Commissioning Testing of Ballast Water Treatment Systems Recommended

As the industry is moving forward with the implementation/compliance of the Ballast Water Management Convention (BWMC), ERMA FIRST encourages testing of every system’s commissioning. 

I. Sampling/Compliance upon BWTS Commissioning

The main objective of commissioning testing is not to validate the Type Approval but to
demonstrate that the principle treatment methods of the system are capable of functioning as installed.  
It is based on the Guidance for the commissioning testing of ballast water management systems (BWM.2/Circ.70), and it will be required by the Flag State of the vessel or the Recognised Organizations (ROs) acting on their behalf. 

At the latest Marine Environment Protection Committee (MEPC) 74 session, that took place at IMO headquarters in London from May 13 to 17, 2019, it endorsed  that commissioning testing should begin as soon as possible in accordance with BWM.2/Circ.70 and agreed to reflect this in the requisite resolution for the adoption of the relevant amendments to mandatory instruments. As an interim measure, the Committee urged Administrations to provide the ROs which act on their behalf with written and clear instructions in relation to the conduct of indicative analysis testing of BWMS at the time of their commissioning on board ships flying their flag, including what actions were to be taken in the event of this testing demonstrating non-compliance.

HSSC-2017 (mandatory for European Commission flags) was integrated into the BWM Convention by amendments to regulation E-1.1 and E-1.5. Those amendments will become effective October 2021.

Until July 22, many Flags, such as Liberia, Singapore, Panama and Malta, are requiring or getting ready to require compliance testing at commissioning. More details on this follow.  

Flag 

Liberia Flag released Instructions to all RO’s

“Pending entry into force of the draft amendment to regulation E-1 of the BWM Convention, please note that the BWM.2/Circ.70 on validation testing during commissioning of BWMS installed on ships is guidance only and may be voluntarily applied by owners/operators/recognized organizations/shipyards until entry into force of the draft amendment to regulation E-1 of the BWM Convention.”

In case owners voluntarily carry out validation testing during commissioning, then we have provided guidance:

In this regard, the arrangement for conducting the test and commercial dealings pertaining to the commissioning test should be between the shipowners/manager/shipyard/contractor and the manufacturer.

The persons collecting and conducting the test should be independent of the BWMS manufacturer and accepted by the RO which issues the IBWMC.

A written report including methods and detailed results of the commissioning testing should be provided by the shipyard/manufacturer to the attending RO surveyor for verification before an IBWMC may be issued. The RO is authorized to issue a statement of fact in this regard."

Singapore 

MPA Shipping Circulars No. 9 of 2019 is applicable.

Specifically, the commissioning test shall be carried out for BWMS that is installed on board applicable SRS (Ships that are required to meet the D2 performance standards as per Ballast Water Management Convention Regulation B3, as amended) of 400GT and above after 8 September 2019.

Applicable SRS of less than 400GT may undergo the commission test voluntarily. The arrangement for conducting the test and any commercial dealings pertaining to the commissioning test shall be between the shipowners / manager / shipyard / contractor and the manufacturer.

The commissioning test shall be carried out to the satisfaction of the attending RO surveyor after a complete installation of the BWMS, and after all ballasting equipment (e.g. pumps and piping) has been fully tested as appropriate.

A written report including methods and detailed results of the commissioning testing should be provided to the attending RO surveyor for verification before an International Ballast Water Management Certificate (IBWMC) can be issued.

The arrangement for conducting the test and any commercial dealings pertaining to the commissioning test shall be between the shipowners / manager /shipyard / contractor and the manufacturer. The Administration of Singapore MPA does not carry out approval of any specific testing facility.

The testing facility engaged to conduct the commissioning test shall be independent of the manufacturer of the BWMS and accepted by the RO which issues the IBWMC.

Panama

MMC 345 Circular will be updated to reflect the amended Informations. It  will invite all Ship Owners and RO´s to start the commissioning test process from now.

It follows the instructions from the Guidance for the commissioning testing of ballast water management systems (BWM.2/Circ.70 from, 01 Nov 2018). 

RO´s must have the labs, that they used for the test and are responsible to make the sample. Shipowner Personnel and/or Manufacturer service engineer is eligible to perform the test under supervision of the RO surveyor and must be recorded.

As mentioned in BWM.2/Circ.70, “commissioning testing is to validate the installation of a ballast water management system (BWMS). If the vessel change or replace equipment must be made another “additional survey be made after a change, replacement, or significant repair of the structure, equipment, systems, fittings, arrangements and material necessary to achieve full compliance with the Convention”

Malta Flag

Office is still reviewing the process of providing interim instructions to ROs in relation to the conduct of indicative analysis and testing at the time of their commissioning; including what actions to be taken in the event of testing demonstrating non-compliance.
Concerns and clarifications request through the vessel’s class.

Class Notations    

DNV GL until now is the only Class Society that released Guidance.

DNV GL Classification Society has already included such rule [1] that will be into force 01 Jan 2020, applicable to all DNV GL Class vessels. During onboard commissioning.

For BWM (T), a commissioning specific to the ballast water treatment system shall be carried out according to the Convention. The commissioning shall follow an approved commissioning procedure. If required by the flag administration, a biological compliance test shall also be carried out and a report shall be submitted in accordance with BWM.2/Circ.70. Meeting the full set of requirements in the referenced rules (DNV GL class notation BWM (T), will equally qualify for having the international BWM certificate issued. Consequently, all-ships that have to comply with the Convention should have a Class Notation BMW (T) [2].

ABS is working on setting up a Service provider Network Scheme.

Recommendation to Shipowners:

Liaise with vessel’s Flag and/or RO and request the latest Instructions /Guidance regarding Commissioning and Issuance of the Ballast water Management Certificate.

Update your Training Program to include latest Circulars related to Commissioning (Designated Officer familiar with the Procedures, Resources could be added to  Ballast Water Management Plan). BWM.2/Circ.42/Rev.1 Guidance on ballast water sampling and analysis for trial use in accordance with the BWM Convention and Guidelines (G2) and BWM.2/Circ. 70 Guidance for the commissioning testing of ballast water management systems are the basic Resources to fulfill the Requirements. Amendments to the Guidelines for ballast water management and development of ballast water management plans (G4)” (Resolution MEPC.306(73)). Other could be added after additional instructions by Flag/RO.

Contact first Your Flag/RO of the vessel for taking the approval on the procedure that is acceptable

II. Compliance tests on ERMA FIRST Ballast Water Treatment Systems.
 
ERMA FIRST, having great confidence in its equipment biological performance and in its effort to provide full support to its clients, has been proactive on such development. As such it offers to its clients the below service options: 

a.       EF-Compliance Lab Service: An indicative sampling by an independent, certified laboratory with a combined IMO and VGP analysis. This includes D2 Analysis Detailed Intake and Discharge, IMO Self-monitoring, Sampling point positioning, VGP Biological Sampling and Residual for your first VGP analysis and report.
 
b.       EF-Indicative analysis tools: Indicative sampling with a portable testing kit that could be used by Trained Shipowner personnel. In any case, you should contact first Your Flag/RO of the vessel for taking the approval on the procedure that is acceptable.

The installation of the BWTS serves a specific purpose. This is the vessels’ compliance according to IMO and USCG discharge standards. Despite the rigorous and strict type approval schemes available, there is still uncertainty on the owners' side on the equipment performance. Specially on those attractive solutions where the BWTS is not relying on a complete treatment process such as filtration and disinfection. For those cases the compliance testing at commissioning can prove or not the integrity of the chosen technology. 

III. The risks involved when the already installed BWTS is not in compliance.

After the entry into force of the Convention, there are two standards, D1&D2 that are enforced on ships based on the applicability regime. For those vessels which should comply with the D2 standards, the performance of their BWTS can only achieve that. Therefore an operational, efficient BWTS capable to operate in real harbor water conditions with minimum System Design Limitations is requested. When a BWTS has repeatedly proven to be non compliant then the risk of not allowing the vessel to discharge ballast water is high. To tackle such situations captain of ports have requested vessels to leave the terminal for conducting full Ballast Water Exchange or partial at the open sea prior discharging ballast water in their territory. Such options impose significant delays and costs on the shipowner or vessels’ manager. 

Being proactive on choosing a reliable technology and also conduct a successful Compliance Test at commissioning eliminates such risks.

Major flags such as Liberia have already published relevant guidance. 

In case D-2 is enforced at the time of commissioning for this ship, and validation testing using indicative analysis cannot be completed for reasons such as system design limitations (SDL); other valid reasons such as this, then RO should issue a short term IBWMC for D-2 for 3 months. 
This is to allow time for the validation test to be carried out to the satisfaction of the attending RO surveyor and the attending RO surveyor ensures the following:

Reasons for the commissioning test not being completed successfully are recorded in the ballast water record book;

The attending RO surveyor is provided with new arrangements for the commission test (e.g. date, time, location);

The ship’s ballast water management plan (BWMP) has incorporated appropriate contingency measures in line with the “Amendments to the Guidelines for ballast water management and development of ballast water management plans (G4)” (Resolution MEPC.306(73)).

The ship’s Master and the designated ballast water management officer are aware of the “Guidance on contingency measures under the BWM Convention”, BWM.2/Circ.62, as may be amended, in particular on the communication between the ship and the port State; and the ship’s Master and the designated ballast water management officer are aware of the reporting requirements to the competent port Authority as per regulation E1.7 of the BWM Convention when the vessel is calling a foreign port and shall comply with any additional requirements that the port State may impose.

IV. The role of filter in BWTS compliance

Many researches from academic institutes and the majority of BWTS manufacturers (more than 70 percent) resulted that mechanical separation is essential to Ballast Water Treatment Systems. It is estimated that between 10 and 12 billion tons of ballast water is transferred around the globe each year, with the potential to carry bacteria, plankton, viruses, small fish, crabs or jellyfish into foreign ecological systems [4].

In the early days of ballast water treatment, it was assumed that a simple filter/strainer on the intake would prevent the majority of organisms entering the ballast tanks. Nevertheless, research proved that the mesh required would have to be much finer, down to 40μm that will lead into less energy required for disinfection to take place as less disinfectant concentration is produced. Organisms larger than 50μm are in their adult stage of life and as a result they have developed resistance (hard shells) against any form of water disinfection. Consequently, no-filter BWTS that utilize active substances require increased Total Residual Oxidants demand (i.e. chlorine as TRO) and holding time in order to avoid any non-compliant risks.

There are no tricks to compromise technology. For meeting D2 standards without filter using electrolysis the TRO production should be increased to high levels ( >31mg/Lit) [5]. Such can be achieved via one or a combination of the below:

Terms such as electrophoresis to all ballast water do not exist or supported by any scientific or engineering document. Its is the chlorine which oxidizes the bacterial and the pathogens, Organisms in dimensions higher than 40 microns are insensitive to chlorine. As such the only elimination method is either the use of filter, or the extreme high TRO concentration or at least long holding time. The later will kill such insensitive organisms due to starvation. 

Moreover, the absence of filter leads into high solid material concentration in ballast water that consumes the chlorine at a very fast rate [6]. As such, minimized or no holding time creates question marks if there will be disinfection efficacy and compliant operation in real circumstances of high sediments and turbid sea water.

In addition, filter protects components’ internal, wetted parts. Unfiltered water, which contains obviously various sized solids / debris (consisting of both organic and inorganic material), has a detrimental effect on the lifetime of the anode electrodes, heart of the electrolysis technology. These anodes consist usually of a precious metal oxide mixture coating applied on a titanium substrate and are highly susceptible to mechanical wear caused by unfiltered water at high velocities[6].

Besides, taking into consideration that in some no-filter BWTS, the electrolyzer housing is made of metal, the debris passing through in combination with the high-water velocity effectively sandblast the housing causing accelerated mechanical wear. This wear in combination with the produced oxidants on site could prove to have a catastrophic effect on the structural integrity of the electrolyzers.

Equally important is the ballasting sequence: BWTS without filter come with a T-strainer with a mesh filter of approx. 3000μm retention capacity. If T-Strainer is clogged, then ballasting operation must be stopped due to the required manual cleaning of the internal mesh. Crew should open the strainer, extract the filtering mesh and clean it manually to be in its initial clean condition.

Last but not least, is the TRO sampling: With no filter, there will be challenging TRO sampling and analysis procedures, due to the existence of large solids in seawater that will result in frequent Sensor filter clogging. Moreover, solids affect the efficiency of the photometric sensor measurements.

V. Conclusions

The quest for a reduced overall equipment cost needs to be bound by performance and endurance requirements. The initial savings from the purchase and installation of a BWTS can be easily spent to cover operation delay charges or fines. The correct process design and engineering combined with a proper material selection are the primary cornerstones for high performance and durability of a BWTS in the demanding marine environment. Performing compliance testing during commissioning will ensure that the shipowners’ investment is successful and hopefully will act as a screen to keep the non sound but approved systems out of the market. 

[1] http://rules.dnvgl.com/docs/pdf/DNVGL/RU-SHIP/2019-07/DNVGL-RU-SHIP-Pt6Ch7.pdf
 
[2] http://rules.dnvgl.com/docs/pdf/DNVGL/SI/2019-07/DNVGL-SI-0551.pdf
 
[3]https://www.mpa.gov.sg/web/portal/home/port-of-singapore/circulars-and-notices/shipping-circulars/detail/aec8be4a-c8da-4428-8863-6734b9ee296f
 
[4]  Information from article in Ballast Water Treatment Technology 2019 by Riviera; “The art of filtration’’

[5] Sensitivity of barnacle cyprid larvae to chlorine, N.H.B.M Kaag & A.C. Sneeks, C103/10, IMARES

[6] Marie Deborde , Urs von Gunten, Water Res. 42 (2008), 13 - 51