Market forces at work on ballast water treatment regulations
The recent withdrawal of the Unitor ballast water treatment system by Wilhelmsen Technical Solutions is being viewed by industry as another wake-up call for IMO to open up its type approval requirements for revision. Most in the industry are assuming Wilhelmsen’s withdrawal was a recognition that its type approved system might not achieve compliance with the IMO discharge standard under all conditions, and indeed that’s how the announcement seems to be pitched. However a source close to the South African developer of the Unitor technology believes the reasons for Wilhelmsen’s withdrawal rested more with commercialisation difficulties than technical performance. Either way, many parties are now preparing papers for the next MEPC meeting on what changes are required to the present type approval regime.
Probably more telling than the Wilhelmsen withdrawal, or indeed the earlier Peraclean Ocean withdrawal, was the announcement of the type approval testing results for DESMI Ocean Guard. This company claimed to be the first to test using fresh water. It is not currently a requirement for type approval. Unexpectedly, too many organisms over 50 microns were penetrating the system and the company now has a patent pending for a filter arrangement that can eliminate the soft, flexible, freshwater organisms that caused the problem.
As well as the limited salinity range required for testing, there is no requirement to test with different water temperatures. Concerns have also been raised about the need to only monitor performance for five days. In any case, G8 is a guidance only, not mandatory, and even if short cuts aren’t taken, the testing can heavily reflect the individual nature of local ecosystems surrounding a particular testing house, says David Tongue, director of regulatory affairs at the International Chamber of Shipping.
“The G8 testing guidance was developed and agreed before any systems had actually been put forward,” says Tongue. “We’ve learnt a lot since then so it is our contention that it needs revisiting. There is a general lack of confidence.”
RISING MANUFACTURER CONCERNS
A look at the latest marketing material from the equipment manufacturers shows they are aware of the rising concerns about the limitations of the type approval regime. NK describes its final acceptance tests as taking place in the presence of yards, class and owners. Brightsky Electronic took care to include the information that its shipboard trials took place, summer and winter, in the Yellow Sea, East China Sea and the mouth of the Pearl River. The company also noted specific species including densities of bacteria that were present in the land-based tests. Leaving IMO behind, Qingdao Headway highlights the latest California State Lands Commission evaluation that suggests its system is the only one that has demonstrated the potential to meet California’s standards 100% of the time in shipboard tests.
Testing houses are also adapting to the situation. DHI used the DESMI results to market its optimal location with access to fresh and saline waters. Erma First’s announcement that it had gained IMO’s final G8 approval in March noted that the land based trials were performed by “the reputable NIOZ”. As with Qingdao Headway, Erma First’s shipboard tests returned discharge results considerably below the IMO D-2 standards, again implying prospective compliance with the more demanding requirements put forward by California.
SOPHISTICATED SYSTEMS
Many manufacturers are placing emphasis on system sophistication to the point where this is starting to overshadow previous marketing crunch points such as unit size, installation flexibility and power requirements. “Small footprint and high-end technology,” says OceanSaver of its Mark II system. “Low maintenance requirement and incredibly easy menu control,” says GEA Westfalia of its recently type approved BallastMaster ultraV system. Mahle claims a quick start for its system and a stand-by function if ballasting or de-ballasting is interrupted. Siemens claims an additional payback for owners. Previously, the ballast tank corrosion protection offered by inerting systems was the only perceived financial benefit of treatment systems, but Siemens claims its dual purpose system can also be used to protect the ship’s cooling water circuits.
Manufacturer RWO now offers 3D-scan technology to increase the speed of engineering design for retrofitting. Hamworthy offers a range of flexible solutions from equipment only supply through to full turnkey retrofit installations including design, mechanical and electrical installation, system integration, commissioning and all associated flag and class approval activities.
Similar services are offered by the engineering companies entering the installation market. Goltens Green Technologies works with a range of manufacturers and has been involved in projects on nine vessels over the last two years. Five of the projects were installing Optimarin’s system on offshore supply vessels owned by GulfMark Offshore and the 3D laser technology Goltens employs enabled various systems to be compared. MESAB exclusively installs Alfa Laval’s treatment system but still recommends laser scanning as it gives a complete picture of the intended physical location of the equipment and means that all the data are back with the engineer and stored electronically for easy access at a later stage.
Engineering company Instrumental Marine Services believes that by having an on voyage installation option, the work can be done on a closer, more professional level than when dealing with a large bid package from an installation provider when the vessel is out of service. Typically an installation can be carried out with a team of three to five installers with a significant lower risk of accidents and a much higher quality than while undergoing a regular shipyard overhaul, says marketing director Petter Syse. “This simply because there are no interferences from other repairs and disturbances. Also, it is to be expected that lead time will be quite extended when 40,000 to 60,000 orders are placed. These delayed component deliveries will have an insignificant impact when carried out on voyage. If in the yard, it will end up having to be done on voyage at a later stage, at a cost premium,” he says.
Soon, having installed a ballast water treatment system won’t mark a shipowner as being above and beyond compliance. “Treatment is only the first step,” says Dr Dale Neef, managing director of independent data management consulting company DNA Maritime. Results have to be recorded and reported and there is the potential for analysis to reveal efficiency gains that can be made with for example, the optimisation of pump operation. Most data is already available on board from ballast pumps, tank level indicators, valve flow sensors and treatment systems, and condition based monitoring companies such as SKF, ESRG, MIMIC and SBM have the technical capacity to act as systems integrators and to pull disparate ballast data together into reports electronically. Most fleet management software doesn’t yet have the ability to capture and organise the data electronically but improved functionality in this area is on its way.
INFORMED ABOUT EFFICACY
Other extras could keep operators informed about system efficacy. Hach has developed a portable Rapid Ballast Water Compliance Test Kit that rapidly measures living organisms 10 to 50 microns in size. The Glosten Associates and the California State Lands Commission have developed a prototype real-time compliance monitoring system which is independent of treatment system and which could be installed on board. It is easy to use and likely to cost around $150,000, says The Glosten Associates. It should be able to be operated by a single crew member or compliance officer and could also be made modular and portable. In case of compliance problems, or emergency situations, The Glosten Associates has also developed an onboard emergency treatment dosing protocol in association with the US Geological Survey and National Parks.
Cofely West Industrie has developed a barge-mounted system because, as it says, a ship must be able to enter port and load cargo no matter the state of its ballast water. Cofely is currently testing the system with industry partners, and additionally the company has developed a real-time bacteria detection system so it can offer a service to confirm compliance with the IMO standard.
Not wanting to rely exclusively on marketing material, Tim Wilkins, environmental manager at Intertanko, has gathered feedback about members’ system selection and installation experiences, and compiled this into a commentary to assist others in their discussions with manufacturers. Guidance on the Selection and Installation of Ballast Water Management Systems for Tankers was published this year and it includes information not often found in manufacturers’ brochures such as the potential need to allow for an increase in ballasting time due to backflushing filters. According to the guide, the maximum treatment rate selected for a system may need to be 10%-15% greater than the actual rates required to account for this.
TYPE APPROVAL CONCERNS
The concerns about type approval dovetail compliance testing concerns that did not receive detailed evaluation at MEPC63. At an earlier meeting the International Chamber of Shipping, supported by Panama, the Bahamas and Singapore, stopped the compliance testing protocols that were to be proposed to MEPC63. The protocols included indicative analysis where indirect measures rather than individual organism counts are used to broadly assess the abundance of living organisms in ballast water. The organisation argued that this has taken indicative analysis beyond its original environmental protection role and made it a tool for enforcement. Indicative sampling is open to a range of different sampling methods and vulnerable to bias, potentially to the detriment of ship operators who have installed and run a treatment system in good faith.
Ratification of the convention is no longer expected this year, but so that shipowners are not caught unawares, Germanischer Lloyd will soon release a tool which will allow them to calculate the due date of compliance with the D2 treatment standard for any vessel. This is based on the construction date and the size of vessel and covers both vessels in service and newbuildings.
