The development of systems for the onboard treatment of ballast water has been under way since the late 90’s. By water treatment process equipment standards, the market may no longer be embryonic, but it is still in its infancy.
The initial offerings involved the obvious process migration from other high flow treatment applications in the industrial and municipal markets such as UV, electrochlorination, other chlorine compounds, and ozone. This was followed soon after with integrated process systems combining these and other techniques.
Due to the unique operating environment onboard, other methods soon evolved that utilized process equipment from other ship applications such as inert gas and oxygen stripping systems. All of this effort fits a typical pattern of new applications for equipment to meet new environmental and operational requirements.
As we move into the second decade of ballast water process systems engineering and development, we are seeing the introduction of systems that have been developed specifically for this application, rather than the result of “technology transfer.”
This again is somewhat typical of application engineering for systems to meet a specific market niche and its unique circumstances and is often driven internally, from the end user’s perspective.
There are several unique, and rather challenging, forces influencing the further development of systems for this application. At the heart of the issue is the regulatory scenario. Environmental regulation is the driving force behind the demand for systems for ballast water treatment. These systems provide little or no strategic operational advantages to the ships employing them and are purely a tool to achieve compliance.
That said, the rules, while clearly defined, are not yet being enforced and do not require, compliance through the use of systems. Quite to the contrary, nearly all jurisdictions worldwide do not currently accept the treated water from systems to meet the regulatory requirements. Ballast water exchange is still the required and accepted method of ballast water management.
Unfortunately most of the international and domestic requirements include compliance dates that do not take these circumstances into consideration. As a result, those ship owners installing systems to date, and for the foreseeable future, do not use the systems as part of normal ballast operations. This situation is cost prohibitive and inconvenient for the owners and operators. But it is an extremely problematic influence on the evolution of systems.
One of the most important inputs to enable the maturation of such technology is the experience and resulting data that comes from use in “normal practice.” The conditions and all of the associated operational and environmental variables that systems will face on trading vessels cannot be adequately simulated in off ship testing. This real world experience is essential to enable further development of existing technologies and to reveal new opportunities and cultivate innovation.
This has already been observed in the conditions under which systems are tested for type approval. While rigorous, only a limited range of conditions can be practically imposed during these trials. Often these conditions do not adequately represent the operating and environmental conditions the ship will encounter. A case in point is evident in the experience of Transport Canada. Three vessels entering Canadian Great Lakes ports with ballast water treatment systems type approved according to IMO recognized procedures were sampled for compliance to the D2 standard. Each was found to be non-complaint. While many factors could have played a part, the environmental conditions in the Great Lakes are significantly different that those conditions encountered during the approvals testing and may have been the single most influential factor.
Further evidence of this challenging situation can be noted with the withdrawal from the market of the Unitor Ballast Water Treatment System by Wilhelmsen Technical Solutions. While the system was Type Approved, after rigorous evaluations and considerations from the perspective of a highly regarded marine equipment supplier a conclusion was reached that the type approval did not provide adequate assurance of compliance across the broad range of conditions, both environmental and operational that may be encountered by vessels in global trade. The preservation of the Wilhelmsen name and reputation and the responsibility to their clients made the very costly and difficult decision the only prudent option.
At IMO, the situation regarding ratification of the Convention in the near future seems to have reached an impasse. The debate over the Guidelines for Sampling and Analysis for Compliance (G2) for use by Port State Control continues to raise doubts in the minds of major flag States like Panama and Bahamas. The underlying science enabling the development of the methods for sampling and analysis continue to improve, but may take some time to be considered “universally applicable.” Until consensus is reached on these methods, the Convention may continue to languish in its current state.
The issue of the disparity between the methods for testing for approval (G8 & G9) and those methods being considered for compliance evaluations is further complicating the issue. Earlier this year at MEPC 63, International Chamber of Shipping opened the topic of an overhaul of G8 due to this situation. Again this raises concerns about the potential non-compliance of Type Approved systems in use as part of routine ballast operations.
Perhaps a further comparison to the industrial and municipal markets is appropriate. In order to encourage the implementation of new technologies and practices and to gain the operational experience crucial to the refinement of those technologies compliance provisions are often established enabling “experimental use” or interim compliance provisions. This approach alleviates the industry concerns of non compliance resulting from the use of “early generation” systems, yet still provides a first level of environmental protection as a result of their implementation and use.
Like all industries responding to new environmental requirements and breaking new ground in sustainable operations, the shipping industry will endure a period of technology development and maturation. The good news is that with over 50 companies now engaged in the effort, among them global leaders in process systems development, the obstacles will be addressed and overcome. Technology developers must acknowledge their role as “solutions providers” not just equipment sellers in order to take the burden off the ship owners that make an early commitment to fitting their vessels with these new systems.
While in some ways more complex, this scenario has been played out before with ship’s equipment in MSD’s and oil water separators. And we must all accept that, with ever tightening environmental regulations, this will not be the last such situation. With air emissions restrictions already being adopted the next challenge is already on the horizon.
About the Author
Mr. Stewart provides consulting services to government and industry in the areas of ballast water and air emissions. He is a member of the US delegation to IMO and a frequent Chair and speaker at international conferences on the subjects.
(As published in the May 2012 edition of Maritime Reporter & Engineering News - http://www.digitalwavepublishing.com/pubs/nwm/maritimereporter/201205)