Mr. Sandip Patil, Surveyor, IRClass says that recent developments regarding the implementation of the Ballast Water Management Convention has triggered a chaotic situation for ship owners as there is a high possibility of fitting a treatment system twice due to clashes between two-type approval regimes i.e. USCG and IMO. He suggests a port-based measure called BWTBoat as a solution.
Current Situation at IMO
With the accession of Finland, the Ballast Water Management Convention will definitely enter into force on September 8, 2017. However, this has triggered a chaotic situation for ship owners as there is a high possibility of fitting a treatment system twice due to clashes between two-type approval regimes i.e. USCG and IMO.
On one side, there is no commercial availability of USCG-approved system and on the other, ship owners are concerned about efficacy of IMO type approved treatment systems.
Though the discharge standards are equal (until 2017 at least), there is a major difference in guidelines e.g. non-acceptance of UV systems by USCG.
Water qualities such as species, sediments, salinity, temperature and parts per million (PPM) etc. differ from port to port, and country to country. For example, based on PPM itself, the filter designs can vary widely or species content may require more chlorine dose for one type of water, and may be much less for another.
That means, different system designs will be needed for different waters. However, onboard ships, only one type of ballast treatment system design can be fitted or is economically possible to do so. Then how is it possible that a single design of treatment system fitted on ship will be able to treat different waters to one standard at all times?
Therefore, ship owners and the industry need to understand that the problem of marine protection will not be resolved with a stricter approval guidelines for treatment systems, but require a method of using treatment technologies technology which is flexible, movable, cheaper and robust, and can be customized for water quality at source port to deliver desired discharge standard.
Port-based measure i.e. treated ballast water delivering facility called BWTBoats is the answer for the above issue
IMO has provided port reception facility as a method of ballast water management under regulation B 3.6 and G 5 guidelines but over the years, different scientific reports proved it is unviable due to huge infrastructure investment.
IRClass reinvented this port-based concept in 2013 and aligning it with the treatment or process followed by IMO type approved ballast water treatment systems. Hence, rather than treating water at discharge, new concept ships will receive treated water at source or ballast uptake port. Such treated ballast water delivering facility called BWTBoats uses chlorination technology.
As these BWTBoats will be deployed at ballast uptake port, the treatment system design can be customized easily for source port water quality and discharge port standard. Again we can easily perform repairs, maintenance and change of parts or systems.
What ships need to do is to retrofit itself with an International Shore connection and fit a cheaper and smaller TRO neutralizer unit which may be required for neutralizing excess chlorine dose that remains at the time of discharge.
BWTBoat concept progress at IMO
India submitted final paper MEPC 70/4/4 to MEPC 70 for approval in principle, and also submitted draft guidance for implementation of the same. (Earlier paper references – MEPC 65/2/20, 66/2/8, 66/2/INF.17)
Recently Islamic Republic of IRAN submitted comment paper (MEPC 70/4/19) in support of BWTBoats concept, calling it an alternative for smaller ships which can be effectively implemented in a region.
Why BWTBoat is an Economically Viable option?
The total number of ports around the world are far lesser than number of ships i.e. 2,500 ports versus 40,000 ships. In a voyage data analysis conducted by IRClass on approximately 26,000 ships spread over 650 ports in 44 Asian nations, it was found that around 2,400 BWTBoats are sufficient to cater to 18,000 regional ships without causing delays to existing port operations.(Refer MEPC 66/INF.17)
Only ports where ballast uptake happens need to be deployed with BWTBoats.
Voyages among closer domestic/coastal ports can be waived off due to same risk areas.
BWTBOAT as Global Solution for BWM convention Chaos: Possible Roadmap
With respect to the current challenge, should ship owners and flag states decide unanimously to adopt Port based facility i.e. BWTBoat as a global viable solution, the following can be the roadmap for effective implementation – to resolve the chaos.
- IMO Resolution: – Possible draft amendment to B-3 regulation for phase wise implementation of port based facilities e.g. BWTBoats deployment at highest cargo imports/ballast uptake ports in first schedule of implementation.
- During the schedule, if BWTBoat is not available, then till that time ships should perform ballast exchange, especially one based on dilution method.
- Fitment of present type approved systems on BWTBoats – At the same time, ships should retrofit themselves with International shore connection.
- Toll based on per ton of ballast water service fee (approximately $0.25/ton) acceptable to ship owners to be levied for receiving treated water from BWTBoat.
- After 4-5 years, amend the guidelines with reference to outcome of experience building phase, USCG guidelines and any other research. New guidelines shall be mandatory and unique.
- Replacement of existing treatment systems on BWTBoats in parts or full, based on operational results comparison with experience building phase outcome.
In conlcusion, with port based measures, the responsibility of delivering compliant treated water will be shared by port authorities as well as through certification of such boats. If ships can receive such treated water in ballast uptake ports at a viable rate, then it should not be a problem to both ship owners and BWMS manufacturers.
Written by Sandip Patil, Surveyor, IRClass & Project Manager for the BWTBoat concept
The views presented hereabove are only those of the author and not necessarily those of GREEN4SEA and are for information sharing and discussion purposes only.
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About Sandip Patil
Mr Sandip Patil is Surveyor with IRClass and project manager for the BWTBoat concept (under development). He has 10 years of experience in Research & Innovation and currently works as in-charge for Innovation Cell at Indian Register of Shipping – an international ship classification society and member of IACS. During past four years, he has presented the BWTBoat concept in various International conferences and forums such as IMO-GloBallast Busan 2013, Montreal 2016; Green Ship Technology, Hamburg 2013 etc.
This concept, supplied in response to the accurate description of the difficulties faced by BWTSs installed aboard vessels, maybe an ideal solution but it is not a practical solution. There will be niche ports or routs where; this or Damen or Ballast Container or Royal Roos etc etc can practically and economically offer a non-vessel mounted BW treatment solution. As a blanket solution there are not enough aligned interests to provide resources for the treatment boats and the compatible reduction equipment installations on the world’s fleet. What about those who do not want actively oxidizing waters in their ballast tanks?
The difficulties (generally underestimated) of providing vessel mounted worldwide treatment are well described here but the difficulties of providing a general worldwide non-vessel mounted ballast treatment solution are not addressed here.