipowners could have if their research into system suitability is not thorough enough. “It’s fine to have a maintenance contract with the system supplier,” he told BWTT, “but the individual components also need to be readily available everywhere as well.”

That could well be a problem for owners as delays in obtaining parts could lead to lengthy and expensive delays. Mr Hansson also explained some of the benefits of the FlexKraft Marine power supply modules his company supplies to ballast system makers. The modules are all identical regardless of system size and power demand. They are supplied in cabinets allowing stacks of up to 10 modules in each, which would be sufficient for a system with a flow rate of 1,000 m3/h.

Ian Hamilton, project leader at marine electrical wiring control and instrumentation specialist CMR Group, also believes that standardisation will benefit BWMS power supplies.

It has developed a modular control panel arrangement, which it has dubbed Goldfinch, that it believes will allow BWMS makers to expand and improve their services.

In a statement to BWTT, Mr Hamilton said that close co-operation with BWMS makers to modularise and standardise control panels “can reduce costs and cut delivery and manufacturing lead times, allowing them to focus on core components while taking advantage of standard parts and consistent pricing.”

When it launched Goldfinch in February, the company estimated that it will reduce time-to-market lead times by 75 per cent. BWTT

Taking care over components


40 | SYSTEM SELECTION

US stance adds to owners’ difficult choices

The false start over the entry into force date of the Ballast Water Management Convention (BWMC) has only added

to the confusion facing owners as they contemplate the costly decision to order and install ballast water treatment systems on their vessels.

The general industry consensus that the threshold had been reached to bring the BWMC into force in November 2016 was broken when a re-calculation for IMO revealed that the proportion of the world fleet represented by ratifications was still tantalisingly short of the necessary 35 per cent, so the wait goes on until a country or group of countries takes it upon themselves to bring the waiting to an end.

When it appeared that the threshold had been reached, suppliers were bracing themselves for a rush of orders as owners would be unable to kick the can down the road any longer. But the further delay enables owners to take another deep breath before the inevitable happens.

However, even when the date is finally set that is unlikely to signal an end to the uncertainty. The US following its own path adds a further layer of uncertainty for owners.

When it seemed that the date was known, the International Chamber of Shipping (ICS) warned that IMO should finalise the revision of the G8 type-approval guidelines as soon as possible, to give shipowners “absolute confidence that the expensive equipment they will soon have to install will be effective in

treating ballast water conditions normally encountered during worldwide operations and be regarded as fully compliant during port state control (PSC) inspections.” In practice, the current position is that amendments to the BWMC will be tabled at IMO as soon as it comes into force.

ICS pointed out that there is still great uncertainty with respect to the more stringent US approval regime for treatment equipment, which has been phased in since January 2014, requiring all ships discharging ballast water in US waters to use a treatment system approved by the US Coast Guard. But with no systems having been approved, ships required to comply with US regulations have either been granted extensions to the dates for fitting the required treatment systems or else permitted to install a US Coast Guard accepted Alternate Management System (AMS), effectively meaning systems that have been type-approved in accordance with existing IMO guidelines.

Since 1 January 2016 vessels can no longer discharge ballast in US waters unless their ballast water management system (BWMS) is compliant with the US Coast Guard. The US regulations mean that, since the start of the year, ships built before December 2013 with less than 1,500m3 or more than 5,000m3 of ballast must not discharge ballast in US waters unless they have a compliant BWMS or have carried out a ballast water exchange prior to entering US waters. Ships with ballast capacities of between 1,500m3 and 5,000m3 have had to comply since 1 January 2014

Tore Andersen (Optimarin): Install a system that is reliable, simple to maintain, easy to install (credit: Optimarin)

Selecting the right BWMS is not getting any easier as regulatory uncertainty is another factor that owners must consider

by Steve Matthews


SYSTEM SELECTION | 41

and all newbuildings have had to comply since 1 December 2013. Ships without a compliant BWMS must install one at their next scheduled drydocking.

After five years a fully US Coast Guard (USCG) approved system must be installed, but there is no guarantee that systems with AMS status will be granted full approval. This means that shipowners might have to replace their systems completely after five years.

The main concerns related to those systems based on ultra-violet (UV) treatment, for which doubts have been raised about their approval in the US. This could result in a situation where owners have installed UV treatment systems that are compliant with IMO regulations but would not be accepted in the US. This puts owners in an extremely difficult situation when choosing the most appropriate technology for their ships. It also means that suppliers of UV systems face a tough task in persuading owners to take that risk.

In spite of this uncertainty in the US and globally, the fact remains that at some point in the near future shipowners that have not already done so will have to make decisions about what BWMS they are going to install on their vessels to enable them to continue trading.

Owners of new vessels have been making those decisions for some time, and that has included UV systems in some instances. Belgium-based Scaldis Salvage, for example, opted to install a Wärtsilä Aquarius UV treatment system for its new crane ship under construction in China to a design by Royal IHC. In this case Wärtsilä is also supplying the main engines and generators for the vessel. Wärtsilä believes that its reputation across a number of sectors might give it an edge over the many BWMS suppliers that are less well known and that many owners will prefer to opt for a company with such long held credentials for ships’ equipment.

Joe Thomas, director for ballast water management systems at Wärtsilä Marine Solutions, said: “Wärtsilä offers products and solutions that cover all technical aspects of the shipping and energy markets. All operations are ultimately inter-related, which is why we, as a total solutions provider, are in the unique position of being able to connect the dots so that the entire chain can be completed as efficiently and effectively as possible. BWMS is one more important dot in formulating a completely sustainable environmental solution.”

For those owners that do not want to take the risk of UV systems in light of the uncertainty surrounding the US’s stance, Wärtsilä can also provide systems using electro-chlorination instead of UV.

Another supplier that has gained some recent success in winning orders, and installed its first commercial system as long ago as 2000, onboard the cruise ship Regal Princess, Norway-based Optimarin says that the latest developments, especially in the US mean that it is more important than ever that owners make the right choice of BWMS.

Optimarin chief executive Tore Andersen, said: “There is so much confusion surrounding the issue of ballast water treatment.” Optimarin says that the uncertainty in the US means that the UV systems that many owners might prefer because of their simplicity, ease of operation and the fact that they use no chemicals are struggling with regard to US approval. Optimarin is hoping to gain a market advantage of being the first UV system to gain US approval, which it hopes to secure later in 2016, having already satisfied the USCG marine water tests.

Mr Andersen’s advice to owners is straightforward, if unsurprising: “Install a system that is reliable, simple to maintain, easy to install, make sure any supplier can show a history of retrofit success, and proven within the marketplace. This is still a relatively young sector, so it pays to go with a name you can trust.”

By early February 2016 Optimarin had

sold more than 360 of its UV treatment systems, with over 270 systems installed. These include newbuildings and more than 60 retrofit contracts. Optimarin’s system uses a combination of automatic back flushing, self-cleaning filters and UV irradiation to neutralise all organisms, bacteria and pathogens in ballast water.

Among its new orders in 2016 is from Atlantis Tankers to install 10 systems on its chemical tankers: two on newbuild vessels and eight retrofits. A major factor in winning this order, according to Mr Andersen, was that it has secured full explosion-proof approval for use in hazardous areas, which is crucial for systems operating on tankers.

Another Norway-based supplier uses a different technology that does not come up against the UV controversy in the US. OceanSaver has obtained US AMS approval for its combination of filtration and disinfection through a patented electrodialysis system. Its Mark II system is intended for large vessels handling substantial volumes of ballast water, such as Suezmax tankers and very large crude carriers, and LNG carriers. One such contract will involve the retrofitting a system on the Engie LNG carrier Provalys with two systems, each able to handle 3,000m3 of ballast water.

SCF Novoship Technical Management, the technical management arm of Russian owner Sovcomflot, is among operators opting for a non-UV system. It has selected the Echochlor BWMS to be retrofitted

Panasia has adopted a different approach to obtaining US approval for its UV system (credit: Panasia)


42 | SYSTEM SELECTION

later in 2016 on three of its Aframax tankers and one product tanker. The Ecochlor system uses a two-step process to treat ballast water: filtration and then disinfection using biocide, chlorine dioxide.

The uncertainty created by the US stance and the impact that might have on owners’ choice of systems is reflected in the fact that four suppliers of BWMS using UV – Trojan Marinex, Alfa Laval, Desmi Ocean Guard and Hyde Marine – are fighting the USCG decision to reject their reliance on the ‘most probable number’ analysis method. Three of those companies have submitted type-approval applications. These contentious technical arguments about UV systems approvals only add to the confusion for owners seeking to make decisions.

Another supplier, Panasia, has said that the US ruling can easily lead customers to misunderstand and misinterpret the status of UV technology. It has adopted a different approach for obtaining approval for its GloEn-Patrol filtration and UV based system that it believes overcomes the problems faced by some other UV systems. It also hopes to gain full USCG type-approval in 2016.

The finer points of the various technologies and their efforts to gain the requisite IMO and US approvals are

explained more fully elsewhere in this guide. But the nature of the debate and the potential consequences of owners making a wrong decision when selecting systems shows clearly that they need to take onboard all available expert technical advice before they make a final decision on what is best for their particular vessels, taking into account the vessels’ design and operating profile, including expected ballasting and deballasting frequency, volumes and possible crucially, where they will be operating.

Finance is an additional parameter that will influence owners’ choice of system. Michael Simms, a partner at shipping accountancy firm Moore Stephens, commented: “The overall cost and financing challenge which BWMC compliance represents in the current difficult economic climate cannot be over-estimated. By contrast, the accounting should be more straightforward. The initial expenditure will be treated as capital whilst ongoing operation will be an operating cost. It is essential that those affected by the new legislation understand exactly what is required of them by what date and how best to secure the necessary funding.”

This is not an easy time for many shipowners, grappling as they are with often difficult markets and trying to control costs, while having to make crucial decisions involving spending large amounts of capital with no direct economic return, other than meeting the ability to keep their ships trading.

Even from a purely technical perspective, owners face an array of systems and suppliers. When the regulatory uncertainty is thrown into the mix, it is understandable that many owners are confused and nervous about making what might turn out to be wrong, and very expensive, decisions. BWTT

LNG Carrier Provalys is to install OceanSaver’s BWMS (credit: Engie)

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CASE STUDY | 45

T he Ecochlor BWTS was due to have completed all land-

based and shipboard testing for United States Coast Guard (USCG) type-approval as this issue went to press. When that is done, a final report will be sent to the independent laboratory (IL), which will confirm that the system has met the type-approval requirements and send a ‘Letter of Recommendation’ to the USCG. Then Ecochlor will prepare and submit a USCG type-approval application.

Ecochlor was one of the first ballast water management system (BWMS) manufacturers to pursue USCG type-approval. In September 2013 it selected DNV GL as its IL, one benefit being that this would secure DNV GL classification society approval simultaneously with USCG type-approval. Then a letter of intent (LOI) was sent to the USCG to initiate testing.

An Ecochlor BWTS was installed at California Maritime Academy’s Golden Bear Facility (GBF) in March 2015 with both land-based and shipboard testing starting in April. Simultaneously, environmental testing was coordinated and will be performed by Retlif Testing Laboratory; both are USCG-approved sub-laboratories.

After commissioning the Ecochlor BWTS on the training ship Golden Bear,

a document was signed confirming that Ecochlor staff would not be involved in operating the system during testing. The Ecochlor team’s experience with GBF has been very positive and DNV GL has been very thorough in overseeing the testing. The system’s USCG type-approval test results have been consistent with its IMO type-approval results.

The process is both costly and time-consuming. Ecochlor’s expenses for USCG type-approval have reached almost US$4 million, of which US$3.3 million were spent on IL testing and services. The rest was spent on the system itself, plus installation and labour costs.

Currently, 32 manufacturers have submitted LOIs to USCG. To date, only three have completed testing and submitted an application to the USCG. All three use UV technology but in late 2015, USCG’s Marine Safety Center informed them, along with a fourth manufacturer, that their testing method, known as the ‘most probable number’ method, was not equivalent to its Environmental Technology Verification protocol and was unacceptable for type-approval.

Under the USCG Final Rule, most vessels are now required to install a BWMS at their next scheduled dry docking. With no USCG type-approved

system on the market, a BWMS that has received USCG Alternate Management System (AMS) acceptance can be used in the interim, but vessels operating these systems will have to comply with the EPA Vessel General Permit (VGP), which initially requires semi-annual testing of ballast water discharge.

International Shipholding Corp operates an Ecochlor BWTS on its vehicle carrier Green Bay and recently completed VGP testing. Technical director Regis Burkhardt reviewed a list of EPA-certified labs that could perform VGP testing and discovered that some labs were available on the West Coast but not on the East Coast. And many labs could carry out biological testing but not for residuals of ClO2, as required for the Ecochlor unit. “It will take some time for an infrastructure of laboratories to be developed in the US,” he said.

Outside the US, a lab

would not have to be EPA-certified but would need to use the same laboratory testing methods. “This gave me further concerns as to what is available for VGP testing overseas,” he said.

He hired a turn-key service provider to manage the process: EnviroManagement. It provided sampling services, including locating and arranging for lab services at three ports on the ship’s schedule. Marcie Merksamer, vice president of EnviroManagement, said that it arranged the logistics for the ship’s sampling fairly quickly, but urged shipowners to plan as far in advance as possible: the various analyses are often performed by separate specialised laboratories.

Ultimately, the third-party laboratory analysis and field testing for ClO2 residual found that ballast water treated by the Ecochlor BWTS on Green Bay met the VGP effluent limits. BWTT

TOM PERLICH, FOUNDER AND PRESIDENT OF ECOCHLOR, EXPLAINS THE PROCESS, CHALLENGES AND COSTS INVOLVED IN USCG’S TESTING PROCESS

Meredith McPherson, science coordinator at California State University Maritime Academy’s Golden Bear Facility, coordinated testing for the Ecochlor BWTS (credit: Golden Bear Facility)

USCG TYPE-APPROVAL: GETTING THE TESTING DONE


46 | CASE STUDY

FITTING A SUNRUI BALCLOR BWMS ON BOARD AN AFRAMAX TANKER WAS A NEW EXPERIENCE FOR YARD, OWNER AND DESIGNER, WITH LESSONS LEARNED

INSTALLATION TESTED YARD’S PROJECT MANAGEMENT

T o be ready for IMO’s Ballast Water Management

Convention (BWMC) and US Coast Guard regulations, many shipowners have been studying ballast water management systems (BWMSs) of all kinds. Some owners have gone further and started some pilot projects.

SunRui Marine Environment Engineering Co has been involved in such a project, which was a new venture for the owner, yard and system designer.

The owner has a huge tanker fleet, mainly consisting of VLCC, Suezmax and Aframax tonnage. After reviewing all the active makers, it selected BalClor BWMS, manufactured by SunRui Marine Environment Engineering Co, to be installed on an Aframax tanker docking in a Turkish yard. It selected SunRui because of its 30+ years of experience in electrolysis technology and its reliable treatment system, which uses side-stream electrolysis technology.

The first step involved

onboard scanning, designing and class approval. This work was done by a third party designing company appointed by owner, which led to a lot of communication among all three parties: shipowner, BWMS maker and designer. SunRui suggests that it would be preferable for BWMS makers to be able to tackle all 3-D designing works to improve efficiency and remove the owner’s responsibility of chasing the designing company.

After the 3-D modelling, the ship’s owner immediately noticed the elephant in the room: the pump room was too small to install a whole treatment system. This situation is not rare: limited space is always the biggest obstacle to install BWMSs on tankers. But BalClor only requires its filters to be installed in pump room, so this issue was quickly solved with a little design work for the main ballast pipeline.

One advantage of BalClor BWMS is that, even with one more pump onboard for ballasting and deballasting the

aft peak tank, there is no need for an additional treatment unit or modifications to existing piping, as the treatment system in the engineroom can be used for this as well.

Then came installation, during which SunRui’s supervision engineers were present, providing technical support to the yard and handling all related works to keep the process smooth.

But there were challenges. First, since this project was the first of its type for the designer, there were some designing mistakes. For example, the feeding pipe and dosing pipe to/from the electrolysis unit were misconnected on the detail drawings. SunRui’s supervision engineers worked with the owner and redesigned the two pipes.

Second, this was also a new project for both owner and yard. The BWMS was delivered in wooden cases and left on ship’s main deck. Many yard workers were involved in handling, lifting and installing the equipment and some small components were misplaced. This caused some

headaches but could be easily avoided by the yard arranging one person to be in charge.

Of course, the yard’s workers were not familiar with the BalClor BWMS and only a few workers could understand English, which cost SunRui’s supervision engineers a lot of time in explaining its details.

This delayed SunRui’s service engineers from starting commissioning, leaving them two days – instead of the planned five – for commissioning and crew training. However, since all BalClor BWMSs have been pre-tested by simulating the onboard running conditions, system commissioning was finished and approved by class within the limited time. Crew training and some additional tests required by owner were accomplished in US waters with SunRui’s service engineers on board.

At the time of writing, in early 2016, SunRui holds more than 30 retrofitting orders for vessels including bulk carriers, container ships, semi-submersibles and tankers. BWTT

SunRui’s BalClor BWMS on the dockside ready for installation on an Aframax tanker (credit: SunRui)

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CASE STUDY | 49

ALFA LAVAL DESCRIBES AN INSTALLATION ON A VESSEL THAT WILL OPERATE IN FREEZING TEMPERATURES AND NEEDS AN EX-RATED SYSTEM FITTED INTO A LIMITED SPACE

A key hurdle in installing a ballast water treatment system is adapting it to the needs of an individual vessel. This is most challenging when the vessel itself has exceptional

requirements, as is the case with a series of state-of-the-art coastal articulated tank barge and tugboat units (ATBs) being built for a US operator.

The series’ scope of operations will include freezing conditions in Alaska and the vessels will have minimal machinery space. These factors necessitate a reliable and compact solution, especially as the vessels’ machinery will be unmanned while underway.

They are being equipped with two Alfa Laval PureBallast 3.1 systems rated IEC EX, each handling 1,000 m3/h and installed as a module.

PureBallast 3.1 is an in-line treatment system whose chemical-free operation supports the vessels’ minimal manning, as does its high level of automation, which includes cleaning-in-place to remove biological build-up and secure optimal performance. Provided the water is in liquid form, it operates in frigid conditions without additional heating.

Two stages of treatment are involved. Following an initial filtration stage, biological disinfection occurs through an enhanced form of UV treatment. This is performed in a corrosion-resistant reactor, which is a pressure vessel of 254 SMO steel with an expected service life of 20 years or more.

The special design of the reactor’s synthetic quartz lamp sleeves transmits a broader wavelength spectrum, providing 10 per cent more UV light during disinfection. Combined with the reactor’s internal design, this ensures optimal UV dosage, low energy consumption and reduced operating cost.

The reactor also features power ramp-up capabilities, enabling PureBallast 3.1 to provide full-flow treatment in waters with low UV transmittance.

To overcome the vessels’ explosion-proof (EX) requirements and lack of machinery space, each PureBallast 3.1 system is delivered as a self-contained module with the dimensions of a 20ft high-cube ISO container. This is divided by a gas-tight bulkhead into an electrical space and a wet space and has ISO corner fittings for handling.

The electrical space is designated as a safe area, containing the electrical equipment not rated for installation in a hazardous area. Its access door and ventilation openings must also be located in a safe area. The wet space is designated as a hazardous area without a source of cargo vapour release. It contains the wet components of the PureBallast 3.1 system, as well as ancillary equipment.

With the vessels to be unmanned during underway periods, system drainage and operational procedures are in place to ensure that freezing conditions do not negatively impact or damage any part of the installed system.

As no fresh water or freshwater cooling is available on deck, the module design has internal storage tanks and cooling independent from the ATB. During treatment, ballast water cools a closed-loop glycol system that uses an Alfa Laval plate heat exchanger and circulating pump.

Because the module design is standardised, transportation and vessel integration are simplified. Each unit is supplied pre-assembled, pre-wired, outfitted and factory wet-tested. The finished quality reduces installation errors and time at the yard, which receives an interface drawing and can perform a plug-and-play installation.

The design has ABS type-approval and USCG Alternate Management System status for installation on US-flagged tank vessels. Creating it involved many operational and physical challenges and demanded a high level of project management experience and execution. Alfa Laval has worked closely with Marine Systems Inc (MSI) and Glosten Associates in creating this simple, self-sufficient solution for challenging conditions. BWTT

COPING WITH CHALLENGING ENVIRONMENTS

The in-line enhanced UV reactor in the hazardous area (credit: Alfa Laval)


50 | CASE STUDY

OCEANSAVER PROVIDES A RETROFIT FOR PROVALYSOceanSaver is applying what it has learned from a number of LNG retrofits as it works on a large LNGC

L NG shipowners are especially focused on safety and quality of performance. With their ability to handle high volumes of water, electrochlorination systems are especially suitable

for LNG carriers. For OceanSaver, this makes the LNG fleet a core focus and it has carried out a number on retrofits on such tonnage.

At the time of writing, in mid-March, a project for the French energy company Engie is well under way to retrofit an OceanSaver BWMS on its 2006-built 150,000m3 capacity LNG carrier Provalys. When it was built, it was the largest LNGC in the world. The contract also includes an option for a sister vessel.

OceanSaver’s BWTS MK II system combines pre-filtration using a 40µm mechanical self-cleaning screenfilter with electrochemical disinfection. Provalys has two main ballast water loops operated by two ballast water pumps, with a third available as redundancy, so the OceanSaver installation configuration consists of separate filters installed on each loop.

These are both served from a single unit – called C2E – that produces disinfectant by treating about one per cent of the waterflow with an electrodialytic process. This unit can serve both loops either simultaneously or independently, one at a time. Space for the C2E unit and its necessary infrastructure has been allocated in the engineroom.

The aft-peak tank treatment is operated by the main system

and it also serves as a reservoir for feeding the membrane cell in the C2E should the salinity of the ballast water being loaded fail to meet the level required to produce the disinfectant. OceanSaver’s supply also includes operations control for installation in the cargo control room and in the engine control room.

OceanSaver conducted a 3-D scan survey as the basis for a detailed 3-D model, engineering considerations and ultimately drawings. OceanSaver is also responsible for issuing class drawings and will support the class approval process. By the time this edition of BWTT is published, these drawings, the final 3-D model and other details will have been submitted to class.

Engie ordered the system in October 2015 and it will be ready for shipment in July 2016 for installation during docking scheduled for September 2016. The owner will be responsible for the actual installation with OceanSaver providing on-site support by the presence of an engineer during the entire installation period.

Common ground for most LNG BWMS specifications – both for newbuildings and retrofits – often relate to the level of reliability and redundancy that can be achieved. In addition, there are always technical challenges and commercial consequences for the shipowner.

Installing a BWMS is a major operation with complex interfaces to critical systems. In a newbuilding context, the yard and supplier may have sufficient time to determine, evaluate and complete the final design layout but retrofitting projects often lack the luxury of time.

For these contracts, dedication and understanding by the supplier is essential, as is a higher level of involvement from the shipowner, and responsibilities between the involved parties in a retrofit project may be divided differently. Communication and sharing of information as early as possible as well as a mutual understanding and expectation with regards to responsibilities are essential for a successful result.

OceanSaver’s retrofit model covers the dedication of responsibilities and a progress milestone programme for quality control purposes. It makes sense to allow six-10 months for the completion of a retrofit project following the contractual agreement, although it can and has been undertaken within shorter timeframes.

Before that, the process of selecting a BWMS brings many issues to the table. Some are system-specific, addressing operational and technical characteristics whilst others have a more strategic flavour. In view of the uncertainties related to regulations and in particular reflecting on the fact that no systems in the marketplace have yet to become USCG type-approved, complete compliance is one concern for owners, along with the relatively unknown reputations of many BWMS suppliers. BWTT

OceanSaver’s C2E unit, which will be fitted onboard Engie’s LNG carrier Provalys in September (credit: OceanSaver)

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LEADING EXPERTS IN BALLAST WATER MANAGEMENT

Mouawad Consulting delivers advisory services for the maritime

industry, specialising the field of Ballast Water Management (BWM).

We offer turnkey retrofit solutions for ship owners, including

_ 3D scanning,

_ Design

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REGULATIONS

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Mouawad Consulting AS

Stafsbergvegen 21, NO-2318 Hamar, Norway

T: +47 480 50 902 | E: [email protected]


LEADING EXPERTS IN BALLAST WATER MANAGEMENT

Mouawad Consulting delivers advisory services for the maritime

industry, specialising the field of Ballast Water Management (BWM).

We offer turnkey retrofit solutions for ship owners, including

_ 3D scanning,

_ Design

_ Class drawings development and follow up

_ Pre-fabrication of pipes,

_ Installation, supervision and commissioning of BWM Systems.

Other services include

_ Market and feasibility studies

_ Regulatory compliance with EPA and USCG for ships

_ Design and type approval consultancy for manufacturers

of BWM Systems.

ASK US HOW AND WHEN TO

COMPLY WITH THE UPCOMING BWM

REGULATIONS

bwm.no

Mouawad Consulting AS

Stafsbergvegen 21, NO-2318 Hamar, Norway

T: +47 480 50 902 | E: [email protected]

OPINION | 53

IT IS TIME TO CHOOSE YOUR BWMSAs deadlines loom, the time for action on installing a ballast water management system has arrived, say Debra DiCianna, senior environmental solutions engineer, and Yoshi Ozaki, director, of American Bureau of Shipping

With the US Coast Guard (USCG) type-approval announcements on ballast

water management systems (BWMSs) on the horizon, shipowners considering their compliance strategies are set for a busy year monitoring regulatory developments and evaluating options.

At the time of writing, in February, the USCG has acknowledged 32 letters of intent. Most of those vendors have contracted with an independent laboratory (IL) for testing and many have already begun testing. The expectation is that the USCG could award type-approvals as soon as the third quarter of 2016.

Fortunately, the USCG system of extensions is providing some relief, with the vessels’ next dry-docking date being set as the installation deadline rather than the previous short-term extended compliance date.

At the moment, obtaining an extension remains a straightforward procedure, but owners should be aware that as type-approvals begin to be awarded, increasingly detailed explanations will be required for further extensions. In some cases, this could include proving that the process of researching or contracting for system installation is underway.

The USCG’s rigorous testing regime has been designed as far as possible to remove the variability of system efficacy under actual operating conditions. A key requirement is that land-based testing requires five consecutive, valid and successful test cycles, something not presently required by IMO’s Ballast Water Management Convention.

Although USCG testing is prescriptive, it does allow vendors to identify the operational constraints of a system when developing their

specific test plan. When evaluating systems, owners should take into account the range of salinities at which land-based testing was conducted and the treatment rated capacity used for both land-based and shipboard testing. This is the maximum continuous capacity, expressed in m3/hr, for which the BWMS is type-approved and is particularly important for BWMSs with large capacities and high flow rates.

It is critical to understand that a BWMS type-approval certificate does not guarantee effective operation in all conditions but more specific and rigorous testing of a BWMS during the required six months’ shipboard testing should alleviate concerns about port state inspections.

There are a lot of variables, so it is important that those wishing to fit an approved system so as to achieve early compliance with the USCG discharge standards should balance that decision against the risk that the first approved systems may not be the optimal choice for the vessel under consideration.

A better approach would be to begin evaluating the technologies most suitable for the design and operation of a particular ship and work with vendors to determine the most appropriate models. This approach allows shipowners to identify the most suitable systems and to prepare the supporting documentation that may be needed for future USCG extension requests. Future extensions will require shipowners to demonstrate that available type-approved BWMS are not suitable for their ships.

Owners evaluating a BWMS should be aware of the vendor’s status and progress in USCG testing and should understand the choices the manufacturer made when developing its test plan. Performance will be vital, particularly because ships can be boarded at any time for inspection and sampling.

It is not surprising that USCG type-approval is regarded by owners as akin to the ‘Holy Grail’, given its testing requirements. The emergence of approved systems should certainly dispel doubts about which systems owners will choose to install.

In the process of selecting a system, it will be essential to carry out a comprehensive BWMS technology evaluation for design and operability. First movers are already well down this path. For the others, the time to begin is now. BWTT

Debra DiCianna, left, Yoshi Ozaki, right (ABS): “the time to begin is now” (credit: ABS)


54 | OPINION

Shipowners are caught between politics and science

When the International Maritime Organization’s Ballast Water Management

Convention (BWMC) enters into force, implementation will require a very large capital investment by the shipping industry in a relatively short period of time. More than 60,000 vessels will need to install ballast water management systems (BWMSs) so, at an average cost of US$1-2 million per vessel, the industry will need to make a capital investment well in excess of US$60 billion.

Given the size of the investment, it would be preferable if owners could be certain that their investments will result in regulatory compliance. Unfortunately, that certainty does not currently exist.

We find ourselves in a situation in which owners could be required by the BWMC to install treatment systems without having certainty that those systems would comply with its discharge standards and without having certainty that those systems could be used to meet treatment requirements in the United States.

That uncertainty comes from the interaction of the two primary regulatory regimes that apply to ballast water.

The first is the BWMC, which will enter into force one year after signatories representing 35 per cent of the world’s tonnage deposit their instruments of ratification. At the time of writing, we are just a fraction of a percentage point short of that threshold. Once the convention enters into force, vessels will have to install treatment systems on a phased schedule.

The second is the US regime, which is actually two separate regimes based on two

sets of laws. The Environmental Protection Agency (EPA) regulates ballast water under its Vessel General Permit issued under the Clean Water Act while the US Coast Guard regulates ballast water under two related invasive species statutes.

Having two sets of statutes and two federal agencies regulating ballast water discharges is not the result of planning or policy; it is the result of litigation. The system does not make sense from any perspective, but Congress has not yet acted to fix it.

The US and IMO discharge standards are the same, so that does not present a problem, at least for now. What does present a problem is that the type-approval standards for treatment systems under the US regime and the IMO convention can, and so far have, produced different results.

IMO requires that systems be type-approved based on the “G8” guidelines. Based on concerns about the ability of the IMO type-approval process to produce compliant equipment, the US developed a stricter set of type-approval procedures. The USCG requires that systems used to treat ballast water discharged into US waters must receive its type-approval.

Once the BWMC enters into force, vessels will be required to install systems that have been type-approved based on IMO requirements. But if they install a system not approved in the US, that system will not meet the US requirements. As of today, there are no USCG type-approved BWMSs so there is no system that a shipowner can use to comply everywhere. For a global industry, that is a big problem.

If US treatment system type-approvals

are granted soon and if revised IMO G8 type-approval guidelines are implemented before the convention enters into force, that dilemma will be solved. But the success of an environmental protection programme of this magnitude should not rest on a hope about something that we cannot predict or control.

However the current dilemma gets resolved, there is a lesson here: the science and the capabilities of the technologies on which environmental solutions will be based must be understood at the beginning of the process. With ballast water, the politics were settled before the science. That is a mistake we should avoid in the future. BWTT

Vessel owners cannot be certain that if they invest in a BWMS it will comply with the regulations. At present, they do not have that certainty, says John Butler, president and CEO of the World Shipping Council

John Butler (World Shipping Council): “there is no single system that a vessel owner can use to comply everywhere” (credit: WSC)

“With ballast water, the politics were

settled before the science”

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E veryone involved in ballast water management seems to have stories to tell of their experiences,

frustrations and complete and utter dissatisfaction with regulators, IMO, the US Coast Guard (USCG) and whoever else is involved in this sector.

Many had hoped that the USCG type-approval process would at least be one objective process that could be relied upon to bring answers to many of the questions and scepticism that has been thrown at IMO’s type-approval process, but even those hopes seem to be misplaced.

It is no secret that shipowners rely heavily on the USCG to resolve any questions they might have had about the efficacy of treatment technologies, including the way they have been tested and approved by many countries worldwide. The USCG is often viewed as the reliable, able and trusted body that can evaluate ballast water management systems (BWMSs) in a robust and rigorous way and so confirm or disprove the work done by the IMO. But is that the case?

In the USCG model for evaluating marine equipment, the term ‘independent

laboratory’ (IL) is often used to identify private entities that are approved and audited by the USCG to perform certain tests, the results of which would form the basis for type-approval by the USCG. Only reports by ILs are acceptable to the USCG.

The model of IL that the USCG uses is similar to the ‘recognized organization’ (RO) concept that IMO uses for class societies. But class societies compete on price and apply different standards based on their own rules and regulations, in addition to IMO’s. Unfortunately for ballast water management, the same thing is taking place with ILs testing BWMSs under the Code of Federal Regulation (CFR) that sets out testing requirements used by the USCG for BWMSs, known as 46 CFR 162.060.

The first step in a USCG type-approval process is choosing an IL and a test facility to perform the required tests. Running a background check on the challenge water conditions at the test site is a very important factor for a BWMS maker since this will determine whether or not the system will pass the type-approval testing. More importantly, it will determine the

limitations that the USCG type-approval will impose on the BWMS if it does pass the tests.

For example, testing in fresh water at 0.8 PSU* is very convenient for manufacturers with technology that is dependent on salinity (for example, electrochlorination). Choosing a test facility that offers fresh water testing at 0.1 PSU is not as convenient because, although both tests would give approval for use in fresh water, one would have an operational limit of 0.8 PSU while the other a limit of 0.1 PSU.

For a shipowner that is intending to buy a BWMS to operate it in fresh water, thorough research to find out the level of salinity in the ports its ships are calling becomes crucial, because 0.1 PSU and 0.8 PSU are very different, even though both are labelled fresh water. However, such research is often futile for most ships that simply trade wherever the winds take them. A simple solution would be to include on the type-approval certificate the minimum salinity that the system is tested under, but it is not yet clear whether the USCG will do that or not.

What applies to salinity, applies as

56 | USCG TYPE-APPROVAL

USCG TYPE-APPROVALS:

what to expectIn this assessment of the USCG type-approval process, independent consultant Jad Mouawad sets out his impressions of how it works


USCG TYPE-APPROVAL | 57

well to other parameters. These include: temperature; total suspended solids (TSS) concentrations; added or natural TSS types and sizes; types of organisms in different categories and how those organisms react to the technology you intend to apply; types and amount of added material to increase dissolved organic carbon (DOC) and particulate organic carbon (POC). And there are more that could be listed.

After making this selection, manufacturers should start looking into how thorough ILs are in the first phase of the type-approval process, which is the readiness evaluation. This assessment is based on how deep the technical review is, how thorough and to what degree ILs look into the control and automation system of a BWMS and how much class rules or CFR rules will apply to their equipment.

For example, one sub-contractor to an IL started requiring failure mode and effects analysis (FMEA) from BWMSs. This is an advanced analysis, usually used by the offshore industry and shipping industry in connection with required and very sensitive vessel functions. Yet no other

IL requires FMEA and this sub-contractor recently stopped requiring FMEA. Another IL requires a very thorough safety analysis for a BWMS, while others do not even acknowledge the risks.

If ILs are so different, is there any point in doing all these tests and thinking that a USCG type-approval is a guarantee that the system is robust?

The short answer is: yes. Despite the flaws and gaps of the USCG type-approval testing regime, our experience at Mouawad Consulting is that the USCG is working hard to bridge those gaps, taking decisions and sending interpretations to their ILs. It is responding positively to practical proposals and solutions but it will take years before things are streamlined. Still, this regime is far more robust and consistent than many regimes that IMO member states have applied when using the G8 guidelines for IMO type-approvals.

*PSU: practical salinity unit. Fresh water is defined in the Environmental Technology Verification (ETV) Protocol as water with salinity lower than 1 PSU

Choosing a suitable independent laboratory – such as this one, operated by the Great Ships Initiative, is essential in applying for USCG type-approval (credit: US Maritime Administration)

Since ballast water management regulations can never be specific enough for a regulator to apply the same standard globally, shipowners must look thoroughly into what they are buying.

Buyers should be alert to the latest marketing trend: Mouawad Consulting has found that some BWMS manufacturers announce that they have submitted a letter of intent (LoI) signalling their intention to start USCG type-approval testing, saying that the actual testing dates are pending availability of testing facilities or pending approval of testing facilities by the USCG.

Yet a quick phone call to the approved test labs often shows good availability. Anyone can submit an LoI and not act on it. Unfortunately, this has become a widespread strategy among manufacturers who may be hoping to sell enough equipment to fund the expensive tests. My advice is to get definite contracts and payments showing a real intent of testing for USCG type-approval.

Finally, making a type-approval standard more specific and robust helps little when equipment is wrongly installed or operated. The former is especially alarming and it is important that class societies, shipyards, administrations and designers understand what systems need to operate properly, how they should be installed, commissioned, serviced and operated.

Buyer beware!

With the wide variations in the approaches taken by independent laboratories (ILs) outlined above, shipowners might wonder how the USCG audits potential ILs. The USCG will sometimes visit a test facility and follow one testing run.

Auditors face a challenge, however: during a test run, many deviations can take place and the USCG can never be sure that test facilities handle those similarly. A deviation can mean a failed test, breaking the required run of five consecutive successful tests. So test facilities might feel under pressure to declare an unsuccessful test as “failed due to conditions outside the control of the BWMS.”

Perhaps more critical, though, are the readiness evaluations, mentioned above. The USCG has no chance of making sure that if a system secures approval from one IL it would have done so from any other IL. BWTT

Auditing the auditors

58 | AFTER-SALES SERVICE

Tips for good serviceOnce a system has been installed, keeping it well maintained and in working order is essential by Bill Thomson

O ne important consideration for any ballast water management

system (BWMS) is availability. If, for any reason, the system is out of action then the ship is severely restricted in its ability to trade. Any consumable items and necessary spare parts, have to be available in ports to which the ship trades – otherwise it will not be able to discharge ballast water.

After-sales service systems count for a lot when choosing a BWMS supplier. Wärtsilä, for example, can call on its service network of over 1,700 technicians in 70 locations, available at all times, to support its Aquarius BWMS range. That is not to say a smaller, more specialised manufacturer cannot provide good service. Mark Kustermans, market manager of Trojan Marinex, pointed to its two specialist partners, Damen Shipyards and GEA, which provide start-up, commissioning and operational service to its end users.

Damen is also partnered with Evoqua, while GEA is itself part of a large organisation, with a global network that can deliver parts for its own BallastMaster BWMS within 48 hours to all major ports from two logistic centres in the European and Asia Pacific regions. According to its head of marine sales, Sven Mario Jadzinski, such service should rarely be required: “The system has been designed to run safely and with 100 per cent reliability between scheduled maintenance intervals,” he assured BWTT.

Its onboard commissioning programme includes training shipboard personnel in fault

diagnosis and repair and the system is designed with fail-safe technology, he said, adding: “the crew receives continuous indications that the system is working correctly, while process data such as throughput capacity and UV transmission rate are recorded and stored.”

Phil Hughes, commercial manager of Coldharbour Marine, agreed. “Owners and managers must ensure not only that the system suits their particular vessel, but that commissioning and servicing is carried out by competent engineers who are fully trained and experienced with that system, and not simply locally-based generalists hired on the basis of cost.”

Keeping track of how the system is functioning is vital. All provide onboard displays of system status and alarms, with some, such as Trojan Marinex, providing automatic shutdown if necessary. Some suppliers take this a stage further by offering remote monitoring and diagnosis capabilities. Wärtsilä is working to integrate BWMS into its remote monitoring

system, while Coldharbour can offer diagnosis via remote log-in. Not all manufacturers see this as necessary or desirable. Mr Kustermans cited the limitations in ship-to-shore communications as a barrier to effective remote fault diagnosis.

Evoqua believes it can offer a service package unparalleled in the BWMS market, having recently established a partnership with Drew Marine. Evoqua’s business development manager, Ed McNally, said: “With a presence in over 900 ports worldwide, Drew’s service and logistics network offers ship operators everything necessary to comply with the self-monitoring requirements of the US Environmental Protection Agency’s vessel general permit.” This is additional to Evoqua’s own service network, which is constantly being expanded with increased part stocks, he said.

“We’re very aware that

in the event of technical difficulties, vessels can become immediately non-compliant,” Mr McNally added. “It is crucial that any BWMS issues are resolved as quickly as possible. We aim for responses to technical queries within two hours and issues fixed within 24 hours of initial contact.”

Ecochlor pointed out that, unlike most other shipboard machinery, the BWMS runs for only a small percentage of the time, so it has found that maintenance is minimal and infrequent. It has also signed an agreement with Drew Marine to provide supply and delivery of precursor chemicals and technical support.

Hyde Marine′s product manager Mark Riggio agreed that after-sales support is vital: “With most customers not purchasing full redundancy in BWMS, the effectiveness of service support will be key to long-term performance.” BWTT

Cathelco has a network of nearly 50 agents and installers worldwide for its BWMSs, staffed by qualified marine engineers (credit: Cathelco)

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CONTAINERISED SYSTEMS | 61

With a formal product launch planned for May this year, Ballast Water Containers (BWC) is conducting market research on its newly-launched website and its

survey questions make it clear what the company’s purpose will be: containerised ballast systems for mobile use or permanent installations.

BWC has been set up by Malin Group of the UK, which specialises in a range of activities including project cargo shipping. One group company, Cleanship Solutions, advises shipowners on meeting environmental regulations, including ballast water management, and its general manager, Chris McMenemy, told BWTT that BWC has been set up to support “niche areas of the industry that are likely going to struggle to comply.”

With Malin Group’s experience in heavy lift transport, Cleanship Solutions realised that barges “are going to have a hard time complying, both technologically and commercially,” he said. Since

they conduct ballast operations for only a few weeks of the year, the capital cost of a ballast water management system (BWMS) “is unpalatable for them,” he explained.

Instead, BWC will offer a containerised system that could be purchased or leased. It will be based around proprietary BWMS equipment as it is designed to slot into the existing infrastructure used on heavy lift projects. It will include a number of innovative features, Mr McMenemy said. “We are doing more than just sticking it in a steel box.”

Shipowners wanting to buy a system can specify which BWMS is fitted and the company is working on some feasibility projects with different owners on that basis, he told BWTT.

BWC will also provide a range of services, from feasibility studies and project planning to obtaining pre-approval from flag and port authorities for barge operations and providing the mobile system and trained operators.

BWC brings boxed ballast to bargesA new company is launched to develop containerised ballast treatment systems, initially for heavy lift barges

Dutch company UniBallast believes it is ushering in “a new era of ballast water treatment,” thanks to its containerised BWMS and universal ballast water port connector (UBPC). This allows

a ship to connect to a mobile containerised treatment system, which could be on deck or on shore.

UniBallast has also developed a design for a matching treatment unit, which

would be the size of a 20ft or 40ft box, depending on the equipment that is fitted inside; the company will install any system that will fit into the space.

“Retro-fitting a complete ballast water treatment system

on a vessel is not always the best way forward,” the company’s literature says. “Having a containerised unit on deck or treating the ballast with a shore based installation might be a better solution.” BWTT

Ballast connector heralds ‘a new era’ of BWMS

Containerised BWMS simplifies installationA containerised ballast water management system (BWMS) secured its first two deliveries in September 2015 for use on a newbuild tank barge constructed by Gunderson Marine. The system is called the Ballast Treatment System Deck Module and was conceived by US engine services and spare parts specialist Marine Systems.

Marine Systems appointed

naval architecture and marine engineering consultancy Glosten to develop the unit, which combines Alfa Laval PureBallast 3.1 treatment systems and Filtrex filters. The components were fitted into a housing with the same footprint as a 20ft container.

Glosten’s marketing manager, Zenzile Brooks, told BWTT that the system was designed for US-flagged

unmanned tank barges. This requires it to meet the US Coast Guard’s more restrictive requirements in way of hazardous areas. It is also suitable for unmanned barge operations and for lay-up without power.

Each unit can treat 1,000 m3/hr of ballast water. The units are approved by both ABS and USCG for hazardous area installations.

One of the containerised ballast water modules under construction (credit: Glosten)

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SU - Ballast Water Treatment Technologies Ad_A4.indd 1 3/30/2016 11:09:40 AM


62 | CONTAINERISED SYSTEMS

SHIPBOARD TESTS FOR PORT SOLUTIONA lthough the main focus for

BWMS is on systems installed for treatment onboard vessels,

there are a still a number of advocates of the advantages of port-based solutions for treating ballast water that would avoid ships having to install expensive equipment that is vulnerable to an uncertain regulatory environment and potential failures.

However, even port-based systems need to have the necessary type-approval and must also generate the confidence of ship operators that they can meet their requirements as well as meeting the necessary regulatory standards.

One such system that is currently undergoing shipboard testing is Damen’s InvaSave mobile treatment system that is seeking IMO type-approval and national approval from the Netherlands authorities. It has already undergone various land-based tests, which Damen says were successful, at the Marine Eco Analytics

testing organisation in the Netherlands during 2015. This is being followed by shipboard tests on board the 800 teu container vessel Henrike Schepers, owned in Germany by HS Schiffahrts and currently operated by Iceland-based Samskip.

Henrike Schepers was built in 2008 to a Damen design and operates container services in northwest Europe. The trial involves ballast water being taken onboard untreated and the equipment will be used on discharge and tested for its effectiveness and compliance. The InvaSave system can be mounted on a barge to be moved around a port, or mounted on a road trailer.

A vessel needing to discharge its untreated ballast water can connect to the InvaSave unit, which then processes the water and discharges the treated ballast water in the port.

Damen’s manager for ballast water treatment, Gert-Jan Oude Egberink said: “It can serve as a port-based alternative

for shipowners that may not want to retrofit an onboard treatment system, perhaps because their ships operate on non-exempted fixed routes or their ships are so old as to make any investment in such a system prohibitively expensive. Alternatives like InvaSave are also required for ports that need to provide backup in the case of emergencies when ships’ onboard treatment systems fail. It will prevent expensive delays in ports caused by failing onboard systems. And some types of vessels don’t need to invest in an onboard BWT system at all.”

He told BWTT: “Every BWMS that wants to receive a type-approval needs to pass both land-based and shipboard tests. We have very good relations with this ship operator and this vessel was built by Damen. We are following IMO guidelines and therefore we have to perform a shipboard test, although the InvaSave is meant to be exploited as a port based service.” BWTT

Despite being port-based, the InvaSave system must pass shipboard tests (credit: Damen)

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64 | COSTS AND BENEFITS

Counting the cost of ballast treatmentInstalling a BWMS can be expensive. But that is just the start: operational costs will mount up. Manufacturers outline some of the ongoing expenses that must be taken into account

by Bill Thomson

A lthough installation costs of ballast water management systems (BWMSs) are considerable – estimates by shipowner organisation BIMCO suggest up to US$5

million per ship – these sums could be dwarfed by operational costs over the ship’s lifetime.

In determining the total lifetime costs, owners will have to factor in the cost of consumables and spare parts, as well as monitoring to ensure that the systems are doing their job in keeping the ship compliant.

Many manufacturers are conscious of operational costs and have attempted to keep consumable parts and materials to a minimum. For example, Evoqua’s business development manager Ed McNally said: “We designed the SeaCure system with maximum uptime in mind. Nevertheless, owners and operators may need to devote a minimal amount of voyage time for routine maintenance and visual inspection to ensure the BWMS is kept in good operational condition.”

He explained that definitive costs vary with system size and management approach, but Evoqua can supply a five-year spare parts package and its 40-year experience with electrochlorination cells in other industries allows Evoqua to offer a long warranty on the core components.

Ecochlor’s president and founder, Tom Perlich, offered some specific guidelines for the running costs of its chemical-based system, suggesting figures of US$0.08/m3 of treated water for precursor chemical, while fuel costs typically range from US$25 to US$200 per annum depending on flow rate and power requirement. Chemicals are supplied about every six months.

In addition, there are maintenance costs, and he recommends that owners budget approximately US$2,000 annually for miscellaneous maintenance activities. Filters will also need replacing at intervals of between five and ten years, with a replacement cost ranging between US$3,600 and US$12,500 per screen.

Mark Riggio, product manager for Hyde Marine, believes that system reliability is key to keeping compliance costs under control. “We have over 10 years of experience with systems in operation and reach out to all users, incorporating their feedback directly in our design,” he said. “The equipment is designed to be very simple to repair and troubleshoot, with alarms and indications incorporated to show any component or system malfunction, and we offer detailed instructions to shipboard crews.”

Coldharbour Marine’s commercial manager Phil Hughes shares the view that inherent reliability is needed to give confidence over

Ecochlor’s chemical costs start at US$0.08/m3 of treated water (credit: Ecochlor)


COSTS AND BENEFITS | 65

the life of the equipment. “Our system is inherently reliable as the in-tank elements have few or no moving parts. Our inert gas generator, which provides the gas for BW treatment, has no burner cone to be replaced and no demister pads to block and replace. Few spare parts are needed; we have no filters, no UV lamps and no electrodes to decay or need replacing.”

Mark Kustermans, market manager at Trojan Marinex, said that owners must carefully consider operational expenditure, particularly if they decide to keep a vessel for more than about five years, when replacement components become necessary. “Annual expenses can range from 3 per cent to more than 15 per cent of the capital cost,” he said.

But he said that all BWMS technologies have some operational benefits that can minimise additional costs. “Our system is equipped with TrojanUV Solo Lamp technology, with a life expectancy beyond 10,000 hours, equivalent to more than 10 years of normal ballast water treatment operation,” he said. This compares with typical medium-pressure lamps that have a life expectancy of 4,000 hours, he added.

Mr Kustermans also stressed the importance of regular discharge sampling and calibration of sensors to the cost of compliance. He cited the US Environmental Protection Agency’s 2013 vessel general permit, which specifies a schedule of independent monitoring, two to four times per year, with annual calibration of monitoring equipment.

“This dual compliance requirement for all active substance systems – biological and residual biocide monitoring – increases the cost of compliance over physical treatment methods, such as UV, and is an additional consideration when evaluating technologies,” he said.

Operational costs also played a part in Maersk Line’s decision last year to fit at least 14 of Desmi Ocean Guard’s RayClean treatment systems on a series of new container vessels to be built at Cosco Zhoushan shipyard in China.

The system uses low pressure UV, which Desmi said has low power consumption, and Rasmus Folsø, chief executive of Desmi Ocean Guard, commented at the time: “Total Cost of Ownership analyses have shown us that the RayClean system will provide considerable operational cost savings to Maersk Line compared to competing systems, due to the low power consumption and long lifetime of the UV lamps.”

Hyde Marine believes that system reliability is key to keeping compliance costs under control (credit: Hyde Marine)

The “huge cost of US type-approvals” was blamed by one ballast water management system (BWMS) manufacturer for pulling out of the market last year. A source at the company, which asked not to be identified, told BWTT in November that those costs, together with low prices and difficulties in forecasting future demand, had led it to shelve its marketing and development work.

The company offers two different technologies and holds IMO approval for one of them. It had anticipated receiving IMO approval for the other by the end of the year and had been demonstrating its equipment at the Nor-Shipping exhibition in June last year, so the decision reflected developments during the closing months of the year.

Continuing delays in ratifying IMO’s Ballast Water Management Convention (BWMC) almost certainly played a part, commented one market observer to BWTT, recalling a similar move a year ago and reported in last year’s edition. At that time, German manufacturer RWO had stopped marketing its ballast water management system, CleanBallast, preferring instead to promote its core products.

That remains its position now: The system is not currently listed on its website’s home page but details can still be found there via a search engine and it is listed in the directory section of this edition of BWTT.

These are just two examples of a wider concern. Speaking last year, Kjeld Dittmann, chairman of the European Ships and Maritime Equipment Association (SEA Europe), which represents European shipyards and equipment manufacturers, said that confusion and delays around environmental regulations are reducing investment in ballast water treatment solutions and other environmental innovations.

Although Europe’s maritime technology sector “is leading the world in innovative solutions to environmental challenges,” he said, these delays represent “a significant risk for our sector.” What he saw as “the lack of transparency and clarity” about enacting and enforcing regulations puts jobs and investments at risk, he said. “Europe needs to show political leadership and not be too shy to enforce those measures, particularly when our own industry has stuck its neck out to develop the green technology solutions,” he said. BWTT

Manufacturers worry over mounting costs

Kjeld Dittmann (SEA Europe): Delays in regulation represent

“a significant risk for our sector” (credit: SEA Europe)

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DIRECTORY | 67

BWMS MANUFACTURER COUNTRY BWMS NAME PROCESSACTIVE

SUBSTANCE APPROVAL*

SYSTEM TYPE

APPROVAL

USCG AMS**

21 Centurywww.21csb.com

Korea ARAFiltration,

Plasma, UVFinal 2012/07

Yes 2012/07

Ahead Ocean technologywww.aheadocean.en.ec21.com

China Ahead Filtration, UVYes

2015/01

Alfa Lavalwww.alfalaval.com

Sweden PureBallast 2.0 Filtration, UV Final 2011/03Yes

2011/03Y

Alfa Lavalwww.alfalaval.com

Sweden PureBallast 3.0 Filtration, UVYes

2014/02Y

Aqua Engineeringwww.aquaeng.kr

Korea AquaStarElectrolysis/

ElectrochlorinationFinal 2012/03

Yes 2012/06

Y

Auramarinewww.auramarine.com

Finland CrystalBallast Filtration, UVYes

2012/10Y

Azienda Chimica Genovesewww.acgmarine.com

Italy ELCOLCELL BTsFiltration, Electrolysis/

ElectrochlorinationBasic 2014/03 No

Bawatwww.bawat.dk

Denmark Bawat Heat, DeoxygenationYes

2014/10Y

Bio UVwww.bio-uv.com

France Bio-Sea Filtration, UVYes

2013/02Y

Cathelcowww.cathelco.com

UK Filtration, UVYes

2014/05Y

Coldharbour Marinewww.coldharbourmarine.com

UK GLD Ultrasound, DeoxygenationYes

2015/02Y

COSCOwww.cosco.com

China Blue Ocean ShieldCyclonic,

Filtration, UVYes

2011/02Y

Dalian Maritime Universitywww.dlmu.edu.cn

China DMU-OHFiltration,

Advanced oxidationBasic 2012/03 No

Desmi Ocean Guardwww.desmiOcean Guard.com

Denmark OxycleanFiltration,

UV, OzonationFinal 2012/10

Yes 2012/11

Y

Desmi Ocean Guardwww.desmiOcean Guard.com

Denmark Rayclean Filtration, UVYes

2014/09Y

Dow Chemical Pacificwww.dow.com

Singapore Dow Pinnacle Filtration, Ozonation None No

Ecochlorwww.ecochlor.com

USA ES Filtration, Chlorination Final 2010/10Yes

2011/11Y

Ecomarine Technology Research Associationwww.hitachizosen.co.jp

Japan Ecomarine-ECFiltration, Electrolysis/

ElectrochlorinationFinal 2015/04 No

Elite Marine BWTS Corp.www.bwts.cn

China Seascape Filtration, UVYes

2013/12Y

Envirotechwww.blueseas.com.sg

Singapore BlueSeasFiltration, Electrolysis/


Ballast water treatment systems

*Systems with ‘active substance approval status’ under IMO’s G9 requirements have either Final or Basic approval or None. For systems following IMOs G8 route, which do not need this approval, this column is blank. ** USCG AMS status is indicated but without any date, since some systems have multiple dates depending on system variants.


68 | DIRECTORY


SUBSTANCE APPROVAL*

SYSTEM TYPE

APPROVAL

USCG AMS**

Envirotechwww.blueseas.com.sg

Singapore BlueWorld Filtration, Chlorination Basic 2011/07 No

Erma Firstwww.ermafirst.com

Greece ESK EngineeringCyclonic, Electrolysis/

ElectrochlorinationFinal

2012/03Yes

2012/05Y

Erma Firstwww.ermafirst.com

Greece FITFiltration, Electrolysis/

ElectrochlorinationNone

Yes 2015/01

Y

Evonik Industrieswww.peraclean-ocean.com

Germany AVITALIS Filtration, Chemical Final 2014/03 No

Evoqua Siemenswww.siemens.com

Germany SeacureFiltration, Electrolysis/


Yes 2014/02

Y

Ferrate Treatment Technologieswww.ferratetreatment.com

USA Ferrate Ferrate No

GEA Westfaliawww.westfalia-separator.com

GermanyBallastMaster

EcoPFiltration, Electrolysis/

ElectrochlorinationBasic

2011/07No

GEA Westfaliawww.westfalia-separator.com

GermanyBallastMaster

UltraVFiltration, UV

Yes 2011/12 and 2014/08

Y

Gensyswww.gensysgroup.com

Germany BAWAC UV No

Hanla IMSwww.hanlaims.com

Korea EcoGuardianFiltration, Electrolysis/

ElectrochlorinationFinal

2013/05No

Headway Technologywww.headwaytech.com

China Ocean GuardFiltration, Advanced

oxidation, ElectrocatalysisFinal 2010/10

Yes 2011/03

Y

Hi Tech Marinewww.htmarine.com.au

Australia SeaSafe-3 Heat Yes 1997

Hitachiwww.hitachi.com

Japan ClearBallast Filtration, Flocculation Final 2009/07Yes

2010/03

Hwaseungwww.hsma.com

Korea HS BallastElectrolysis/


Hyde Marinewww.hydemarine.com

USAHyde GUARDIAN

/ GoldFiltration, UV

Yes 2009/04

Y

Hyundai HIwww.hhi.co.kr

Korea EcoBallast Filtration, UV Final 2010/03Yes

2011/03Y

Hyundai HIwww.hhi.co.kr

Korea HiBallastFiltration, Electrolysis/


Yes 2011/11

Y

JFE Engineeringwww.jfe-eng.co.jp

Japan BallastAce Filtration, Chlorination Final 2010/03Yes

2010/05Y

JFE Engineeringwww.jfe-eng.co.jp

Japan NeoChlor Marine Filtration, Chlorination Final 2012/10Yes

2013/06

Jiangsu Nanji Machinerywww.jsnj.com

China NiBallastFiltration, Memb,

DeoxygenationYes

2013/01Y

Jiujiang PMTR Institutewww.oceandoctor.cn

China Ocean DoctorFiltration, UV,

Advanced oxidationFinal 2013/05

Yes 2013/12

Y

Kadalneer Technologies Singapore Varuna Filtration, Electrochlorination Basic 2015/04 No

KALF Engineering www.kalf.sg

Singapore ElysisGuard Filtration, Electrochlorination Basic 2014/10 No

Katayama Chemicalwww.katayama-chem.co.jp

Japan Sky System Chemical Basic 2011/07Yes

2014/10

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DIRECTORY | 71


SUBSTANCE APPROVAL*

SYSTEM TYPE

APPROVAL

USCG AMS**

Katayama Chemicalwww.katayama-chem.co.jp

Japan SPO SystemFiltration, Chemical,

CavitationBasic 2011/07 No

Knutsen Technologywww.knutsenoas.com

Norway KBAL Pressure vacuum, UVYes

2012/11Y

Korea Top Marine www.ktmarine.co.kr

KoreaMarinomate

(ex KTM)Cavitation, Electrolysis/


Kuraraywww.kuraray.co.jp

Japan Microfade Filtration, Chlorination Final 2012/03Yes

2012/05Y

Kurita Water Industries www.kurita.co.jp

Japan KURITA Chemical Final 2014/10 No

Kwang Sanwww.kwangsan.com

Korea BioViolet Filtration, UVYes

2015/04Y

Kwang Sanwww.kwangsan.com

Korea EnBallastFiltration, Electrolysis/


Mahle www.mahle-industrialfiltration.com

GermanyOcean Protection

System OPSFiltration, UV

Yes 2011/04

Y

MH Systemswww.mhsystemscorp.com

USA Deoxygenation No

Mitsui Engineeringwww.mes.co.jp

Japan FineBallast MF Membrane FiltrationYes

2013/11

Mitsui Engineeringwww.mes.co.jp

Japan FineBallast OZFiltration, Ozonation,

CavitationFinal 2010/10

Yes 2011/07

Y

MIURAwww.miuraz.co.jp

Japan Miura BWMS Filtration, UVYes

2014/03Y

MMC Green Technologywww.mmcgt.no

Norway MMC Filtration, UVYes

2012/12Y

NEI Treatment Systemswww.nei-marine.com

USA VOS Deoxygenation, CavitationYes

2009/09Y

NK Cowww.nkcf.com

Korea Nk-Cl BlueBallast Chemical Basic 2015/04 No

NuTech O3/NK Cowww.nkcf.com

Korea BlueBallast Ozonation Final 2009/07Yes

2009/07Y

OceanSaverwww.OceanSaver.com

Norway MkIIFiltration, Electrolysis/

Electrochlorination, Deoxygenation

Final 2008/10Yes

2011/12Y

Optimarinwww.optimarin.com

Norway OBS Filtration, UVYes

2009/11Y

PACT www.pactchina.com

China PACT Marine Filtration, UVYes

2014/07Y

Panasiawww.gloen-patrol.com

Korea GloEn-Patrol Filtration, UV Final 2010/03Yes

2009/12Y

Panasiawww.gloen-patrol.com

Korea GloEn-SaverFiltration, Electrolysis/


Panasonic Environmental Systems & Engineeringwww.panasonic.co.jp

Japan ATPS-BlueElectrolysis/


Redox Maritime Technologieswww.redoxmaritime.no

Norway Redox Filtration, Ozonation, UV Basic 2013/05 No



SUBSTANCE APPROVAL*

SYSTEM TYPE

APPROVAL

USCG AMS**

RWOwww.rwo.de

Germany CleanBallastFiltration, Electrolysis/


Yes 2010/09

Y

Samkun Centurywww.samkunok.com

Korea ARA Filtration, Plasma, UV Final 2010/10Yes

2012/06Y

Samsung HIwww.shi.samsung.co.kr

Korea Neo-PurimarFiltration, Electrolysis/


Samsung HIwww.shi.samsung.com

Korea PurimarFiltration, Electrolysis/

ElectrochlorinationFinal 2011/07 Yes 2011/10 Y

Severn Trent De Norawww.balpure.com

USA BALPUREFiltration, Electrolysis/


Shanghai Cyeco Environmental Technologywww.cyecomarine.com

China Cyeco Filtration, UV Yes 2012/06 Y

Shanghai Hengyuan Marine Equipmentwww.sh-hengyaun.com

China HY-BWMS Filtration, UV Yes 2013/08 Y

Shanghai Jiazhou Environmental Mechanical & Electrical

China BALWAT Filtration, UV Yes 2013/02

STX Metalswww.stxmetal.co.kr

Korea SmartBallastElectrolysis/


SunBo Industrieswww.sunboind.co.kr

Korea BlueZone Ozonation Final 2014/10 No

SunRuiwww.sunrui.net

China BalClorFiltration, Electrolysis/


Techcrosswww.techcross.net

Korea Electro-CleenElectrolysis/



Korea ECS-HyChem Filtration, Chemical Basic 2015/04 No


Korea ECS-HyChlor Filtration, Electrochlorination Basic 2015/04 No


Korea ECS-HybridFiltration, UV, Electrolysis/


Trojanwww.trojanmarinex.com

USA Marinex Filtration, UV Yes 2014/03 Y

Ulmatec Pyrowww.ulmatec.no

Norway Heat No

University of Strathclydewww.strath.ac.uk

UK ClearBal Chemical None No

Van Oordwww.vanoord.com

Netherlands Fresh water, Chlorination Basic 2013/05 No

Wärtsiläwww.wartsila.com

Finland Aquarius ECFiltration, Electrolysis/


Wärtsiläwww.wartsila.com

Finland Aquarius UV Filtration, UV Yes 2012/12 Y

Wuxi Bright Skywww.bsky.cn

China BSKY Filtration, UV Yes 2011/03 Y

Zhejiang Yingpengwww.zjyingpeng.com

China YP-BWMS Filtration, UV Yes 2015/02 Y

72 | DIRECTORY

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