Ballast Advisory

8/9/2019 Ballast Advisory

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Ballast Water Treatment Advisory


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Our Mission

The mission of ABS is to serve the public interest as well as theneeds of our clients by promoting the security of life, propertyand the natural environment primarily through the developmentand verification of standards for the design, construction andoperational maintenance of marine-related facilities.

Quality & Environmental Policy

It is the policy of ABS to be responsive to the individual andcollective needs of our clients as well as those of the public atlarge, to provide quality services in support of our mission, andto provide our services consistent with international standardsdeveloped to avoid, reduce or control pollution to the environment.

All of our client commitments, supporting actions, and servicesdelivered must be recognized as expressions of Quality. We pledgeto monitor our performance as an on-going activity and to strive forcontinuous improvement.

We commit to operate consistent with applicable environmentallegislation and regulations and to provide a framework forestablishing and reviewing environmental objectives and targets.


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ABS BALLAST WATER TREATMENT ADVISORY 1

Ballast Water Treatment Advisory

Table of Contents

Introduction

I. Regulatory Developments

a. International Regulatory Status (IMO)

b. Overview of Some Regional, National & Local Regulations

II. BWT Technologies

a. Overview of Treatment Technologies

b. Treatment System Approval by IMO & Member States

III. BWT Considerations

a. Considerations for Selection of Treatment Systems

b. Treatment Technology Factors

c. General Treatment System Considerations

d. Challenges for Installation Engineering

IV. Evaluation Checklists

a. Vessel Ballast System Particulars Owner Supplied Data

b. Ship & Service Characteristics that Impact BWT Selection

Owner Supplied Data

c. Treatment Technology Factors Vendor Supplied Data

d. General Treatment System Considerations Vendor Supplied Data

e. Challenges for Installation Engineering Owner Supplied Data

Appendix: Technical Information for Ballast Water Treatment Systems

DisclaimerThe development and approval of ballast water treatment systems is a dynamic process.The information contained in this ABS Advisory Notice should not be construed as beingall encompassing and readers are urged to contact ABS or review the latest IMO informationavailable to determine the extent to which the status of the various systems included heremay have changed and if other systems have been proposed for review and approval.


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2 ABS BALLAST WATER TREATMENT ADVISORY

The ballast water and sediments carriedby ships have been identified as a majorpathway for the transport of harmful

invasive aquatic organisms and pathogens.Ships often take on ballast water in one portand carry such ballast to other ports where itis discharged. The ballast water and sedimentscontain living organisms which, despite theharsh conditions in the ballast tanks and pipingsystems, survive to compete with native speciesin the port of discharge. If the non-nativeorganisms have few natural predators or othernatural controls they may become invasiveand change the local ecosystems, sometimes

dramatically.

The direct economic impact of aquatic invasivespecies, as well as the potential long termdamage to the health of the local marineenvironment and the people who depend onthat environment, is substantial and has beenwell documented. International, national andregional regulations have been implemented tocontrol the transport of the aquatic organisms.The current efforts rely on ballast water

management (BWM) practices, includingballast exchange, and other measures aimedat preventing or minimizing the uptake and

discharge of contaminated water or sedimentwhen ballasting or deballasting. These methodsmay not be completely effective in preventing

invasive species and furthermore are notrequired if the safety of the vessel would be atrisk during the exchange. Systems that treatballast water to remove or kill organisms arenot only potentially more reliable but aredesigned and installed to achieve measurableefficacy levels while not impacting vessel safety.

This ABS Advisory Notice has been producedto summarize the current state of ballast watertreatment regulations and available technologies

in order to provide useful guidance toshipowners, operators, and builders in theirdecisions about suitable treatment options.This Notice contains five sections:

Introduction

Section 1 Regulatory Developments

Section 2 Overview of Treatment Technologies

Section 3Considerations for System Selection,Installation and Operation

Section 4 Evaluation Checklists

Appendix Available Systems


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Section 1:

RegulatoryDevelopments

International RegulatoryStatus (IMO)

In 2004, the IMO adopted the International Con-vention for the Control and Management of ShipsBallast Water and Sediments. The Convention callsfor ships to conduct a ballast water exchange or tomeet a concentration-based ballast water dischargestandard in accordance with a gradually imple-mented schedule linked to the ships build date andthe amount of ballast carried on board the ship.

Acceptance of the Convention has been slow.Entry into force will occur 12 months after ratifica-tion by 30 States representing 35 percent of worldmerchant shipping gross tonnage. The currentinformation on ratification is included in Table 1.Because of the slow pace of adoption, the imple-mentation deadlines written into the Conventionhave become obsolete before they could becomemandatory. This has required adjustments to the

implementation schedule. This uncertain regula-tory schedule makes it all the more difficult forowners, builders and manufacturers to plan forthe necessary equipment.

Until such time as the Convention enters intoforce and the implementation schedule becomesbinding internationally, action to address the issueof invasive species is increasingly occurring atnational, regional and local levels. More than adozen individual nations, in addition to regions as

diverse as northwest Europe, the Great Lakes andAntarctica, have introduced specific regulationsaddressing the discharge ofballast in their waters. Furthercomplicating the issue,individual local governmentauthorities such as those inCalifornia, Michigan, NewYork and others within theUS, and the State of Victoriain Australia, have introduced

local ballast water managementrequirements. A small numberof these jurisdictions mayprohibit the discharge of

ballast water entirely (Panama within the PanamaCanal), require chlorination (Buenos Aires), orrestrict in-port discharge to an approved onshorereception facility.

Owners are encouraged to contact their relevantflag State, port agents or shipowner association

for the latest specific information on nationalor regional requirements as new and additionalrequirements are being mandated on a regularbasis. The following sections provide informationon the requirements for treatment as outlined inthe IMO Convention. A few significant regionaldevelopments are also provided.

Applicability of the IMO BWM Convention

The 2004 IMO BWM Convention applies to allvessel types operating in the aquatic environmentand designed to carry ballast water that are entitledto fly the flag of a Party to the Convention. Thisincludes submersibles, floating craft and platformsincluding floating storage units (FSUs) and floatingproduction storage and offloading units (FPSOs),although the applicable requirements vary. Refer toTable 1 for a list of Parties to the Convention.

IMO BWM Convention Treatment Standards

The Convention includes two regulations that

prescribe ballast water management standards;Regulation D-1 addresses the Ballast WaterExchange standard and Regulation D-2 details theBallast Water Performance standard.Ballast water exchange is founded on the principlethat organisms and pathogens contained in ballastwater taken on board from coastal waters will notsurvive when discharged into deep oceans or openseas, as these waters have different temperatures,salinity and chemical composition. Similarly thedeep ocean waters or open seas, when comparedto the coastal waters, contain fewer organisms

Table 1: Status of Ratification of the IMO BWM Convention

(As of 1 June 2010)

States % Tonnage Parties to the Convention:

Needed: 30 Needed: 35%Albania, Antigua and Barbuda, Barbados,

Brazil, Canada, Cook Islands, Egypt, France,Kenya, Kiribati, Republic of Korea, Liberia,Maldives, Marshall Islands, Mexico, the

Netherlands, Nigeria, Norway, Saint Kittsand Nevis, Sierra Leone, South Africa, Spain,Sweden, Syrian Arab Republic and Tuvalu.

Currently: 25Currently:24.28%


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Ballast

Cpty(m3)

BuildDate

*First Intermediate or Renewal Survey, whichever occurs first, after the anniversary date

of delivery in the respective year

2009 2010 2011 2012 2013 2014 2015 2016 2017

< 1,500

< 2009

in 2009 Note: D-1; D-2 by 2nd Annual but not beyond 31 Dec. 2011 or EIF, whichever is later

> 2009 D-2 (at delivery or EIF, whichever is later)

> 1,500or

< 5,000

< 2009

in 2009 Note: D-1; D-2 by 2nd Annual but not beyond 31 Dec. 2011 or EIF, whichever is later

> 2009 D-2 (at delivery or EIF, whichever is later)

> 5,000< 2012

> 2012

and pathogens and those that do exist are lesslikely to adapt to the new coastal or freshwaterenvironment. Therefore the probability of organismand pathogen transfer through ballast water issignificantly reduced.As a result, an exchange of ballast water is

performed while the vessel is located in the deepocean. Ships performing ballast water exchange arerequired to do so with an efficiency of at least 95percent volumetric exchange. Acceptable methodsfor ballast water exchange are the SequentialMethod, the Flow-through Method and theDilution Method.

Noting that ballast water exchange presentssignificant operational concerns and challenges,and also that ballast exchange may not provide a

totally effective solution to reduce the spread ofunwanted aquatic organisms and pathogens fromships ballast water over time, the Conventionrequires an upgrade to the installation of ballastwater treatment systems in accordance with aspecified schedule.

The D-2 standard mandates compliance with aspecified biological result. This criterion is in theform of specific limits on aquatic life in the ballastdischarge as detailed:

Ships conducting ballast water management inaccordance with this regulation shall discharge:

Less than 10 viable organism per m3 > 50 inminimum dimension, and

Less than 10 viable organisms per ml < 50and >10 in minimum dimension, and

Less than the following concentrations ofindicator microbes:

Toxicognic Vibrio cholera less than1 colony forming unit (cfu) per 100 ml,

or less than 1 cfu per 1 gram zooplanktonsamples

Escherichia coli less than 250 cfu per 100 ml

Intestinal Enterococci less than 100 cfuper 100 ml

The D-2 standard is the metric used to measurethe efficacy of the treatment system and it appliesto the system as installed on board and used inactual operations. All treatment systems mustbe type approved by an Administration under a

robust protocol which requires that they satisfythis standard in full scale operations. In any portor offshore terminal, an officer authorized by aParty to the Convention may board a vessel towhich the Convention applies and test the ballastwater discharge for compliance by taking samples.

IMO Convention Compliance Timeframe

Table 2 indicates the implementation scheduleof the 2004 BWM Convention as revised byResolution A.1005(25) which addresses shipswith a build date of 2009. This adjustment wasadopted as a result of a review of the entry intoforce provisions of the Convention during the25th Session of the IMO Assembly in November2007 and the stage of development of approved

Table 2: IMO BWM Convention Implementation Schedule

Revised per Resolution A.1005(25)

D-1orD-2 D-2*

D-2*

D-2*

D-1orD-2

D-1orD-2

D-2 (at delivery or EIF, whichever is later)N/A

Note: EIF = Entry into force


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Of special interest to owners and builders are therequirements for ballast water sampling containedin G2 as it impacts ballast system design andoperation. The objective of the G2 guideline is toprovide all parties, including Port State Controlofficers, with practical and technical guidance onballast water sampling and analysis for determiningif the ship is in compliance with the ballastwater management convention. It is importantto note that the G2 guideline discusses generalsampling procedures and does not address the

legal requirements as the legislative proceduresand requirements for enforcement action based onbiological testing are significantly different fromcountry to country. The guideline includes thefollowing important issues related to operationof the treatment system:

It was recognized by IMO that the sampling mustbe simple, rapid and applicable at the point ofballast discharge and safe to the ship and crew.Time needed for the analysis of the collectedsamples shall not be used as a basis for unduly

delaying the operation, departure or movementof the vessel.

The sample is to be taken from the dischargeline, as near to the point of discharge as possible,

during discharge. Note that the G8 guidelinealso calls for sampling points; however, thepoints in the G2 guideline are not just fortesting during the type approval but also forin-service testing. Tank sampling for thosesystems which use a treatment system is notpreferred as the scientific trials have shownthat these samples may not provide accurateestimates of the organism concentration.An exception to this guidance may be whenthe ballast tanks are emptied through direct

overboard discharge valves such as in upperwing tanks.

Isokinetic sampling ports are recommendedso that the sample water is collected atthe same flow rate as the ballast water inthe discharge line, since this will lessenthe likelihood of there being a differencein the organism and particulate matterconcentrations.

Initial and indicative analysis to establishwhether a ship is complying with the D-2

standard may be undertaken by a microscopeand, if further doubt exists, the samples are toundergo a more stringent analysis to establishif the D-2 standard is being met.


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The use of monitoring and in line recordingdevices of physical and/or chemical indicators arebeing proposed and developed as a valid means toverify that the ballast water is adequately treatedand conforms to the ballast water treatmentperformance standard.

Regulation C-1 of the Convention enables a Partyto the Convention, either individually or jointlywith other parties, to take additional measures inaddition to those in the Convention to prevent,reduce or eliminate the transfer of harmfulorganisms and pathogens. In recognizing thepotential impact that such measures may have oninternational shipping, IMO developed the G13guideline. The provisions in this regulation andguideline are interesting in that they allow for theseadditional measures under international Law only

if the MEPC approves these additional measures.The evaluation criteria to be used by the MEPC indetermining whether it grants its approval for theadditional measures to control aquatic invasivespecies in a specified region is if it would adverselyimpact areas adjacent to the region or impactthe safety or commercial nature of internationalshipping activities. It is not certain how regionalmeasures in excess of IMO requirements wouldbe viewed under this guideline. This is potentiallyvery important for those vessels intending to transit

to regions with local requirements, for exampleUS waters.

Guidelines G8 to G10 address the approvalof ballast water treatment systems. These arediscussed in Section 2 of this Advisory Notice.

Overview of Some Regional,

National & Local RegulationsUnited States/USCG

The United States first passed ballast waterlegislation in 1990 as the Nonindigenous AquaticNuisance Prevention and Control Act of 1990(NANPCA). This law established the Coast Guards(USCG) regulatory jurisdiction over ballast watermanagement, mandated a regional ballast watermanagement program for the Great Lakes andcalled for studies to document the need for a

national ballast water management program.

To implement the NANPCA the USCG publisheda final rule in the Federal Register on 8 April1993 wherein 33 CFR Part 151, Subpart C, themandatory ballast water management requirementsfor ships entering the waters of the Great Lakesafter operating outside of the US ExclusiveEconomic Zone were established. These regulationswere extended to portions of the Hudson Riverin 1994. In 1996 the US Congress enacted theNational Invasive Species Act (NISA). This chargedthe USCG with establishing a voluntary ballast



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water management program for all other USports and required vessels to submit ballast watermanagement reports.

In addition, this Act directed the USCG tosubmit a report to the US Congress on theeffectiveness of the voluntary program andto make the program mandatory if the rate of

compliance with the voluntary guidelines wasdetermined to be inadequate. In May 1999 theUSCG published an interim rule in the FederalRegister entitled Implementation of the NationalInvasive Species Act of 1996. This interim rulecreated the mandatory ballast water reportingand recordkeeping requirements and promptedvoluntary BWM practices (including ballast waterexchange) for all vessels entering all waters of theUnited States after operating outside the exclusiveeconomic zone.

In November 2001 the interim rule was amendedand published as a final rule. On 3 June 2002, theUSCG submitted the first ballast water managementreport to Congress wherein it was concludedthat compliance with the mandatory reportingrequirements was insufficient to allow for anaccurate assessment of the voluntary ballast watermanagement program. This report to Congressalso stated that it is the intention of the Secretaryof Homeland Security to have the USCG takeadditional actions to reduce the inflow of aquatic

nuisance species. In June 2004, the voluntaryguidelines of 33 CFR 151, Subpart D were mademandatory for all vessels equipped with ballastwater tanks.

In the last several years there have been a numberof bills introduced in the US Congress that proposea ballast discharge standard. None have yet becomelaw. However, the USCG has recently releaseda notice of proposed rulemaking (FR 44633 28August 2009). The report of proposed rulemakingand regulatory analysis includes an assessmentof the economic impact of treatment standards

between the IMO D-2 levels and levels up to 1,000times more stringent (see Table 3).

The proposed treatment regulation calls for atwo phase implementation schedule. The Phase1 standard is the same as the IMO D-2 and theimplementation schedule is similar to the IMOschedule. Existing ships (those built prior to1 January 2012) with ballast water capacity ofbetween 1,500 and 5,000 m3 will be required tomeet this standard by their 1st dry docking after1 January 2014. Ships with ballast water capacity

of less than 1,500 m3 or greater than 5,000 m3 mustmeet the standard by their first drydocking after1 January 2016. New vessels (those with builddates on or after 1 January 2012) will be requiredto meet it at delivery.

The proposed Phase 2 standard is up to 1000times more stringent than the Phase I (and IMO)standard. The Phase 2 discharge requirements mustbe met by new ships with a build date on or after1 January 2016. For ships with a build date before

1 January 2016, the compliance date is the firstdrydocking after 1 January 2016 or five years aftera Phase 1 system was installed, whichever is later. Apracticability review to be conducted by the USCG

Table 3: Discharge Standards in USCG Proposed Regulation

(August 2009)

Organism SizeUS Proposed LawPhase 1 Standard

US Proposed LawPhase 2 Standard

IMO Regulation D-2

> 50 m in min dimension < 10 viable organisms/m3

< 1 viable organisms/100m3

< 10 viable organisms/m3

< 50 and >10 in min.dimension

< 10 viable organisms/ml < 1 viable organisms/100ml < 10 viable organisms/ml

< 10 m in min. dimension no limit< 103 bacteria/100 ml< 104 viruses/100 ml

no limit

Escherichia coli < 250 cfu/100 ml < 126 cfu/100 ml < 250 cfu/100 ml

Intestinal enterococci < 100 cfu/100 ml < 33 cfu/100 ml < 100 cfu/100 ml

Toxicogenic Vibrio cholerae < 1 cfu/100 ml < 1 cfu/100 ml< 1 cfu/100 ml or

< 1 cfu/gram wet weight

zooplankton samples


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Table 4: Discharge Standards in Current California Law

is also proposed for 2013 to evaluate whetherthe technology to achieve the Phase 2 standard isavailable in order to confirm the future phase entryinto force dates.

While the standards and schedule generally applyto all commercial ships discharging ballast in USwaters, there is a notable exemption for crude oil

tankers engaged in coastwise trade.

Ballast discharges in US ports are further regulatedby the Vessel General Permit (VGP) for theNational Pollution Discharge Elimination System(NPDES) program under the Clean Water Act(CWA). Previously exempted from the NPDESprogram, ballast water discharges in port mustnow be documented and the vessel must followfederal regulation aimed at controlling dischargeof harmful or invasive elements within the ballastwater. Treatment is not explicitly required and

there is no treatment standard in US Federalregulatory regime in the current VGP. However, theCWA allows each individual State to add specificprovisions, including performance standards, to theVGP. A treatment system that uses active substances(chemicals or biological agents) would be subjectto scrutiny under the Clean Water Act.

California

Californias Marine Invasive Species Act (2003)established the Marine Invasive Species Programand directed a state agency to develop performancestandards for ballast water discharge. In 2006 theState passed the Coastal Ecosystems Protection Act

(SB497) which incorporated the recommendedstandards and made them mandatory. Theimplementation schedule was initially set to matchthe IMO schedule. In 2008, a review requiredby the law of available treatment technologiesrecommended that the implementation date fornew ships be delayed one year to 2010.

As shown in Table 4, the California standards aremuch more stringent than the IMO standards andsimilar (but not identical) to the Phase 2 standardrecently proposed by the USCG (see Table 3). TheCalifornia law includes very explicit guidelines forsampling points and methods.

Further, note that California law currently sets afinal discharge implementation date of 1 January2020 that specifies zero detectable living organismsfor all size ranges in the ballast discharge stream.

Others

In the US, some Great Lakes states such as Illinois,Indiana, Minnesota and Ohio, are also consideringtheir own discharge standards in line with theIMO D-2 requirements. In addition to California,New York and Pennsylvania have moved into lawdischarge standards that exceed IMO D-2.

Several other Administrations have passed lawsregulating ballast water that include provisionsfor best practices and ballast exchange. Some arealso considering discharge standards in line withthe IMO D-2 requirements as they consider theirdecision to ratify the 2004 IMO Convention.

Organism Size California Law IMO Regulation D-2US Proposed LawPhase 2 Standard

> 50 m in min. dimension No detectable living organisms < 10 viable organisms/m3 < 1 viable organisms/100 m3

< 50 and > 10 in min.dimension

< 0.01 living organisms per ml < 10 viable organisms/ml < 1 viable organisms/100 ml

< 10 m in min. dimension< 103 bacteria/100 ml< 104 viruses/100 ml

no limit< 103 bacteria/100 ml< 104 viruses/100 ml

Escherichia coli < 126 cfu3/100 ml < 250 cfu/100 ml < 126 cfu/100 ml

Intestinal enterococci < 33 cfu/100 ml < 100 cfu/100 ml < 33 cfu/100 ml

Toxicogenic Vibrio cholerae

< 1 cfu/100 ml or< 1cfu/gram wet weight

zoological samples

< 1 cfu/100 ml or< 1 cfu/gram wet weight

zooplankton samples

< 1 cfu/100 ml


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Section 2

BWT TechnologiesThis section of the Advisory Notice providesan explanation of treatment technologiescurrently being developed, the regulatory approvalprocess certifying vendor-supplied equipment ascompliant with the regulation, and a list of availablesystems currently on the market as ofthe date of publication of this document.

Overview of TreatmentTechnologies

IMO defines ballast water treatment equipment as:

the equipment which mechanically,physically, chemically or biologically processeseither singularly or in combination to remove,render harmless or avoid the uptake ordischarge of harmful organisms or pathogens.Ballast water treatment equipment may operateat the uptake or discharge of ballast water,during the voyage, or at a combination ofthese events.

Types of Treatment TechnologiesThe technologies currently available or beingdeveloped can generally be grouped under threebroad categories based on their primary mechanismfor rendering the organism inactive: mechanical,physical and chemical. These groups and the morepromising technologies related to each are shown inFigure 1 and described briefly in the following text.

Mechanical Systems

Filtration sediment and particles are removedwith disk and screen filters during ballast intake.They are often self-cleaning with a back-flushingcycle. The waste stream is directed overboardback to the water source. These filtration systemscreate pressure drops and a reduced flow rate dueto resistance in the filter elements and the self-cleaning procedures.

Cyclonic separation solid particles areseparated from the water due to centrifugalforces. Only those particles with a specific gravitygreater than that of water can be separated.

Electro-mechanical separation a flocculent isinjected that attaches to organisms and sediment.Magnetic separation and filtration is used toremove the solid particles.

Physical Disinfection

Ultraviolet light UV radiation is used toattack and break down the cell membranekilling the organism outright or destroying itsability to reproduce. The effectiveness dependson the turbidity of the ballast water (i.e. theconcentration of sediments) as this couldlimit the transmission of the UV radiation. UVlights are required to be maintained and powerconsumption needs to be considered.

Cavitation/ultrasounds venturi pipes or slitplates are used to generate cavitation bubbles andthis high energy bubble creation and collapseresults in hydrodynamic forces and ultrasonicoscillations, or high frequency noise, whichdisrupts the cell walls of organisms effectivelykilling them.

Figure 1: Treatment Technology Types

Mechanical Systems Physical Disinfection Chemical Treatment

Electro-mechanicalSeparation

Deoxygenation

Filtration Ultraviolet Light Disinfecting Biocides

Cyclonic Separation Cavitation Electrolytic Chlorination


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De-oxygenation various methods areused to remove thedissolved oxygenin the ballast waterand replace it withinactive gases, such

as nitrogen or otherinert gas. Removingthe oxygen not onlykills the aerobic organisms but it can also havebenefits for corrosion prevention provided thatthe oxygen content is maintained at the correctlevels. De-oxygenation can require a prolongedperiod in order to render the organisms andpathogens harmless to the receiving waters.

Chemical Treatment

Chemical biocides pre-prepared orpackaged disinfectants designed to bedosed into the ballast flow and kill the livingorganisms by chemical poisoning or oxidation.Typical biocides include chlorine, chlorideions, chlorine dioxide, sodium hypochloriteand ozone. Residual biocides in the ballastwater must meet ballast discharge standardswhich may necessitate neutralizationtechniques.

Electrolytic chlorination electrical current isapplied directly to the ballast water flow in anelectrolytic chamber, generating free chlorine,sodium hypochlorite and hydroxyl radicals,causing electrochemical oxidation through thecreation of ozone and hydrogen peroxide. Thismethod is limited in effectiveness to seawaterhaving a certain level of dissolved salt and,could also create unwanted residuals.

Types of chemical treatments include ActiveSubstances or Preparations. The official defini-tions given in the BWM Convention are asfollows:

Active substance a substance or organism,including a virus or a fungus that has a generalor specific action on or against harmful aquaticorganisms and pathogens.

Preparation any commercial formulationcontaining one or more active substances in-cluding any additives. This term also includesany active substances generated on board for

the purpose of ballast water treatment and anyrelevant chemicals formed in the ballast watertreatment system that make use of active sub-stances to comply with the BWM Convention.

Technical Challenges& System Combinations

The treatment technologies differ in methodand rate of application, scalability, holding time(required for kill rates and safe discharge), powerrequirements, effects on other ship systems orstructure (corrosion), inherent safety and costs ofoperation. In many cases their efficacy varies withconditions of the ballast water, flow rates, volumeof water treated and holding time. There are alsoissues of whether treatment is done at intake, whilebeing held on board, at discharge,or a combination of the three times.

For instance, filtration, separation and UV radiationare done during ballast loading and discharge andare sized for the maximum flow rate in the ballastsystem. Conversely chemical biocides and de-oxygenation are usually applied to attain a certain

concentration in the water in the ballast tanks. Theefficacies of these systems do not depend so muchon the flow rate of the pumps as the time the ballastis allowed to remain in the tanks to achieve thedesired kill rate. Short voyages can be a problemfor these technologies.

Matching the treatment technology to the shiptype, or more accurately the ballast system type,and vessel service is the key to designinga successful ballast water treatment system.

To overcome the limitations of a particular technol-ogy many proposed treatment systems are basedon a combination of two or more technologies.Although there are approved chemical disinfectiononly treatments, these are also combined with someform of pre-treatment to make them more effectivefor certain vessel or ballast conditions.

The most prevalent system types are ones thatcombine mechanical separation/filtration with

UV radiation or chemical disinfection. The initialmechanical separation/filtration is used to removethe larger organisms in order to increase theeffectiveness of the secondary treatments.


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Treatment System Approvalby IMO & Member States

IMO Approval Regime

Regulation D-3 of the BWM Convention requiresthat the ballast water treatment systems must beapproved by the Flag State Administration and forthose treatment systems which make use of activesubstances or preparations, by the IMO as well. Itis important to note that the Convention requiresthat discharges of ballast water from ships mustmeet the D-2 performance standard on an ongoingbasis.

However type approval of a ballast treatmentsystem should not be considered as an indicationthat a given system will work on all vessels in all

situations. Even after installing a type approvedsystem, the owner/operator is still responsiblefor compliance of the discharge throughout thevessels life.

To achieve consistency in the approval process,IMO has prepared several Guidelines.

G8 Guidelines for Approval of Ballast WaterManagement Systems

Resolution MEPC.174(58)

G9 Procedure for Approval of BallastWater Management Systems that

Make Use of Active Substances

Resolution MEPC.169(57)

G10 Guidelines for Approval and Oversightof Prototype Ballast Water TreatmentTechnology Programs

Draft Resolution MEPC.140(54)

These guidelines outline the approval frameworkand a uniform manner of testing, analysis ofsamples and evaluation of results. G8 and G9together address the approval required underRegulation D-3 of the Convention. G8 addressesthe suitability and efficacy of the system. In addi-tion, where it can be reasonably concluded thatthe treatment process could result in changes tothe chemical composition of the treated watersuch that adverse impacts to the receiving watersmight occur upon discharge, additional testingwill be required by the G8 Guidelines. G9 ad-dresses the acceptability of any active substancesand preparations for use in ballast water treatmentsystems concerning ship safety, human health andthe aquatic environment. G9 is provided as a safe-guard for the sustainable use of active substancesand preparations.

To encourage the development of new ballastwater treatment technologies, the Conventionincludes an allowance for short term approval of a

treatment system that undergoes prototype testingaccording to G10. For any ship that participates in



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a prototype testing program, the requirements ofRegulation D-2 shall not apply until five years afterthe date the equipment was installed or five yearsafter the date on which the ship would otherwisebe required to comply with D-2, whichever is later.

The G8/G9 approval process is a robust and

lengthy process requiring approximately oneyear to complete. It includes the following:

Documentation review and approval of thedesign and construction of the system anddetermine if there are any fundamentalproblems that might constrain the ability of thesystem to manage ballast water or operate safely.

Successful compliance with environ-mentaltesting by an approved laboratory of all systemcomponents. This testing

is to include specified limits of vibration,temperature, humidity, fluctuations in powersupply, inclination and, if applicable, protectionfrom green water impact.

Land-based testing to confirm that the systemcan meet the D-2 standard for a range ofwater conditions (fresh, brackish and sea).The land-based approval testing is intendedto provide replicability and comparabilityto other treatment systems. Any limitationsimposed by the treatment system on the testing

procedure should be noted and evaluated bythe Administration in its consideration for typeapproval. In some situations, the land-basedtesting can be done on scaled-down equipment.

Shipboard testing of a complete, full scalesystem throughout a full ballast cycle (uptake,storage, treatment, and discharge). At least threeconsecutive successful test cycles that complywith regulation D-2 are required over a periodnot less than six months.

Once the technical review and testing are com-pleted to the satisfaction of the Administrationand the Administration is satisfied that the qualityassurance program employed by the manufacturerwill mean that the equipment can be producedconsistently to the required specification, a TypeApproval Certificate may be issued. When a typeapproved ballast water treatment system is in-stalled on board a vessel, an installation surveyis conducted to confirm that the system has beeninstalled as designed, is ready for operation, and

conforms to the Type Approval Certificate. Uponsuccessful completion of the installation survey,a BWM Certificate may be issued as required bythe Convention.

Systems with active substances or preparationsmust undergo the additional approval processcontained in the IMO G9 Guideline to verify thatthe potential hazardous properties of the activesubstance or preparations or relevant chemicalsformed in treated ballast water do not create

any unreasonable risk to the ship and personneland that the ballast water is no longer toxic. Thetoxicity testing is needed to confirm that theactive substance or preparation used does notcause conditions which have the potential ofharming the receiving environment or humanhealth.

The additional approval required under the G9uses a two-tier methodology consisting of a Basicand Final Approval.

Basic approval confirms that, based on theinformation available, there are no unacceptableadverse effects, nor a potential for unreasonablerisk to the environment, human health,property or resources. It includes screeningfor persistency, bioaccumulation and toxicity.Testing is conducted in a laboratory underconditions simulating ballast water dischargefollowing treatment.

Final approval confirms the previousevaluations of risks to the ship, crew and the

environment including the storage, handlingand application of active substances orpreparations, remain valid and the concernsexpressed during the basic approval process


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IMO. This technical group is the Group of Expertson the Scientific Aspects of Marine EnvironmentalProtection Ballast Water Working Group

(GESAMP-BWWG). The GESAMP-BWWG makesa recommendation to the IMO MEPC which, onthe basis of the GESAMP-BWWGs report, willconfer approval on a treatment system that usesactive substances.

The overall approval process is summarized inTable 5. Shaded parts (G9) can be omitted for

systems not using active substances(e.g., de-oxygenation or ultrasonic).A more complete flow chart ofthe approval process is shown inFigure 2.

Verifying Equipment Approval

Any system which is being consideredfor installation on board a ship shouldhave a valid Type Approval Certificatein the proper form and signed bythe Administration. This certificateshould:

Identify the type and model of the

system, related equipment assemblydrawings and model specificationnumbers;

Include a reference to the fullperformance test protocol onwhich the approval is based andbe accompanied by a copy of theoriginal test results;

State the specific application forwhich the treatment system isapproved, e.g. for specific ballast

water capacities, flow rates,salinity or temperature regimes,or other limiting conditions orcircumstances as appropriate.

have been addressed, as well as the residualtoxicity of the discharge conforms to theevaluation undertaken for basic approval. Inaddition a risk evaluation is performed at thefinal approval to qualitatively account for thecumulative effects that may occur due to thenature of shipping and port operations.

Both steps involve not only review by theAdministration, but also a direct and completereview by a special technical group set up within

Table 5: Ballast Water Treatment System Approval Process Overview

Approval Process for ManufacturerShip Specific

Approval

Key Steps inApproval Process

Documentation

Review& Approval

Basic Approvalfor Active

Substances(G9)

SystemApproval Land& Shipboard

Testing

Final Approvalfor Active

Substances(G9)

Type ApprovalCertificate

InstallationSurvey

ApprovalAuthority

AdministrationGESAMP-

BWWG, IMOAdministration

GESAMP-BWWG, IMO

Administration Administration



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Figure 2: Flow Chart of Ballast Water Management System Approval

BWM System(treatment, control & monitoring)

Yes

Yes

No

Yes

Yes

Yes

Yes

No

No No

G(9)

G(9)

G(8)

Type

Approval

Prototype

Testing G(10)

Yes

Yes

No

NoYes

Resultsmay

beused

No

No

No

Yes

Yes

No

No

Manufacturer testsfound satisfactoryby a government

BWNS includes activesubstances

Basic approval oractive substancesgranted by IMO

Land-based testingto D-2 standardis satisfactory

Shipboard testingto D-2 standardis satisfactory

BWMS includesactive substances

BWMS adversely changeschemical composition

of treated water

Shipboard testingto evaluate against

D-2 standard

All BW dischargedduring test period

meets D-2 standard

Ship issued BWMCertificate after functional

test of BWMS

Documentation review & approval by a government

BMW system testprotocol options

Final approval foractive substancesgranted by IMO

Government grantstype approval

of BWMS

Type Approved BWMScan be installed on board

any ship


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Table 6: BWM System Approvals as of MEPC 60Approval Status of BWM Systems using Active Substances (G9)

Treatment System Approval Status

The following tables summarize the current basic, final and type approval status of record. Systems thathave received final and/or type approval are described more fully in the Appendix of this publication.

System Name Proposed By Approval Type Approved By

PureBallast System Norway Basic & Final MEPC 56

SEDNA-Ocean BWM System using PERACLEAN Ocean System GermanyBasic MEPC 54

Final MEPC 57

OceanSaver BWM System NorwayBasic MEPC 57

Final MEPC 58

Electro-Cleen System (Electrolytic Disinfection) KoreaBasic MEPC 54

Final MEPC 58

RWO BWMS (CleanBallast) using EctoSys Electro-chemical System GermanyBasic MEPC 55

Final MEPC 59

NK-03 Blue Ballast System (Ozone) KoreaBasic MEPC 56

Final MEPC 59

Hitachi BW Purification System (ClearBallast) JapanBasic MEPC 57

Final MEPC 59

Hamworthy Sedinox BWMS NetherlandsBasic MEPC 58

Final MEPC 59

Resource Ballast Technologies System (Unitor) South AfricaBasic MEPC 57

Final MEPC 60

GloEn-Patrol System KoreaBasic MEPC 57

Final MEPC 60,

JFE BallastAce (in cooperation with TG) JapanBasic MEPC 58

Final MEPC 60

HHI BWMS (EcoBallast) Republic of KoreaBasic MEPC 59

Final MEPC 60

FineBallast Ozone System Japan Basic MEPC 55

Ecochlor BW Treatment System Germany Basic MEPC 58

Blue Ocean Shield BWMS China Basic MEPC 59

AquaTriComb BW Treatment System Germany Basic MEPC 59

SiCURE BWMS Germany Basic MEPC 60

Sunrui BWMS China Basic MEPC 60

DESMI Ocean Guard BWMS Denmark Basic MEPC 60

Blue Ocean Guardian (BOG) BWMS Republic of Korea Basic MEPC 60

HHI BWMS (HiBallast) Republic of Korea Basic MEPC 60

KS BWMS (En-Ballast) Republic of Korea Basic MEPC 60

OceanGuard BWMS Norway Basic MEPC 60

Severn Trent DeNora BalPure Germany Basic MEPC 60


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Table 7: Ballast Water Management Systems with Type Approval Certification (G8)

ApprovalDate

Name ofAdministration

Name of the BallastWater Management

System

Active SubstanceEmployed

1 June 2008Norwegian

AdministrationPureBallast System

Free radicals Cl2-, ClB-,Br2- and CO3-

(Refer to MEPC 56/2/2,Annex 5)

2 June 2008Federal Maritime andHydrographic Agency,

Germany

SEDNA BWMS(Using Peraclean

Ocean System)(temporarily withdrawn

from the market)

PERACLEAN Ocean(Refer to MEPC 57/2/10,

Annex 7)

3 September 2008Office of the Maritime

Administration,Marshall Islands

NEI Treatment SystemVOS-2500-101

None Used

4 December 2008

Ministry of Land,Transport and

Maritime Affairs,Republic of Korea

Electro-CleenTM System

HOCl (OCl-), HOBr (OBr-).O3 (H2O2), OH-


5 April 2009Norwegian

Administration

OceanSaver Ballast WaterManagement System

(OS BWMS)

HClO, Cl2, O

3, H

2O

2, ClO

2

and ClO-


6 April 2009 The United KingdomHyde GUARDIANTM

Ballast WaterManagement System

None Used

7 November 2009



NK-O3 BlueBallast System(Ozone)

O3


8 November 2009Norwegian

AdministrationOptiMarin Ballast System None Used

9 December 2009



GloEn-PatrolTMMPUV irradiation


10 March 2010Maritime Bureau, Ministryof Land, Infrastructure,Transport and Tourism ofJapanese Government

Hitachi ClearBallastPAC, Fe3O4 and PASA



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Section 3

ConsiderationsThis section has been prepared to summarize forvessel owners, operators and builders the practicalrealities of shipboard ballast water systems sothat they can be in a better position to evaluatetreatment technology options and plan for theirinstallation. Included are discussions of the keyfeatures of ships ballast water handling systemsand practices, and the features of the varioustreatment technologies that will have an importantimpact on the ship or ballast practices and costs.

Considerations for Selection

of Treatment Systems

Overview

Ballast water treatment is still an evolving technol-ogy with an ever-growing number of manufacturersdeveloping systems to meet the anticipated regula-tory requirements. Readers are urged to contactABS or review the latest IMO information todetermine the current status of treatment systemapprovals. This current situation means that thereis limited in-service experience for the systems

being offered and there is a general understandingthat no single system is suitable for all ship types orservice. The owner/operator must make a consid-ered choice for the ballast water treatment that bestsuits the demands of the ship and service taking

into account vendor specifications and the extentof shore side and shipboard testing carried out dur-ing the type approval process. A careful engineeringanalysis of the following factors bring order tothe decision-making process. These issues arediscussed in some detail as follows.

Ship and Vessel Service Characteristicsthat Impact BWT Selection

Ship type and capacity

Ballast water handling practices includingNOBOBS (no ballast on board ships)

Ballast water characteristics

Vessel service characteristics

Ballast system characteristics

Treatment Technology Factors Treatment method

Treatment system pressure drops

Equipment size and space requirements

Materials, equipment protection (IP rating)and hazardous spaces

Power requirements

Impacts on ballast tank and pipe corrosion

Health and safety (handling, operation and

maintenance)

General Treatment System Considerations

Proven efficacy and official approvals

Vendor qualifications and reputation

Maintenance requirements and systemreliability

Simple operation (control and monitoring)

Life cycle costs

Challenges for Installation Engineering Intake/discharge isolation

(cross-contamination)

Sampling and in-service testing

Maintaining ballasting flexibility

Ship Type & Capacity

In most instances, the ship type will be thelargest single determinant in selecting asuitable treatment system. For this purpose

it is convenient to consider two groups of shiptypes: high ballast dependent ships such astankers and bulkers; and low ballast dependentships such as containerships, general cargo ships,



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and cruise ships. These groupings are basedon differences in total ballast capacity, amountof discharge at any one port and ballast flowrates.

As the data in Table 8 indicates, there is a widerange of ballast capacities and pumping rates

common to the commercial ship sector. Notably,the high ballast-dependent vessels regularly sailin ballast only conditions (without cargo). Theirpump rates are designed to allow full load ordischarge in a fixed period of time to facilitaterapid port turnaround times (typically 12, 18 or24 hours for ballast operations). The low ballastdependent vessels generally have smaller ballastcapacities and also may rarely undertake a ballastonly voyage. Their pumps do not typically haveto handle a full load of ballast on a regular basis.

Movement of ballast is more limited and often isa shift (one tank to another to adjust trim or heel)rather than a simple full ballast load/dischargeoperation.

Ballast Water Handling Practices

The proper sizing of a treatment system dependson the amount of ballast that has to be treatedat any given port, more so than the total ballastcapacity or maximum flow rate. If, through activeballast management, discharge can be reduced

or eliminated then treatment demands decrease.For example, most containerships rarely need todischarge a full ballast load at any one time.

It also should be noted that a large amount ofthe treatment system prototype testing is doneon moderately sized systems (< 250 m3/hour)or is scaled up from other industries and not allsystems scale up well to the sizes required for thehigh ballast capacity pumping rates or volumesof several thousand m3/hour.

Another ballast practice issue that impactstreatment selection is how accumulated mud andsilt in the ballast tanks is addressed. This residueitself can contain invasive species even when thetank is empty of water (a NOBOB no ballast onboard condition). Even if ballast is loaded locallyit can become contaminated by the residue in thetank. This may necessitate the treatment of ballastwater on discharge as well as loading. If there islittle mud accumulation and the tanks are cleaned

regularly, this may be less of a concern and thetreatment system can be selected accordingly.For those ships constructed in or after 2009,compliance with G12 guideline is to be applied.

Ballast Water Characteristics

Turbidity, salinity and silt content can impactthe efficacy, maintenance or reliability of sometechnologies. If regular calls in a port are plannedwhere the water has high mud/silt content or has alow salt content (fresh or brackish) this should beconsidered in the treatment technology selection.

Vessel Service Characteristics

The vessel service or trade route may also becritical for treatment system selection. For example,

certain ship types may not be discharging ballastin the US so there will be no concern for USregulations and the key regulatory requirementand efficacy standards will be those from IMO. Iftreatment options for local requirements are tooexpensive, then operators trading to those areasonly occasionally may opt to forego shipboardinstallation of additional treatment capability andinstead adjust their ballast management to avoiddischarge or pay high use costs for a shore/portbased system (where available).

Common Ballast System Characteristics

There are also a number of other vessel featuresrelated to ship type that are not exclusive to thehigh/low ballast dependent categorization definedabove yet have an impact on treatment systemselection. These include the number of separateballast systems (e.g., oil tankers often have two,one in way of the cargo area and one aft of thecargo), whether eductors are used to supplementballast discharge, small or crowded engine rooms,

or explosion proof ballast equipment requirements.How these features represent design challenges fortreatment systems are discussed in the followingsections.

Diagram of Ballast Water Management System


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Table 8: Ballast Water Capacity & Ballast Pump Rates by Vessel Type

Vessel Category Vessel TypeRepresentative Ballast

Capacity (m3)RepresentativePump Rate (m3)

High BallastDependent

Vessels

Bulk Carriers

Handy 18,000 1,300

Panamax 35,000 1,800

Capesize 65,000 3,000

Tankers

Handy 6,500 1,100

Handymax-Aframax 31,000 2,500

Suezmax 54,000 3,125

VLCC 90,000 5,000

ULCC 95,000 5,800

Low BallastDependent

Vessels

ContainershipsFeeder 3,000 250

Feedermax 3,500 400

Handy 8,000 400

Subpanamax 14,000 500

Panamax 17,000 500

Postpanamax 20,000 750

Other Vessels

Chemical Carriers 11,000 600

Passenger Ships 3,000 250General Cargo 4,500 400

Ro/Ro 8,000 400

Combination Vessels 7,000 400

Note: Representative values are nominal values that reflect a combination of data sources and vessel sizes in each category.

Treatment Technology Factors

The second most important set of factors inselecting a suitable treatment system, after shiptype and service, are the operating characteristicsand requirements of the individual treatmenttechnologies. As noted in Section 2 of thisNotice, BWT Technologies, there are numeroustechnologies being actively researched andimplemented that should be able to meet at leastthe IMO discharge standards. These technologiesdiffer in method and rate of application, scalability,required holding time, power and related systemrequirements, impacts on corrosion and inherentsafety. Each ships design, as well as an owners

particular operating practices and internal riskassessments, will determine how important eachof these factors is in the selection process. Takentogether, these factors and how the treatment

systems address them, indicate the level of analysisrequired for effective implementation of theparticular treatment system.

In any case, the following endeavors to describethe more important factors to help provide aframework for system consideration.

Treatment Method

The methods and technologies being consideredfor ballast water treatment can be grouped by basicapproach as follows:

Mechanical systems (filtration or separation)

Physical disinfection (UV radiation, cavitation,de-oxygenation, etc.)

Chemical treatment (biocides and electro-chlorination)


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less than 1 bar to about 2 bar. In some cases,back pressure valves may need to be added tothe system after a separator to provide sufficientbackpressure for clearing out sludge and/or self-cleaning. If the installation requires significantlengths of new ballast piping and valving thensome additional pressure drops will be introduced

that could prove significant.

The self cleaning or back-flushing operation willredirect some of the ballast flow directly overboardand reduce the flow rate into the tank further.Some cyclones redirect as much as 5 percent to10 percent of the flow stream for sludge removal.

The pressure drops and self cleaning process willimpact in-service flow rates and system designpressure. For most ships it is not expected that

ballast pumps will need to be upgraded. However,the actual flow rates of ballast delivered to thetanks achievable with the selected system mustbe used when evaluating ballasting times andoperation of the treatment system. It could be thatballasting with some treatment systems with highpressure drops and self-cleaning systems couldtake 20 percent longer than ballasting withouttreatment.It should also be noted that at some level of

additional system resistance, gravity ballastingmay no longer be feasible because the pressuredifferentials with the sea water are reduced andacceptable flow rates cannot be maintained.Some separation equipment simply cannot runwithout sufficient system pressure drop. This willultimately increase the total power required forthe ballasting operation because the main pumpswill have to be operated for a longer period.

Each system has a few fundamentalcharacteristics that impact its suitability forcertain ship types, service or flow rates. Most ofthe treatment systems use a combination of twoor more of these technologies to overcome anindividual technologys shortcomings.

Mechanical SystemsThese require redirecting the full ballastflow through filters, hydrocyclones or otherseparators. For high volume applications, the sizeof the equipment required can be problematic. Ifthey are used during ballast discharge, the filtratemust be maintained on board. High sedimentloads can cause problems for filters.

Physical DisinfectionUltraviolet radiation and cavitation require

processing of the entire ballast flow but holdingtime is not required as treatment is completeonce the water passes through the equipment.UV exposure is usually done at both intake anddischarge. Its effectiveness degrades with cloudyor turbid water that restricts light penetration.De-oxygenation can be done at intake to thefull ballast flow or directly in the ballast tankswith bubblers. However, the full kill rates maytake several days to achieve so the ballast tanksmust also have a closed vent system and be fully

inerted.

Chemical TreatmentThese treatments are dosed into the existingballast piping during intake or directly into theballast tanks. The dosage rates must be adjustedto provide the desired kill rate. The chemicals areusually lethal within several hours of treatmentso long holding times are not required. However,the chemicals must beneutralized or be allowedto become biologicallyineffective before the ballastwater can be consideredsafe for discharge.

Treatment SystemPressure Drops

The treatment systems thatprocess the full ballast flowthrough filters, separationsystems or venturis, create

added resistance to ballastflow. The pressure drops forsuch elements vary, withmost systems claiming from



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Equipment Size & Space Requirements

Treatment systems come in all shapes and sizes.The footprint requirements can vary from 1 to25 m for a system that can handle 200 m3/hour.For a 2,000 m3/hour system the space requirementscan be 1 to 100 m. Systems that use filtration or

require generating equipment for disinfection, inertgas generators for example, tend to increase in sizewith ballast flow rates more than other systems thattreat with chemical dosing.

Another very important space consideration isthe ballast piping itself. If the treatment systemrequires new branch lines to be installed, this cansometimes have an even greater impact on thespace requirements than the treatment equipmentitself. In most engine rooms, the ballast pipingis the largest pipe used. On small containerships

with medium capacity pumps it can be over 250mm. In the high ballast capacity ships it can easilybe over 500 mm diameter. It can be a challengeto find room for tie-in points to the manifold area

around the ballast pumps as well as space in theER to run significant lengths of pipe to remotelocations if sufficient room for a piece of treatmentequipment is unavailable. Systems that do notrequire redirecting main ballast flow certainly havean advantage in this case.

In addition to the total or overall size of thetreatment equipment, the systems modularity mayalso impact the ease with which it can be installedin an existing engine room. Taking delivery of asystem preassembled on a skid and expecting it tobe installed in a single lift is unrealistic unless it isgoing in at new construction. To reduce installationcosts and time, system components will usuallybe lifted and fitted separately. So the ability of asystem to be easily broken down into modules ofconvenient size and located in various areas in theengine room gives the installer many more options

for completing the work.

Not to be overlooked in the search for space forsystem installation is the need to provide for

Table 9: Important Treatment Method Characteristics

TreatmentProcess

Method of Treatment When AppliedTime forLethality

Effort onCorrosion

ChlorineGeneration

Use electrolytic cell to generate chlorine and brominethat act as biocides. Next, sodium sulfate neutralizes

the ballast water prior to discharge. As long as freechlorine exists in the tank, biocide will be active so

dosage can be adjusted to keep biocide always active.

At uptake and

neutralize atdischarge

Hours

High dosage levels

promote steelcorrosion

ChemicalApplication

Mix proprietary chemicals with the ballast waterin metered dosage rates at intake to kill livingorganisms. Chemicals degrade over time so

ballast will be safe to discharge.

At uptake via eductor 24 hoursHigh dosage levels

promote steelcorrosion

Filtration &

Radiation

Filtration of the incoming water, usually withself-cleaning 50 micron filters, in parallel with discharge

of filtrate to the waters where intake takes place.

Ballast water is exposed to a form of radiation, such asUV energy or other hydroxyl radical generator,

to kill smaller organisms and bacteria.

At uptake for filterand UV and at

discharge for UVAt treatment No effect

De-oxygenation

Mix inert gas generated on board with the ballastwater, either by a venturi eductor or by bubbling from

pipes in the tanks. This removes oxygen from the waterand lowers pH, therefore killing the living organisms.This process requires the atmosphere in the ballast

tank be maintained in an inert condition.

At uptake for somesystems and in tanks

for others4 to 6 days

Relatively lesscorrosive

OzoneGeneration

Ozone is generated on board and acts as a biocide.It is applied during the ballast pumping process by

eductor either at uptake or discharge. It can

be combined with filtration or other methodsof treatment.

At uptake forsome systems and

at dischargefor others

Up to 15 hours

Limited effect asozone has shortlife. If treated

at discharge, noeffect.


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adequate access to the equipment for maintenance.This can include ladders and platforms, additionallighting, lifting eyes or crane rails, space forstorage and handling of consumables andcleaning of internal components (as required).Space requirements for storage and handling ofchemicals used in treatment systems should also

be considered. This space can be outside theengine room and may require fire fighting system,ventilation system, etc. Requirements related to theMaterial Safety Data Sheet (MSDS) are describedlater in this Advisory Notice.

Materials, Equipment Protection (IP Rating)& Hazardous Spaces

A ballast water treatment system must meet allthe normal requirements for shipboard materials,

equipment protection and hazardous space safety.The materials used in the system componentsand the level of equipment protection (IP rating)provided should be reviewed at the type approvalstage and certified as to be in compliance with theClass requirements for similar equipment installedin similar locations on board. One importantaspect of this approval is review of the materialsfor fire rating if the review authority deems thetreatment system an essential system. In that case,some plastic pipe materials may not be allowed.

Additionally, valve materials and remote operation/shut downs may be required. These issues are notnormally a concern for shipowners, unless theywish to specify higher grade materials for longerdesign service life and lower maintenance costs.

Critical to selecting a system however, is anunderstanding of the restrictions that may beplaced on equipment location due to the specificregulations regarding the class of equipment thatcan be placed in a hazardous space. Equipmentplaced in the engine room does not have specialexplosion (EX) requirements whereas equipmentin the pump room of an oil tanker must beintrinsically safe (EX ia or EX ib), except thatexplosion proof lighting enclosures and lightsare allowed in pump rooms. Further, ballast fromtanks adjacent to cargo oil tanks cannot be runthrough pipe in the engine room. Large treatmentsystems or ones that use UV lamp banks (whichcannot be made intrinsically safe) may find theserequirements especially difficult to overcome.

Recent rule developments have opened up thepreviously strict interpretations of the electricalequipment requirements by allowing, ...electricalequipment, cables and wiring which do not

conform to the standards may be installed inhazardous locations based on a risk assessment tothe satisfaction of the Administration, to ensurethat an equivalent level of safety is assured.(Refer to the amendment to SOLAS Reg. II-1/45.11which entered in force on 1 July 2006 for shipsconstructed after 2007.) The installation of non-

intrinsically safe equipment in the pump roomcould be considered on a case by case basis takinginto consideration the equipment within thepump room, the arrangement of the equipment,the number of air changes, etc., subject to thestandards, interpretation and risk assessmentapproach of the approving authority.

Power Requirements

Electrical power consumption by ballast water

treatment systems is potentially a significanthurdle for some technologies on the high ballastdependent ships. Large power consumers such asUV light banks, electrolytic chlorination systemsand de-oxygenation systems can require 150 toover 200 kW for a 2,000/m3 treatment flow rate.If these systems must operate when other largeshipboard consumers are also operating, totalship service electrical generating capacity maybe insufficient.

The large electrical loads are also the mainoperating cost for these systems. In contrast,treatment systems that rely on chemical biocidesand preparations that can be dosed into the ballastflow have an almost insignificant electrical loadimpact but require storage space, handling anddispensing equipment.


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Impacts on Ballast Tank & Pipe Corrosion

For all ships, but especially the high ballastdependent ships, the battle against steel wastage

due to salt water-induced corrosion can be thesingle largest maintenance cost as the vessel ages.Treatment systems that change the chemicalcomposition of the ballast water and/or theatmosphere in the ballast tanks can impact thecorrosion rates in the tanks and piping. If notdesigned and handled properly, treatment systemsmay also damage ballast tank coatings resultingin increased coating maintenance and ultimatelyincreased corrosion as well.

Systems that remove oxygen and maintain an inert,oxygen-deprived condition in the tanks can offersignificant reductions in corrosion rates. Someof the change in oxidation rate is attributable tochanges in pH caused by the treatment. Somevendor studies have actually concluded that savingson steel and coating renewals over the life of thevessel are much greater than the life cycle costsof the treatment systems. Alternatively, many ofthe chemical biocides and preparations, includingozone, have been linked to increased corrosionrates.

Experimental data is not always conclusiveregarding the impact of chemical disinfectantsin actual service conditions in ships ballasttanks with standard tank coatings and anodes,normal cycling of ballast levels and chemicalconcentrations required for treatment. Evende-oxygenation systems can cause acceleratedcorrosion if they completely remove the oxygenand create a condition that promotes anaerobic-type, microbiologically-influenced corrosion. This

could be in the form of acid-producing bacteria(APB) and sulfate-reducing bacteria (SRB). Thecondition may be accentuated if there is analternating oxygenated/de-oxygenated condition.

In order for de-oxygenation to be beneficial forcorrosion protection, it has to reduce the oxygenlevels sufficiently to slow oxidation and kill anybiofilms that might form, but not so low as toprovide an atmosphere conducive to the growthof APBs and SRBs.

With the currently available data, it is difficult topredict, with a high degree of confidence, exactlyhow different treatment systems will changecorrosion rates. At this point, it is necessary tomove forward with an understanding of thisuncertainty and plan maintenance and inspectionintervals to suit expected risks appropriately.Coating manufacturers should also be consultedregarding the reaction of their coatings to theplanned additives. Only when sufficient operationalexperience is gained with given treatment systems

will clearer guidelines be possible.

Health & Safety (Handling, Operation& Maintenance)

The use of chemical biocides and other activesubstances on board ships raises a concern over thehealth and safety of those responsible for operatingthe equipment and handling the materials, as wellas the risk of unintentional discharge into theenvironment. Treatment systems that use activesubstances or preparations must undergo a strict

review and approval process to identify persistence,bioaccumulation and toxicity. If the system isgiven final approval by IMO, this indicates thatpersistence, bioaccumulation and toxicity arebelow threshold levels and that, if the substancesare handled as directed, they are considered safefor shipboard use.

Every system using active substances shouldbe provided with a Material Safety Data Sheet(MSDS) which describes the proper storage and

handling procedures as well as the informationon the quantity to be added to the ballast waterand the maximum allowable concentration of thesubstances in the treated water. Further, the systemshould not permit exceedance of the maximumdosage and maximum allowable dischargeconcentration at any time.

It is important to note that limits for the level ofactive biocides that may remain in the dischargedballast can also be regulated by local water quality

regulations and can vary by port. If discharging insensitive areas, a treatment system with difficult tocontrol biocide inactivation might not be the rightchoice. At the very least, the manufacturer should


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be requested to provide written confirmation thatthe effluent meets the requirements within the local

jurisdictions that the vessel is likely to operate in.Compliance with these guidelines should indicatethat all reasonable precautions have been takento protect the health and safety of the crew andenvironment. Nevertheless, it does put an added

hazardous material management burden onthe crew. The skill and training of the crew andtheir ability to manage this safety risk should beconsidered when selecting a treatment system.

General Treatment SystemConsiderations

All ballast water treatment technologies sharecertain common selection criteria that should be

considered in addition to the ship and technologyspecific factors.

Proven Efficacy & Official Approvals

First and foremost, a system must meet thedischarge standard applicable to the vesselsvoyage where ballast discharges are planned orlikely. General worldwide service is covered bythe IMO Conventions requirements but somelocal authorities, such as the state of California,have more stringent requirements and earlier

implementation dates. A certificate of typeapproval from a flag Administration wouldindicate that, under test conditions, the systemmeets the discharge standards required. Unless theinstallation is part of a prototype or type approvaltest, the equipment supplier should be able toproduce the type approval certificate. Systemswith type approval are also listed on the IMOwebsite. This formal approval of the equipmentwill be necessary if the vessel is to obtain theIMO Ballast Water Management Certificate

showing compliance with the BWMConvention following successfulsystem functional tests on board.

Vendor Qualifications & Reputation

As with any piece of equipment, theability of the vendor or manufacturerto deliver the product on timeand in the quantities requested isvery important. However with thisemerging technology, the production

capacity is unproven and stillvery small in most cases. Somemanufacturers may suffer from longlead times on orders, especially if

demand increases rapidly. Even though productionfacilities are subject to quality control review bythe type approval authority, until a track record isestablished, manufacturing quality and reliabilitycan be an unknown. Those systems relying onexisting technologies or marine components willhave an advantage in this regard.

Maintenance Requirements& System Reliability

There is insufficient experience with treatmentsystem options to establish a good baseline forsystem reliability. Those systems relying onexisting technologies or marine components willbe able to provide better reliability estimates.Lacking in-service experience, an indication ofreliability risk may be available by considering the

system complexity. Filters, UV light chambers andsimple chemical dosing systems are among theleast complex options and regular maintenanceis possible with ships crew. Electrochlorinationand other chemical generating systems as well assystems with more than two stages of treatmentcan be considered among the most complex.

Simple Operation: Control & Monitoring

All treatment systems should provide a simpleto use remote control panel at or near the main

ballast control panel. It should include indicatorlights for key valves and system operations andan on/off control. Most systems will providemain control panels near the equipment thatallow local operation but also monitor systemoperation. Beyond this, it is up to the owner howfar integration of the treatment system is carriedin the main control/alarm/monitoring system. Iffull integration is required, additional tie-ins withsystem electronics may need to be special orderedfrom the manufacturer.



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Life Cycle Cost

The bottom line concern for owners is the true lifecycle cost of the system. Acquisition costs are themost straightforward to determine because they aredirectly quoted by the vendors and include all theirsunk costs for research and development, approvalsand certification. Installation costs vary fromsystem to system and are more difficult to quantify.Installation costs include changes to existingpiping, equipment and structure, as well as thedirect equipment installation, connection, startup,testing and survey by the approval authority. Mostsystems will require some out of service time forthe ship in order to complete the installation butnone of those currently on the market is likely torequire drydocking.

Establishing both installation and operating costsis difficult as both will vary significantly dependingupon the type and size of ship, the system selectedand prevailing market conditions. When evaluatingthe probable operating costs of a system, thefollowing should be taken into account:

Energy required to operate the systemincluding electric power and fuel for generatingtreatment materials (ozone, inert gas and otherbiocides)

Consumables such as chemicals, lamps andfilter elements

Crew labor to operate and maintain the system,including training

Periodic maintenance, servicing andcomponent replacement

Challenges for InstallationEngineering

Many of the challenges related to engineering theactual installation of a ballast water treatment sys-tem are addressed in the section describing thetreatment technology factors. These challenges can

be especially acute when in-stalling a system on an exist-ing vessel. Finding solutionsto treatment system backpressure and potential flowrate reductions, power con-sumption demands, control

system integration and spacerequirements, as a well asaccess for installation, canbe difficult and costly.

As these are worked out with the vendor, designengineer and class the following additional factorsshould be taken into consideration as a successfulinstallation can still be problematic if they are notproperly addressed.

Intake/Discharge Isolation:Cross-Contamination

When designing the piping system modificationrequired for treatment system installation, careis required to prevent any accidental cross-contamination of intake and discharge water.This is a concern for systems that redirect themain ballast flow. Cross-contamination can occurif contaminated water, either from the sea chestor a tank which may require treatment prior todischarge, passes through a pipe that is shared by

the treated ballast water being discharged. Valveswhich do not provide a reliable seal may also allowsome contamination of treated ballast.

The ideal isolation of intake and discharge flowsis not always possible. However, in two pumpballast systems where flexibility in the ballasting/deballasting time is acceptable, it is recommendedthat one pump be dedicated for ballast intake andone for discharge. Transfers between tanks shouldbe done by the discharge or clean pump unless

treatment is active in the ballast tanks (as with de-oxygenation).

Sampling & In-Service Testing

Port State Control and other authorized regulatoryofficers may, at any time for the purpose ofdetermining whether the ship is in compliancewith the discharge requirements, come on boardand take samples of the ballast water. Designingproper and convenient sampling and testingfacilities should be considered an important part

of the installation engineering. As noted in Section1 of this Notice, IMO Guideline G2, Guidelinesfor Ballast Water Sampling, calls for sampling tobe simple, rapid, applicable at the point of ballast

Invasive Species

The map shows the estimateddistribution of invasive marinespecies. Many marineorganisms are carriedin ballast water or onthe hulls of ships.

Sources: Benjamin S. Halpern, Nat ional Center for Ecological Analysis & Synthesis Graham Roberts, Jonathan Corum/The New York Times

High


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As can be seen, in only a few cases are treatmenttechnologies deemed unsuitable for particularvessel types. The selection process then must takeup the details. As an aid for use in this process, achecklist of key questions and considerations has

been included in the System Evaluation ChecklistSection at the end of this Advisory Notice. Thiscan be useful in establishing criteria. The valueand rating of each factor is left up to the individualresponsible for making the purchasing decision.

Table 10: Suitability of a Ballast Treatment System Type to a Vessel Type

Vessel Category Vessel Size RangeChlorineGenerate

ChemicalApply

Filter &Radiate

DeoxygenateOzone

Generate

Bulk Carriers

Handy-Handymax < 60,000 DWT Yes Yes Yes Yes Yes

Panamax-Kamsarmax < 60,000-90,000 DWT Yes Yes Yes Yes Yes

Capesize >1200,000 DWT Except Large Yes Except Large Yes Yes

Tankers

Handy < 35,000 DWT Some Systems Yes Some Systems Yes Some Systems

Handymax-Aframax 35,000-120,000 DWT Some Systems Yes Some Systems Yes Some Systems

Suezmax 160,000-180,000 DWT Some Systems Yes Some Systems Some Systems Some Systems

VLCC 200,000-320,000 DWT No, Too Large Yes No, Too Large Some Systems Some Systems

ULCC > 320,000 DWT No, Too Large Yes No, Too Large Some Systems Some Systems

Containerships

Feeder < 500-3,000 TEU Yes Yes Yes Yes Yes

Panamax 3,000-4,500 TEU Yes Yes Yes Yes Yes

Postpanamax 4,500-9,000 TEU Yes Yes Yes Yes Yes

Ultralarge > 9,000 TEU Yes Yes Yes Yes Yes

Other Vessels

Passenger Ship All Sizes Yes Yes Yes Yes Yes

Gas Carrier All Sizes Except Large Yes Except Large Some Systems Some Systems

Chemical Carrier All Sizes Some Systems Yes Some Systems Some Systems Some Systems

RORO All Sizes Yes Yes Yes Yes Yes

Combination Vessel All Sizes Yes Yes Yes Yes Yes

General Cargo All Sizes Yes Yes Yes Yes Yes

Fishing Vessels All Sizes Yes Yes Yes Yes Yes

OSVs All Sizes Yes Yes Yes Yes Yes

Note: For tankers, chemical carriers and gas carriers, some systems are not suitable, either because they are not designed to beinstalled in a hazardous atmosphere such as a tanker pump room or because they are not produced at the high capacity requiredfor large tankers.


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Vessel Ballast System Particulars

Owner Supplied Data

1. Ballast system arrangement

a. Total ballast capacity

b. Number of ballast tanks

c. Minimum/maximum ballast tank size

d. Are ballast tanks contiguous with cargo oil or other hazardous cargo tanks?

e. Is there a dedicated set of heel control tanks (FW or SW)?

f. Number of separate ballast systems (not served by same pump)

g. Proper and convenient sampling and testing facilities

2. Ballast system equipment

a. Number of ballast pumps and rating (flow rate and pressure for each)

b. Overall ballast rate (m3/hour)

c. Ballast pump location (ER, pump room, main deck, etc.)

d. Main ballast line configuration (ring main or single line)

e. Type of stripping system, if any

f. Are all ballast system valves remotely operated?

g. Are ballast pumps/piping shared with other systems (bilge, fire, cooling water)?

h. Number and location of sea chests (height above bottom)

i. Diameter of main ballast line to/from pumps

j. Number and size of spare circuit breakers on main switchboard

k. Estimated spare electrical capacity during ballasting operations

Evaluation Checklists


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Ship & Service Characteristics that Impact BWT SelectionOwner Supplied Data

1. Ship type and capacity

a. Ship type: high ballast dependent or low ballast dependent

2. Ballast water handling practices

a. On average, how much ballast is loaded or discharged at any given port?

b. What are the time constraints on ballast intake (how fast must it happen)?

c. Maximum required flow rate for intake of ballast

d. What are the time constraints on ballast discharge (how fast must it happen)?

e. Maximum required flow rate for discharge of ballast

f. Sediment build up in tanks (little, moderate, significant)

g. Is treatment required for possible NOBOB condition?h. Minimum time ballast is held in a tank between port calls

3. Ballast water characteristics

a. Are there freshwater ports encountered where ballast is taken in?

b. Minimum salinity of brackish water encountered

c. Turbidity or silt content of port water (low, moderate, heavy)

4. Vessel service characteristics

a. Any unique service constraints or trading patterns regarding ballast use?b. Is there trade to special BWT zones: California, Great Lakes, Australia, etc.?

c. Does active ballast management allow zero ballast discharge in some/all ports?

5. Ballast system characteristics

a. What are the gravity intake/discharge practices?

b. Can internal ballast transfer for trim, heel, bending moment control beeasily accomplished?

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Treatment Technology FactorsVendor Supplied Data

1. Treatment method

a. Description of technology offered (all stages)b. For UV system: lamp type, required minimum intensity and water clarity

c. For chemical: Required minimum dosage rate and minimum holding time

Neutralizing agents (how created, stored, dosed?)

How long before safe to discharge?

Chemicals generated on board or supplied as preparations?

d. For de-oxygenation: How much inert gas required?

Minimum holding time

2. Treatment system capacitya. Overall treatment capacity (m3)

b. Overall treatment rate (m3/hour)

3. Treatment system pressure drops

a. Expected pressure drops added by treatment system to main ballast flow

b. Quantity of ballast redirected for cleaning or sludge discharge

c. Is gravity intake/discharge possible with this system?

4. Equipment size and space requirementsa. Total space required for treatment equipment

b. Size of largest single component

c. Weight of largest single component

d. Space required for maintenance (element removal, etc.)

5. Materials, equipment protection (IP rating) and hazardous spaces

a. IP rating of components

b. EX rating of components

c. Any special risk assessments performed to date for hazardous space installations?

6. Power requirements

a. Average and maximum power requirements and operating voltage

b. Duration of maximum power consumption as function of ballast process

7. Impacts on ballast tank and pipe corrosion

a. Is there published R&D available regarding the impact on tank and pipe corrosion rates?

8. Health and safety (handling, operation, maintenance)

a. Quantity of treatment chemicals needed (per ton of ballast water treated)

b. For active substances: a copy of the MEPC final approval with recommendations

c. For active substances: Material Safety Data Sheets

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Challenges for Installation EngineeringOwner Supplied Data

1. Intake/discharge isolation: cross-contamination

a. Can piping installation options provide good contamination protection?b. Can intake and discharge pumps be isolated and dedicated to that service?

2. Sampling and in-service testing

a. Is there adequate space and facilities for sampling and testing?

3. Maintaining ballasting flexibility

a. Can the treatment system options selected provide full ballast flexibility?

4. Other

a. Is

Ballast Advisory

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