When the Coast Guard’s final rule on ballast water management became effective in June, the event perhaps signaled the end of one arduous journey for regulators, but the beginning of another for shipowners.
The U.S. rule establishes discharge standards for living organisms which ballast water management systems (BWMS) must be able to satisfy. This so-called phase one standard closely conforms to the IMO’s version, bringing the dream of global standardization one step closer. Globally, ballast discharge standards are also inching towards the finish line, as the IMO standard gets closer to ratification with only a few more signatures and a greater percentage of the world’s tonnage needed for ratification. Despite delays by various governments, that standard is widely expected to enter into force within the next two years.
Notwithstanding the good news, it is also not hard to understand why so few operators have, to date, installed BWMS on their vessels. The depressed state of global shipping markets over the past few years certainly has played a role. Not everyone has the reported average price of $1 million per ship needed to install the systems, and those who do, are reluctant to do so until they absolutely have to. Also lurking just around the corner is the separate, but equally important U.S. Environmental Protection Agency’s ongoing Vessel General Permit process, which also covers ballast water discharges. Adding to that uncertainty is the myriad of individual U.S. state mandates still in play and the specter of a stricter, U.S. Coast Guard (phase II) standard.
One thing is certain: a large percentage of the world’s merchant fleet will eventually need to be fitted with a BWMS. The question of when, where, how and which system to employ represents one of the more critical business decisions facing operators today. Real concerns remain about the availability of sufficient numbers of suitable ballast water treatment equipment, as well as whether new deadlines can be met. As many as 70,000 vessels – of differing size, purpose, trading pattern and myriad other variables – may need to be fitted with BWT equipment within this decade, with the greatest numbers estimated to likely happen in 2017, 2018 and 2019. Now, there is little time to waste and this is also no time to make a mistake. What you do next will make all the difference.
What should you look for in a ballast water treatment (BWT) system? Actually, that depends on a number of variables. Asking the right question(s) of your vendor up front could eventually make all the difference as you move towards compliance. What you will probably discover is that there is no “silver bullet” when it comes to BWT systems. The variables to consider are many; and there are many questions to pose to your potential vendor. MarPro has listed (some of) the more important considerations below:
The Manufacturer: Arguably, as much attention should be paid to the staying power, financial stability, global reach (partnerships) and viability of a particular vendor as you might give to the quality of their BWT product. Some firms have been in the billion dollar BWT game for more than a decade and some are just coming to the table, as evidenced by the explosion in the numbers of type-approved systems in the last five years alone. That’s not to say that a new player can’t get the job done. More importantly, though, will your vendor be around in five years? Is BWT just a passing trend for them or is it the sector where they have earned their reputation? Finally, ask yourself (and them): Do they have the infrastructure to service your equipment in a timely manner when something goes wrong?
Research: Third party studies of any technology – the Maritime Environmental Research Center (MERC) at the University of Maryland, for example – are a good source of impartial data. Research flag state and IMO approvals – making sure your prospective system is approved in the regions you are likely to transit could be important. It might also be mandatory. Given the potential size of this market, it should not be a surprise that manufacturers, particularly those just entering the game, might rush development efforts and go to market with equipment that might not have been adequately tested in a wide range of water types and marine environments. And, the California State Lands commission report states, “… we mention in the reports that classification society requirements play a role and must be taken into account when selecting a BWMS. But most of the class approvals are for safety or mechanical issues and our focus has been on the biological efficacy of the systems. So we mainly report on approvals that deal with efficacy, and also water quality concerns.”
Due Diligence / Pilot Program: Standardization drives efficiency. That’s a fact. You really don’t want to be dealing with multiple brands and types of systems. Get two BWMS of the same type, vet them, and then standardize across the breadth of your homogenous fleet. Use this “pilot program” to then lock in long term contracts and then secure favorable pricing. Those who wait too long won’t enjoy the pricing that today’s robust competition provides and may not be able procure the numbers of units that they need at times of peak demand. Even if you are not willing to go all in at this point, it is important to dip your toes into the water.
Warranty: What kind warranty does your manufacturer provide? Do they have the viability to back it up? Do they provide a spares kit with installation? Coverage can be negotiable, depending on deal size. It is here where global reach (partnerships) will become very important.
Cost of System: There is a very good reason that this bullet was not placed at the top of the list. That’s because some owners will look for the “cheapest” system available. The initial purchase cost is only one component of what your new BWT system will entail. After installation, will you experience reoccurring expenses related to supplies, chemicals, maintenance? A poorly operating system or one which requires heightened backend attention may eventually cost you a lot more, especially if it means off-hire time in the yard. Increasingly, vendors are moving towards lower acquisition costs, but these dollars then come back into the equation for items such as filters and UV lights.
Installation: How difficult will it be to install the system, how long will it take and how long will your vessel be out of service?
Availability: The dozens of “approved” systems on the market create the impression that the equipment is immediately available. That may not be the case. Newer entries into this equipment equation may not have the manufacturing capability (yet) to meet demand from customers. How long will you have to wait for delivery? Are you in the queue with 1,000 other vessel operators and their collective 70,000+ vessels?
Cubic Footprint: Will the system fit onto your ship and if so, will it hinder your operations and ability to perform commercially. Will it reduce your cargo carrying capacity? As the rules get pushed down to the smaller hulls (think: EPA VGP) getting the system onto the 79 foot hull may be harder than you might first think. Hence, that system that can move 5,000 cubic meters per hour on a VLCC might not be the best choice for your 85 foot research vessel. Conversely, some units double in size as they double their throughput capacity. That’s not a good thing when space is at a premium.
Maintenance: In many cases, a simpler system may be better than the one that includes everything except the skin diver with a spear. Beyond this, a complicated system may require heightened maintenance costs and if some of that falls onto the shoulders of your crew, it eventually creates operational headaches. General rule; the fewer moving parts, the better.
Safety: For systems that employ an “active” substance, safety issues need to be considered. Who will be handling the chemicals and where will they be stored? Will the crew need special training for these tasks and how much manpower will be needed to attend to this aspect of your ballast water management? On the other hand, deoxygenization has been billed touted for its ability to inert the ballast tanks. If a ballast tank were ever to be breached and flooded with hydrocarbons, this could be an issue.
Coatings / Seals / Gaskets / Valves: Questions are being raised – and being discussed by regulatory bodies, including the IMO – about the long term effect of BWMS on applied coatings in ballast tanks. This may affect your decision especially considering a system employing active substances. On the other hand, some systems, particularly those employing deoxygenization, are suggesting that these systems might allow the elimination of sacrificial anodes from the ballast tanks, saving millions of dollars over the life of the vessel. More testing needs to be done, however, because at present insufficient evidence exists on the full impact of a particular system on a particular coating or the corrosion that may occur. Curiously, and for the purposes of this article, paint and coating manufacturers declined to comment for the record. Beyond the coatings, the collective effect of active substances on valves, seals and gaskets is not particularly well known at this point, either.
Holding Time: Depending on the typical length of your vessel’s voyage, some treatments requiring time to work – deoxygenization, for example – might not be appropriate for your operational requirements. On the other hand, if your ships typically operate in foreign trades involving long sea passages, then this may not be an issue.
Routing: Will your fleet transit very cold (Arctic), fresh, brackish or salt waters – or, perhaps all four? Some chemicals may not work as well in colder temperatures, and fresh water may require the introduction of brine into the process in the case of electrochlorinization. And those vessels transiting and taking on ballast in particularly muddy and murky waters may not be the best candidates for UV systems that rely upon penetrating the dissolved solids inherent in such ballast. A technical paper available on the U.S. EPA’s website reports, “The transmissivity of the water being treated is another critical variable affecting the effectiveness of UV systems. Without accessory filtration, or other separation of solids, UV will not likely be as effective as necessary.”
Ballast Capacity: An initial problem in the BWT game was the lack of systems that could adequately move ballast fast enough to keep up with commercial considerations, charter parties and in general, operational readiness. Systems do exist today that can meet even the largest vessel’s needs, and some are scalable depending on the size of the vessel itself. Some are not. And, some might increase the cubic footprint of the system significantly, when they do. Is the doubling of capacity creating a system that is twice as big?
The process of assessing the considerable list of BWT alternative is no simple task. Based largely on regulatory and third party reporting, we’ve listed 14 metrics to consider. Chances are; you’ve got more. This is a good place to start. And yes, it is time to get started. More troubling than the possibility of making the wrong decision with regard to your BWT system should be the coming crush of shipowners all trying to get systems installed at the same time. Depending on who you talk to, that global manufacturing capacity may or may not be there. What then?
The Coast Guard BWT standard is here and the ratification of a similar, more mature IMO benchmark is just around the corner. It’s finally time to go shopping. When you do, make sure you’ve done your homework. There may be no “Silver Bullet” but amongst the pack of 63+ (and counting) technologies on the market, there is a certain solution for and your fleet. Finding it is another thing altogether.
+ (Published in the July 2012 edition of MarineNews - www.marinelink.com) +