USCG Ballast water treatment rules are effective since 2012 and ships visiting US ports need to install a Ballast water treatment system latest by first dry-docking after January 2016. USCG AMS approval is only an interim solution and paths to type approval vary. Many ship owners question UV based solutions due to so called “live versus dead” issue”. USCG has however the ability to accept alternative test methods like the MPN, widely used for UV based systems.
Alternate Management System (AMS) is only an interim solution. It is not a USCG type approval. Trojan Marinex was the first company to apply in the world for USCG type approval. We know quite well the USCG type approval process.
With AMS, there are a lot of pitfalls. First of all, it is valid only for 5 years and there is the obsolescence risk. If you install an AMS system at the moment and the supplier don’t get the USCG type approval for that system as a consequence, you may have to take it off. It is also written in the US law that after the existence of type approved system, you are not allowed to install AMS system anymore.
The USCG type approval is different form the IMO type approval. Apart from the technical differences, there are two other major points.
- Firstly, it is much more prescriptive, so the method of how you do that testing is clearly written. It is not based on guidelines, like the IMO.
- The second is that USCG type approval testing is fully independent. The test facility is testing and operating the system, not the supplier .
There are two ways for suppliers to get the USCG type approval. One is, to do the full testing from start to finish. The second way is the existing data review.
When we look at the USCG type approval process time schedule, we can see that it can take up to two to three years to get a USCG type approval. If I were the ship owner, I would select a system supplier who have clear plans on getting the USCG type approval and have already performed the testing.
The live and the dead issue always comes as a question from the ship owners to UV technology suppliers. How can you get a US type approval, because you do not to kill the organisms? This is true, we are not killing the organisms, we are making them unable to reproduce. The problem UV suppliers have, is not on the technology rather than the test method specified by the USCG. The test method that USCG has given is so-called vital stain assay, that is not responding to the US UV dose at all, because we aren’t killing the organisms, due to this reason we have to look at the growth based test methods. And the USCG gives us a possibility to do so if we provide evidence that the method used is as effective as the vital stain assay method.
When we talk about UV, we have to understand how we disinfect the organisms. Fundamentally, we are penetrating UV radiation to the DNA structure of the organisms and this DNA structure is yielded, so that the organisms cannot reproduce any more. So, if we stop the reproduction, we are actually doing the job.
The growth based method used is called Most Probable Number (MPN) and it is based on the organism population growth during 24 hours and 48 hours Luckily, MPN method is widely used on microbiology and IMO type approval test facilities have also done more than 10 years’ work with the MPN method already. So, there exist a lot of experience on that.
The future USCG type approvals give the ship owners also a better possibility to compare the system suppliers. It will give a clear statement for example on the salinity or temperature ranges, where the system can be operated. Additionally, it will give the UV transmittance, the TRO dosage etc. So, it is much more informative document for you, when selecting your system supplier.
If we talk, for example, about UV transmittance, which is water quality measurement and basically gives a percentage of how much UV radiation is left after one centimetre water column. If the UVT is 93%,like in Mexico, then, the water quality is crystal clear. However, if you go to river ports like Shanghai or New Orleans, normally, the water quality is a little bit less pure. It doesn’t necessarily mean that it is polluted, but there is a lot organic matter coming from rain, from the rivers, from agriculture etc. That is preventing the UV irradiation going further in the water. It is important the system that you are selecting is tested and designed to meet the lower UV transmittance percentage.
Above article is an edited version of Juha Kiukas presentation during the 2015 GREEN4SEA Forum
You may view his presentation video by clicking here
|Click here to view all the presentations on this GREEN4SEA Forum|
About Juha Kiukas
Sales Director, Trojan Marinex
Juha Kiukas is a Marine Naval Architect with over 20 years of experience in various marine markets. He joined Trojan Marinex in 2014 as Sales Director – a role in which he leads the tactical implementation of sales and market integration strategies. Trojan Marinex is part of the Trojan Technologies group of businesses. Direct access to nearly 40 years of industry-defining water treatment expertise has enabled them to create a suite of ballast water treatment systems unlike any other. Their systems are purpose built for the marine environment and provide filtration + UV in a single, compact unit.
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