Thomas Lillig, principal of LTK Maritime Consultancies, reviews Intercargo’s recent views about ballast water treatment for large bulk carriers
Intercargo’s publication (BMW legislation implementation: Possibilities and impossibilities; 25 April 2017) points out the various difficulties and complications of retrofitting bulk carriers with ballast water management systems (BWMSs), as required by the IMO and the United States Coast Guard. The interesting thing is its timing, with the Ballast Water Management Convention (BWMC) coming into force in less than five months and the fact that we have been talking about ballast water treatment since at least 2004.
It gives the impression that the shipping community had their heads in the sand for years by not addressing this issue. Bringing these problems up five months before the BWMC comes into force is bad planning at best and cynical at worst. These issues should have been looked into eight or nine years ago after the first BWMSs were type-approved.
Further, it is questionable why a sector of the industry, which represent one third of the merchant shipping, brings up these issues now. Where have they been?
The shipping industry should have engaged with regulators and manufacturers, with this degree of attention and detail, many years ago. In fairness it must be noted that some owners have engaged and shown commendable commitment to the issue, sometimes well beyond what could have been expected, but this is a small minority of operators.
Intercargo claims that the availability of type-approved systems is insufficient. To date we have more than 27 approved BWMSs that can handle flow rates of 4,000 m3/hr or more (according to Lloyd’s Register’s publication, Available ballast water treatment systems), ie these systems can handle the high discharge rates of bulkers. Furthermore, there are additional systems currently going through type-approval testing that will be addressing this particular part of the market.
Also, it is important to note that the reluctance of embracing ballast water treatment does not make it easy for any new developer to risk the investment into a new technology, in particular considering the continuous wait-and-see attitude that shipowners are showing.
The article mentions UV systems and the challenges of using them on the gravity discharge of top side tanks, but it is generally known that the application of UV treatment is limited to flow rates of 2,000 to 3,000 m3/hr. Bulk carriers have discharge rate of 4,000 and up to 8,000 m3/hr, therefore UV systems will not be used on these carriers.
It is a fact that a retrofit process, regardless of the vessel type is, can be very complicated. In some cases components may have to be moved around, pumps and generators might need to be upgraded and at times compromises have to be made. This has all been discussed from the early days. For example, Lloyd’s Register published its Ballast Water Treatment Technology – current status in September of 2008. It has a lot of useful information, including an indication of the power requirements for various treatment systems, so one could say that these are long-known facts.
Under the headline: Low treatment capacity compared to ballasting requirements it said that BWMS filters will introduce “significant pressure drops”.
This statement should be clarified and corrected: Most filters have an inherent pressure drop of less than 0.1 bar. The filter monitors the differential pressure between the inlet and outlet of the filter, which increases when the filter starts to load up. A pre-set value of differential pressure triggers the automatic backflush cycle and the filter returns to the normal operating conditions within seconds. This preset value can be adjusted to any value the operator chooses.
Also, automatic back-flushing filters do not stop operation while back flushing. There is, though, a reduction in flow that depends on the particular filter. In most cases it is not more than 10 per cent, which could be considered during the design phase of the system.
It needs to be recognised that pressure losses might be introduced due additional length and bends in the pipes.
As for the effect of chemicals on the coatings, it is part of the type-approval process that the developer of a treatment system has to test the impact of its “active substance” on various coatings and paints. This was clearly established in 2008 by the IMO and is stated in BWM_2_Circc. 13. Its latest revision, Rev. 3, was published on 10 June 2015.
It is old news that a retrofit process is a very time consuming and complex process and it needs detailed planning. This is the case for all types of vessels and it cannot be generalised: each vessel is a new adventure, in some case it might be easy and in some it might present a great challenge. Regardless of the type of vessel, all aspects of the retrofit process have to be reviewed and approved by class and flag, bulkers are no exception. It should be nothing new.
If a system is properly designed to the ship’s specifications, ie no short cuts are taken, there should be no complications in future cargo operations. This is part of the detailed process taken when planning the installation of a BWMS.
Regulatory implementation: IMO vs US legislation
The most appropriate way moving forward would be to comply with the regulation that applies first, which is dependent on the vessel’s dry docking and survey schedules. It helps a great deal to be proactive, which is something that we have seen little of when it comes to ballast water treatment. Only if one embraces the issue, will there be progress, understanding, learning and advancement. If nothing is being done, we get nowhere.
As the article states correctly, there are three systems approved by the USCG, in addition there are three applications currently being reviewed for approval and it is expected that the approvals will be granted before the next MEPC. Furthermore, there are several manufactures that are in the final stages of completing their applications to the USCG. It could well be that we have six and most likely more USCG type-approved BWMSs become available before the BWMC comes into force. And this number will continue to grow and the choice of robust systems continue to improve.
The only way to improve something, like the BWMC for example, is to apply it, try it out and take what we learn to improve it. The same is true for treatment systems: in order to improve them, and therefore remove the uncertainty of their performance, one has to operate them. Unfortunately, that has not happened. Here we have a group for whom these systems were designed and installed, but they are not using them. Yet, the same group of people turns around and complains “…the installation and operation of unproven equipment only adds to concerns.” This leaves one wondering: who created the uncertainty?
It is not quite clear why the publication puts the adoption of the revised G8 guidelines in doubt. So far it has been agreed that they are a great improvement and align quite closely with the USCG rules, with only minor differences, which have been pointed out in numerous presentations and publications.
Furthermore, it should be pointed out that the reference to US “kill” standard might be superseded by the new Commercial Vessel Incidental Discharge Act, which would allow the MPN method to be used, as it is allowed under the IMO regulation. The US House of Representative and the Senate just approved this bill and is now going through the motions and will be eventually presented to the President for him to sign it into law.
Under the assumption that the MPN method will be accepted by the USCG in the not so distant future, it will make it relatively easy to comply with both regulations.
As for continually reviewing the G8 procedure; it is the same for the US regulations, they are being reviewed at regular intervals and based on experience gained, as well as in case new technology is being introduced, changes might be made to reflect this. It is interesting to note that the authors put the continued review of the regulations in a bad light, when they welcome the revised G8 guidelines as an improvement, which obviously is based on experience and knowledge gained.
Over 40 treatment manufacturers have filed Letters of Intent with the USCG to eventually apply for their approval. At present about 15 manufacturers are going through the type-approval testing and shipboard testing at various test facilities. In addition, in most cases, the available test facilities are booked by system developers for the purpose of achieving USCG type-approval, through the end of 2018. We can therefore expect that more systems will be introduced to the market within the next 24 months, helping us to satisfy the need for additional equipment and choices.
In general, the system manufacturers that are going through or planning to go through the USCG type-approval process are planning to satisfy the revised G8 as well, which is not really difficult to do.
A word to one of the proposals put forward to the IMO
MEPC 70 discussed the possibility of providing an additional allowance for ships with their IOPPC Certificate falling within the first two years following entry-into-force to fit treatment systems by the second IOPP renewal, which would provide a D-2 required compliance span 2019 – 2024.
Any implementation and compliance delay, clearly does nothing for our oceans and is counterproductive to the convention’s intent. The purpose set forth for this convention was to protect our aquatic environment. Furthermore, if the past 13 years taught us anything, it is that the shipowner community favours chronic procrastination (or is it obstruction?) with wait-and-see attitudes. So, most likely they will again do nothing until the new compliance date approaches and at that point start to argue that there are not enough systems available and that they are not reliable. Would anyone be surprised that there might not be enough system manufacturers around, because many of them could no longer survive additional years with next to no sales and they had to give up?
As the ballast water management rules are already in place in the United States, and about one 10th of the world ships call on the US ports, further delaying the implementation of the convention would be counterproductive to say the least, as shipowners would have to continue to operate under two vastly different regimes of regulation.
It could be possible, in case we delay the implementation of this so important convention, that other nations could introduce their own regulations, as they see that nothing is being done by the IMO and this would for sure further complicate the matter!
The purpose of the convention
The convention was set up with the intention to prevent, minimise and ultimately eliminate the transfer of harmful aquatic organisms and pathogens through the control and management of ships' ballast water and sediments.
The cost to control – note: to control – the problem of invasive species in the United States alone is estimated to be around US$100 billion annually. Globally, this cost is more than US$200 billion, annually. So, since the agreement of the BWMC, the world has spent in excess of US$2.6 trillion! That is not small change. Remember that this is damage largely ascribed to the operation of commercial vessels.
Now we have, as stated, 69 systems approved by the IMO. All these developers assumed high risks and developed technologies to counter the invasive species problem and help the convention to become a success. It probably is a good estimate that each of these developers spent around US$30 million to design and to develop their system, depending on how long they have been on the market and where they are in the approval process. At least one manufacturer spent more than US$60 million and eventually withdrew from the market. Combined, developers have probably spent in excess of US$2.1 billion.
The longer we wait for implementation and compliance, the chances are that more equipment suppliers could be lost, as they have to cut their losses. What will that do to the market? I recall the statement from the beginning of the article: “Availability of Type-approved Systems: insufficient”
Current status of the shipping industry
The industry is not doing well, without a doubt. But, around 2005 – 2008, the shipping industry was booming. More and more, generally larger and larger vessels were ordered, built and put into service. But no one was looking at the fact that with more vessels on the market it would become over-saturated and that eventually shipping rates would fall, as obviously happened. In conclusion, the shipping industry is its own worst enemy.
The uncertainty the owners claim over the performance is valid, but why is it there in the first place? As stated before, if we don’t use the BWMS, we cannot learn anything and do not gain experience on how to improve them. The refusal to install and the reluctance to operate is the cause for the uncertainty.
Some of the uncertainty was probably also introduced through the regulations, but again, it takes time to get it right and we are very close, even if we have currently two different regulations, which are very similar.
If shipowners are confused about the various regulations or need to plan a fleet-wide compliance strategy, they can seek help from their flag states, class societies and a pool of highly qualified and very experienced consultants.
As the financial situation of the shipowner communities is slightly stretched, outside sources for financing the purchase and installation of BWMSs are actively sought.
There is one problem: Why would anybody want to invest into an uncertain market, which was created by the same people who are now seeking the financing? It is believed that more sources would become available, once the convention is implemented and the uncertainty is taken out of the equation.
Fortunately, having said the above, we are seeing more financing alternatives, which include financial support from BWMS manufacturers, shipowner equity, banks, shipyards, the Green Bond market, governmental support, and others.
Finally the article addresses production capabilities, available service engineers, the demand in systems and the lack of experiences with, and performance of, the systems. These are valid questions, but one has to consider that the uncertainty the owners put into this market is the culprit of it. We cannot learn anything from a system that is neither installed nor operated. Why would a treatment system developer or manufacturer risk more money and put more people on their payroll, if they are not selling systems? Most of the manufacturers, as well as their suppliers, though, have established facilities that could handle an upswing in the market. And if they have not already done that, they have the plans ready to move forward with expansions.
The closing statement of the article is noteworthy and maybe questionable: “It is only now becoming fully clear to shipowners how complex and onerous the requirements are for bulk carriers that need to be retrofitted with approved BWMS.” To reiterate, we have been talking about ballast water treatment on vessels for the past 13 years at least. Why is this industry, which represents one third of the world merchant shipping industry, only now coming to grips with the challenges this regulation brings with it?
In conclusion, the Intercargo publication has some valuable points, but it should have been published 10 years ago. Further, I completely agree with its authors that pragmatism is the only way forward, not only from the USCG/EPA, as shown, but more importantly from the IMO.
One last comment on the actions of the IMO: Starting to do something is 100 per cent better than doing nothing at all! Delaying the implementation of the BWMC any longer is doing nothing. The IMO has to become proactive and stop delaying its implementation and act on what it said it would do, which started 13 years ago: To protect our oceans from the continued harmful organisms and pathogens through the control and management of ships’ ballast water and sediments.
At present the IMO is like a big scary dog with no bark, no teeth and no bite! Now is the time to change this!