The next milestone in the IMO’s Ballast Water Management Convention, 8 September 2019, is approaching quickly, requiring more vessels to comply with the D2 standard.
Steve Candito, CEO of Ecochlor, suggested, “if you are a shipowner and haven’t even started the decision-making phase regarding a treatment technology for your vessel(s), you might want to rethink your compliance strategy”.
Candito recommended that shipowners should begin retrofit planning a year in advance by reaching out to marine engineering firms experienced in ballast water treatment installations to determine which treatment technology is best suited for their vessel or fleet of ships, and also to the vessel’s classification society (Class) to be aware of any limitations placed on the system’s use. He warned that industry expectations are that both the marine engineering firms and Class will reach their staffing capacity in the very near future. As a result, there is the potential for long bottlenecks in delivery and costly delays for the shipowner.
“Very often, Ecochlor will receive the initial enquiry from an owner asking, ‘how long does it take to manufacture a system?’ We tell them six months, which is the time that it takes once the detailed design drawings are complete. What shipowners don’t realise is that prior to signing a purchase order with the BWTS manufacturer, there are months of dialogue and decisions that go on with the integration engineers, manufacturer and Class. This phase of the project can take anywhere between three to six months depending on the level of services required and should be done prior to the manufacturer’s system build timeline. During this time, most vessels need 3D scans or surveying, basic and detailed engineering drawings and time for Class to review and approve these documents. After years of experience retrofitting vessels with our BWTS, we have determined that to achieve the best possible and least costly results, shipowners really need to start the process a year before their compliance deadline”, shared Candito.
Ballast water treatment systems: Know their limits
Besides vessel size, there are various other factors that need to be taken into consideration when choosing a ballast water management system which include: trade routes, water turbidity, and temperature.
Candito said: “If your ship has a charter that requires travel to ports with ‘dirty water’, for example in the Mississippi River, then an ultraviolet treatment system (UV) is probably not the best option for that vessel. In addition, a larger vessel may require more than one UV treatment system. In turn, that leads to very high-power requirements to adequately treat the ballast water in addition to needing more space to install multiple systems. On the other hand, a cruise ship traveling in clean Caribbean waters with low ballast flow rates would be a good option for a UV system”.
Another treatment technology is electrochlorination. Under optimal conditions for electrochlorination, the generation of the active substance happens rapidly and sufficient disinfectant is generated. However, as conditions with water salinity, temperature, hardness, and pH change, both the speed at which the active substance is generated and the quantity of hypochlorous acid generated decreases and will affect how the BWTS operates.
“Ecochlor’s unique, patented chlorine dioxide system is very different from electrochlorination’s treatment technology because it works very well in all water conditions without the need for the ship’s crew to recalibrate or change the standard BWTS operation. Additionally, there is no re-treatment or neutralisation when discharging the ballast water”, said Candito.
A report by ABS claimed that only 57% of the systems out there are operable, while the rest are ‘problematic’ or ‘inoperable’. But, the issues of inoperability, it seems, depend on the circumstances of the system’s use. In situations, where the vessel is taking on ballast water that is not ideal for that particular treatment technology, such as turbid water in a UV system or fresh water in an electrochlorination system, the crew must become more involved with operating the system. Unfortunately, this more challenging treatment circumstance can also be when some of the issues regarding the inoperability of the system can occur, particularly if the crew is not well trained.
Inoperability of a BWTS can result in very real fear of fines, or delays imposed by Port State Control (PSC), and reputational damage when the system fails. Contingency plans are now required as part of each vessel BWM Plan.
Candito said: “From the first ballast operation, Ecochlor engages in continuous communication directly with the vessel’s crew and operational data is collected and sent to our service team. This communication allows for early notification of equipment problems and allows us to resolve the issue before it becomes a problem.
“Contingency planning for an Ecochlor system is very different from our competitors because we don’t treat or neutralise during discharge, so any issues most likely will happen during intake. Ideally, we want to assist the crew while they are still ballasting, but if we can’t solve the problem remotely, we might be able to get someone on board the ship depending on where they are located. Worst case scenario, the ship would leave for their next port with untreated ballast water. This additional time before discharge allows our service technicians to continue to work with the crew to identify the problem. Thus, the crew has time to contact PSC at the arrival port to inform them of the issue and allows for a ballast water exchange while in transit. Other BWTS may have to leave the port for the exchange and then return if the problem is not identified until the point of ballast discharge.”
Crews on board: Meeting regulatory expectations
If inoperability is an issue that stems from the lack of understanding of the system, then arguably crew training is of tremendous importance.
“Right now, in the experience building phase, the regulators are only expecting the crew to do very basic things. They should know how to turn the system on; properly document that they are using the system; and the ship should have a BWM Plan. The crew should also be familiar with the latest regulations required for compliance”, said Candito.
To assist the crew, Ecochlor offers many options for training the ship’s crew from in-person training at commissioning and then at the first ballast operation, to a multi-level computer-based training program, a portable HMI simulator that allows for training to be brought “on the road” or to classroom sites globally.
Candito included: “We are also in the process of completing a training facility at our North Haven, Connecticut location. At this site, we can bring the shipowners installation superintendent, crew or any stakeholder involved in the operation of our BWTS. At this facility, we will have an Ecochlor treatment system as well as a wet filter and dry filter that will allow crew members to actually operate a system and see how it functions in real-life situations.”
Getting ballast water testing right
One of the topics discussed at this year’s MEPC73 revolved around testing and how to do it reliably.
“Right now, there isn’t enough information or understanding from the scientific community or a globally-approved test kit or procedure to do real-time testing”, said Candito. “It was expected at MEPC73 that there would be a proposal detailing guidance for BWTS sample analysis at commissioning, but they deferred that until the next meeting.”
In preparation for when testing at commissioning and ports becomes more routine, Ecochlor has established the only BWTS Compliance Guarantee in the industry. EcoCare™ ensures regulatory compliance for their treatment technology with IMO, USCG and individual U.S. state standards. It addresses system efficacy for treating ballast water and will insure the vessel against financial penalties up to USD 1 Million relating to fines, port charges or delays due to ballast water treatment efficacy non-compliance.
To learn more about Ecochlor’s unique BWM Compliance Guarantee and shipowner partner program for training, service and maintenance you can download their case study at www.casestudy.ecochlor.com. To speak to a member of the sales team contact email@example.com.
Steve Candito is CEO of Ecochlor ballast water treatment systems (BWTS) and has more than 30 years of experience in the maritime industry. Prior to joining Ecochlor, Steve was Founder, President and CEO of Foresea Consulting where he provided various advisory services including strategic planning, regulatory compliance and crisis management to the maritime and environmental communities. Before Foresea, he was President and CEO of National Response Corporation (NRC). During his 20+ years at NRC he grew the business from a start-up to a leading global emergency response and environmental services firm. He has extensive experience with OPA 90 compliance issues with particular focus on vessel owner and insurance matters.
Steve was previously an attorney with Haight Gardner Poor & Havens from 1985 to 1993 where he specialised in maritime litigation and environmental law. He also served as a marine engineer aboard Exxon USA’s domestic tanker fleet. Steve graduated from Hofstra University School of Law and the United States Merchant Marine Academy.