Ballast Water Treatment Technology 2018 by rivieramaritimemedia

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contents

2018

12 26

Regulars 5 Plus ça change 62 Best of the Web 65 Directory

Regulation 6 MEPC 72 calls for mandatory sampling 8 New dates set for BWMC; Uncertainty for specialised ships 9 USCG and EPA update; Improvements to BWMC based on experience

Technology 10 Ballast-free design avoids need for BWMS; Take care over BWMS power supplies, professor warns

Containerised systems 12 Containerised systems offer savings 13 BWTBoat beats poor water; Damen plans to expand its InvaSave network

US regulations 14 USCG makes changes to ballast rules; EPA expected to publish draft VGP

Hull fouling 17 Biofouling management: it is time to act 18 Regional biofouling regulations

Environment

20 International data project aims to manage invasive species 21 How GRIIS factors into IMO work on Aichi targets 22 Case studies show the scale of the problem

Suppliers forum 24 Big bang fails to fire for BWMS makers 25 USCG and G8 type-approval applications increase 26 BWMS suppliers fill the training gap

Ship operators forum 29 Managers question systems’ reliability 30 Tanker operators want certainty; USCG type-approvals are vital, say shipowner bodies

Infographic

31 An owner’s guide to BWMS retrofits

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Ballast Water Treatment Technology 2018

contents Filtration 32 Lack of filters is no obstruction for effective treatment 34 Filtering out type-approval concerns; New filter boasts flexible options for BWMS installations

Port and flag states 36 Port state control inspections reveal BWMS deficiencies 37 Installation delay solves ‘unworkable’ schedule, say flag states

ISO 38 Industry gets involved in ISO’s ballast water management work 39 ISO links regulations to the real world

Sampling 40 Compliance improves, but sampling standards needed 41 Port states use portable kits; Saudi Arabia shares sampling data

Class societies 43 IACS sets up BWMS working group; Class societies respond to ballast management concerns 44 ABS: only 57% of BWMSs work; ClassNK makes new rules for BWMS work

System selection 46 Online tool reveals unexpected selection priorities 47 How to select a BWMS 48 Choosing and using a BWMS installation

Shipyards 51 Can shipyards rise to retrofit rush? Sembcorp fitted 12 BWMSs in 2017

Published May 2018 Executive Editor: Paul Gunton t: +44 20 8370 7003 e: paul.gunton@rivieramm.com Sales Manager: Paul Dowling t: +44 20 8370 7014 e: paul.dowling@rivieramm.com Head of Sales – Asia: Kym Tan t: +65 6809 1278 e: kym.tan@rivieramm.com Production Manager: Ram Mahbubani t: +44 20 8370 7010 e: ram.mahbubani@rivieramm.com Subscriptions: Sally Church t: +44 20 8370 7018 e: sally.church@rivieramm.com Chairman: John Labdon Managing Director: Steve Labdon Finance Director: Cathy Labdon Operations Director: Graham Harman Head of Content: Edwin Lampert Head of Production: Hamish Dickie Published by: Riviera Maritime Media Ltd Mitre House 66 Abbey Road Enfield EN1 2QN UK

Case studies 52 DIY installation saved money for Seatruck 53 Changing minds can be a challenge 54 MMC Green Tech started with a bang 55 Schedule change posed logistics challenges for Techcross

Finance

56 Banks begin to back ballast systems 57 Leasing could be less expensive than purchasing

Opinion 59 Owners should focus on their priorities and plans 60 There is strength in numbers 61 Inadequate training threatens ballast compliance

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Ballast Water Treatment Technology 2018

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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COMMENT | 5

PLUS ÇA CHANGE I Paul Gunton, Editor

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have looked back to my comment in last year’s edition: much has changed, but much has stayed the same. First, the changes. The number of states that have ratified IMO’s Ballast Water Management Convention (BWMC) has risen from 54 to 69 – up 28%. But the proportion of the world’s tonnage those flags represent has gone up from 53.41% to 75.11%, a rise of 40% in tonnage terms, due to some big flags (including Bahamas, Greece and Malta) getting on board. It seems only yesterday that I was obsessing about every 0.01% of the fleet as the figure edged towards the elusive 35% to trigger the convention’s entry into force. Now we are at more than double that. US Coast Guard (USCG) type-approvals are mounting up, and installation extensions are becoming harder to get. But do not forget about the Environmental Protection Agency (EPA) and its new Vessel General Permit (VGP), due to come into force in December. In late 2016 we were promised a draft version in mid-2017, or late 2017 if the schedule slipped. It has slipped quite a lot. As I started to write these words in late April, I received an email from the EPA telling me to expect a draft in early July at the earliest. “Those estimates of the draft permit being available in late 2017 did not come true,” my contact said. Can the next VGP really need so much revision that it is taking a whole year of unexpected additional work? Another big change since last year is that shipboard tests are being carried out, and not just in the US. Saudi Arabia, which only ratified the convention in April last year, is leading this charge. Data it presented during IMO’s PPR 5 meeting in February, as its contribution to the BWMC’s experience-building phase, was generally welcomed. With so many tankers loading so much oil in the kingdom, I am not surprised it is being proactive about checking the vast amounts of ballast being offloaded in its ports, although some tell me that its real motivation for taking an interest in water quality is because it wants to revive its pre-oil fishing industry. Alongside all this change and movement, there is the same sense of delay as in previous years. Last year it was International Oil Pollution Prevention certificates that were being mucked about with to delay installations. This time

the deferred D-2 compliance regime agreed at MEPC 71 has taken on that role. By the time some ships have to install BWMSs, the convention will be marking its 20th anniversary. Another detail that has stayed the same is my surprise at the number of BWMSs in the directory section at the back of this guide: 97 this year. When will the shakeout that I have long predicted actually begin? How many of these will apply for USCG type-approval, and how big will the market be for any systems that do not achieve that status? I shall answer those questions. The shakeout will begin once the retrofit boom is in full swing, and market leaders naturally emerge. So that will be during 2022-24. Of those 97, some manufacturers have multiple systems, and many of those companies have strong parent groups. So at least half will apply for USCG typeapproval. And the market for non-USCG typeapproved systems? Bigger than many currently believe. There is a notion that owners will prefer USCG type-approved systems as an insurance against future trade opportunities and eventual resale, but there are enough regional operators and owners who buy on price to sustain a second tier of systems. I realise that those forecasts – like those that predicted we would all be commuting in flying cars by now – put me at risk of future ridicule. We shall see. Compiling this guide each year provides a unique opportunity to consider these bigger questions and think about the long term if I have learned anything from them it is this: Plus ça change, plus c’est la même chose. BWTT

“Those estimates of the draft permit being available in late 2017 did not come true”

Ballast Water Treatment Technology 2018

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8 | REGULATIONS

MEPC 72 CALLS FOR MANDATORY SAMPLING IMO’S MARINE ENVIRONMENT PROTECTION COMMITTEE MADE SOME IMPORTANT DECISIONS IN APRIL, WRITES JAD MOUAWAD*

hen IMO’s Marine Environment Protection Committee met for its 72nd meeting (MEPC 72) in April, one of its most important decisions was to establish the principle and procedures for mandatory ballast water sampling. This is to check that each ballast water management system (BWMS) installed on a ship complies with the D-2 standard set out in IMO’s Ballast Water Management Convention (BWMC) before the ship receives its International Ballast Water Management Certificate. The proposal was made during discussions about the revision of IMO’s Guidelines G8 and met large acceptance among the delegates. Previously, procedures were being developed to include this as a mandatory requirement under the convention’s Regulation E, which contains rules about survey and certification. During MEPC 72, its Ballast Water Review Group (BWRG) agreed to develop guidance on how sampling should take place, but this guidance will not be available for implementation before MEPC 73 in October 2018. The current guidance includes these principles: • Sample at uptake, without having any requirements concerning the water’s properties and number of organisms • Sample during discharge to verify compliance with the D-2 standard. The guidance available

Ballast Water Treatment Technology 2018

at this stage indicates that the analysis should be of an indicative nature. But because indicative analysis is not able to establish compliance with the D-2 standard – since it cannot count organisms with such low numbers as is required under the D-2 standard – this text does not make much sense as it stood at the end of MEPC 72. Furthermore, the sampling volumes and representativeness of the samples taken were not adequately specified in the guidance. In summary, MEPC 72 agreed that sampling for compliance in conjunction with commissioning of BWMSs is already covered in Regulation E-1.1.1, but that more clarification is needed through a sampling procedure. The draft procedure was accepted by MEPC 72, which requested submissions to MEPC 73. The detailed procedures for sampling will be discussed only once, during MEPC 73, with a view to their adoption. They will then become mandatory for all ships, making it necessary for each ship to pass the D-2 discharge standard prior to being issued an International Ballast Water Management Certificate. While the meeting was in progress, the BWRG addressed other topics including the remaining revisions of guidelines and circulars as a consequence of the revision of Guidelines G8, which will become the Code for Approval of Ballast Water Management Systems (to be known as the BWMS Code). The BWRG also considered contingency measures and

Jad Mouawad (Mouawad Consulting): Establishing the principle of mandatory ballast water sampling was one of MEPC’s most important decisions (credit: SICC)

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REGULATIONS | 9

items related to details of the convention’s ‘experience-building phase.’ Meanwhile, the plenary sessions at MEPC 72 discussed the adoption of the BWMS Code and how the BWMC would apply to unmanned barges and rescue tugs. Since MEPC 70 in October 2016, a large number of technical and policy decisions have been made at IMO and in the US, in what seemed like a rush by regulators to anticipate the wide implementation of the BWMC by the worldwide fleet. This rush was met by intense activity to extend the installation deadline. This was done in conjunction with MEPC 71, which famously decided to push the timeline for ships to comply with the D-2 standard (effectively by installing a BWMS) by two years starting from 8 September 2019 and for the following five years until all renewal surveys for the International Oil Pollution Prevention Certificates have been completed. In addition to that

significant decision, the ‘Experience Building Phase’ concept was adopted, paving the way for a long-term review of the BWMC’s implementation, in the hope that changes to its provisions will be based on feedback on how its different provisions are being rolled out and applied. In addition to MEPC, the Pollution Prevention and Response (PPR) subcommittee met in February 2018 and discussed the issue of system design limitations and guidance for ports with challenging water conditions. Parallel to the work done at IMO, since the last issue of BWTT the BWMS market has seen the first type-approval certificates issued based on the 2016 G8 Guidelines, US Coast Guard (USCG) type-approval applications reach double digits and the USCG issuing a revised Navigation and Vessel Inspection Circular 01-18 (NVIC) that included revised guidance on reporting requirements, record keeping, compliance guidance and enforcement.

MEPC 72 was a crowded session and included important

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The USCG also issued a policy letter on inoperable BWMSs and provided guidance for US-flagged vessels on how to comply with the BWMC. In 2018 there has been a sharp decline in extensions issued by the USCG because the bar has been raised much higher for ships to receive such extensions. A closer look at these developments, which happened in a period of less than 12 months, reveals a clear drift towards the implementation phase of the BWMC. This is not surprising, although, at the time of writing in mid-April, many aspects of the preparation for the BWMC are still underway, such as the official adoption of the BWMS Code and various guidance notes for administrations on how to conduct type-approval. A clear indication of this impetus in the regulatory field is the number of guidance notes issued by the USCG to shipowners on how ships can comply with the various ballast water management regulations – either foreign-flagged

ships planning to discharge ballast water in the US or US-flagged ships planning to comply with the BWMC. Another sign of support for improving understanding of regulatory requirements was seen during MEPC 72 when China received wide support for its suggestion to develop a standard course for seafarers about the BWMC. But even as the BWMC moves towards implementation and despite efforts by IMO and various administrations to clarify how the BWMC will roll out, there is no unified approach towards its implementation. As examples, one can mention its application to fishing vessels, how to deal with ships that arrive to ports with non-compliant water, how it can be implemented on unmanned barges and how to apply the ‘Same Risk Area’ definitions to obtain exemptions. BWTT *Jad Mouawad is the founder of Norway-based Mouawad Consulting

ballast water management decisions (credit: IMO)

Ballast Water Treatment Technology 2018

10 | REGULATIONS

NEW IMPLEMENTATION DATES SET FOR IMO’S BWMC In an effort to give enough time for shipowners to fit ballast water management systems (BWMSs) to their vessels, IMO’s Marine Environment Protection Committee decided at its 71st meeting in July 2017 to extend the implementation dates of the D-2 standard by about two years. This is how the new schedule will apply: New Ships: Under the agreed amendments, ships constructed on or after 8 September 2017 will have to comply with the D-2 standard at delivery. Existing ships: Ships constructed before 8 September 2017 must comply with the D-2 standard as follows:

• At the first International Oil Pollution Prevention Certificate (IOPPC) renewal survey completed on or after (a) 8 September 2019; or (b) 8 September 2017, only if an IOPPC renewal survey was completed on or after 8 September 2014 but prior to 8 September 2017. • At the second IOPPC renewal survey after 8 September 2017 only if (a) the first IOPPC renewal survey was completed prior to 8 September 2019; and (b) an IOPPC renewal survey was not completed on or after 8 September 2014 but prior to 8 September 2017. • Ships to which the IOPP Certification scheme does not apply must comply with the D-2 standard by 8 September 2024 at the latest.

The USCG published an article in March outlining how its new policy on extensions will be applied

Improvements to IMO’s BWMC will be based on experience Faced with many uncertainties about how its Ballast Water Management Convention (BWMC) will work in practice, IMO’s MEPC 71 meeting in July 2017 established the experience-building phase (EBP), whose purpose is to allow the MEPC to monitor and improve the BWMC. The EBP consists of a data-gathering stage, a data analysis stage and a BWMC review stage. The EBP started on 8 September 2017 and will end at the entry into force of a package of priority amendments. The EBP is managed and organised by IMO’s secretariat and uses standard forms to gather and analyse the data. The EBP does not alter the BWMC’s implementation in any way. It includes the already-agreed ‘trial period’ during which methods for sampling and analysis of ballast water during port state control

inspections will be evaluated without penalising the ships in case of non-compliance with the D-2 standard. Initial data from the EBP is expected to be available for consideration by MEPC 74 in Q2 2019, and the EBP is expected to continue until MEPC 79 in Q3 2022. Submissions of experiences from the EBP are taking place, with the latest one provided by Saudi Arabia to the fifth meeting of IMO’s Sub-Committee on Pollution Prevention and Response (PPR 5) in February 2018. That submission was based on indicative tests that targeted only phytoplankton in the size range of 10 μm to 50 μm, and found the vast majority of ships tested were compliant with the D-1 (exchange) standard. Of the 45 ships that were actively using a ballast water management system, only five did not meet the D-2 standard.

The BWMS Code is in force

1. Whether the BWMS complies with the USCG type-approval programme. 2. Whether the BWMS complies with the BWMS Code. 3. What implementation dates are required by the USCG and EPA. 4. What implementation dates are required by IMO. Because the BWMS Code is different from the USCG typeapproval programme – and in many areas more stringent – the answer to Question 2 will not always be easy to answer. At the time of writing just after MEPC 72, only two BWMSs have achieved type-approval with the BWMS Code: SunRui’s BalClor and Alfa Laval’s PureBallast 3.2.

The BWMS Code entered into force in April 2018, and will become mandatory for new BWMSs receiving type-approval and for existing BWMSs that renew their type-approval certificates after October 2018. Furthermore, all BWMSs to be installed on board ships after October 2020 must be type-approved following the BWMS Code. For a shipowner that is looking at making purchase agreements for BWMS for a fleet, the decision must now consider the following, in addition to the technical and commercial aspects:

Ballast Water Treatment Technology 2018

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REGULATIONS | 11

USCG and EPA regulations evolve The USCG, and consequently the US Environmental Protection Agency (EPA), has not changed its implementation schedule since it was published in 2012. Those regulations require all ships built on or after 1 December 2013 to comply with the Ballast Water Discharge Standard (BWDS) using a USCG type-approved BWMS at delivery. For those ships built prior to 1 December 2013, the regulations require them to comply by their first drydock after 1 January 2014 or 1 January 2016, depending on their ballast water capacity. Due to a lack of USCG type-approved BWMSs, for many years the USCG issued extensions for ships, deferring the application dates to meet the BWDS for

up to five years. This practice continued throughout 2017, when shipowners could simply indicate to the USCG that they had made decisions to comply and get an extension. In 2018, this practice has changed. On 7 March 2018, the USCG published an article on its online Maritime Commons blog outlining how the new policy of extensions will be applied. The USCG is now asking for evidence of definite plans such as purchase orders before a non-USCG typeapproved BWMS is installed and for reports that the chosen system is expected to receive USCG type-approval in the following 12 months. It also wants to know the date and location of the retrofit before issuing an extension of a maximum of 12 months from

the vessel’s drydocking date. While this restrictive approach will decrease the applications for new extensions, most operators and owners have had earlier extensions for their ships and will start installing BWMSs on board their vessels as the drydocking dates start approaching. As if the existence of two implementation schedules was not confusing enough for shipowners, the new BWMS Code (see page 6) will have to be followed for ships installing BWMSs after 2020, making it uncertain whether currently approved BWMSs are robust enough to meet the new code’s requirements. BWMS manufacturers are starting to receive questions about their strategy to meet those requirements, which are different from the USCG’s type-approval programme. The EPA is due to publish

a new Vessel General Permit (VGP) for vessel discharges in the US to replace the current 2013 version, which expires on 19 December 2018. While it is not expected that the new VGP will make significant changes to the requirements for BWM, the EPA wanted to take into consideration comments and suggestions from the public on how to improve the current text. The EPA has confirmed on many occasions that it did not intend to change the discharge standard requirements in the VGP as a consequence of a ruling in American courts in 2015 that seemed to imply they had to do so. In fact, the EPA was asked by the judge to justify the choice of its current standard in a better way, which is what it intends to do when it releases the new VGP.

Uncertainty hangs over specialised ships There is uncertainty about how some ship types will comply with the provisions of IMO’s Ballast Water Management Convention (BWMC). These include unmanned non-self-propelled (UNSP) barges, rescue tugs, semi-submersibles with extreme ballast flow rates, and pelagic fishing vessels with refrigerated seawater tanks. All these face serious challenges in meeting even the BWMC’s D-1 standard. Many submissions to IMO have sought exemptions or special treatment for various types of vessels. The usual response from the Marine Environment Protection Committee (MEPC) has been that blanket exemptions for specific ship types are not possible, and that all ships must comply with the BWMC.

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MEPC chairman Hideaki Saito, denied Singapore’s request that unmanned non-selfpropelled barges could be excluded from the BWMC (credit: IMO)

This came up most recently during MEPC 72 in April, in a submission by Singapore, Denmark and Turkey. It was clear from the general comments from MEPC’s plenary that there were diverging opinions on how to deal with those vessels. The matter was deferred to MEPC 73 in October 2018, but the reply by MEPC’s chairman to Singapore on whether UNSP barges could be exempted from conducting ballast water exchange was a clear ‘No.’ While MEPC was moving forward with its experience building and USCG was building its stable of type-approved BWMSs, two test facilities ceased testing for BWMS type approval: DHI Singapore and the Maryland Environmental

Research Center (MERC). Both test facilities had conducted IMO and USCG type-approval testing for many years, and MERC was one of the early movers in developing testing protocols. Citing different implementation practices of the USCG Regulations, MERC decided in 2017 to close down its testing barge and concentrate on other ballast water research topics and on research in other areas. DHI decided to close down its testing facility in Singapore and concentrate its activity on land in Denmark. But it will maintain its shipboard testing capacity in Singapore. DHI stated that the challenges of testing in tropical waters, mainly related to holding time, were the main reasons behind its decision. BWTT

Ballast Water Treatment Technology 2018

12 | TECHNOLOGY

Ballast-free design avoids need for BWMS LNGC concept maintains propeller immersion stability without needing to ballast when unladen

A deep V-shaped hull means the ship’s propeller remains immersed without needing ballast (credit: Lloyd’s Register)

TT, Lloyd’s Register (LR) and Dalian Shipbuilding Industry Corp (DSIC) embarked on the second phase of their ballast-free LNG carrier joint development project in March by welcoming Belgian shipping company Exmar as a project partner in tandem with the launch of the latest stage in the 30,000 m³ B-Free LNG carrier design initiative. The project participants have developed a ballast-free,

medium-sized membrane tank LNG carrier design that received approval in principle from LR in December 2017. Phase 2 of the project aims to develop the design further and validate results from the first phase by applying more detailed analysis and verification, including model testing. For mid-size LNGCs, ballast water is more critical to achieving sufficient draught for propeller immersion when the vessel is unladen, rather than for stability. The B-Free design meets this challenge through a triangular shaped lower part of the hull, LR explained. This allows the vessel to sit deeper in the water when unladen, achieving the necessary propeller immersion for its 5.6 m diameter propeller while maintaining stability. The design also potentially offers lower construction and operational costs because there is no need for a ballast water management system. The project partners point out that with their B-Free design they have been able to provide the same cargo-carrying capacity as a conventional 30,000 m3 LNGC, but in a much smaller hull. The B-Free LNGC has a lightship weight of about 1,000 tonnes less than that of the conventional ship, resulting in improved harbour access and lower harbour fees, they say. During Phase 2 of the B-Free LNG carrier design project, DSIC will concentrate on ship layout and performance, including hull line optimisation, utilising computational fluid dynamics; ship model test verification; propulsion selection; and hull structure basic design. GTT states that its Mark III membrane is the containment system chosen for the B-Free design. A two-cargo-tank configuration is used rather than the three- or four-tank arrangement usually considered for such ships.

TAKE CARE OVER BWMS POWER SUPPLIES, PROFESSOR WARNS Retrofits involving high-power electronic systems, such as ballast water management systems (BWMSs), should take account of potential electromagnetic compatibility (EMC) problems, warned Frank Leferink, professor of EMC at University of Twente in the Netherlands and technical authority on EMC for Thales Nederland. In an exclusive assessment of these concerns prepared for BWTT and summarised here, Prof Leferink said that electronic equipment such as power electronics for energy-efficient lighting, electric propulsion and BWMSs consume power in a pulsed manner, which is completely different from conventional power supply systems, which were designed for mostly linear loads with a power factor (PF) different from unity.

Ballast Water Treatment Technology 2018

“Modern electronic loads consume pulsed currents, with a high peak current with respect to effective current and, if continuous, a high total harmonic distortion of the current (THDi).” Because the power supply system on a ship has a high internal impedance, the THDi results in a high total harmonic distortion of the voltages (THDv), which can cause problems with sensitive electronic equipment such as navigation, communication and automation equipment and reduce accuracy in measuring equipment. “All classification societies are extremely concerned about harmonic voltage distortion and the possible consequences should some critical item of equipment malfunction or fail,” Prof Leferink said, and they impose strict limitations on the

magnitude of harmonic voltage distortion. Due to space restrictions with BWMS and other retrofits, cheaper and smaller systems are often selected without active PF circuits and sufficient filtering, causing many severe problems later on, he said. In BWMSs that use UV lamps, “the applied electronic lamp drivers with active PF circuits, low mains distortion, filtering for low EMC levels and improved immunity to mains voltage surges will lead to superior performance,” he said. Overvoltage peaks can deteriorate or destroy the lamps in the ballast water system, he added. Using proper power systems can also achieve significant cost savings through reduced energy demand, lower operating temperatures and extended electrical equipment life. BWTT

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14 | CONTAINERISED SYSTEMS

Containerised systems offer savings to specialist operators

Mobile systems could be an economic solution for some operators (credit: BWC)

Barges, OSVs and other craft with variable operating patterns could use mobile systems, according to one manufacturer

obile ballast water management systems (BWMSs) could save some ship operators up to 80% of their compliance costs, according to the chief executive of UK-based Ballast Water Containers (BWC), Richard Lawson. He made the claim during a presentation in March at a seminar organised by BWC’s parent, the Malin Group, aimed at barge owners and operators, for whom Mr Lawson believes mobile containerised systems such as those his company offers “represent one of the most commercially efficient methods of compliance.” As reported elsewhere in this guide, in April the 72nd meeting of IMO’s Marine Environment Protection Committee rejected a proposal that unmanned non-selfpropelled barges be excluded from the Ballast Water Management Convention, so they must comply with its provisions. Mobile treatment systems are particularly suitable for vessels with low utilisation, such as barges, Mr Lawson said, or those with minimal and predictable ballasting

Ballast Water Treatment Technology 2018

operations – such as fixed-route container vessels and liner services. “An owner investing in a small number of mobile treatment systems could share them between multiple vessels, avoiding having to retrofit each vessel individually,” he said. BWC’s mobile system, called BWCBute, would also be suitable for offshore support vessels (OSVs), Mr Lawson told BWTT. He pointed out that a supply vessel’s operational area varies from project to project, and will need to treat ballast water if it is crossing international boundaries. “Like any equipment, a BWMS sitting idle on a vessel for several months – or even years – is not an ideal scenario,” he said. “You can be sure it will require a major overhaul to get it back to operational readiness.” In his view, these problems are avoided by installing a mobile system only when an OSV’s operation calls for ballast treatment. Otherwise, it could be removed and deployed on another vessel. BWC installs proprietary BWMSs in its containers and currently offers the

US Coast Guard (USCG) type-approved Ecochlor and Optimarin treatment systems or Wärtsilä’s Aquarius AQ-250-UV BWMS, which applied for USCG type-approval in early April. Having a choice of technology “is important if we want to fully satisfy the needs of our clients,” Mr Lawson said. He reported interest from ports and port services companies in containerised BWMSs following MEPC 71 in July, which approved a circular that sets out what ports should do if a ship arrives that is not fitted with a BWMS and has not been able to conduct ballast water exchange. The circular requires such ships to contact the port authority to confirm the availability of “reception facilities, port- or land-based treatment systems or any other alternative measures to the D-1 standard acceptable to the port authority.” After the BWMC came into force in September, he again noted that “interest in mobile containerised treatment systems continues to grow” as an alternative to retrofitting. BWTT

www.ballastwatermanagement.co.uk

CONTAINERSIED SYSTEMS | 15

WATER QUALITY CONCERNS SUPPORT BWTBOAT CONCEPT IRClass’s proposed BWTBoat is designed to deliver treated ballast to ships and could overcome concerns raised at IMO about the difficulties of ballasting in ports with high levels of total suspended solids (TSS). In a report prepared for BWTT, the BWTBoat’s inventor and project manager Sandip Patil referred to what he called an “eye-opening” submission by South Korea to IMO’s Marine Environment Protection Committee in July 2017 (MEPC 71). Its paper reported that ballast water management systems (BWMSs) do not work properly in ports with challenging water quality because either their filters become clogged or ballasting operations are delayed because of frequent back-flushing. Korea’s paper suggested that, as a contingency measure, ships should take in untreated ballast in these ports, conduct a ballast water exchange in mid-ocean and treat the water taken on board at that time. One response to that came from Canada during the fifth meeting of IMO’s Sub-Committee on Pollution Prevention and Response (PPR) in February 2018. Canada raised concerns that this might breach the Ballast Water Management Convention (BWMC) because water would be taken on board untreated. It also raised doubts about whether a discharge port would accept this procedure. Both the Korean and Canadian papers mentioned the possibility of receiving clear ballast from port-based facilities, if those were available, Mr Patil said. BWTBoats can do that, he

Cl2 Filters BWTBOAT

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added. They have a much larger water catchment area than a ship and multiple filters to deliver flows of up to 10,000 m3/h, he explained. Even before what he termed the “muddy water ports issue,” BWTBoats had a unique business model, he said. “Now BWTBoats can provide additional benefit by providing an option to provide just filtered water to ships at muddy water ports.” A ship fitted with its own BWMS would receive this filtered water and treat it further using its onboard system. IRClass has been working on this concept since 2013. Mr Patil’s report described a design development that

has halved its cost and means that ships do not need any retrofitting or deck connections to receive treated ballast water from BWTBoats. He described the new arrangement as acting like an “external plug-in to ship’s sea chest.” In his paper, Mr Patil realised that although BWMSs are mostly tested at real-world biological loads, they are not subjected to real-world sediment loads. “G8 guidelines only specify the TSS condition as >50 ppm (>24 ppm for USCG) but no upper limit,” he commented in his report for BWTT. “In the real world, TSS load can vary up to 1,000 ppm, directly affecting – delaying or stopping – cargo operations.”

DAMEN PLANS TO EXPAND ITS INVASAVE NETWORK Southern European and Scandinavian ports are the next targets for Damen Green Solutions (DGS) as it looks to expand its network of InvaSave containerised ballast water management systems. Damen Green Solutions product manager Matthijs Schuiten told BWTT in March that the company is also investigating the possibilities for port treatment in the US. These plans mirror comments by DGS sales manager Philip Rabe, who said in December 2017 that the company’s goal “is to build up a reliable worldwide ballast water service network.” They follow growth during 2017 that made its units available in 10 north European ports by the end of the year under two service agreements: one with fellow Damen Group member Damen Shiprepair & Conversion, covering eight ports, and one with

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MariFlex, covering two ports. But the Damen Group is cautious about growth prospects, telling BWTT in a statement in December that “the number of customers will increase in line with the enforcement of the ballast water regulations.” In March, Mr Schuiten said that the delayed compliance schedule for ships to meet IMO’s D-2 standard, which was agreed by its Marine Environment Protection Committee in July 2017, has had an effect on the prospects for port-based systems. InvaSave offers an option to vessels that cannot meet that standard, which “will only become relevant in 2019 when the first ships constructed after 8 September 2017 start to arrive in the ports. This is almost two years later then the original timetable,” Mr Schuiten said. BWTT

Ballast Water Treatment Technology 2018

16 | US REGULATIONS

USCG MAKES CHANGES TO BALLAST RULES A CIRCULAR AND A SERIES OF ONLINE POSTS REVEAL A NEW US APPROACH TO IMPLEMENTING ITS BALLAST RULES

n March, the US Coast Guard (USCG) issued a revised Navigation and Vessel Inspection Circular, NVIC 01-18, that fundamentally changed how it views requests for extensions to compliance dates under its ballast water management requirements. More details can be found in the ‘Regulation’ section of this edition of BWTT. Some observers have been critical of the 35-page NVIC’s contents. US law firm Blank Rome, for example, published an article in its newsletter Mainbrace in March saying that, although the new NVIC discusses how the USCG will review extension requests, “it falls short of providing an applicant with clear standards for what is required in terms of receiving an extension.” That article was written by Jeanne Grasso, a partner at the firm, and Sean Pribyl, an associate, who wrote that within 24 hours of the NVIC’s release, the USCG had rejected extension requests, some of which had been pending for months. “Those denials shed light on what the USCG is actually now requiring,” they went on, finding that the requirements “range from impractical to impossible for most shipowners.” The NVIC was issued on 1 March. On 7 March the USCG issued some clarification on its online Maritime Commons blog, in which it documented the information it wanted before it would consider granting extensions to vessels “that intend to install a BWMS that is expected to receive [USCG] type-approval in the near future.” It also reminded vessel owners and operators “that there are several acceptable methods for managing ballast water listed in 33 CFR 151.1510 or 151.2025.” Those references relate to the relevant sections of the US Code of Federal Regulations that set out US ballast water management requirements. The USCG told BWTT in a statement that it expects “shipowners and operators to read and become familiar with … 33 CFR Part 151, Subparts C and D if vessels they own or manage trade with the US.” Asked what support the USCG offers shipowners to comply with ballast management regulations, the USCG pointed to a range of online material, including a series of five articles in November and December 2017 written by its assistant commandant for prevention policy, Rear Admiral John Nadeau. In his first article he acknowledged that there were “challenges associated with managing ballast water,” saying that he was “not surprised to be questioned about ballast water during nearly every discussion I have with the maritime industry.”

EPA expected to publish draft VGP in Q3

A draft version of the US Environmental Protection Agency’s (EPA’s) Vessel General Permit will be published in July “at the earliest,” team leader of the Water Permits Division, US EPA, Jack Faulk, told BWTT in April. It is due to enter into force on 19 December when it will replace the current VGP that has been in place since 2013, and

Ballast Water Treatment Technology 2018

USCG’s assistant commandant for prevention policy published articles to address “challenges with managing ballast water”

which was challenged by environmental groups in court in 2015. In January this year, Mr Faulk had advised BWTT that “we are considering the 2015 court ruling as part of the drafting process.” This timetable is later than had originally been promised. In a webinar in late 2016, the EPA had advised that it was gathering information and intended to publish a draft by Q3 2017 but said that it might slip to late 2017. In April, however, Mr Faulk acknowledged that the EPA is “behind schedule in drafting the next permit so those estimates of the draft permit being available in late 2017 did not come true.” Once the draft is published it will be open for comments but “we have been informally telling folks that if they have thoughts [or] comments they would like for us to consider when drafting the next permit, they are free to do so,” Mr Faulk said.

USCG releases more details about type-approval requests

A change in the format the US Coast Guard (USCG) uses to list type-approval applications from ballast water management system (BWMS) applications in April revealed that four companies with USCG type-approved systems had applied for further approvals to cover various amendments to their systems. This marked a change in policy shortly after BWTT queried why one company that this publication knew had applied for a further type-approval was not listed on the USCG’s Maritime Safety Center’s table and was advised that the centre “does not announce requests for changes to an approved system.” Applications for initial type-approvals are also publicised via the USCG’s Maritime Commons online blog. Its editor, Lt Amy Midgett, told BWTT that its query “certainly contributed to the decision to expand the spreadsheet.” The Maritime Safety Center had also received a number of requests from manufacturers for the same thing, she added. BWTT

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HULL FOULING | 19

Biofouling management: it is time to act Biofouling causes global environmental problems and some regions have already put strategies in force, warns the UK P&I Club

iofouling “poses many challenges to the marine industry, among which the global environmental problems of invasive aquatic species (IAS) and greenhouse gas (GHG) emissions stand out.” Those are the opening words of a report prepared for BWTT by the UK P&I Club based on advice the club first published in its Legal Update series of papers in November 2017. The research behind that was prepared by Madlene Wangrau, who was then a postgraduate researcher on a placement with the club, who said at the time that her work “suggests that 70-80% of IAS introductions occur through biofouling, and new areas are constantly being invaded.” Her work has been developed further by the club's legal team for this publication. IAS are defined as species that may pose threats to human, animal and plant life, economic and cultural activities and the aquatic environment. Their introduction to new environments “has been identified as one of the greatest threats to the world’s freshwater, coastal and marine environments,” the club’s

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Australia’s Biosecurity Act is expected to be amended following consultation that ended in January (credit: Australian Government Dept of Agriculture and Water Resources)

report said. Although it is challenging to quantify global impacts specifically for biofouling species, the impacts of invasive species are significant. For example, the costs arising from the introduction of the zebra and quagga mussels into the US alone have been estimated at around US$1Bn per year. Based on Ms Wangrau’s work, the club believes that the spread of IAS via ship biofouling was previously underestimated. “The problem has intensified over the last few decades due to increased traffic volume [and] studies show that biofouling species are causing enormous damage,” its report said. This damage includes not only biodiversity loss but also damage in other areas, including tourism, marine resources, property and infrastructure and human health. “The problem thus requires urgent international attention. The consensus is that the prevention of the introduction of IAS is more efficient and more economical than combating IAS,” the club’s report advised.

Hull fouling also has an impact on GHG emissions because it increases hull and propeller resistance, which in turn increases fuel consumption and GHG emissions. As a result, measures related to managing ships’ biofouling can in many cases be effective in enhancing ships’ energy efficiency.

UK P&I’S APPROACH

In its report, the UK P&I Club set out its own stance on biofouling: “the urgency of the problem is not being adequately conveyed and few incentives are being created for stakeholders to address the problem.” It recommends to its members that they comply with IMO’s 2011 Guidelines for the Control and Management of Ships’ Biofouling to Minimise the Transfer of Invasive Aquatic Species even though they are still voluntary. It described their introduction as “an important move” and said that “all stakeholders stand to benefit from better control and management of hull fouling.” It is also reminding members, particularly those

whose ships will be calling at ports in regions with special biofouling requirements, to start tailoring their biofouling management plans to the specific requirements of those states. The club also supports the GloFouling Partnerships project and is bringing its work to the attention of its members through its legal publications and lossprevention initiatives.

IMO’S APPROACH TO HULL FOULING

Following the adoption of IMO’s Ballast Water Management Convention (BWMC), the organisation developed its 2011 guidelines with the aim of providing a globally consistent approach to the management of biofouling. Those guidelines “represent a decisive step towards reducing the transfer of IAS by ships but their implementation is problematic,” the UK Club’s report suggested. “Due to a mixture of technical, scientific, environmental and economic factors, the biofouling issue is more complex than most other shipping pollution issues,” it explained. Implementing the guidelines requires enhanced awareness, technical co-operation and proper mobilisation of existing resources, it said. But since the guidelines are voluntary, “the private sector is lacking in incentives to develop innovative biofouling reduction and remediation technologies.” To take on these challenges, IMO’s secretariat is implementing technical co-operation activities under its Integrated Technical Cooperation Programme

Ballast Water Treatment Technology 2018

20 | HULL FOULING

to raise awareness of the implications of IAS carried in hull fouling and to support global implementation of the guidelines. One initiative launched in August last year was the GloFouling Partnerships, which is a collaboration of the

Global Environment Facility (GEF), the United Nations Development Programme (UNDP) and IMO. At the time of writing in February, the project was going through a detailed preparation phase before it starts work. It is designed to help developing

Regional biofouling regulations Some countries and regions have already set out requirements that ships must meet to reduce the impact of hull fouling on their coastal waters. In its report, the UK P&I Club provided details of actions being taken in Australia, California and New Zealand.

AUSTRALIA

Australia’s Biosecurity Act 2015 applies to the shipping sector and regulates the biosecurity risks associated with goods, people and conveyances entering Australia. Under the act, the Department of Agriculture and Water Resources is investigating new biofouling management options for ships arriving in Australian territory. At the time of writing, in February, a Regulation Impact Statement was being prepared following consultation with industries, the community and other stakeholders. The National Biofouling Management Guidelines for the aquaculture industry are designed to help shipowners and operators, and the wider maritime industry, to manage and control biofouling of ships. As this issue went to press in late April, a bill, the Biosecurity Amendment (Miscellaneous Measures) Bill 2017, had been introduced into Australia’s parliament that proposes changes to the Biosecurity Act 2015. • For more information visit http://bit.ly/BWTT-AusFouling

NEW ZEALAND

New Zealand’s Craft Risk Management Standard came into effect as this issue of BWTT was published in May. Ships must arrive in New Zealand with a ‘clean hull’ which, for ships staying up to 20 days and only visiting designated ports, allows a slight amount of biofouling with additional fouling (up to 5% cover) allowed in niche and other areas. If ships are staying for 21 days or longer, or wish to visit areas not approved as Places of First Arrival (places that are not approved ports, such as Milford Sound), the requirements are stricter. In those areas, the only biofouling that long-stay ships are allowed to have is a slime layer and gooseneck barnacles. There are three ways that a ship can meet the requirements: • Clean or treat their hull either less than 30 days prior to arrival or within 24 hours of arrival to New Zealand territory. • Maintain a clean hull through best practice maintenance. • By applying approved treatments. • For more information, visit http://bit.ly/BWTT-NZFouling

Ballast Water Treatment Technology 2018

countries minimise the impacts of aquatic biofouling by focusing on developing and strengthening institutional resources to implement the 2011 biofouling guidelines. In the same manner as the GEF-UNDP-IMO GloBallast Partnerships, which came to

an end in June 2017 after a decade of work, the GloFouling Partnerships project aims to catalyse a similar global transformation in reducing the transboundary introduction of IAS via biofouling with the additional benefit of reducing GHG emissions.

CALIFORNIA

California’s Biofouling Management to Minimize the Transfer of Nonindigenous Species from Vessels Arriving at California Ports (Article 4.8) regulations have been effective since 1 October 2017. They apply to: • All ships of 300 gt or above that carry, or are capable of carrying, ballast water that arrive at a Californian port. • Ships delivered on or after 1 January 2018 and to other ships on completion of their first regularly scheduled out-of-water maintenance (ie drydocking) on or after that date. Biofouling management requirements under the regulations include: • Development and maintenance of a Biofouling Management Plan. • Development and maintenance of a Biofouling Record Book. • Implementation of mandatory biofouling management of the ship’s wetted surfaces. • Implementation of mandatory biofouling management for ships that undergo an extended residency period. It is possible to submit a petition for alternative methods of compliance with the requirements of Article 4.8, and the California State Lands Commission has released a guidance document to improve knowledge about the regulations and how to comply with them. • For more information visit http://bit.ly/BWTT-CalFouling

US COAST GUARD

Since 21 June 2012, the US Coast Guard (USCG) has required ships to have a biofouling management plan on board. This biofouling management plan may be a stand-alone document or integrated as part of the ship’s operational procedures and referenced in the ballast water management plan. If referenced as a separate plan, the fouling maintenance and sediment removal procedures should be available for inspection. It is important that these procedures and plans are specific to each ship. A complete biofouling management plan should include the following information: • An introduction for the ship’s crew to explain the need for biofouling management. • Ship particulars. • Description of the anti-fouling systems applied. • Description of the ship’s operating profile. • Description of the areas susceptible to biofouling and actions taken for each area. • Description of the operation and maintenance of the anti-fouling system used. • Safety procedures for the ship and crew. • Record-keeping requirements. BWTT

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22 | ENVIRONMENT

International data project aims to manage invasive species

global operation is underway to address the threat of invasive species – including those carried in shipping ballast water – and the weapons of choice are datadriven checklists. Scientists from countries and organisations around the world are contributing to create the Global Register of Introduced and Invasive Species (GRIIS), a centralised, open and country-specific database of the organisms wreaking havoc on ecosystems everywhere. A paper published in the scientific journal Nature in January 2018 (http://bit.ly/ BWTT-GRIIS) offered a detailed description of the data behind GRIIS and included its first 23 “exemplar” checklists. The checklists house more than 11,000 records on introduced and invasive species with environmental impact assessments present for more than 20% of these. It named “cross-border trade and transport” as the “principal driver of new species introductions.” The GRIIS database uses

A new database will help develop strategies to address global spread of invasive species, writes Jamey Bergman

a series of country-specific checklists to help governments build a foundation of verified data for use in developing national strategies to combat invasive species, according to the authors of a paper detailing the project. Prof Melodie McGeoch of Australia’s Monash University and Shyama Pagad, programme officer for the International Union for Conservation of Nature’s Invasive Species Specialist Group, based at New Zealand’s University of Auckland, are two of five contributors to the paper. Writing on Nature’s blog, they said invasive species are harming ecosystems in every country and on every continent, and that knowing which species are where is

The water hyacinth limits oxygen and sunlight in ports and rivers, see page 22 (credit: Wikimedia/US Department of Agriculture)

the first step in limiting or reversing that damage. “The [GRIIS] register provides a missing piece of the puzzle that we hope will make monitoring and managing the threat to the environment from invasive species more effective,” they wrote. The team’s paper says that GRIIS provides significant support for national governments to identify and prioritise invasive alien species, establishing both national and global baselines. They say these baselines will enable a global system for monitoring trends in invasive species invasions by providing “open and readily accessible inventories of species that have become naturalised or invasive in countries outside of their

historic ranges – with global coverage and across taxa.” GRIIS is “a major step forward in the delivery of information needed to effectively deal with the problem of biological invasions,” Prof McGeoch said in a related statement. “It was designed to facilitate transparent, repeatable information on invasions.” But the exercise of identifying the origins and tracking the invasion pathways becomes more complex for invasive organisms introduced through ballast water discharges or through biofouling on the hulls of merchant ships, according to Colette O’Flynn, GRIIS country editor and invasive species officer for Ireland’s National Biodiversity Data Centre. “For something to be assigned as invasive, first it must be non-native to your area. So it wouldn’t actually be found there: it’s only there because of human intervention,” Ms Flynn explained in an interview with BWTT. “But with many marine species, we don’t know what is native or non-native. They’re often termed what we call cryptogenic: their origin is unknown. Sometimes there is obscurity with tagging marine species as non-native or invasive just because of not being sure of their origin,” she said. Comparing marine, freshwater and terrestrial waters, “marine is the one we know least about invasive species, just because of the difficulties involved with studying them and in understanding where they

ENVIRONMENT | 23

originate from.” Ms O’Flynn said the “good thing” about IMO’s Ballast Water Management Convention, in theory, is that it offers comprehensive coverage of the introduction of nonnative and potentially invasive species in its sanitisation requirements for ballast water. “It does not matter if [species in ballast water] were to be native or non-native, or what the origin was. The idea behind it is that it will treat all that water to reduce any potential risk,” she said. Ireland is one of the countries whose data has been collated into an exemplar

checklist that can be used as a template for other countries to follow. Ms O’Flynn said that being on the leading edge of developing a national GRIIS checklist gave Ireland an advantage in the fight against marine invasive species. “We know so much about certain species in Ireland that we know our hull-fouling species and our ballast species, based on data from other countries as well as here. But, of course, for a species recorded in the marine environment, we can never be sure how exactly it got there. You can only kind of conjecture, really,” she said.

HOW GRIIS FACTORS INTO IMO WORK ON AICHI TARGETS Data from GRIIS feeds into national Clearing House Mechanisms (CHMs) under the Convention on Biological Diversity (CBD) via the Global Biodiversity Information Facility (GBIF) to meet biodiversity targets set out in the UN’s Strategic Plan for Biodiversity 2011-2020, which was adopted in 2010 in Japan’s Aichi Prefecture. It specifically linked its plan to IMO’s work by suggesting that “Actions to implement the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, a convention adopted through the International Maritime Organization which seeks to prevent the spread of organisms carried in ships’ ballast water, could also help to achieve progress towards this target.” With that convention viewed as a focus of the implementation of Aichi Target 9 (see below), GRIIS could be helpful for international bodies as well as national governments in dealing with the threat of invasive species, and in working together to meet the targets agreed by signatories to the Convention on Biological Diversity. A second area where GRIIS is likely to play a role in IMO activities is the GloFouling Partnerships Project, launched by IMO in mid-2017. That project will focus on implementing the IMO guidelines for the control and management of ships’ biofouling, which provide guidance on how biofouling should be controlled and managed to reduce the transfer of invasive aquatic species.

AICHI TARGET 9

By 2020, invasive alien species and pathways are identified and prioritised, priority species are controlled or eradicated, and measures are in place to manage pathways to prevent their introduction and establishment.

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“If it’s known to be a species that’s a hull-fouling species, you can guess that it got here because there are ships or boats in the area. If it’s known to be found in ballast water you can say, ‘well we probably have it here because ballast water is discharged in this area.’” That is why these international databases – and even European or regional ones – are helpful, she explained. “You can learn from others’ experiences of dealing with specific invasive species. So GRIIS does help in assessing the risk.” With the initial rollout of the 20 exemplar checklists complete, there are more on the horizon, according to the researchers. Data from nearly every country will soon be included in the programme, the the paper predicts. Overall, more than 200 GRIIS checklists are being generated and the data for 198 countries will be available via the GRIIS website and the Global Biodiversity Information Facility (GBIF) website on a rolling basis. But even though the database is far from complete, Ms O’Flynn said its global potential could not be emphasised strongly enough. “It’s a work in progress and the potential is fantastic,” she said. “It will continue to be more valuable as more countries add more information to it.” One of the most important possibilities the database offers is its potential use as a tool to help policy-makers craft response strategies to nonnative species invasions of ecosystems around the world. As Ms O’Flynn put it, “Only by properly being able to assess risk can we then have better-informed decisionmaking on policies and measures to be taken to prevent further introduction or spread of invasive species.”

Prof Melodie McGeoch: Information from GRIIS can help deal with the problem of biological invasions (credit: Monash University)

Colette O’Flynn: “Only by properly being able to assess risk can we then have betterinformed decision making” (credit: Ireland National Biodiversity Data Centre)

Ballast Water Treatment Technology 2018

24 | ENVIRONMENT

COULD GRIIS HELP SHAPE INTERNATIONAL POLICY AT IMO? The purpose of GRIIS, its researchers say, is to help countries monitor and report on biological invasions in order to allow them to prioritise interventions. As one of the GRIIS paper’s co-authors Piero Genovesi said, “GRIIS provides credible, authoritative and peer-reviewed information on introduced species. By fully understanding the issue, governments can use the checklists to inform effective decision-making and prioritise problem species to tackle first.” But that prioritisation process, in theory, should also allow countries to progress towards achieving globally agreed targets on biodiversity. As chair of the International Union for the Conservation of Nature’s (IUCN) Species Survival Commission’s (SSC) Invasive Species Specialist Group (ISSG), Dr Genovesi and his group have played a significant role in creating GRIIS. His group is already using data included in the GRIIS database to advise IMO. The ISSG website lists, among its activities, “providing technical and scientific advice to IUCN members in their work on invasive species especially in international fora (eg International Maritime Organization).”

With IMO’s Ballast Water Management Convention a focal point for the implementation of Aichi Target 9 (see page 21), GRIIS could continue to prove useful for international bodies and their constituent national government representatives both in dealing with the threat of invasive species and in working together to meet the targets agreed by signatories to the Convention on Biological Diversity. According to IMO, Dr Genovesi’s group is likely to partner with IMO, the United Nations Development Programme (UNDP) and the Global Environment Facility (GEF) on future multilateral capacity-building projects aimed at reducing the ingress of invasive species. These projects will fall under the GloFouling Partnerships Project, launched in mid-2017 to focus on implementation of IMO’s Guidelines for the control and management of ships’ biofouling. “From the GloFouling Project perspective, yes, IMO as the executing agency plans to collaborate with the IUCN – and this is likely to be involving IUCN as a strategic partner,” IMO told BWTT in a statement. “Areas of collaboration could [include] decision-support tools such as the GRIIS, among others.”

The GRIIS database could be valuable in tackling hull biofouling (credit: Wikimedia)

Ballast Water Treatment Technology 2018

CASE STUDIES SHOW THE SCALE OF THE PROBLEM A statement in January by the International Union for the Conservation of Nature (IUCN) highlighted the socioeconomic and environmental impact of invasive species using the case of the water hyacinth. The species, which is native to South America, is spreading across Africa, Asia, Oceania and North America, causing problems by limiting oxygen and sunlight in ports and rivers, the group says. “The infestations have impacted fish levels, blocked navigation routes, increased disease and affected access to water by reducing hydropower capacity. “It is important to effectively monitor and control species movement to reduce these types of scenarios for the future,” the group cautioned. In one case study in the United Arab Emirates, the IUCN said that implementing GRIIS led to the identification of 258 established alien species – only 146 which had been previously identified. When the data was verified, UAE authorities prioritised 57 alien species for intervention. The IUCN Global Invasive Species Database provides additional information on over 850 invasive alien species, specifying their impact, pathways of introduction and management measures. This information can build on the knowledge from the GRIIS database, helping countries develop measures that can prevent the introduction of invasive alien species and manage any impact from already introduced species. BWTT

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26 | SUPPLIERS FORUM

BIG BANG FAILS TO FIRE FOR BWMS MAKERS IMPLEMENTATION DELAYS FRUSTRATE MANY MANUFACTURERS, BUT MOST REMAIN OPTIMISTIC

his year’s edition of Ballast Water Treatment Technology is published at an important time. When last year’s BWTT was published, IMO’s Ballast Water Management Convention (BWMC) was set to come into force, cocking the trigger for the long-expected sales that would result in a return on their large investments over many years. But by its entry-into-force date of 8 September, its explosion had been muzzled by the Marine Environment Protection Committee’s decision in July at MEPC 71 to delay compliance by two years. Meanwhile, the US Coast Guard (USCG) has been type-approving BWMSs and changing the rules on extensions for non-type-approved options. This has

Anders Lindmark (Alfa Laval): Activity has been high since both BWMC and MEPC 71 (credit: Alfa Laval)

Ballast Water Treatment Technology 2018

created demand from shipowners for USCG type-approved systems and a drive for manufacturers to obtain that status. At the same time, manufacturers have been seeking type-approvals under IMO’s revised G8 guidelines. For this edition of BWTT, 10 manufacturers completed a detailed survey of their views and responses to these and other factors affecting their current and future plans. For some, the delayed implementation of the BWMC’s D-2 discharge standard – which is what has deferred installations – has had an impact, but most reported that, with the schedule now settled, business was picking up. Optimarin chief executive Tore Andersen called it “a problem for all makers” while Ecochlor president Tom Perlich said the decision “was met with concern by all manufacturers.” Instead of using the time to install systems and gain experience with them, “many shipowners used [it] to delay retrofitting their vessels through changed International Oil Pollution Prevention (IOPP) certificate renewal dates or USCG extensions,” he said. “One month after Ecochlor received USCG type-approval, the MEPC delay went into effect and many shipowners who were prepared to purchase the Ecochlor System put their buying decisions on hold,” he said. This was compounded because the USCG continued to grant extensions. Nonetheless, Ecochlor “has continued to receive orders and our requests for quotes in the past year have more than tripled. We expect business to ramp up significantly in the coming year as the market continues to develop.” Trojan Marinex market manager Mark Kustermans also saw positive results.

Ecochlor’s USCG type-approval was granted in August 2017. Shortly after, the MEPC delay went into effect

Shipowners have been able to set “clear timetables for ballast water compliance of their fleet.” Although this has slowed retrofits, “it has kick-started the newbuild segment,” he said. Desmi Oceanguard chief executive Rasmus Folsø echoed that experience, saying that the delay had “postponed most of the retrofit projects we were working on.” But since then business has picked up, “and we currently receive more requests and work on more projects than we have ever done before.” Alfa Laval vice president and head of PureBallast work Anders Lindmark welcomed the clarity that the new dates had brought, saying that activity had increased after the BWMC was ratified, and has “continued to be high following MEPC 71.” Wärtsilä sales director for BWMS, Craig Patrick, also spoke of a positive outcome. Although there had been a delay in sales, the company was able to “take a slightly longer view on product development to ensure better reliability.” He reported that some operators have used the time to work with Wärtsilä to develop bespoke operationsupport partnership agreements. BWTT

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SUPPLIERS FORUM | 27

USCG AND G8 TYPE-APPROVAL APPLICATIONS INCREASE

ix ballast water management systems (BWMSs) have US Coast Guard (USCG) type-approval at the time of writing in late April, with seven more applications pending. In addition, four manufacturers that already have USCG type-approval have applied for further approvals for modified versions. For this report, BWTT explored the plans and experiences of BWMS manufacturers that have already achieved USCG and revised-G8 type approvals and of those that aspire to those goals. China’s SunRui holds certificates for both testing standards for its BalClor system. Senior purchasing manager Helen Li said that the revised G8 guidelines “are more in line with the stringent USCG requirements” than the original guidelines. It already held USCG type-approval and “no major changes were needed to meet the revised G8 guidelines,” she said. It just needed one hydrogen sensor to be added and “a slight modification to the control logic,” she said. Alfa Laval is the only other manufacturer to have gained G8 approval since the guidelines were revised. It, too, has USCG type-approval for its Pure Ballast 3 BWMS and its vice president and head of its PureBallast work, Anders Lindmark, said that its activity has been high since it secured USCG type-approval in December 2016 . It conducted the additional testing needed for a revised G8 certificate during 2017, which it received in February 2018 – the first company to reach that milestone. Other manufacturers that are working towards those goals have target dates that match the revised installation timetable agreed by IMO’s Marine Environment Protection Committee in July 2017 (MEPC 71). For example, Bawat chief executive Kim Diederichsen said that he expects to receive revised G8 type-approval in Q1 2019, on the back of its USCG type-approval application, for which shipboard testing was about to start at the time of writing following successful land-based tests. Coldharbour, too, expects to complete its USCG testing this year, with G8 tests

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being run at the same time. This approach is the same as that taken by Wärtsilä. It submitted a USCG type-approval application for its Aquarius EC BWMS in early April, and plans to match that for its UV version in Q3 this year. “Revised G8 requirements are being undertaken as part of our USCG testing schedules, and we will seek recertification as soon as possible,” BWMS sales director Craig Patrick said. Hyde Marine senior market manager Mark Riggio indicated early 2019 as its target date for both USCG and revised G8 type-approvals, as too did De Nora general manager Stelios Kyriacou, who is responsible for its Balpure business. It, too, is conducting USCG and revised G8 tests at the same time. He said: “We extended specific steps to accommodate the new G8 requirements.” Ecochlor president Tom Perlich said that its USCG type-approval testing took place while the G8 guidelines were being revised. It obtained USCG approval on 10 August 2017 and “we do not anticipate a need for separate testing” for G8, Mr Perlich told BWTT. As mentioned elsewhere in this guide, the USCG has reviewed its approach to non-USCG type-approved systems as more have become type-approved. BWTT asked manufacturers how many were needed to meet customer demand. Many did not express a view, but Coldharbour Marine chief executive Andrew Marshall based his answer on the expected 2019 installation timetable. Provided there are 15-20 systems with full USCG and revised G8 type-approvals available by H1 2019, “things should go smoothly,” he said. Optimarin chief executive Tore Andersen suggested the same range “to handle the boom, with IMO ships included.” Mr Patrick suggested that the “2018 cohort of USCG type-approved suppliers fulfil nearly all shipowners’ needs from a technology point of view.” But this should be balanced, he said, against the commercial capabilities and longevity of the supplier selected. Owners should look for “a strong engineering, sales, training

and aftermarket offering,” he advised. Mr Riggio noted that no more USCG type-approved systems are needed to cover demand “because many vessels do not actually need USCG type-approval” because of their operating patterns. But the market currently demands USCG typeapproval for all systems. If that continues, up to five more suppliers will be needed to meet the demand, he said. Mr Perlich suggested that BWTT had asked the wrong question. With shipowners delaying decisions for commercial reasons and the regulations having been pending for so long, “the question could turn out to be ‘how many systems can survive further delays and costs of testing?,’” he said. “Unfortunately, we are starting to see the first wave of the consequences of these delays through manufacturers that are no longer servicing their BWMSs,” he added. BWTT

SunRui’s BalClor BWMS – seen here during its USCG testing – is the first ‘active substance’ system to receive a revised-G8 certificate (credit: SunRui)

Ballast Water Treatment Technology 2018

28 | SUPPLIERS FORUM

BWMS suppliers fill the training gap

Coldharbour Marine’s system uses this inert gas generator and requires little training, its manufacturer claims (credit: Coldharbour Marine)

hipowers and their representatives were united when BWTT asked their views on training for ballast water management: there is not enough of it. Their comments can be read elsewhere in this guide, but manufacturers are helping to plug the gap through their own training schemes. Wärtsilä, for example, offers “a full training solution, covering all levels of support required,” said its sales director for ballast water management systems (BWMSs), Craig Patrick. It can be delivered on the vessel, in a classroom in one of its global locations or online, he said. It is centred around its electrochlorination and UV systems and covers practical details, but also covers IMO and US Coast Guard (USCG) legislation. Alfa Laval vice president and head of PureBallast work Anders Lindmark described training as “a key component” in ensuring that the “major investment” in a quality BWMS will perform over a vessel’s lifetime. It has training centres in Asia, Europe and North America where it offers extensive training for crew, shipowner

Ballast Water Treatment Technology 2018

officers, service engineers and engineering companies, he said. Alfa Laval has a simulator that can be installed at a shipowner’s training centre and computerbased training to provide familiarisation with its system. Crew training also forms part of a system’s commissioning, he said. Bawat offers what its chief executive Kim Diederichsen described as an extensive training package for onboard crew and office personnel. Its onboard training involves both deck and engine officers in a combination of classroom training, simulations and practical exercises before the system is operated under supervision. Its office training package is classroom-based and is structured to suit a company’s specific needs, he said. Optimarin trains crew during and after commissioning, its chief executive Tore Andersen said. It also has systems installed in training centres in Mumbai, Manilla and Stavanger. In Q2 this year, Ecochlor will start work on a training centre with an on-site simulator, instructor and training programme. Company president Tom Perlich told BWTT that

this will be available for ship crews, integrated engineering firms and vessel superintendents before a system is installed. At the time of writing in April, Ecochlor is releasing a computer-based training scheme for use on a ship’s computer, featuring an interactive training program. It provides varying levels of detail depending on the user’s level of responsibility for the system. At present, Ecochlor typically provides training when the shipyard has finished its work, performed in two phases. The first is in a classroom setting, and covers such topics as safety procedures and an overview of system operation. The second phase includes hands-on training in operating the system. A containerised training system is on the cards with De Nora, the general manager responsible for its Balpure business Stelios Kyriacou told BWTT. This would use a second-hand unit and could be moved between its international locations, he said, but most probably would focus on the US. This might be available in 2020, he said. Otherwise, it provides training during commissioning and in-house training, either at a shipowner’s premises or at one of its four training centres, he said. Trojan Marinex provides comprehensive training to ensure that crew can support the safety, operation and maintenance of its system. “We can provide hands-on instruction during commissioning as well as training support afterwards,” market manager Mark Kustermans said. Additional training support can be customised for specific needs, he added. It is a similar story at Desmi Oceanguard, which provides training during commissioning and offers one-day training courses, split between classroom teaching and practice with the system. For Hyde Marine, on-site training is supported by web-based training covering its system’s operation and maintenance. Coldharbour Marine chief executive Andrew Marshall said that its system requires little training. “Since our target customer base is mostly tankers and LNG carriers and our technology is inert gas-based, the typical level of training required is low,” he explained. Bulk carrier crews, who are less familiar with inert gas equipment than those on tankers, would require more, he said, but since the rest of its equipment “is super simple and requires little or no maintenance, the time taken for the crew to achieve full competency on the system is very short,” he said. BWTT

www.ballastwatermanagement.co.uk

From skid to modular version A wide range of systems integration possibilities supported by engineering studies capabilities www.ballast-water-treatment.com

SHIP OPERATORS FORUM | 31

MANAGERS QUESTION SYSTEMS RELIABILITY Two Hong Kong-based managers are disappointed by the performance of BWMSs on their fleets

allast water management systems (BWMSs) are not as reliable in practice as manufacturers promise, according to two shipping company executives speaking at a conference in China last September. Addressing the International BWM Technology and Standardization Forum, organised by the Shipbuilding Information Center of China (SICC) and BIMCO, the chief operating officer of Hong Kong-based Wah Kwong, Zhou Jian Feng, told delegates about unsatisfactory BWMS performance based on experience with the systems fitted on 36% of the company’s fleet. At that time, Wah Kwong listed 22 ships on its website, suggesting that it had then equipped eight ships with BWMSs. Capt Zhou listed four problem areas, with filter clogging as his first concern. He cited one newbuilding on which the filter failed when the crew first operated it and while its manufacturer’s representative was still on board. He also mentioned total residual oxidant (TRO) sensors – saying that their readings are unstable and can seem illogical – and flow rate meters, which can indicate clearly incorrect rates, he said. As a result of the problems, “crews have lost confidence in operating the systems,” he said. They also cause delays to ship operations

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Zhou Jian Feng (Wah Kwong): “Crews have lost confidence in operating the systems” (credit: SICC)

and “bring extra commercial risks to shipowners.” Capt Zhou was also critical of the after-sales service available, describing it as inadequate. “Both the quantity and quality of the service engineers are below expectations,” he said. One system was inoperable for nine months awaiting repair, he added.

He recommended that shipowners should develop contingency plans “for all foreseeable situations” in case their systems fail, and include details in their ballast water management plans. “In the meantime, we hope that manufacturers can continuously improve [the] design and stability of their BWMSs and provide sufficient

and effective after-sales service and support.” Capt Zhou’s comments were echoed by Wallem Shipmanagement group technical director Ioannis Stefanou, who is also based in Hong Kong. He said that when he compiled a ‘snapshot’ of the situation at the end of June 2017, 46% of the systems on ships the company then managed were not fully operational. Ships under Wallem’s management use systems from nine manufacturers across five technologies, Mr Stefanou said. “When they are sold, we are told they are very easy to operate – just press one button – but in reality it’s not like this,” he said. He listed five main areas where equipment gives problems – TRO sensors, systems valves, control units, filters and flow meters – but said that those were just a few from “a huge list.” “It’s worrying,” Mr Stefanou said, pointing out that each of these technologies is used in other areas of industry, but “in the marine environment they don’t last as long as we would like them to.” Unlike Capt Zhou, he paid tribute to suppliers for their “superb response and assistance” to rectify issues, but said that some “are not familiar with their own systems” because few have been installed and operated. Nonetheless, Mr Stefanou said, “manufacturers have been very helpful [in] resolving any issues,” although some are hampered by their limited service network. BWTT

Ballast Water Treatment Technology 2018

32 | SHIP OPERATORS FORUM

TANKER OPERATORS WANT CERTAINTY OVER CONTINGENCY PLANS Confusion over what shipowners should do if they have problems treating ballast water has prompted the tanker owners organisation Intertanko to publish its own guide. Tanker operators need certainty over what contingency measure they can use, its environment director Tim Wilkins told BWTT. Although IMO’s Marine Environment Protection Committee issued a circular after its 71st meeting (MEPC 71) in July 2017 describing contingency measures, it allowed port states to set their own preferences. As a result, operators cannot be certain what options are available to them or what information port states will ask for when deciding what a ship should do if it cannot treat its ballast, Mr Wilkins said. “If you speak to anybody

who has installed systems, they will tell you that it is a struggle to ensure that they are all operating 100% correctly, 100% of the time,” he said. But because different states take different approaches, they face “a huge bureaucratic and administrative nightmare” in dealing with contingency planning. “If there were a standardised way of reporting the failure and filing an application to undertake a contingency measure, it would make life more straightforward and process-orientated,” Mr Wilkins said. In an effort to provide guidance to its members, in March Intertanko published a 19-page guide, Ballast Water Contingency Measures for Tankers. It includes some model reporting forms that Mr Wilkins has developed from documents used by

Tim Wilkins (Intertanko): Shipowners face “a huge bureaucratic and administrative nightmare” over contingency planning (credit: Intertanko)

some Intertanko members. Intertanko will submit the guide to MEPC 73 in October as an information document, and request that member states note the initiative, with no action requested. A draft was passed to the US Coast Guard for its review; it did not raise any objections with it, he said. But even the US has no consistent approach because each ‘captain of the port’ region can set its own contingency requirements, Mr Wilkins said. Reaction to the guide had been favourable, he said, two weeks after its publication. Some flag state administrations had asked for copies and other shipping organisations had also seen it, he added. Since his interview with BWTT, it has been made publicly available on Intertanko’s website, via http://bit.ly/BWTT-IntGuide.

USCG type-approvals are vital, say shipowner bodies US Coast Guard (USCG) type-approval is a more important factor than IMO type-approval to shipowners, if feedback from two leading shipowners organisations is any guide. BWTT contacted InterManager, which represents third-party and in-house shipmanagers worldwide, and the Hong Kong Shipowners Association (HKSOA), one of the world’s largest shipowner associations, its members owning, managing and operating about 180M dwt of ships. Asked how important USCG type-approval is for his members compared with type-approval to IMO's BWMC, InterManager secretary-general Kuba Szymanski said it was extremely important. “No one wants to buy a pig in a poke,” he said. “What would be the point of having ships that could not trade to US?” HKSOA technical director Martin Cresswell agreed, but added that every system that meets the new IMO G8 standard is expected also to pass the USCG type-approval tests. There need to be as many USCG type-approved systems as possible to meet shipowners’ needs. As Mr Szymanski put it, “more systems means more choice and more competition.” Both said the choice available and the number of typeapproved systems will be helped by the delayed implementation schedule agreed at MEPC 71 in July 2017. The two-year delay in installing ballast water management systems (BWMSs) “is very

Ballast Water Treatment Technology 2018

positive,” Mr Cresswell said, because shipowners will be able to choose systems approved to the revised IMO G8 standard or USCG type-approved systems, “which are a lot more robust than the earlier systems,” he said. Mr Szymanski’s response was similar, suggesting that “further delays might help shipmanagers to source better designs because manufacturers will have a better chance to make systems meeting new, more stringent requirements.” But he confessed to some difficulty in coming to a conclusion, saying that the delay “gives the US and other governments more time to decide what they really want to do,” rendering the regulation ‘politician-centric’ rather than, as it should be, ‘human-centric’ “with the end-user in mind,” he said. He was also concerned about the amount of training that seafarers will need. “Our members are really seriously concerned about how to provide training in so many different types of systems,” and how those skills can be made transferable, he said. “Seafarers are really panicking, knowing that port state control is getting a new stick to ‘measure’ the vessel,” he added. Mr Cresswell also had views on training, saying that there was not enough of it so far. He suggested that ECDIS operations provide a good model for what could be offered for BWMS use, with generic and specific training being provided. BWTT

www.ballastwatermanagement.co.uk

An owner’s guide to BWMS retrofits Feasibility study & concept engineering

Class approval

Installation

3 - 5 weeks

4 - 6 weeks

2 - 5 weeks

Basic engineering & classiﬁcation design

Detail engineering

Approvals & commissioning

4 - 8 weeks

2 - 3 weeks

Engineering

Supervision & site support

Project management throughout the project

8 Sept 2024

System selection considerations:

is the deadline for all ships to meet the D2 standard for ballast water management

• Power onboard • Space onboard • Vessel type • Area of operation

Reﬁt vs. scrap? Cost of BWMS: 0.5 - 3 million USD

45 6

documents required by Class manufacturers signing LOI for USCG approval manufacturers approved BWMS approved by ﬂag states

 This infographic is the property of Foreship

34 | FILTRATION

Lack of filters no obstacle for effective treatment Not every treatment system needs a filter to provide effective ballast water management

n the early days of ballast water management development, when the practical aspects of systems aboard ships had not been fully thought through, it was proposed that filtration on its own could provide a solution to species transfer without any other treatment methods. But ballast management pioneers took a different approach, with most of the very earliest projects involving heat treatment alone. That fell out of favour over time, but has since been revived in the Danish maker Bawat’s system, and is being pursued by others, too. It has become obvious in the intervening years that treating ballast water to meet IMO’s 2004 Ballast Water Management Convention (BWMC) standard is more complex than was once thought, and that success usually relies on combining treatment methods. Filtration plays an important part in that, and is a preliminary step in three out of every four systems being marketed or developed at the present time. So although most system makers have opted to make filtration a preliminary to treatment, some have decided that filtration is unnecessary. For example, in a statement in May 2017 announcing its intention to apply for US Coast Guard (USCG) type-approval, Norway-based Knutsen Ballast Water Systems stated that its KBAL system is the only system available on the market that uses neither any kind of chemicals nor any filters. That claim would be disputed by others. UK-based Coldharbour Marine also states that

Ballast Water Treatment Technology 2018

Bollfilter’s aquaBoll filter was unveiled at Marintec by Germany's Consul General in Shanghai, Dr Christine Althauser, and Boll & Kirch chief executive Stefan Starke, see page 34 (credit: Boll & Kirch)

no filters are used, as does Denmark’s Bawat and many others. South Korean maker Techcross does not list filtration as part of its ElectroCleen System (the first system to gain IMO type-approval in 2008), but the

system does include a T-strainer unit with a 3 mm mesh to block large organisms and debris from entering the treatment system. It is debatable whether a mesh of that type can be considered a filter, not least because all of the systems that use

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FILTRATION | 35

filtration as part of their treatment regime do so with a filter of at most 50 μm. That size has been chosen because it will remove some of the organisms of the dimensions that are specifically mentioned in the D2 performance standards of the BWMC. In practice, an organism with a maximum dimension of 50 μm would most likely pass quite easily through such a filter screen because of its natural elasticity and because it would probably be smaller than that in one dimension. For that reason, it is not uncommon to see makers use even finer mesh sizes in their systems, although rarely below 30 μm. Desmi Ocean Guard’s RayClean system, for example, lists a 30 μm wire mesh filter on its original IMO typeapproval certificate. Boll & Kirch managing director Robert Jellinggaard told BWTT that the market trend is toward finer filter sizes and its new aquaBoll series can filter down to 20 μm (see page 34). It is worth mentioning that the convention is not only concerned with ballast water but also specifically refers to sediment in its full title and in its text. Systems without fine filters may use another form of mechanical separation such as a hydrocyclone – even some of the filter systems use this technology as a precursor to filtration – to remove organisms and coarse sediment. It is much harder to prevent fine sediment entering ballast tanks. Scientific studies have shown that fine sediment may consist of particles of 20 μm and smaller, meaning they will pass through most system treatment filters. Even in a hydrocyclone, the sediment’s specific gravity, especially if it has a high organic content, will be below that which the device can separate out. Hydrocyclones are still a feature of some systems, such as the Erma First system, made by the company of the same name. Its USCG type-approved Erma First Fit option uses 40 μm backwashing filters. Other makers have dropped them or withdrawn from active development and commercialisation. Among those that started out using hydrocyclones was Optimarin (in the first generation of its system), but hydrocyclones are no longer used in the version that received USCG type-approval (Optimarin was the first manufacturer to achieve that status). There is no doubt that filtration that removes any organisms from the remaining treatment process will probably make the

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later processes more effective and so aid in meeting the discharge standard, particularly in UV systems where exposure to the UV radiation is essential. Most UV system makers will argue that their system is highly effective in exposing all organisms to radiation. But others doubt whether this is the case, especially in particularly turbid waters, arguing that individual organisms will avoid lethal doses. Most of the systems that do not have filters are intended for use on the largest vessel types: bulk carriers and tankers. These ships have a need for high ballasting rates and uninterrupted ballasting because they are usually obliged to leave the berth immediately after cargo operations have ceased. The makers of these systems point out that, in practice, filters can be very troublesome and require frequent backwashing in all but ideal conditions. Although the makers of systems that do use filters will argue this is not the case, it is a view shared by some seafarers, according to a report written in 2016 by Goran Bakalar, who is affiliated to Croatia’s University of Zadar and to Split-based International Maritime Technology Consultancy. His study, Comparisons of

interdisciplinary ballast water treatment systems and operational experiences from ships, included interviews with ships’ crews. In one case, a bridge officer said that filters were “a constant problem” in a Brazilian port, making the system inoperable. Others echoed that experience. Mr Bakalar reported that all of the officers interviewed stated that “they by-passed the treatment system and continued the ballasting or deballasting process to avoid shutdowns.” (The report is available online via http:// bit.ly/BWTT-Crewstudy.) Of those systems in which filtration does not feature, two thirds have achieved type-approval under IMO’s regulations – but so far none has obtained USCG type-approval. That does not mean that unfiltered systems will not be given USCG type-approval and, at the time of writing in late March, some such systems have begun the process of undergoing the required testing regime. Without exception, their manufacturers are confident that their systems – which use a variety of technologies including heat, deoxygenation and chemical treatment – will achieve the approval without any more difficulty than systems that do have filters. BWTT

The interaction of a BWMS’s filter and disinfection stage “is very tricky to understand,” believes Mark Riggio of Hyde Marine, manufacturer of this Hyde Guardian system (credit: Hyde Marine)

Ballast Water Treatment Technology 2018

36 | FILTRATION

FILTERING OUT TYPE-APPROVAL CONCERNS Most ballast water management systems (BWMSs) need filters. They are essential components of their operation and performance, so when a BWMS is assessed for type-approval its filter forms part of its typeapproved system. Some in the BWMS manufacturing sector have expressed frustration that because of this, if they want to offer a second filter option with their BWMS they have to resubmit the treatment equipment for a second type-approval. At least one manufacturer that already has US Coast Guard (USCG) type-approval has done exactly that and submitted an application for a second filter arrangement. At the time of writing in early April, the USCG had not finished assessing those applications. This applies if any modification is made, which prompted Hyde Marine executive director Chris Todd to say in January that the process discourages innovation and improvement “because if you spend US$4M to get the solution approved, you do not want to spend that again.” But the company’s senior market manager for BWMS, Mark Riggio, understood why authorities take a rigorous approach. “The interaction of the filter and disinfection stage is very tricky to understand,” he told BWTT. “It is difficult to justify through testing that each stage of a treatment system is independent [of ] the other stages.” A related concern applies to the situation that would arise if a component, such as a filter, failed and a similar unit was not available – if the manufacturer had gone out of business, for example. The USCG has made its position clear, in postings on its online Maritime Commons blog. In September 2017, and again in October, it warned that “if the [BWMS] equipment fails to operate and parts from the original equipment manufacturer are no longer available then the equipment is no longer operating under its type-approval and must be replaced.” One suggestion that a manufacturer put to BWTT is that components such as filters could be type-approved separately so that an equivalent or better unit could be substituted without affecting a BWMS’s type-approval status. BWTT contacted a number of leading manufacturers to ask their views on this proposal and received mixed reactions. Most did not wish to express a view.

The USCG type-approved Erma First Fit BWMS uses 40 μm backwashing filters (credit: Erma First)

One who did was Tom Perlich, chief executive of Ecochlor. He would support “any regulatory changes that allowed for the upgrade and improvement of a ballast water treatment system or the replacement of supporting components without further testing for type-approval or re-certification, as long as the BWMS manufacturer and/or parts supplier could demonstrate that their product is of equal or better quality and efficacy.” But Coldharbour Marine chief executive Andrew Marshall urged caution. “People don’t seem to understand that for a BWMS that includes a filtration step, the filter is not simply there as a stand-alone part,” he said. The USCG has no plans to review its stance, if comments by the editor of its online blog, Maritime Commons, Lt Amy Midgett, are any guide. She told BWTT that the primary reason – of many – that its Marine Safety Center (MSC) does not approve individual components is because “the BWMS type-approval regulations are meant to evaluate the effectiveness of a BWMS system as a whole.” There is considerable variability in the arrangement and operation of these systems, she said, so “MSC must consider component changes on a case-by-case basis in order to determine the probable effects on system efficacy.”

New filter boasts flexible options for BWMS installations Ballast water treatment systems will be a significant market for a range of automatic filters that Boll & Kirch unveiled during the Marintec exhibition in China in December 2017, describing its new aquaBoll series as “a new concept for fully automatic water filtration.” Boll & Kirch managing director Robert Jellinggaard told BWTT that the filter has interchangeable components, which would be selected to suit the size, the required filtration efficiency and the degree of contamination of the process water. He highlighted one feature in particular that made the filter suitable for ballast water management systems (BWMSs): it can filter down to 20 μm, which matches

Ballast Water Treatment Technology 2018

market demand for finer filters. AquaBoll is an automatic backwash filter. It is marketed under the company’s Bollfilter brand, and directly replaces its previous model. It is available in seven sizes, covering throughputs ranging from 50 m 3/h to 1,250 m3/h. The smaller sizes have a cast pressure vessel, with its two halves bolted together, making it possible to orientate the inlet and outlet to suit the installation. For the larger sizes, the vessel is made from welded steel, because of the higher pressures involved, Mr Jellinggaard explained. Because of its multi-part housing, filter elements, variable connectionflange positions and different housing

materials, it can be adapted to suit a range of installations, even in small spaces, the company’s literature reports. Bollfilter’s main customer is Optimarin, Mr Jellinggaard said, but it also does business with other BWMS makers. One of them – MMC Green Technology of Norway – was the first to fit the aquaBoll filter. Its sales and marketing director, Børge Gjelseth, told BWTT in January that it had orders for four units even before Boll & Kirch had formally launched the device. In June 2017 another Bollfilter customer, SunRui of China, obtained US Coast Guard type-approval for its system, which included a Bollfilter Automatic Type 6.18.3 filter. BWTT

www.ballastwatermanagement.co.uk

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38 | PORT AND FLAG STATES

Port state control inspections reveal BWMS deficiencies Data from both the Paris MOU and USCG show large numbers of ships being found with problems over ballast management

hips have been detained in Europe and the US because of deficiencies found in their ballast water management systems (BWMSs) and practices, an analysis by BWTT has found. In mid-March, just over six months after IMO’s Ballast Water Management Convention (BWMC) came into force, the Paris MOU secretariat’s online inspection database showed that between 8 September 2017 and 18 March (when the analysis was carried out), ballast treatment deficiencies had been found in 145 inspections on 144 ships, of which 15 had been detained. Most of those detentions recorded ballast deficiencies among a number of ISM-related deficiencies, with ISM problems collectively listed as a ground for detention. But for two ships – their names can be found in the database – the ballast water deficiency itself was listed as a ground for detention so could, on its own, have justified those ships’ detentions. Responding to the findings,

Richard Schiferli (Paris MOU): The BWMC is in force and is being enforced (credit: Paris MOU)

Paris MOU secretary general Richard Schiferli said that a message he would like to get across to owners from the data is that the BWMC is in force and is being enforced by port state control inspectors. Class society DNV GL published a similar analysis in March, covering the period from 8 September 2017 to the end of that year. It assessed the reasons for the deficiencies and found that about a third were for incorrect, not properly filled in or missing entries in the BWM record book, or the book itself was missing. A quarter were the result of incorrect ballast water exchange: either it was not exchanged at all, or the amount of water exchanged was insufficient. Other deficiencies included BWM plans that had not been approved, were incorrect or missing.

Ballast Water Treatment Technology 2018

In the US, ballast water management inspections have been taking place longer than in Europe. The 2017 US Coast Guard port state control report, published in April, included a comparison between 2017’s and 2016’s inspections. Between those years, ballast water management deficiencies recorded during USCG inspections increased from 110 in 2016 to 219 in 2017: a rise of 99.1%. Yet the number of inspections grew by just 1.9%. Its report did not suggest any specific reason for the increase, but noted that most of the deficiencies were related to logs and records, alternate management systems, mandatory practices, ballast

water management plans and the discharge of untreated ballast water into US waters. As a result of the deficiencies, the USCG “imposed operational control restrictions on 17 vessels due to the severity of deficiencies,” the report said. These vessels “received sanctions ranging from warnings, Notices of Violations and Administrative Civil Penalty (Class I) actions for failure to implement BWM requirements,” it added. It identified some common trends among the deficiencies, including a lack of familiarity and training regarding the use of a BWMS and problems over maintenance of the vessel’s BWM plan and

TYPE OF BWM DEFICIENCES 5% Sediments

2% Training

1% Extraordinary condition claims

5% BW reporting form 6% Submission of report

22% Ballast water logs/record

6% BWM plan

18% Alternative management method

17% Ballast water discharge 18% Mandatory practices

The USCG’s annual port state control report provided a breakdown of the ballast water management deficiencies it found in 2017 (source: USCG)

www.ballastwatermanagement.co.uk

PORT AND FLAG STATES | 39

implementation of its BWM strategy. “In some cases, the Coast Guard found that the BWMS was only used during voyages to the US and that crews received little or no training in operating and maintaining the system,” it said. The report did not name any specific vessels, but one high-profile incident in January 2017 involved the

bulk carrier Vega Mars, which faced civil penalty proceedings for an alleged infringement of ballast water discharge standards in Tacoma. The USCG said in a statement at the time that “ballast water was discharged from the vessel without the use of a Coast Guard-approved ballast water management system or other approved means” and details

of the incident can be found on the USCG’s searchable online database. It said then that the vessel faced a maximum penalty of US$38,175 but no further statement was issued by the USCG about the penalty finally imposed. In reply to a question for this report in April 2018, a USCG Marine Investigation Division officer for Sector

Puget Sound based in Seattle told BWTT that “Vega Mars was charged with one violation of the ballast water regulations, which was subsequently found proved. As a result, the hearing officer assessed a civil penalty of $6,000 against the vessel’s operating company.” He said there had been enforcement cases against two other vessels in 2017 for the same violation.

Installation delay solves ‘unworkable’ schedule, say flag states Delaying installation deadlines for ballast water management systems to meet Regulation D-2 of IMO’s Ballast Water Management Convention (BWMC) addressed what the chief commercial officer of the Liberian International Ship and Corporate Registry (LISCR) Alfonso Castillero described as an unworkable implementation schedule “given the availability of ballast water management systems (BWMSs).” He told BWTT that the register was among the leaders in pushing for this extension, which was adopted during IMO’s Marine Environment Protection Committee meeting in April (MEPC 72) after draft amendments were agreed at MEPC 71 in July 2017. He stressed that Liberia was one of the first administrations to ratify the convention “and is entirely committed to its effective and smooth implementation.” But he added that “the existence of important practical and technical considerations compelled it to seek the support of other stakeholders in securing an equitable implementation date for the convention.” Other flag states contacted for this report also supported the

change, including Australia, which was one of the first countries to highlight the risk of invasive species being moved around the globe in ballast water. A spokesman for its Department of Agriculture and Water Resources agreed with the Liberian view, saying that the “slightly extended schedule” was realistic “in terms of ensuring the availability of BWMSs while providing certainty, in terms of timelines, for industry.” The new installation schedule has not delayed implementation of the convention, pointed out the Isle of Man Ship Registry’s technical policy lead, Paul Grace. Ships will have to carry out ballast water exchange and meet the convention’s D-1 standard until their D-2 compliance date arrives, he said. Although the Isle of Man does not have a vote at IMO, since it operates as part of the British Red Ensign Register, he supported the decision, which “has helped to provide clarity to shipowners, flag states and port states and has removed the uncertainty that was in place prior to MEPC 71,” he said.

Great Lakes are ballast water battle grounds Many US states have their own ballast water management rules that are different from federal requirements. The differences became important in November 2017 when both the House and Senate in one of the Great Lakes states, Michigan, voted to align their legislation with federal regulations. But the state’s Republican governor Rick Snyder is a longstanding supporter of the state being “a leader on ballast water standards,” according to a statement on his website, and there were doubts that he would approve the bill. His views were echoed by a Democrat senator, Rebekah Warren, who said that Michigan’s policy is similar to those of 13 other states. “Evidence has shown that these stronger standards have been effective in slowing, although not preventing, the spread of invasive species,” she said. The counter-argument was along commercial lines, with Republican senator Triston Cole saying that Michigan’s more stringent requirements on ballast treatment discouraged ocean-going vessels from using the state’s Great Lakes ports.

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Before the governor could sign the bill, the two versions – from House and Senate – had to be ‘enrolled’ into a single agreed text. At the time of writing in late April, that enrolled bill had not been published or approved. Across the other side of the lakes is Canada, a signatory to IMO’s BWMC. One of the topics on the US Coast Guard’s online ‘Ballast Water FAQs’ addresses the difference between the two regimes, but stresses that both countries “support a strong, environmentally sustainable, Great Lakes economy.” It notes that USCG, the US Environmental Protection Agency and Transport Canada “maintain an ongoing dialogue to identify and resolve differences in their respective regulatory requirements.” At the international level, senior communications advisor at Transport Canada, Annie Joannette, told BWTT that “Canada and the US continue to work closely bilaterally and at IMO towards compatible, practicable and environmentally protective ballast water requirements that reflect economic fairness.” BWTT

Ballast Water Treatment Technology 2018

40 | ISO

INDUSTRY GETS INVOLVED IN ISO’S BALLAST MANAGEMENT WORK COMPANIES SUPPORT STANDARDSETTING WORK, ALTHOUGH UNDERSTANDING OF ISO’S ROLE REMAINS PATCHY

number of companies involved in ballast water management have got involved in the work of the International Organization for Standardization (known as ISO) in developing standards for ballast water management. But it was clear from BWTT’s research for this publication that there is a wide range of knowledge and views about ISO’s role and relevance. In a detailed survey distributed to ballast water management system (BWMS) manufacturers, BWTT asked whether ISO’s work featured in their planning. Of the manufacturers that offered feedback, some have become involved in aspects of its work and others are monitoring its activities. But one admitted to being unaware of ISO’s involvement in ballast water management and a senior executive of another BWMS manufacturer said that because ballast water management rules are largely set by IMO, the USCG and classification societies, “I don’t really know what ISO is trying to achieve.” If his company thought there was an aspect of ISO’s work it could contribute to, then “most certainly” it would join. “But at the moment we don’t. We are only observing,” he added. One of the manufacturers that is contributing to ISO’s work is SunRui of China. It welcomed an ISO delegation – accompanied by BWTT – to its premises in Qingdao in September 2017, and subsequently proposed two projects to ISO that were related to safety aspects of BWMS operation. SunRui received approval for its involvement in March this year. Its work will “provide significant and reliable technical support "for hydrogen safety measures, health and risk assessment in terms of design, installation and risk control requirements on ballasting water management system

“Hydrogen gas is inevitably generated as a by-product of electrolysis”

Ballast Water Treatment Technology 2018

This ISO form confirms that the organistion approved SunRui’s proposed project on hydrogen safety measures (credit: SunRui)

using the electrolytic method,” one of those who drafted SunRui’s proposals, Grace Lee, told BWTT. “Hydrogen gas is inevitably generated as a by-product of electrolysis,” she said. The projects are ISO 23315, Hydrogen Safety Measures on Ballast Water Management System using Electrolytic Method, and ISO 23314, Health and Risk Assessment on Ballast Water Management System using Electrolytic Method. China, Japan, the US, Russia, Denmark and Panama have nominated experts to take an active role in developing the projects. Another company to get involved is the French test-kit manufacturer aqua-tools, which makes the B-Qua ballast water testing kit. Its business development manager for ballast water Carine Magdo told BWTT that she heard about the ISO’s work “by searching for information to write a document to give guidance to our customers about representative sampling.” As a result, the company decided to get involved with ISO’s work and will work with French standardisation organisation AFNOR (Association Française de Normalisation) and ISO to establish new chapters for ISO 11711, which addresses ballast water sampling and analysis and is being developed at IMO’s request. At present, ISO 11711-1:2013 provides guidance on the materials,

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ISO | 41

design, and installation of equipment used to take samples of treated ballast water from the discharge pipe on board a vessel, but does not yet include a standard on how to perform the representative sampling and analysis of ballast water, aqua-tools’ statement said. ISO is working on new chapters, 11711-2 and 11711-3, which are intended to provide guidance on the selection and use of the sampling apparatus. One company that is monitoring progress on that topic is Alfa Laval, whose vice president and head of its PureBallast work, Anders Lindmark, told BWTT that it will make “minor updates to our sample device once the standard is agreed and final.” Among other companies taking part in some ISO work are Desmi Oceanguard and UniBallast, both focusing on aspects relevant to their work. Desmi Oceanguard chief executive Rasmus Folsø highlighted a project that is developing a standard for CFD scaling of UV-based BWMSs, while UniBallast director Fulko Roos said that it is part of the ISO 23055 expert working group, which is establishing requirements for an international ballast water transfer connection flange in accordance with the IMO guidelines G5 for ballast water reception facilities.

Carine Magdo (aqua-tools) discovered ISO’s work when writing a customer information document (credit: aqua-tools)

ISO links regulations to the real world Last year marked 70 years of involvement in shipping topics by the International Organization for Standardization (known as ISO). It has addressed topics specific to ballast water management (BWM) for more than a decade. Its Technical Committee No 8 (TC8) addresses ships and marine technology. One of that committee’s working groups, No 12 (WG 12), was set up in 2016 to focus specifically on aquatic nuisance species, and took on TC8’s work on BWM. WG 12’s convenor is Carolyn Junemann, an environmental protection specialist at the US Department of Transportation’s Maritime Administration. Speaking in September 2017, she said that ISO’s role in maritime discussions is to provide a link “between IMO regulations and requirements and what industry really needs.” Dr Junemann was addressing the International BWM Technology and Standardization Forum, organised by the Shipbuilding Information Center of China (SICC) and BIMCO. She explained that WG 12 “supports the entry into force of [IMO’s] Ballast Water Management Convention and all matters arising from non-indigenous or invasive species and aquatic nuisances.” Her group’s particular focus at the time of the conference was standard ISO 11711, which deals with sampling and compliance standards and relates to IMO guidelines G2

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for ballast water sampling. “We felt this was an important standard to develop so that people operating the ship and those doing compliance monitoring all are on the same page, so there are no misunderstandings,” Dr Junemann said. Part 1 of that standard refers to the design and implementation of the sample port required on board a ship to obtain representative samples. “This would be

Carolyn Junemann (Marad): ISO’s WG 12 addresses “all matters arising from nonindigenous or invasive species and aquatic nuisances”

considered a permanent installation on the ship, so we give guidance on where to place the sample port,” she said. Part 2 will address how a port state control officer will take a sample, including the sample probe and collection device. There will subsequently be a Part 3 to the standard, which will define how the sample is then analysed. Work on that had not started in September but, as mentioned elsewhere in this report, some companies are involved in supporting ISO in developing this and other ballast management-related standards (see ‘Industry gets involved in ISO work’). Other standards being developed include one that is exploring how UV systems can be scaled up, Dr Junemann said, and others that will establish specifications for electrochlorination systems. That topic has since been taken on by the Chinese BWMS manufacturer SunRui, with backing from a number of international experts. Responding to a question after her presentation, Ms Junemann appealed for more industry involvement in developing these standards. Asked when one particular standard would be ready, given the anticipated rush for retrofits in the next few years, she invited conference delegates to participate in ISO’s work. “We can accelerate the timeline, but it requires a lot of work and a lot of participation,” she said. “It just depends on the dedication of the group that wants to participate.” BWTT

Ballast Water Treatment Technology 2018

42 | SAMPLING

Compliance improves, but sampling standards needed Checks show that compliance is improving but reveal concerns over sampling port installations

ample tests show that compliance with ballast water management standards has improved in recent years, according to SGS Group global business development manager Vladimiro Bonamin. Speaking in September 2017, he said that, based on several hundred sampling events worldwide over a number of years, more than 90% had been compliant with the relevant standards. But over the previous 12 months, he said, compliance had been “very, very close to 100%.” Mr Bonamin was addressing the International BWM Technology and Standardization Forum, organised by the Shipbuilding Information Center of China (SICC) and BIMCO, where he told delegates that most of these tests had been carried out for shipowners or manufacturers seeking information about their systems’ performance, although about 150 of them

Vladimiro Bonamin (SGS): Compliance is now “very, very close to 100%” (credit: SICC)

were carried out to issue official test reports. His experience spanned both IMO and the US, divided almost entirely between electrochlorination- and UV-based systems. Other technologies were “very rare,” he said. Although his test results were encouraging, he described some difficulties

SGS’s BALLAST WATER SAMPLING EXPERIENCE (2013-SEPTEMBER 2017) US VGP-related tests

IMO-related tests

650 sampling events on 300 vessels; 90% compliant. 60% chemical; 40% UV 13 tests; 12 compliant

Non-compliance is often a consequence of improper handling of the treatment system. US VGP non-compliance can be due to exceedance of biological or chemical limitations

Source: SGS paper to the International BWM Technology and Standardization Forum, September 2017

Ballast Water Treatment Technology 2018

in carrying out the tests themselves. In some cases, the crew do not know where the sampling port is, he said. And there have been occasions when treatment has been started only shortly before SGS testers have boarded. “It is necessary to wait at least 10 minutes after the system is switched on to start to see good numbers,” he advised. Where SGS has found non-compliance, it is often related to the residual chemicals needed for some systems. In particular, there have been instances where the system has no neutraliser, either because too much was being used or the total residual oxidant sensor was not in calibration. Mr Bonamin also spoke of concerns about sample ports. “Sometimes they are very difficult to reach,” he told the conference. They can also be badly sited in the pipework, he said, illustrating his point with a photograph showing a sampling valve positioned no more than 30 cm before a 90° bend. “The hydrodynamics are completely wrong,” he said. The Institute of Marine Engineering, Science and Technology (IMarEST) shares his concerns. In a submission to the fourth meeting of IMO’s Sub-Committee on Pollution Prevention and Response (PPR 4), it said that although vessel owners acted with good intentions and “many ships have been outfitted with sample ports that are in compliance with [IMO Ballast Water Management Convention (BWMC)] Guidelines G2 ... the current guidelines are not specific and as a result there are many variations of sample ports installed. This variety may challenge efficient and practical port state control inspections.” Its paper included a proposal to standardise sampling ports and explained that, although the BWMC guidelines “provide methods to calculate a sample probe size, they do not provide guidance on the sampling port connection size.” This has resulted in a range of different sized sampling probes and, in some cases, “a flange is presented without a sample probe,”

www.ballastwatermanagement.co.uk

SAMPLING | 43

IMarEST’s submission said. Its proposal was well received, IMarEST Ballast Water Expert Group (BWEG) co-chair Kevin Reynolds told BWTT. As mentioned elsewhere in this publication,

ISO is developing an international standard for sample ports and it will take account of some elements of IMarEST’s paper, he said. Although PPR4 took place in January 2017, the topic is still a concern

now. BWEG’s other co-chair, Marcie Merksamer, told BWTT in April that this topic “is an area of continued focus” and that the BWEG may include this in its work programme.

Port states encourage testing using portable kits As part of IMO’s experience-building phase of implementing its Ballast Water Management Convention (BWMC), ships visiting some ports are being subjected to ballast water checks, although no action is being taken in the event of a deficiency being found. At the time of writing, in late April, BWTT is aware of one state that is conducting these tests, Saudi Arabia, and another that is exploring doing so, Canada. But up to six more are understood to be conducting tests. Canada’s Great Lakes Laboratory for Fisheries and Aquatic Sciences, in Burlington, Ontario, is assessing a number of kits, although exact details have not been made public. French test kit maker aqua-tools revealed in March that its B-Qua equipment had been added to the programme, which is being conducted by the same scientist who conducted a 2015 study to test the efficiency of various ballast water testing methods on board the research vessel Meteor on behalf of Germany’s Federal Maritime and Hydrographic Agency. The Canadian laboratory plans to carry out ballast water sampling and testing on up to 20 ships during 2018, to assess which tool or tools might provide the best rapid assessment of ballast water compliance,

aqua-tools said. Aqua-tools is also involved in testing programmes in Saudi Arabia. It supplied the first of 30 of its Rapid ATP ballast water monitoring systems last August to Swiss testing and certification organisation, SGS Group, which has agreements to inspect and monitor treated ballast waters of vessels arriving in those countries. At that time, SGS Group global business development manager Vladimiro Bonamin told BWTT that the company had worked with seven PSC authorities on a project basis, but said the locations of the other six states were covered by confidentiality agreements. As for Saudi Arabia, though, he said that SGS was one of four inspection companies to have been approved as ballast water test providers to the shipping community. “Ships are now obligated, by local regulations, to sample and perform the indicative test while de-ballasting in Saudi Aramco-controlled ports, using one of the four approved companies,” he said. SGS and LuminUltra of Canada were involved in developing the test equipment alongside aqua-tools, the manufacturer’s statement said. Another company providing testing services in Saudi Arabia is Global Strategic

Saudi Arabia shares sampling data Saudi Arabia shared some initial findings from its onboard sampling initiative in a paper submitted to the fifth meeting of IMO’s SubCommittee on Pollution Prevention and Response (PPR5) in February. Although the paper was dated 1 December 2017 – less than four months after it started requiring sampling on 16 August 2017 – its figures were based on water samples from more than 500 ships. It reported that over 90% of indicative samples from ships that conducted ballast water exchange passed the D-2 standard and were found to have a low count of viable organisms remaining in discharged ballast water. But “a considerable number of ships that have installed

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Alliance (GSA), which uses Chelsea Technologies’ FastBallast portable ballast water analyser. In a statement last August, Chelsea Technolgies said that its FastBallast was selected “following a detailed technical review conducted by Saudi Aramco’s in-house marine biology experts, who identified FastBallast as the most accurate solution in the market for the indicative sampling of ballast water.” It quoted Chelsea Technologies managing director Brian Phillips, who looked forward to “working together with Saudi Aramco to ensure that all third-party ballast water sampling meets the high standards of compliance now required of all vessels calling at Saudi Aramco ports and terminals from international waters.” In an exclusive interview with BWTT, GSA co-founders Adnan Bahamdein and Rajeev Ramachandran stressed that the tests it is conducting are indicative tests and are not the equivalent of a full port state control check. And “there are no penalties,” Mr Bahamdein said. Saudi Aramco’s main goal is data collection, he explained, to understand how many failures there are and where those ships come from. All failures are reported to Saudi Aramco, and “no vessel that has failed has ever failed again,” Mr Bahamdein said.

IMO-approved ballast water management systems [BWMSs] and conducted treatment before discharge were observed to have failed D-2 standards testing for samples taken,” it added. It also found that several ships that have installed typeapproved BWMSs “have expressed, in writing, concerns regarding operational constraints, and hence opted to conduct ballast water exchange instead.” Based on its experience, Saudi Arabia urged more IMO members to conduct indicative sampling initiatives. It proposed a standard for indicative sampling that required sampling to be done by “a competent and certified person,” and for there to be a “clear chain of custody” for the records. The submission was welcomed by other IMO members and shipping organisations at the meeting, but some were concerned by the number of treatment systems that were found not to meet the D-2 standard. BWTT

Ballast Water Treatment Technology 2018

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CLASS SOCIETIES | 45

IACS SETS UP BALLAST WORKING GROUP REVISIONS TO EXISTING REQUIREMENTS AND TANKER-RELATED FACTORS PROMPT CLASS SOCIETY ACTION

he International Association of Classification Societies (IACS) has set up a working group to consider revising its Unified Requirement (UR) M74, Installation of Ballast Water Management Systems, IACS secretary general Robert Ashdown told BWTT. “IACS has acknowledged the need for a clear regulatory framework for the safe installation of water ballast treatment units,” he said. He did not say how the working group will operate, but a source with knowledge of the work told BWTT that two project teams (PTs) have been set up to define “appropriate safety measures” to ensure that ballast water management systems (BWMSs) are installed safely. Among other things, the revision to UR M74 will address the difficulties of installing BWMSs on board oil and chemical tankers, while fulfilling water ballast segregation requirements, the source said. BWTT understands that one PT was established in October 2017 and held a three-day workshop in January, with a second planned later this year. According to BWTT’s source, a report from its first workshop went to IACS’ Machinery Panel, which in turn passed it to the

association’s Safety Panel to be used as the starting point for the second project team, which will look at safety issues around BWMS installations. That second team will assess each technology and, depending on the location where the system is intended to be installed, define appropriate requirements to help shipowners “take advantage of the broad range of technologies available while supporting safe installation on board,” BWTT was told. For example, when an installation involves a ballast water management system (BWMS) that relies on ozone generation, it might specify that the space where the unit will be installed must be protected from the potential risk of a leakage of ozone or oxygen. A BWMS’s operating principle might also limit where a unit can be installed on board. In oil and chemical tankers, for example, if the BWMS treats water by injecting inert gas, its inert gas generator’s location would have to meet the same location limitations as an inert gas generator fitted for cargo tank protection.

Class societies respond to ballast management concerns

Convention (BWMC) came into force on 8 September 2017, “we cannot make any conclusions that suggest BWMSs do not work.” Lloyd’s Register echoed DNV GL’s comments. In remarks prepared jointly by its senior marine consultant (marine and offshore) Yildiz Williams and its senior specialist (marine and offshore) Sahan Abeysekara, it said that whether a system functioned properly could not be assessed without sampling its discharge. “We are looking forward to the [BWMC’s] experiencebuilding phase, when we will have more reliable and

For this report, BWTT contacted the four largest classification societies – DNV GL, ClassNK, ABS and Lloyd’s Register – to understand their views on some key topics that affect ballast water management. ABS’ comments on its research into its clients’ experience of using ballast water management systems (BWMSs) is reported separately, but from the other three societies’ experience we can observe that the

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picture is not yet clear. ClassNK, for example, said that clients had reported cases of BWMSs “not functioning properly due to lack of maintenance,” while DNV GL senior principal engineer (environmental protection) Martin Olofsson said that the class society was collecting data on BWMSs from annual surveys on behalf of flag states. But based on six months of operational data since IMO’s Ballast Water Management

• Read IACS UR M74 via http://bit.ly/UR-M74

Martin Olofsson (DNV GL): “We cannot make any conclusions that suggest BWMSs do not work” (credit: DNV GL)

Ballast Water Treatment Technology 2018

46 | CLASS SOCIETIES

comprehensive data.” Invited to comment on the delayed compliance schedule agreed by the IMO Marine Environment Protection Committee in July last year (MEPC 71), all three societies stressed their impartiality on regulatory matters. But ClassNK observed that the amended timetable “grants shipowners an additional two years to prepare themselves,” and predicted a large number of retrofits from then onwards. ClassNK’s role in that will be “to support shipowners focusing on the operational and installation aspects of the BWMS to ensure successful implementation and compliance with the

regulations,” its feedback said. Despite the delay, there has been no let-up in demand for system approvals, according to Lloyd’s Register. “The demand for installation is proportional to the newbuild market,” it commented, reflecting the convention’s requirement that newbuldings must be equipped with systems. More important than the MEPC-agreed delay is the impact of the many decisions during 2017 to bring forward renewal dates of ships’ International Oil Pollution Prevention (IOPP) certificates, to which installation dates in the BWMC are linked, said Mr Olofsson. That will create a retrofit bubble in 2022, he

suggested: about half of DNV GL’s classed vessels due to fit a BWMS have a due date that year, he said, which amounts to about 2,500 vessels. “If the situation is similar for other classification societies, we may see 10,000 vessels due for a retrofit in 2022,” he said. ClassNK also referred to postponements to IOPP certificate renewals, predicting continuing renewal surveys up to September 2019 as a result. Elsewhere in this publication, shipowners are reported as being concerned about ballast water management training, and class societies are providing some support to them. Lloyd’s Register, for example, offers

ABS survey finds only 57% of BWMSs are operational When class society ABS published the findings of a small survey of shipowners last August, it revealed how few ballast water management systems (BWMSs) were working properly. Although it was based on the experience of just 27 owners that had attended an ABS workshop in April, the size of their fleets meant that ABS was able to aggregate information on 220 BWMSs. It found that just 57% of these systems were operated or were considered operational on demand. “The remaining [43% of] systems were either inoperable or considered problematic,” its report said. No systems were mentioned by name, although treatment technologies were mentioned, which subsequently prompted feedback from some manufacturers using technologies that had not performed well in ABS’ analysis, ABS senior engineer (advisory services) Evon Li told BWTT. But from

its shipowner clients, the most common feedback it receives confirms that they have concerns about BWMS installations, especially “lack of technical support from vendors, lack of training materials or training

Evon Li (ABS): ABS clients are concerned about a lack of support from BWMS vendors (credit: ABS)

Ballast Water Treatment Technology 2018

programmes for the crew, delayed delivery of the spare parts and delay in after-sales service delivery from the BWMS vendor,” Ms Li said. She also warned of possible changes in US Coast Guard (USCG) policy that may introduce new challenges in aligning compliance between US and IMO regulations. “While IMO has agreed to some limited delays in entry into force of the Ballast Water Management Convention (BWMC), US Coast Guard (USCG) policy is evolving from implementation of its discharge requirements to enforcement.” To help clients understand their options and obligations for compliance with IMO and USCG regulations, since 2015 ABS has offered a BWMS Technology Evaluation service. This covers pre-selection or shortlisting of suitable BWMS and support for requesting USCG extensions. • Read ABS’ analysis via http://bit.ly/BWTT-ABSReport

a one-day ballast water management awareness training course, which “provides delegates with a sense of the issues and offers a practical approach along with sharing LR’s operational experience.” ClassNK arranges technical seminars and training for interested parties. DNV GL provides general courses and seminars. But it also answers questions every day from its clients, via its DATE (Direct Access to Technical Experts) service. Ballast water management questions relate to “everything from compliance dates for a particular vessel, to BW exchange areas, to procedures in the BWM Plan,” Mr Olofsson said.

ClassNK makes new rules for BWMS work ClassNK has released a new set of technical rules and guidance for shipowners covering BWMS installations. The revised rules “draw upon the knowledge of ClassNK’s in-house experts, incorporate guidance from the International Association of Classification Societies and satisfy Japanese domestic law,” the society told BWTT. It also said that its 3D laser scanning technology, Peerless, could be useful in BWMS installation planning. It “offers shipowners the opportunity to assess how to retrofit BWMS on their ships quickly,” it said. It avoids time-consuming manual work by taking point data from 3D scanners and converting it into 3D models within one or two days. “These procedures were previously handled manually, taking 10 to 14 days,” the class society said. BWTT

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48 | SYSTEM SELECTION

ONLINE TOOL REVEALS UNEXPECTED SELECTION PRIORITIES COMMERCIAL, NOT TECHNICAL, FACTORS DICTATE MOST BALLAST SYSTEM PURCHASE DECISIONS, CONSULTANT UNIBALLAST HAS FOUND

hipowners choose their ballast water management system (BWMS) based more on commercial factors than on technical considerations, according to the Dutch consultant UniBallast. It specialises in providing advice on ballast water management systems (BWMSs) for seagoing vessels and, in 2016, launched an online tool to help shipowners select suitable systems for their ships. Using the experience and feedback it has gained from reviewing how the tool has been used, together with discussions with shipowners as part of its wider consultancy services, UniBallast owner and director Fulko Roos prepared an exclusive overview for BWTT in which he considers the implications of the decisions shipowners are making. UniBallast’s finding that commercial considerations take precedence came as a surprise because its tool was designed to help ship operators select from available treatment systems based on various parameters, such as unit size, working method and typeapproval status. This would be in line with decisions on other parts of a ship’s equipment package and agreements about its propulsion train, so making decisions on non-technical grounds “strongly limits the flexibility of owners and operators regarding BWMS selection,” UniBallast’s report said. When shipowners do start with technology in mind, UniBallast has noticed that they are very much focused on a specific type of treatment system, such as UV or chemical, or on a specific system maker. “We came across this when doing some feasibility studies and basic and detailed engineering for retrofits,” Mr Roos said. At the time UniBallast became involved in these early studies or in the later engineering aspects of the treatment system, “most of the time the selection had already been made.” Unfortunately, in UniBallast’s view, “the shipowner had not always selected the system that fitted the type of ship and its operational profile best,” its report said. “This reduces much-soughtafter flexibility,” it added, and as if to underline its finding about commercial priorities, it remarked that representatives in shipowners’ technical departments confirmed this trend.

IMPACT OF DELAY

A 3D installation model from a feasibility study for a 13,000 TEU container ship (credit: UniBallast)

Ballast Water Treatment Technology 2018

When IMO’s Marine Environment Protection Committee agreed to delay installation dates for BWMSs at its 71st meeting in July 2017, manufacturers immediately noticed a setback because of the postponement. But this has had two contrasting impacts on their business, UniBallast believes. On one hand, it is an unfortunate event, because some BWMS makers will leave the market, leaving less choice for vessel owners. But on the other hand, it buys extra time for existing makers to improve their systems further. UniBallast reported seeing this trend clearly from its database updates, recording that some types of BWMSs were revoked at some point and others modified to meet market demands and regulations. Some makers were, for example, able to introduce systems that could reduce the holding time to zero, while others made their systems much more compact or improved on the maintenance space required. As a result of these updates, “we are currently working on an updated version,” the report said in late February. Those updates also revealed that its online tool has proved valuable for BWMS makers, as well as the owners and operators it was designed for. “In general, they seemed very pleased with the selection tool,” its report said. “For some reason we did not expect this.”

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SYSTEM SELECTION | 49

Overall, “we are positive about the future,” UniBallast’s report said. “Postponement does not mean cancellation of the implementation of the convention and ballast water treatment is a way to improve the quality of our oceans: something we should all be concerned about.” Mr Roos was pleased to see increasing numbers of manufacturers applying for US Coast Guard type-approval. UniBallast welcomed renewed interest in the concept of in-port treatment facilities around the world. This would help address what the consultant views as a significant concern for shipowners, and would offer them flexibility in case systems break down or additional treatment capacity is required. UniBallast is planning to develop an additional selection tool that would detail in-port treatment systems and their locations, providing an overview of treatment system types, connection details and flow capacities. In support of such treatment options, “we have a complete concept ready for this which we are continuously discussing with various ports to optimise and fit to meet existing port-related rules and regulations,” its paper said. That concept is its IACS-type approved Universal Ballastwater Port Connector. If adopted, it would allow ballast water to be discharged to any treatment facility, such as a portable container with a built-in BWMS. “It would be even better if this could lead to an international standard,” its paper said. In an effort to achieve that aim, UniBallast has joined the ISO 23055 Expert Working Group that is developing standards for an International Ballast Water Transfer Connection Flange, in accordance with the IMO Guidelines for Ballast Water Reception Facilities G5.

UniBallast has developed a Universal Ballastwater Port Connector that would allow ballast water to be discharged to external treatment systems (credit: UniBallast)

How to select a ballast water management system Shipowners may not be considering all the options available to them when selecting a ballast water management system, suggested the Dutch consultant UniBallast in an exclusive report prepared for BWTT (see main article). There are various methods of treating ballast water and makers will, of course, recommend their own systems, its report notes. But shipowners and operators should take the first step by making a feasibility study that at least takes into account their ships’ operational profile, current ballast water capacity, space requirements and level of technical knowledge within the company, UniBallast’s report urged. This type of study should compare different technologies and take into account all

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disciplines involved in the installation, and give owners figures and clear conclusions about the pros and cons of each analysed system. Their operation profiles, for example, will dictate whether an in-line or in-tank treatment system would be the best fit and UniBallast plans to add this selection criterion to a later version of its online system selection tool. For example, based on a ship’s operational profile or sailing areas, some manufacturers reduce their system’s treatment rate capacity (TRC) by up to 10% of the standard specification in low-clarity water, which may increase ballast operation time, making those systems unsuitable for high-stress port operations. On the other hand, if ballasting or de-ballasting time is not an issue for an owner, selecting

a unit with a small TRC could save equipment and installation costs. Another operational factor is whether a US Coast Guard type-approved unit is needed. If so, at the moment that reduces the available technologies and manufacturers drastically, UniBallast’s report noted, so this selection criterion should be based on a ‘must-have’ and not just a ‘nice-to-have’ requirement, it advised. Containerised systems should also be considered in some situations, such as for barges. For example, some barges have a ballast system installed, while others do not. For those that do, this will be one of the key drivers to select on onboard system – either in-line or in-tank – or a containerised solution, and “we really did

expect to give much more independent advice” on these considerations, UniBallast’s paper said. This possibility is another feature that UniBallast plans to add to its selection tool, so that it can indicate when an approved containerised version of a BWMS is available, approved and can operate under T0conditions, which allow zero holding time. Some data that would be helpful in choosing a BWMS is not readily available from makers or their websites. For example, said UniBallast, downtime figures, ease of operation and maintenance cost per unit. These depend on how the system is used, the maintenance performed by the crew on board and other variables, “making it a subjective figure difficult to quantify,” UniBallast said. BWTT

Ballast Water Treatment Technology 2018

50 | SYSTEM SELECTION

CHOOSING AND USING A BWMS INSTALLATION FROM SELECTING TO OPERATING A BWMS, SHIPOWNERS NEED TO UNDERSTAND THE TECHNOLOGY AND THE REGULATIONS, SAY PENELOPE COOKE AND CONAN O’DRISCOLL OF BROOKES BELL*

allast water management systems (BWMSs) already on the market treat the water using chemicals known as active substances (such as chlorination, oxidation and biocides), or physical processes (such as filtration, UV, heat and electrolysis) or a combination of both. Provided the BWMS meets or exceeds the D-2 performance standard of IMO’s Ballast Water Management Convention (BWMC), either treatment process is acceptable because the performance standards for IMO and US Coast Guard (USCG) are the same. Where differences occur is in equipment testing and verification protocols: IMO guidelines do not require independent testing, whereas the USCG specifies mandatory type-approval testing that is independent from manufacturers. Some owners of existing vessels have chosen to decouple their IOPP renewal survey from the Harmonised System of Survey and Certification (HSSC), taking advantage of the requirement to comply with the BWMC only by the first IOPP renewal survey after 8 September 2019. As a result, BWMS installation dates could be up to six years from now, meaning the age of a vessel – and the effect on its value such a system would have – may need to be taken into account. Typical planning and preengineering times are advertised at between six months and one year, hence retrofitting BWMSs on existing vessels is likely to be the predominant focus for the foreseeable future. A BWMS includes not only the ballast water treatment equipment, but also its associated control equipment, manufacturer-specified piping arrangements, control and monitoring equipment, and sampling facilities. An understanding of the functionality and usability of BWMSs may be valuable in deciding which one is selected and owners would do well to consider the following when choosing: • Technology: Is it proven to be reliable? Are the processes used robust?

Ballast Water Treatment Technology 2018

Dr Penelope Cooke and Conan O’Driscoll (Brookes Bell): Understanding the functionality and usability of BWMSs will determine which one is selected (credit: Brookes Bell)

• Size: Where will it fit? Can it be easily maintained? • Availability: Consider availability of spare parts and service technicians. • Vessel trading pattern: What types of water will it operate in? Will the water’s turbidity affect the system’s operation? • Availability of system consumables: These will need to be ordered, and in sufficient quantity for voyages where such consumables are not available. • Crew training and crew workload: Despite claims that some systems require ‘minimal crew interaction,’ we believe crew must maintain responsibility for checking the system regularly during a voyage, specifically during ballast water exchange. • Power consumption: Is an additional generator required? • Ballast tank coatings: Will the chemicals affect tank coatings? • Futureproofing: Some systems will become obsolete, so consideration should be given to their interchangeability. The BWMC details three ballast water exchange methods – sequential, flowthrough and dilution – that deal not only with ballast water but with accumulated sediment in the tanks, which must also

be flushed out. All qualifying vessels will ultimately need a compliant ballast water management plan (BWMP) and a ballast water management certificate or statement of compliance. The BWMP should include the duties of key shipboard personnel undertaking ballast water tasks, all of whom should be fully conversant with the system’s safety aspects. To reduce potential compliance issues, ballast water records must be accurately maintained, and the BWMP should be able to be clearly demonstrated on board during any inspections. Part of the duties associated with operating any BWMS relate to whether it uses chemicals, or ‘active substances,’ given their risk to the environment, human health, property or resources. Active substances are intended to be toxic, so appropriate safety controls on their storage and handling are required. It is prohibited to discharge such chemicals into the sea. BWTT *Dr Penelope Cooke is an associate and consulting scientist and Conan O’Driscoll is an associate and marine engineer, both at the marine technical and surveying consultancy Brookes Bell Group

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SHIPYARDS | 53

CAN SHIPYARDS RISE TO THE RETROFIT RUSH? Shipyards face difficulties because of the number of BWMS retrofits that will be needed

hipbuilders “are the least familiarised stakeholders” in the expected rush to fit ballast water management systems (BWMSs) to meet IMO’s extended deadline, according to one leading shipyard executive. Dave Iwamoto, a senior executive at shipbuilder Japan Marine United and a council member of the Active Shipbuilding Experts’ Federation (ASEF), which brings together 10 Asian shipbuilding groups, was speaking in September 2017 at the International BWM Technology and Standardization Forum organised by the Shipbuilding Information Center of China (SICC) and BIMCO. He told delegates that because many shipowners have delayed installing BWMSs, “not many shipyards have built up practical experience.” In addition, not all of them can handle the range of services

DAVE IWAMOTO (ASEF): “Not many shipyards have built up practical experience” (credit: SICC)

needed to retrofit a BWMS, he suggested as he outlined a catalogue of potential difficulties that could be avoided with proper planning. Mr Iwamoto cautioned that this planning should begin about a year before installation is scheduled “to have a comfortable dedicated working plan.” He advised

SEMBCORP FITTED 12 BWMS IN 2017 Singapore yard Sembcorp has carried out ballast water management system (BWMS) retrofits as part of its Green Technology Retrofit (GTR) programme. Starting in February 2017, it fitted BWMSs on all three ASEAN Cableship vessels and in November that year it fitted a UV BWMS on the seismic vessel Ramform Sovereign. Further installations brought the yard’s total number of ballast water-related projects during 2017 to 12.

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against combining the work with a scheduled drydocking, saying that the work should not be treated as “an accessory job” that is added onto a drydocking repair list. Due to the number of parties involved in a BWMS project – such as designers, suppliers, fitters, and flag-state representatives – there can be a lot of managers but no leader, Mr Iwamoto explained. This can be avoided if discussions are held “so that necessary procedural disciplines are in place from the very beginning to ensure effective progress of the work.” He also stressed the need for care when handling BWMS components. They are more delicate than equipment that shipbuilders normally handle, he said. “Particular care is needed for associated instrumentation, since any damage to this may not allow final commissioning work when time may be running out.” Even before the equipment arrives at a yard, there may be

delays caused by import rules. “If the work is done in one country with a BWMS purchased from another, customs regulations cannot be disregarded,” Mr Iwamoto said. And there will be no compensation for delays “caused by regulatory requirements beyond any commercial party’s responsibility.” With all these potential difficulties, Mr Iwamoto said that a retrofit is more complex than a newbuilding installation. For example, details of the existing piping arrangements may not appear on the drawings and whether the complete installation works properly cannot be confirmed until it has been tested, by which point “most of the work is already done and substantial rectifications may not be easy.” If a BWMS does not perform properly, it may be difficult to identify the cause. It might be unsuitable equipment or design, or poor workmanship with responsibility lying with the shipowner, engineering company, equipment maker, shipyard or contractor. “We need to clearly understand that this is a very complicated thing,” Mr Iwamoto said.

The yard can offer its own unique BWMS, the Semb-Eco L-UV, which was developed jointly with Ecospec. It uses LED-UV irradiation and ultra low frequency electromagnetic waves in a combination that Ecospec reports “produces a highly efficient nonchemical treatment system that consumes very low power.” Sembcorp has co-operation agreements with six other BWMS makers covering a range of technologies. They include the UK’s Coldharbour Marine, which offers a gas lift diffusion system, and De Nora of Italy, whose Balpure BWMS uses electrolysis and electrochlorination. BWTT

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54 | CASE STUDY

DIY INSTALLATION SAVED MONEY FOR SEATRUCK BY USING ITS OWN CREW AND LOCAL CONTRACTORS, SEATRUCK FOUND AN ECONOMICAL SOLUTION TO INSTALLATION COSTS

itting a ballast water management system (BWMS) using ship staff and selected subcontractors “is a lot cheaper” than other installation options, according to Ben Coppack, fleet director at Seatruck Ferries. For an average of about £175,000 (US$246,000) per ship, the Irish Sea operator installed an Optimarin Ballast System (OBS) on each of five roro freight ferries. Installations began in November 2016 onboard the 5,300 dwt Seatruck Progress and continued until September 2017. They are part of Seatruck’s fleet of 10 ships, which are grouped into three classes: 4,935 dwt, 5,193 dwt and 5,300 dwt. They serve Heysham and Liverpool on the UK mainland, Warren Point in Northern Ireland and Dublin in Ireland. It is that service to Dublin – an international destination – that made these installations necessary on the specific ships that operate that route although, at the time of writing in late March, Ireland has not yet ratified IMO’s Ballast Water Management Convention (BWMC). Work was shared between the ships’ onboard crew and shore-based contractors while the ships stayed in service. But Mr Coppack said this approach was only possible because their trading pattern puts them in the same ports every day, allowing shore contractors to “come on board, measure up and go ashore.”

Seatruck’s crew installed Optimarin systems on its vessels (credit: Optimarin)

Ballast Water Treatment Technology 2018

For example, the crew carried out initial pipework – cutting it to fit and tacking it together on board – before it was taken ashore for welding and galvanising. It was then put back on board and fixed in place by the crew. The OBS was also assembled in situ by the onboard staff. For four of the ships, the system was delivered as a set of components – such as the filter, UV tubes, flow meters and backflushing pump, Mr Coppack listed – and the crew used Optimarin’s manuals to assemble them. For the other ship, Seatruck bought a skidmounted system that Optimarin had available from stock, although it needed to be broken down to get it into the vessel. Installation was very straightforward, Mr Coppack said. “It’s just filters, pipes and pumps,” he pointed out, with just three layout arrangements needed, one for each of the three classes of ship. Nonetheless, Optimarin chief executive Tore Andersen was impressed by Seatruck’s achievement. “This is the first time I’ve heard of a shipowner installing this number of systems itself while its vessels are in service,” he said. But that is only half the story, Mr Coppack said. As well as pipes, pumps and other components, there is also the electrical side of the installation. and he paid tribute to the SeaKing Group, which provided an electrical technician to travel with the ship to connect all the components. Wärtsilä SAM Electronics provided the control systems. Mr Coppack chose a UV treatment system because of the limited space available and because it did not use any chemicals, which would add to its operating cost. The ships do not load much ballast compared with large oceangoing ships – only about 100150 m3. But they do this twice each day, which is much more often than other ship types, so the total volume, and thus the amount of chemical that would be needed for some systems, is large. The units are rated at around 330 m3/hr and their power requirements were not excessive, Mr Coppack said. No upgrades to the ships’ generators were needed and using the BWMS has not had any impact on the power available to other consumers. “We have not had to modify our operation in any way,” he said. Optimarin was chosen as a supplier because it has a lot of experience and because its Norway base was relatively local, compared with other potential suppliers, Mr Coppack told BWTT. In an Optimarin statement in October 2017 to mark the end of the retrofit programme, he acknowledged Optimarin’s systems and service, reporting that the supplier had responded quickly to queries. “We’re very pleased we took this approach,” he said at that time, “ensuring port state compliance and ballast water treatment reliability ahead of regulatory demands.” BWTT

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CASE STUDY | 55

CHANGING MINDS CAN BE A CHALLENGE

efore installing a ballast water management system (BWMS) an owner must decide which one to use. After 10 years of seeing an endless stream of in-line BWMSs being presented, technical departments no longer have questions about the ballast water management rules or if BWMSs will even be required. They know the metrics they are looking for. So introducing a completely different type of BWMS can be a challenge in itself – yet an in-tank BWMS offers many advantages for many vessels. Its metrics are very different from other systems, though. The factors they are familiar with are removed from the equation. Total ballast volume and time are the new metrics, and time can be on a sliding scale – more time can allow smaller, cheaper, equipment. To answer the question “how much time is needed?” with “it depends” does not sound like a great reply. But an in-tank system can open the door to a new way of looking at ballast water management. Potentially smaller equipment operating at sea for a longer time means no impact on port activities and increased confidence in technical and biological compliance. One owner that quickly saw the opportunity is CMB/Bocimar. Talking to Envirocleanse about its patented inTank BWMS, the potential advantages were clear to see, particularly

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FOR AN INDUSTRY FAMILIAR WITH IN-LINE SYSTEMS, PERSUADING SHIPOWNERS TO CONSIDER AN ALTERNATIVE IS A HURDLE, ENVIROCLEANSE REPORTS

EC generator assembly

circulation return Bulk chemical assembly Nozzle supply

Seachest Dosing module

A schematic diagram of an Envirocleanse inTank system (credit: Envirocleanse)

for Bocimar’s fleet of larger vessels. In late 2017, after an initial engineering feasibility was completed, a pilot study agreement was signed to install a small inTank BWMS aboard the Capesize bulk carrier Mineral New York. The first step, completed during Q1 2018, was to install the hardware for the unit. While the operating differences of an in-tank BWMS minimise the impact on vessel operations, many of the installation challenges are similar to those of an in-line system. Its lack of filters certainly helps, as does the relatively small

size of the three skids – an electrochlorination cell with power supplies, a dosing unit with circulation pump and a De-Chlor neutralising unit. It was decided to install this equipment in the machinery space but, with no filters required, it could be fitted in a deckhouse. A containerised installation is also possible. Despite the skids’ relatively small footprints, getting each to its intended location required careful planning and some short-term relocation of other equipment in their paths. Moving this equipment, just temporarily, was a particular challenge in this installation

because it was being completed at sea. The largest hurdle for an inTank installation is its circulation piping. Some stripping lines could be used and installation of some prefabricated sections was completed. Fitters and welders are generally very good at relatively straight runs of small pipe, but it was an achievement to complete this at sea, including to the cargo ballast hold. Differences between in-line and in-tank solutions disappear when it comes to integrating the new BWMS’s control with the existing ballast water control system. For both types, integration with the ballast control system should lead to ballast treatment control that is as seamless as possible. For newbuild installations this can be engineered into the system from the beginning, but aboard Mineral New York we were faced with an older control system. The Envirocleanse team, which included the marine engineer Glosten with help from CMB/ Bocimar, developed a panel that allows the vessel to switch into treatment control at will. At the time of writing in early April, work is just beginning on the study – but so far inTank has successfully mixed a 25,000 m3 cargo ballast hold. We believe this demonstrates the efficiency of its patented solid-state mixing nozzles and answers questions about scaling the system. BWTT

Ballast Water Treatment Technology 2018

56 | CASE STUDY

MMC Green Tech started with a bang A couple of early seismic newbuilding jobs for MMC Green Technology led to three retrofit projects last year

MC Green Technology is a Norwegian supplier of environmentallyfriendly solutions for the maritime industry. Its parent company, MMC, has more than 25 years of experience making process technology, such as using filters and UV to secure the best environment for salmon on live fish carriers. In 2010, MMC set up a separate company focusing on ballast water management systems (BWMSs) with filters and UV radiation as main components. It was in 2011, even before MMC Green Technology received IMO type-approval for its MMC BWMS, that it secured its first two orders from Sanco Shipping, which was building two high-end seismic vessels at Kleven Myklebust.

Sanco Shipping looks for environmentally-friendly solutions for its fleet and in mid2017 decided to retrofit three of its ships with BWMSs, even though seismic vessels are not considered as ballast-dependent vessels: they generally only need ballast to compensate for fuel consumption. It also has a long tradition of selecting local suppliers, as long as its quality standards are met and the price is competitive. Because the operator already had MMC BWMSs on its two newbuildings and feedback from the crews was positive, it decided to use MMC BWMSs again. First of the trio was Sanco Spirit, which had been in lay-up for about a year when it got a long-term contract with PGS for worldwide operation. Because it was lying alongside only 15 minutes’

An MMC BWMS installed on one of Sanco Shipping’s seismic vessels (credit: MMC Green Technology)

Ballast Water Treatment Technology 2018

drive from the MMC office, Sanco Shipping asked for a turnkey solution, with MMC Green Technology taking care of everything, including mechanical and electric installation, the ballast water management plan and class approval. The total installation was done in about two weeks. The system installed was an MMC BWMS 100 m3/h unit, which has a small footprint, so only cabinets had to be dismounted to make room for it. This has two ballast pumps, each with a separate suction line although, to comply with class requirements, there had to be two bypass valves, one for each pump. All valves on board were manually operated: some had to be changed to be fully automatic, while others needed position feedback sensors. Both inlet and overboard lines had to be fitted with non-return valves, as required by the class society. The ship’s original power source was sufficient to serve the ballast water treatment unit. It just needed new 63A and 32A circuit breakers: as the vessel is mainly equipped with a 690 V electrical network, the MMC BWMS unit had to be prepared to match it. Sanco Spirit has a standard alarm system, so the only requirement was a general alarm given when there is an alarm on the BWMS. As Sanco Spirit is Gibraltarregistered, a statement of acceptance for its MMC

BWMS was needed. The Government of Gibraltar published its Ballast Water Management Convention Guidance (http://bit.ly/ GibBWMC) in September 2016, stating that it will accept type-approval certificates of other contracting administrations on its vessels, provided that the equipment has been developed in line with IMO’s G8 or G9 guidelines. The next ship, Sanco Star, was planned for drydocking in Las Palmas. Since Sanco Spirit was also heading toward Las Palmas, Sanco used it to transport parts for this next installation. It was berthed next to the MMC head office, where all the components were loaded. This installation was performed at Astican Shipyard, but was carried out a little differently: there was less space available so the system was installed as separate components. The last vessel was Sanco Sky, which was fitted with an MMC BWMS 500 m3/h that was installed as separate components. It was a former tanker and had quite complex ballast piping so, in 2016, some of the piping was rebuilt to prepare for the installation. The work was done at Kleven Myklebust yard, 30 minutes’ drive from MMC’s factory. The Sanco Shipping fleet has many US jobs but, until MMC has obtained USCG type-approval for its BWMS, the vessels are relying on the system’s USCG AMS status. Meanwhile, MMC Green Technology is performing landbased tests to apply for USCG type-approval at Norway’s NIVA test centre after appointing DNV GL as its independent laboratory last year. Shipboard testing is being done on a bulk carrier trading in northern Europe and the Baltic Sea. As of early March, MMC Green Technology had sold about 120 systems worldwide, of which around 100 had been installed on a range of vessel types. BWTT

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CASE STUDY | 57

A schedule change posed logistics challenges for Techcross When a ship due for a BWMS retrofit changed its operating schedule, the work had to be done at an outer-port anchorage

echcross has installed about 1,000 ballast water management systems (BWMSs) on newbuildings and in retrofit projects. Those retrofits ranged in size from 150 m3/hr up to 3,000 m3/hr and the manufacturer’s preference is to fit them during a drydocking period or, if that is not possible, during a voyage. So when it proposed that a retrofit installation on a 4,800 dwt tanker be carried out during a voyage, it was already its less-preferred option. But then the ship’s operating schedule was suddenly changed, making even that impossible. Instead, the work was conducted in the outer port of Yeosu in South Korea in August 2017, so it became even more important to finish the installation promptly to suit the vessel’s schedule. This change of plan meant that the installers had to overcome the difficulties of an unstable working environment with no allowance given for the change from the original time frame. Techcross has developed its Electro-Cleen System (ECS) to be simple, with no filter. A simplified system is crucial when retrofitting a BWMS on ships with space restrictions. Its task for this project was to fit one of its ECS300B BWMSs, which uses direct electrolysis technology. As a first step, Techcross carried out an onboard survey using a 3D scanner. Its dedicated retrofitting team finished the installation’s design work within two weeks, based on the survey result. Once the equipment had been manufactured and supplied, Techcross completed its installation in three consecutive stages. First, without the luxury of a drydock, installation work in the outer port needed a separate tug boat with a crane and a means to transport and lift supplies from the port’s berths to the vessel, which made the task more complicated. Second, the installers found that the ECS’s total residual oxidant sampling pipe and neutralising-agent dosing pipe had ended up partially blocking the vessel passageway. To deal with that situation, they immediately modified the design drawings and reinstalled the lines in an effort to resolve the inconvenience. Finally, they made additional modifications to improve the efficiency of installation work by proactively managing their working time flexibly to meet the ship’s operating schedule. For example, in order to reduce the extra work that can only be identified once a job has started, they quickly removed fittings that needed adjusting so that the main welding work could continue. Only highly specialised suppliers can draw on their own experience and expertise in this way, Techcross said, pointing out that it has engineering designs and performance records of onboard surveys from more than 200 vessels.

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Installation work in progress on the 4,800 dwt tanker (credit: Techcross)

Its team of engineers and designers has developed a variety of retrofitting programmes that can be optimised to each vessel’s particular installation environment. Another crucial factor is the supplier’s sustainability. Aftersales services will become increasingly important as the number of BWMS deliveries increase. From the perspective of long-term operation, shipowners have to take a closer look at how sustainable the suppliers it has in mind for a job will be in the future. BWMSs require ongoing inspection and maintenance of equipment and accessories, such as spare parts. On top of that, support will be needed from the supplier, both periodically and irregularly after installation. So if the supplier withdraws from the market for any reason, shipowners that have selected that supplier’s system are very likely to find it difficult to obtain these long-term services. Because of this, shipowners should pay great attention to how big and important the supplier’s BWMS business is when compared with its other activities and how many global partners it has that can provide immediate services. BWTT

Ballast Water Treatment Technology 2018

58 | FINANCE

Banks begin to back ballast systems More financing options for BWMS installations are becoming available as banks and lease-finance providers enter the market

hen last year’s issue of BWTT was published, financing options for ballast water management systems (BWMSs) were limited. ‘Don’t bank on the bank’ was the message at that time, based on remarks by a financial consultant who had spoken to a few banks about their views on funding BWMS investments and found none that were “even thinking of doing it.” This year, the situation is a little more positive. Within days of BWTT’s publication last year, Dutch bank ABN Amro concluded what it said was the world’s first financing for BWMS installations on several vessels for a Danish client, Celsius Shipping. In a statement in early May 2017, ABN Amro associate director, transportation, for north Europe Bart van Veen described the loan as “a creative financing solution” that matched the bank’s commitment to support sustainable shipping. Little information was available at the time, but the bank provided more insights about its backing for ballast water management projects during a September 2017 seminar organised by the Royal Association of Netherlands Shipowners (KVNR) to explore financing for sustainable shipping. The bank is a founder-member of the Sustainable Shipping Initiative and has developed its own “vision for a sustainable shipping industry in 2040,” its presentation reported. Financing BWMSs in both construction and operational projects forms part of that strategy, delegates heard. Another bank to indicate that it was considering the merits of bank financing for BWMS projects at that seminar was ING. In February 2018 it signed an agreement with the European Investment

Ballast Water Treatment Technology 2018

ABN Amro announced ‘the world’s first financing for BWMS installations’ on its website last May

Bank (EIB) to support green investments for the European shipping market worth €300M (US$370M), with each partner contributing half that figure over a period of three years. According to a statement issued by the EIB to mark the agreement, the funds will be used “for projects with

Tom Perlich (Ecochlor): “Financial institutions will become more willing to provide support” (credit: Ecochlor)

a green innovation element covering the construction of new vessels or retrofitting of existing vessels.” Export credit agencies can be valuable partners in securing finance. Export Credit Norway has a particular focus on the maritime sector and has created a dedicated team to offer finance to international vessel owners that purchase retrofit equipment from Norwegian suppliers, which include BWMS manufacturers. Its director of lending, ocean industries, Olav Einar Rygg, told BWTT that there are three people in the team who proactively look for projects to support with a funding arrangement developed specifically for this sector. Mr Rygg described it as a framework loan agreement “where we add up all Norwegian retrofit supplies to a shipowner and make annual disbursements [covering] the whole retrofit programme, typically during a period of three to five years.” Most equipment suppliers contacted by BWTT mentioned export credit schemes when asked about financing options, as has been the case in previous editions of

www.ballastwatermanagement.co.uk

FINANCE | 59

this guide. For example, the chief executive of Danish BWMS maker Bawat, Kim Diederichsen, said that the company could offer financial support through the Danish Export Credit Agency. But he added that, “as the Bawat BWMS is probably the most sustainable BWMS on the market, the Danish Green Investment Fund also offers funding to Danish customers.” A new topic that cropped up in BWTT’s research this year was lease financing. Hyde Marine is one manufacturer exploring this source of funding. Senior market manager Mark Riggio told BWTT that the company is “exploring a partnership with a leasing company” that he said will “eliminate the capital costs associated with system installation.” At Wärtsilä, BWMS sales director Craig Patrick made a similar comment, reporting that “we continue to explore” an equipment leasing model. This would allow owners “effectively to lease and pay for the BWMS over a term period,” he explained, which could extend to a payment-pertreatment model in the future. Ecochlor chief executive Tom Perlich also mentioned lease finance as a possible future option. Although the company does not currently offer financial support for installations, “we have had some brief discussions with several lenders and leasing companies, but we are still researching opportunities,” he said. Manufacturers were also more optimistic about support from financial institutions for BWMS projects. For example, Coldharbour chief executive Andrew Marshall reported that financial institutions are more willing to fund ballast treatment than they were a year ago. Mr Perlich suggested a reason for that. “With the BWMS market opening up, financial institutions will become more willing to provide support to shipowners for installations,” he said.

Leasing “could be less expensive than purchasing” Complying with environmental regulations “presents a difficult challenge as shipowners are cash strapped and the industry is still recovering from the last economic downturn,” said Thomas Lillig, principal of LTK Maritime Consultancies. He believes that lease financing offers a solution to this dilemma and said that, once its tax advantages are taken into account, “lease financing could often be less expensive than purchasing.” He has been appointed as the lead agent for a Texas-based lease-finance company, FloLease. Mr Lillig told BWTT that it can be very hard for shipowners, in particular smaller ones, to find lending options with suitable conditions and restrictions. “Quite often, financial lending options require the equipment to originate from the same country as the lending,” he said. But leasing removes the heavy upfront equipment costs and the FloLease scheme allows shipowners to choose a suitable ballast water management system (BWMS) independently of the technology’s country of origin, he said. A short-term lease of 36-60 months can help older vessels avoid premature scrapping and, as there is no upfront capital investment, lease payments could be considered operational expenses, he said. Long-term leases of 60-120 months are also available, based on a lease-to-own model. This could be structured so that the owner pays the equipment’s fair market value at the end of the lease or just US$1 to fully own the equipment. This arrangement treats the lessee as the owner of the asset or lease, which means that the lease is considered a loan and interest payments are considered operating

What does a BWMS installation cost? There is little definite public information about what a ballast water management installation costs, but two tanker operators have published figures that provide some perspective on the cash involved. In July, tanker operator Euronav presented some figures that included an estimate of US$1.8M per ship to fit a system (http://bit.ly/BWTT-Euronav, page

www.ballastwatermanagement.co.uk

25). A month earlier, the Kuwait Oil Tanker Co (KOTC) had put some figures on its website (http://bit.ly/BWTT-KOTC) that made public the precise results of an invitation to tender for ballast water treatment systems. KOTC’s published figure, together with earlier information from Alfa Laval, indicated a cost of U$348,550 per unit

Tomas Lillig (FloLease): “Lease financing could often be less expensive than purchasing”

expenses. The asset can then be reported on the balance sheet and be depreciated, he said. There are also operating benefits from this arrangement. The scheme that Mr Lillig promotes creates a partnership between shipowner, manufacturer and FloLease, he said. The owner agrees to operate and maintain the equipment following the vendor’s recommendations and complying with regulations, while the vendor supports the equipment through the term of the lease and resolves any problems with it. Meanwhile, FloLease will monitor the system 24/7 via its proprietary satellite data hub, which transfers all system inconsistencies, alerts and alarms to a monitoring centre and instantly reports any issues to the owner and manufacturer.

and US$713,000 per ship, excluding commissioning. Alfa Laval’s was the lowest quote. KOTC say how many ships or systems this tender was for but Alfa Laval had earlier issued a statement saying it was going to supply 45 of its PureBallast treatment systems to a “Middle East-based tanker operator,” and Alfa Laval’s vice president responsible for its PureBallast project Anders Lindmark confirmed to BWTT that the KOTC tender was the contract its release referred to. BWTT

Ballast Water Treatment Technology 2018

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OPINION | 61

OWNERS SHOULD FOCUS ON THEIR PRIORITIES AND PLANS

IMCO’s members around the world include more than 800 shipowners that operate well over half of the world’s deadweight tonnage. BIMCO members are without doubt a large representative sample when it comes to experience using ballast water management systems (BWMSs). They worry that they will be on their own to deal with the obligations and responsibilities that BWMSs bring because the yards that fit them accept little responsibility for them. On its own, that is a big and continuing concern but, on top of that, the Ballast Water Management Convention itself is not easy to understand. Much of the talk since the convention was adopted in 2004 has been about equipment. One concern is that many shipowners that did the right thing and spent a lot of money on equipment now realise that it does not work very well. Going forward, it is actually the US that will dictate what is installed. Systems must be suitable for global operations, and a US Coast Guard (USCG) type-approval means that a system should also be able to fulfil IMO’s revised G8 guidelines. We are not sure whether the opposite applies. If you know for sure that a ship will never go to the US at any time in its life, then G8 is good enough – otherwise, you have to think about this carefully. But what matters most to owners and operators are their obligations under the convention, especially since

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Shipowners are worried about their obligations as they set their ballast management priorities, writes BIMCO deputy secretary general Lars Robert Pedersen

certain jurisdictions have statutory requirements that go beyond the BWMC – which the convention allows them to have. My advice to owners is that you need to have a plan for what you do on board your ship. As well as doing things right, you must do them according to your plan so your plan has to be right. For example, it has to cover how you will comply with the various discharge standards but also – importantly – set out what to do if you do not comply. As well as covering ideal conditions, you must also cover all the variants and unknowns, and have some contingency plans. Keep the plan simple and flexible. Make sure it is read, understood and implemented because one of the primary compliance issues we will face will stem from crews not following the plan. The plan must cover maintenance, servicing and record-keeping, using the ballast-water record book. Designate an officer to oversee the plan, but

remember that the officer is also part of your plan. If he or she is not sure of his or her responsibilities, that is a deficiency that could trigger an in-depth port state control investigation into non-compliance. Make sure your plan is relevant. Some ships have equipment capable of meeting the BWMC’s D-2 treatment performance standard, and their plans state that they must achieve that simply because they have suitable equipment. But being so rigid may not be very smart from a compliance point of view if those ships do not yet need to comply with D-2 – some may have until 2024 before that is necessary. Why force yourself into D-2 compliance, using equipment that may not work very well, when you have the option of meeting D-1 exchange standard instead? Shipowners that specify D-2 in their plan should update it to also include D-1, and take the opportunity to get experience using the BWMS before it becomes essential. Lastly, I will mention training because crew competency is vital. On board, the ballast water officer must understand what it means to implement the plan. Get the manufacturers involved in training the crew, and make sure you have effective handover procedures to subsequent crew – otherwise they will be the ones who will get into compliance issues. Ashore, involve the superintendents, because they need to understand that

ballast management involves more than just flicking a switch. Address ballast water compliance topics during officer seminars. Shipowners’ concerns will remain for a long time, but my message is a simple one: we need to know how to comply, and we need to understand the enforcement machine that has been put in place so we can be prepared. BWTT

Lars Robert Pedersen (BIMCO): “What most matters to owners and operators are their obligations under the convention” (credit: BIMCO)

Ballast Water Treatment Technology 2018

62 | OPINION

STRENGTH IN NUMBERS MARK RIGGIO* EXPLAINS WHY AND HOW HE AND OTHERS HAVE GIVEN THE BALLAST SECTOR A UNIFIED VOICE

BEMA’s formational meeting brought together 13 participants with another 25 dialling in (credit: Hyde Marine)

anufacturers and stakeholders in the ballast water management system (BWMS) market took a major step forward by codifying a unified manufacturers association in March. The paramount need for this association arose following the postponement of the implementation dates for IMO’s Ballast Water Management Convention, which was agreed in July 2017 during the Marine Environment Protection Committee’s 71st meeting. After that, a small group of us – all dedicated industry insiders – gathered in New York to draw up the framework of what was to become the Ballastwater Equipment Manufacturers Association (BEMA), which moved from concept to reality at its first official meeting on 9 March. Attendees at that meeting, made up of representatives of equipment manufacturers, stakeholders and component suppliers from all technologies and regions of the world, voted on and adopted a set of draft bylaws and other formation documents, setting the stage for forming of the organisation’s board of directors and electing its first slate of association officers. The idea of forming an association of BWMS manufacturers had been around for many years, and there were a few efforts to get it done to no avail. What makes this time different is the industry’s realisation that we need to have a unified voice in the conversation. BEMA will be that voice. We have set up BEMA as a registered trade association based in the US to provide co-ordinated, technical, non-commercial guidance to both the maritime industry and regulatory agencies that are trying to

Ballast Water Treatment Technology 2018

understand the intricacies of ballast water treatment. BEMA will serve as a key resource for shipowners, designers, testing equipment suppliers and regulators to discuss openly how ballast water treatment systems work, how they are designed, and what the reasonable expectations of systems are, as they are installed and operated across the world fleet. Another member of our formation committee was Marcie Merksamer of EnviroManagement. She has found it “encouraging to see how enthusiastically the equipment manufacturers have embraced the organisation” and remarked on the “quick and energetic response from suppliers representing all of the major technology

BEMA’S OBJECTIVES BEMA will provide manufacturers and service providers with leadership and a unified voice. To accomplish this mission, we have set some key objectives, which are summarised in the list of points below. • Represent and serve as a central, common voice for ballast water equipment manufacturers. • Promote the application of effective technology in ballast water treatment operations, consistent with applicable regulations, current status of the art and sound engineering practice. • Provide design and operational expertise to balance the numerous

types in the industry and from every region of the world.” It is no exaggeration to describe BEMA as a truly global enterprise. Our initial formation meeting took place in London, during the fifth meeting of IMO’s Pollution Prevention and Response Sub-Committee (PPR5) in February. We initially discussed applying for nongovernmental organisation observer status at IMO this year, but after consultations with both industry and prospective members, our focus turned to ensuring that the association first provides value to the industry. Another of our founders, Ecochlor chief executive Steve Candito, counselled that “there is a lot of value that the association can provide even before we achieve NGO status at IMO.” BEMA held its first official board meeting on 19 April and we will also be scheduling meetings with shipowner associations and industry trade groups to provide unbiased direction and advice about the impending retrofit period, currently scheduled to begin in September 2019. BEMA is already attracting attention and has been approached by ICS, BIMCO and others to discuss important implementation challenges. It is clear that the industry wants to discuss solutions, and we are ready to talk. BWTT • For more information, visit the association’s website at www.BWEMA.org *Mark Riggio is senior market manager for BWMS maker Hyde Marine

perspectives from regulators, shipowner organisations, scientific testing networks and environmental organisations. • Participate at IMO and represent the industry to advance knowledge about the design, manufacture, installation, maintenance and long-term functionality of ballast water treatment systems. • Provide and stimulate authoritative organised research, education and information exchange within the industry and with other industries, government bodies and interested organisations. • Mobilise and finance voluntary, staff and professional expertise to provide the required range of service to members. • To maintain liaison and co-operate with governmental agencies [and] trade and professional associations.

www.ballastwatermanagement.co.uk

OPINION | 63

Inadequate training threatens ballast compliance

raining has, for a long time, been considered persona non grata in the field of ballast water management (BWM). While some people have argued that it will be an important part of the entire BWM compliance process, there has been little in the way of dedicated investment and development – with many considering training as a problem for the future. But with hundreds of ballast water management systems (BWMSs) already installed and (partially) operational, the need for suitable industry training is already here – and the lack of suitable solutions is already apparent. Shipping is about to enter one of its most significant periods of investment in history, and BWM is not the only show in town. With the IMO 2020 sulphur cap coming into force alongside EU Ship Recycling requirements, the industry is collectively being driven towards spending billions of dollars in achieving compliance. While this bill is, to say the least, unpalatable, the amount of money that will shortly be spent is not the only worry. Another is the fact that the compliance solutions currently available make achieving compliance almost impossible. That may be a polarising statement, but it is true. The 2017 study undertaken by classification society ABS found that 43% of installed BWMSs were either inoperable or problematic. Of course, that study cited numerous reasons for this startling statistic – including installation and operational issues, and a lack of after-sales support (a common complaint that we hear around the world). Comprehensive compliance solutions would avoid many of these issues. Impartial and honest advice upfront would avoid badly chosen systems being installed, while thorough engineering analysis could avoid operational issues once installed. Critical analysis during the feasibility study could and should consider the lack of after-sales support from a manufacturer within any recommendations made. But the biggest takeaway from the study, perhaps unsurprisingly, was the lack of crew familiarity and training: “Crew members are constantly on rotation not only on and off the ship but on and off different ships with a variety of ballast water systems. This variety can lead to confusion on operational

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There is far too little investment or commitment to training to meet imminent regulations, warns Chris McMenemy*

procedures and maintenance schedules,” the ABS study noted. After all, without sufficient training, crew members are being thrust onto the front lines of environmental compliance without so much as a ‘cheat sheet’ to go to battle with. Shore-based staff are no different when they are faced with making significant investment and operational decisions. Without training, achieving compliance is as good as impossible. This problem can only grow as the industry progresses through the compliance process over the next six years, with about 30,000 BWMSs to be installed. Even if we assumed each vessel had just 10 crew members requiring immediate training – that will be 300,000 crew. Multiply this over the lifetime of these vessels and the numbers are in the millions! With the solutions out there today, achieving mass compliance is simply not going to happen. There just has not been enough emphasis on the issue of training, despite it being a fundamental part of

Chris McMenemy (Cleanship Solutions): “Without training, achieving compliance is as good as impossible” (credit: Cleanship Solutions)

successfully achieving compliance. The industry must focus on the practical compliance issues that matter now, such as training, not on grandstanding and debating legislative semantics. Owners, operators, crew and staff will all be faced with the reality of achieving compliance – and to help them get there, they require action. The industry needs comprehensive, practical training that is readily available worldwide. Of course, a small number of training packages are available. But large training houses simply turning the handle on their rather impersonal, and often impractical, business models will not help solve the issue of global compliance. We live in a world where access to incredible technology and information is at our fingertips, yet shipping is still heavily reliant on training modules locked to a single PC on board. We expect our frontline crew members to become educated in legislative requirements only when they have time to do so on board. That is not going to cut it in achieving compliance. Crew members want instant access to comprehensive training courses before they join a vessel. And they want courses available not just on a PC, but also on their phones and tablets. They want the chance to join a vessel with a certificate, not with a gaping hole in compliance knowledge. Shore-based staff are no different. They want the chance to become as proficient as possible on compliance subjects, and not be curtailed by licensing issues or node-locked PCs. I make no apology for saying that we have addressed this at Cleanship Solutions. We have launched a training platform dedicated to providing a range of comprehensive environmental compliance themed e-learning courses available at any time from a portable device. Our introductory courses are not only CPDcertified by IMarEST, but also 100% free to enrol and gain certification. Until such time as the industry drops the charades and instead focuses on ensuring owners and operators have practical solutions to achieving compliance, the clear warnings may continue to fall on deaf ears. BWTT *Chris McMenemy is managing director of Cleanship Solutions

Ballast Water Treatment Technology 2018

64 | BEST OF THE WEB

BEST OF THE WEB

ballastwatermanagement.co.uk

Log on to our website to keep track of the latest industry news Testing centre urges less pessimism over ballast treatment

DHI ends land-based tests in Singapore

Reports about the effectiveness of typeapproved ballast water management systems and the rigorousness of their testing have a “pessimistic tone,” said staff at the Golden Bear Research Center in the US in a statement. But there are “shortcomings [in] existing regulations,” the facility’s chief engineer Bill Davidson told BWTT. He was summarising a lengthy response to what he and his colleagues view as a negative reaction in reports of the closure of two testing centres, MERC in the US and DHI in Singapore. “A one-million-fold reduction in anthropogenic ballast water organism transport is cause for celebration, not criticism,” the statement said.

Testing organisation DHI has closed its Singapore centre for land-based typeapproval tests on ballast water management systems (BWMSs). Since 1 March, DHI will only arrange shipboard tests from Singapore. Its Danish headquarters continues to offer both types of testing. The organisation acts as a sub-laboratory to two USCG-approved independent laboratories –Lloyd’s Register and DNV GL. Both organisations told BWTT that they will continue to work with DHI’s Denmark facility and alternative partners in Asia.

http://bit.ly/LessPess

IMO, USCG ‘shortcomings’ cited as MERC ends testing The Maritime Environmental Resource Center (MERC) ended its ballast water management system (BWMS) certification testing programme due to what it called shortcomings in national and international regulations. MERC director Mario Tamburri cited the need for more rigorous testing, consistent enforcement and transparent procedures on the part of the United States Coast Guard (USCG), IMO and others. “While perfection is unrealistic, it is possible to be rigorous, consistent and transparent when testing BWMSs, which is necessary for the regulations to succeed,” Dr Tamburri told BWTT. An MERC statement took issue with both IMO and USCG testing processes over several shortcomings, including allowing test facilities to “ignore live larvae … and large algal cells simply because they often don’t or naturally can’t move on their own.” http://bit.ly/MERC-TA

Ballast Water Treatment Technology 2018

Convention, ICS chairman Esben Poulsson urged shipowners, equipment manufacturers and governments to cooperate “to ensure that … this significant new regulatory regime will deliver maximum environmental benefit.” ICS advised shipowners to tell manufacturers they will only fit systems that have been certified in accordance with the revised G8 testing standards, to ensure that “systems installed on ships will be fit for purpose in all known operating conditions,” he said. http://bit.ly/ICS-Bill

http://bit.ly/DHI-Sing

Type-approvals to list design limitations Alfa Laval ‘first with a revised G8 certificate’ Alfa Laval was the first ballast water management system maker to gain typeapproval under IMO’s revised G8 testing procedures. Its PureBallast 3 was issued with its certificate on 2 February by class society DNV GL, acting on behalf of the Norwegian Maritime Authority. Its statement recalled that systems approved under the former guidelines can still be installed until 2020, so “there is no immediate need to purchase a system with revised G8 compliance.” It said that its decision to conduct tests against the new requirements was based on “customer concerns” as well as legislative developments.

Draft guidance on system design limitations (SDLs) of BWMSs was agreed by IMO’s Sub-Committee on Pollution Prevention and Response (PPR 5) in February. The guidance establishes a common approach to describing operational limitations “with a view to increasing global consistency in the application of SDLs and the implementation of self-monitoring,” according to its preamble. If the guidance is approved by MEPC 73 in October 2018, SDLs will be included on type-approval certificates to “complement the standardised tests in the 2016 Guidelines (G8) by providing validated information on the conditions for which an individual BWMS is designed,” the guidance note said.

http://bit.ly/First-G8

http://bit.ly/IMO-SDLs

Shipping faces big ballast bill, says ICS Shipping faces a global bill of about US$100Bn to fit ballast water management systems, according to the International Chamber of Shipping (ICS). In a statement marking the entry into force of IMO’s Ballast Water Management

Type-approval ‘discourages innovation’ The type-approvals required in the US and by IMO for ballast water management systems (BWMS) discourages innovation and improvement, said Hyde Marine executive director Chris Todd.

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BEST OF THE WEB | 65

“Once approved, a manufacturer cannot make modifications and improvements without another round of expensive testing, so this discourages innovation and improvement as the testing process is so long and expensive,” he said. On average, the full test process costs US$4M for the two-year process, he said. The situation might change once shipowners install BWMSs and then want improvements in the future, he said. http://bit.ly/TA-Innov

Denmark-China MoU will lead to wider co-operation A memorandum of understanding (MoU) signed between Danish Maritime and the Shipbuilding Information Centre of China will lead to wider links between the countries’ maritime technology sectors. Danish Maritime managing director Jenny Braat described the MoU as the first step towards stronger co-operation between the two countries “on green shipping,

environment-friendly equipment and safety.” Its text was not made public, Ms Braat said, because it was an agreement “at a political level.” It is now up to industry members “to find areas where they can co-operate,” she said.

biodiversity and because their “direct and indirect health effects and the damage to the environment are often irreversible,” he said. http://bit.ly/BWMC-EIF

http://bit.ly/DenCh-MOU

‘Misinformation and lies’ will lead to treatment disaster IMO head welcomes ‘landmark step’ Entry into force of IMO’s Ballast Water Management Convention (BWMC) was “a landmark step towards halting the spread of invasive aquatic species,” said IMO secretary-general Kitack Lim on 8 September as that landmark was reached. The convention’s entry into force provides “clear and robust standards for the management of ballast water on ships,” he said. He described the problem of invasive species as “one of the greatest threats to the ecological and the economic well-being of the planet,” because of the damage they cause to

Misinformation and “whopping gorilla-sized lies” in the ballast water management industry will result in “a disaster of epic proportions,” Coldharbour Marine chief executive Andrew Marshall said. Regrowth after treatment is a significant area for misinformation, he said. He also singled out filtration systems, suggesting that it is “nonsense” to expect to be able to pass up to 6,000 tonnes/hr of dirty seawater through a 50 μm filter for 18 hours non-stop. Owners would be naïve to assume that, because a system has a type-approval certificate, “it will deliver what they want,” he said. http://bit.ly/BWMS-Lies

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DIRECTORY | 67

Ballast water treatment systems BWMS MANUFACTURER

ACTIVE SUBSTANCE APPROVAL*

SYSTEM TYPE APPROVAL

REVISED G8 TYPEAPPROVAL

USCG AMS**

WEBSITE

COUNTRY

BWMS NAME

PROCESS

Ahead Ocean technology

www.aheadocean. en.ec21.com

China

Ahead

Filtration, UV

Alfa Laval

www.alfalaval.com

Sweden

PureBallast 2.0

Filtration, UV

Alfa Laval

www.alfalaval.com

Sweden

PureBallast 3.0

Filtration, UV

www.aquaeng.kr

Korea

AquaStar

Electrolysis/ Electrochlorination

www.auramarine.com

Finland

CrystalBallast

Filtration, UV

www.acgmarine.com

Italy

ELCOLCELL BTs

Filtration, Electrolysis/ Electrochlorination

Bawat

www.bawat.dk

Denmark

Bawat

Heat, Deoxygenation

Yes 2014/10

Bio UV

www.ballast-watertreatment.com

France

Bio-Sea

Filtration, UV

Yes 2013/02

Bio UV

www.ballast-watertreatment.com

France

Bio-Sea Low flow

Filtration UV

Yes 2015/12

Cathelco

www.cathelco.com

Filtration, UV

Yes 2014/05

www. coldharbourmarine.com

GLD

Ultrasound, Deoxygenation

Yes 2015/02

www.cosco.com

China

Blue Ocean Shield

Cyclonic, Filtration, UV

Yes 2011/02

www.dlmu.edu.cn

China

DMU-OH

Filtration, Advanced oxidation

www.damengreen.com

Netherlands

Invasave 300

Filtration, UV

www.balpure.com

USA

Balpure

Filtration, Electrolysis/ Electrochlorination

Desmi Ocean Guard

www.desmioceanguard. com

Denmark

CompactClean

Filtration, UV,

Desmi Ocean Guard

www.desmioceanguard. com

Denmark

Oxyclean

Filtration, UV, Ozonation

Desmi Ocean Guard

www.desmioceanguard. com

Denmark

Rayclean

Filtration, UV

www.dow.com

Singapore

Dow Pinnacle

Filtration, Ozonation

None

www.ecochlor.com

USA

Ecochlor

Filtration, Chlorination

Final 2010/10

Yes 2011/11

www.hitachizosen.co.jp

Japan

Ecomarine-EC

Filtration, Electrolysis/ Electrochlorination

Final 2015/04

Aqua Star (ex Aqua Engineering) Auramarine Azienda Chimica Genovese

Coldharbour Marine

COSCO

Dalian Maritime University Damen Green Solutions (1) De Nora Water Technologies

Dow Chemical Pacific

Ecochlor Ecomarine Technology Research Association

Final 2011/03

Yes 2015/01

Yes 2011/03

Yes 2014/02

Final 2012/03

Basic 2014/03

Basic 2012/03

Yes 2018/02

Yes 2012/06

Yes 2012/10

USCG TYPEAPPROVAL

2016/12

Applied for

Yes 2017/03

Final 2010/10

Yes 2011/07

Applied for

Final 2012/10

Yes 2012/11

Yes 2014/09

2017/08

*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. (1) Intended as a port-based system but can be fitted to ships. (2) IMO’S MEPC 69 received information that no active substance is used (3) This table was updated after MEPC 72 in April 2018

www.ballastwatermanagement.co.uk

Ballast Water Treatment Technology 2018

68 | DIRECTORY

BWMS MANUFACTURER

ACTIVE SUBSTANCE APPROVAL*

SYSTEM TYPE APPROVAL

REVISED G8 TYPEAPPROVAL

USCG AMS**

WEBSITE

COUNTRY

BWMS NAME

PROCESS

www.ecospec.com

Singapore

Semb-Eco LUV

Filtration, UV, ULF Wave

Yes 2016/07

www.bwts.cn

China

Seascape

Filtration, UV

Yes 2013/12

Envirocleanse

www.eco-enviro.com

USA

inTank

Bulk chemical

None

Envirocleanse

www.eco-enviro.com

USA

InTank

Filtration, Electrolysis/ Electrochlorination

Basic 2017/07

Envirotech

www.blueseas.com.sg

Singapore

BlueSeas

Filtration, Electrolysis/ Electrochlorination

Basic 2011/07

Envirotech

www.blueseas.com.sg

Singapore

BlueWorld

Filtration, Chlorination

Basic 2011/07

Erma First

www.ermafirst.com

Greece

ESK Engineering

Cyclonic, Electrolysis/ Electrochlorination

Final 2012/03

Yes 2012/05

Erma First

www.ermafirst.com

Greece

FIT

Filtration, Electrolysis/ Electrochlorination

None

Yes 2015/01

www.evoqua.com/ seacure

Germany

Seacure

Filtration, Electrolysis/ Electrochlorination

Final 2012/03

Yes 2014/02

Ferrate Treatment technologies

www.ferratetreatment. com

USA

Ferrate

Flow Water Technologies

www. flowwatertechnologies. com

Cyprus

FlowSafe

Filtration, Electrochlorination

None

GEA Westfalia

www.westfaliaseparator.com

Germany

BallastMaster EcoP

Filtration, Electrolysis/ Electrochlorination

Basic 2011/07

GEA Westfalia

www.westfaliaseparator.com

Germany

BallastMaster UltraV

Filtration, UV

Yes 2011/12

www.gensysgroup.com

Germany

BAWAC

www.hanlaims.com

Korea

EcoGuardian

Filtration, Electrolysis/ Electrochlorination

Final 2013/05

Yes 2015/05

www.headwaytech.com

China

OceanGuard

Filtration, Advanced oxidation, Electrocatalysis

Final 2010/10

Yes 2011/03

www.htmarine.com.au

Australia

SeaSafe-3

Heat

www.hitachi.com

Japan

ClearBallast

Filtration, Flocculation

Final 2009/07

Yes 2010/03

www.hsma.com

Korea

HS Ballast

Electrolysis/ Electrochlorination

Basic 2012/10

www.hydemarine.com

USA

Hyde Guardian / Gold

Filtration, UV

Hyundai HI

www.hhi.co.kr

Korea

EcoBallast

Filtration, UV

Hyundai HI

www.hhi.co.kr

Korea

HiBallast

JFE Engineering

www.jfe-eng.co.jp

Japan

JFE Engineering

www.jfe-eng.co.jp

Ecospec / Sembcorp Marine Elite Marine BWTS Corp.

Evoqua Siemens

Gensys

Hanla IMS

Headway Technology

Hi Tech Marine

Hitachi

Hwaseung

Hyde Marine

Jiangsu Nanji Machiinery Jiujiang PMTR Institute

2017/10

Yes 1997

Yes 2009/04

Final 2010/03

Yes 2011/03

Filtration, Electrolysis/ Electrochlorination

Final 2011/07

Yes 2011/11

BallastAce

Filtration, Chlorination

Final 2010/03

Yes 2010/05

Japan

NeoChlor Marine

Filtration, Chlorination

Final 2012/10

Yes 2013/06

www.jsnj.com

China

NiBallast

Filtration, Memb, Deoxygenation

www.oceandoctor.cn

China

Ocean Doctor

Filtration, UV, Advanced oxidation

Ballast Water Treatment Technology 2018

USCG TYPEAPPROVAL

Final 2013/05

Yes 2013/01

Yes 2013/12

Applied for

www.ballastwatermanagement.co.uk

DIRECTORY | 69

COUNTRY

BWMS NAME

PROCESS

ACTIVE SUBSTANCE APPROVAL*

SYSTEM TYPE APPROVAL

Singapore

Varuna

Filtration, Electrochlorination

Basic 2015/04

www.kalf.sg

Singapore

ElysisGuard

Filtration, Electrochlorination

Basic 2014/10

Katayama Chemical

www.katayama-chem. co.jp

Japan

SPO System

Filtration, Chemical, Cavitation

Basic 2011/07

Katayama Chemical/Nippon Yuka Kogyo

www.katayama-chem. co.jp

Japan

Sky System

Chemical

Final 2014/04

Yes 2014/10

Knutsen Technology

www.knutsenoas.com

Norway

KBAL

Pressure vacuum, UV

Yes 2012/11

www.ktmarine.co.kr

Korea

Marinomate (ex KTM)

Cavitation, Electrolysis/ Electrochlorination

Final 2014/10

Yes 2016/03

www.kuraray.co.jp

Japan

Microfade

Filtration, Chlorination

Final 2012/03

Yes 2012/05

Kuraray/Kashira

www.kurara.co.jp

Japan

Microfade II

Filtration, Chemical

Basic 2017/07

Kurita Water Industries

www.kurita.co.jp

Japan

KURITA

Chemical

Final 2014/10

Yes 2017/01

Kwang San

www.kwangsan.com

Korea

EnBallast

Filtration, Electrolysis/ Electrochlorination

Basic 2010/03

Kwang San

www.kwangsan.com

Korea

BioViolet

Filtration, UV

Yes 2015/04

www.mahleindustrialFiltrationration. com

Germany

Ocean Protection System OPS

Filtration, UV

Yes 2011/04

www.mhsystemscorp. com

USA

Deoxygenation

Mitsui Engineering

www.mes.co.jp

Japan

FineBallast OZ

Filtration, Ozonation, Cavitation

Mitsui Engineering

www.mes.co.jp

Japan

FineBallast MF

Membrane Filtration

Yes 2013/11

www.miuraz.co.jp

Japan

Miura BWMS

Filtration, UV

Yes 2014/03

www.mmcgt.no

Norway

MMC

Filtration, UV

Yes 2012/12

www.nei-marine.com

USA

VOS

Deoxygenation, Cavitation

Yes 2009/09

NK Co

www.nkcf.com

Korea

Nk-Cl BlueBallast

Chemical

Final 2016/04

NuTech O3/NK Co

www.nkcf.com

Korea

BlueBallast

Ozonation

Final 2009/07

Yes 2009/07

www.oceansaver.com

Norway

MkII

Filtration, Electrolysis/ Electrochlorination, Deoxygenation

Final 2008/10

Yes 2011/12

2016/12

www.optimarin.com

Norway

OBS

Filtration, UV

Yes 2009/11

2016/12

Panasia

www.gloen-patrol

Korea

GloEn-Saver

Filtration, Electrolysis/ Electrochlorination

Basic 2012/10

Panasia

www.gloen-patrol

Korea

GloEn-Patrol

Filtration, UV

Final 2010/03

Yes 2009/12

Applied for

www.panasonic.co.jp

Japan

ATPS-Blue

Electrolysis/ Electrochlorination

Final 2016/04

Yes 2017/03

BWMS MANUFACTURER

WEBSITE

Kadalneer Technologies KALF Engineering

Korea Top Marine

Kuraray

Mahle

MH Systems

MIURA

MMC Green Technology NEI Treatment Systems

TeamTec (OceanSaver)

Optimarin

Panasonic Environmental Systems & Engineering

www.ballastwatermanagement.co.uk

Final 2010/10

Yes 2011/07

REVISED G8 TYPEAPPROVAL

USCG AMS**

USCG TYPEAPPROVAL

Ballast Water Treatment Technology 2018

70 | DIRECTORY

WEBSITE

COUNTRY

BWMS NAME

PROCESS

ACTIVE SUBSTANCE APPROVAL*

SYSTEM TYPE APPROVAL

www.redox.no

Norway

Redox

Filtration, Ozonation, UV

Basic 2013/05

www.rwo.de

Germany

CleanBallast

Filtration, Electrolysis/ Electrochlorination

Final 2009/07

Yes 2010/09

www.samkunok.com

Korea

ARA

Filtration, Plasma, UV

Final 2010/10

Yes 2012/06

Samsung HI

www.shi.samsung.co.kr

Korea

Neo-Purimar

Filtration, Electrolysis/ Electrochlorination

Final 2012/03

Samsung HI

www.shi.samsung.com

Korea

Purimar

Filtration, Electrolysis/ Electrochlorination

Final 2011/07

Yes 2011/10

Shanghai Cyeco Environmental Technology

www.cyecomarine.com

China

Cyeco

Filtration, UV

Yes 2012/06

Shanghai Hengyuan Marine Equipment

www.sh-hengyaun.com

China

HY-BWMS

Filtration, UV

Yes 2013/08

China

BALWAT

Filtration, UV

Yes 2013/02

www.sh-lees.com/en/ about.php

China

LeesGreen

Filtration, UV

Yes 2016/01

www.stxmetal.co.kr

Korea

SmartBallast

Electrolysis/ Electrochlorination

Final 2012/10

Yes 2013/10

www.sunboind.co.kr

Korea

BlueZone

Ozonation

Final 2014/10

Yes 2015/09

www.sunrui.net

China

BalClor

Filtration, Electrolysis/ Electrochlorination

Final 2010/10

Yes 2011/01

Techcross

www.techcross.net

Korea

ECS-HyChem

Filtration, Chemical

Final 2016/10

Techcross

www.techcross.net

Korea

ECS-HyChlor

Filtration, Electrochlorination

Final 2016/04

Techcross

www.techcross.net

Korea

ECS-Hybrid

Filtration, UV, Electrolysis/ Electrochlorination

Basic 2017/07

Techcross

www.techcross.net

Korea

Electro-Cleen

Electrolysis/ Electrochlorination

Final 2008/10

www.trojanmarinex. com

Canada

Marinex

Ulmatec Pyro

www.ulmatec.no

Norway

University of Strathclyde

www.strath.ac.uk

Van Oord (2)

www.vanoord.com

Netherlands

Wärtsilä

www.wartsila.com

Finland

Aquarius UV

Filtration, UV

Wärtsilä

www.wartsila.com

Finland

Aquarius EC

Filtration, Electrolysis/ Electrochlorination

www.bsky.cn

China

BSKY

www.pactchina.com

China

www.zjyingpeng.com

China

BWMS MANUFACTURER Redox Maritime Technologies

RWO

Samkun Century

Shanghai Jiazhou Environmental Mechanical & Electrical Shanghai LEE'S FUDA Electromechanical Science & Technology Co STX Metals

SunBo Industries

SunRui

Trojan

Wuxi Bright Sky Yi Xing PACT Environmental Technology Zhejiang Yingpeng

Ballast Water Treatment Technology 2018

ClearBal

REVISED G8 TYPEAPPROVAL

USCG TYPEAPPROVAL

Applied for

2018/01

Yes 2008/12

Applied for

Filtration, UV

Yes 2014/03

Heat

Chemical

Basic 2016/10

Fresh water, Chlorination

Basic 2013/05

Yes 2015/11

2018/04

USCG AMS**

Yes 2012/12

Yes 2013/12

Filtration, UV

Yes 2011/03

PACT Marine

Filtration, UV

Yes 2014/07

YP-BWMS

Filtration, UV

Yes 2015/02

Final 2012/10

Applied for

www.ballastwatermanagement.co.uk

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