Crew members performing pipe coating. (Image: Mouawad Consulting)Crew members performing pipe coating. (Image: Mouawad Consulting)

An estimated 60-70 percent of the merchant fleet is yet to have a ballast water treatment system installed. Industry experience so far gives a clear warning of the pitfalls

SGS Global Marine Services released a white paper in May describing its experience with commissioning testing for 95 systems. One fifth failed to meet the D-2 performance standard, and half of the indicative tests that gave negative performance results were refuted when detailed analysis was undertaken.

Sampling ports proved problematic. Only around seven percent of ships had sampling ports that adhered to both the G-2 Guidelines and ISO 11711-1:2019 specifications. Once in place, it was impossible for surveyors to verify that sampling probes were installed correctly and facing into the flow of ballast water.

Total residual oxidant (TRO) levels in discharge water were found to be higher than 0.1 mg/l in a number of cases. “While high TRO concentrations likely ensure that the D-2 standard is met, the concentrations may be in violation of local, state or federal requirements,” warned SGS.

The company found that all failures to meet the D-2 standard occurred as a result of organisms ≥50µm in size. Rarely, failures were detected for smaller organisms as well. SGS stated that it is not surprising that larger organisms are resistant to treatment, so it is important to ensure that filters are functioning well.

Reliability and filters key concerns

Sudhir Bhimani, Group Environmental Compliance Director at Hong Kong-based Anglo-Eastern Ship Management, says mandating commissioning testing is a positive step and will help to increase confidence in systems being purchased by owners when it is done prior to handover. The company has installation and operations experience with 19 different systems on over 325 ships.

Equipment costs have come down, but he says the reliability of operations and after-sales service support still remains a point of concern. “The good news is that a few manufacturers have spent lot of time and resources in research, so the performance of their ballast water treatment system has improved and confidence in operational capability appears to be growing in the industry.”

However, operation in fresh or muddy water ports remains a challenge for most systems and some filter systems are not able to cope with the cargo discharging requirements in ports. “With ballast water treatment system design limitations (filters getting clogged), ships are forced to rely on contingency plans of exchange at sea with approval of the flag state and port concerned,” he says.

Ballast water testing facilities have been a big challenge even prior to the pandemic and have not been available in many ports worldwide, says Bhimani. “Now we see the facilities increasing and trust that over the coming months, owners/operators will have a choice of ports to carry out ballast water testing. Also, many companies are working on developing reliable onboard test kits which would benefit the industry at large once such kits and their testing methodologies have secured US Coast Guard approval.”

Variations in flag state approaches

Jad Mouawad, CEO of Mouawad Consulting, cautions that indicative testing for gross non-compliance is not verified by Administrations through IMO procedures as those remain to be developed. “Different flag states are implementing this requirement in different ways and through a different timeline. The official entry into force of this amendment is in 2021, since this is a formal amendment to the Ballast Water Management Convention. The quality and capacity of the testing facilities, especially in China, remains to be proven.”

He says that probably the only part of the implementation phase of the Convention that is working as planned is the issuance of type approvals by the US Coast Guard, with over 30 certificates now issued. “Applications to the US Coast Guard reached their peaked a while back, and the curve is pointing downwards for new applications, meaning that we are seeing approximately 25 to 35 systems as the ones remaining in the market.”

In contrast, the US Vessel Incidental Discharge Act (VIDA) is something of a puzzle. The Act clearly separates the responsibilities of the Environmental Protection Agency (EPA) and the US Coast Guard, with regulations and implementation being the responsibility of the US Coast Guard towards the ships throughout the country.

It also opens the way for the US to consider organisms that cannot reproduce to be dead. “This is important for UV-based systems (almost 50 percent of the market) as it means less dose, less power and more competitive systems if they are allowed to use viability techniques during their type approval assessment,” says Mouawad. “However, the VIDA has so far not lived up to its intent, as the US Coast Guard seems to be reluctant in accepting methods that measure viability of organisms based on their reproductive capability.” The VIDA is expected to be fully implemented by 2022, with the EPA and US Coast Guard working together to align and publish new sets of regulations from December 2020.

rG-8 requirements

Regarding the revised G-8 requirements (BWMS Code), Mouawad says unofficial figures (i.e. type approval certificates issued but not yet reported to the IMO) place the number of systems type approved according the Code at around 17. “Hard efforts are required by the remaining makers to be certified in accordance with the BWMS Code prior to 28 October 2020.”

Recent surveys and experience gathered through field work by Mouawad Consulting show that as much as 75 percent of installed ballast water treatment systems either do not work at all or work with problems; with the majority working with problems. “While those figures may be shocking to someone trying to understand how systems are working onboard ships, they are reasonably expected, as those systems are new equipment only recently being mass tested and installed on ships,” says Mouawad. A large number of the problems relate to a lack of maintenance or equipment sitting idle for many years before being restarted.

“A good portion of those systems have a design that lack the robustness needed for operation onboard ships’ harsh environment. This applies especially to the colorimetric TRO meters using sampling devices and other arrangement that make them very vulnerable. In my experience, we seldom, if even, board a ship and find all TRO meters well maintained and working properly. This alone is enough to shut down the complete ballasting and deballasting operation.”

He says equipment manufacturers have neglected or underestimated the immense challenge of providing worldwide support, 24 hours a day. “Ships calling a port anywhere in the world, at all times, facing defects of components, shortage of chemicals or other challenges to operate their systems require immediate assistance. This is still a major challenge for manufacturers with only few managing to tackle the issue.”

As a rule of thumb, Mouawad expects systems to be large functional (i.e. more than 90 percent in good working condition) five years after their retrofit. This means by 2029 at the earliest.

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