Webinar Series Q&A
Session 01:
BWTS Compliance - Challenges
01. What are the latest updates from IMO?
02. Can you provide some recommendations on the commissioning testing and some instructions to avoid non-compliance?
03. What is the first input for data collection in experience building phase and how long will it continue?
04.What is the best equipment for the treatment of Ballast Water?
05.Can you give us your personal view/ thoughts for the expected deadline for the BWTS installations?
06.Are you expecting USCG to request full compliance testing, including the above 50 microns?
07.Can you please elaborate a bit more about the operational limitation of 0.9 PSU?
08. How many tests should be carried out on annual basis to satisfy EPA VGP and IMO requirements?
09. During loading the ballast system stops working and we take untreated ballast water. According to the contingency measures we have to report the defect to the port authorities. The question is whether we should report the deficiency in the discharging ballast port or in port were we load the ballast as well.
IMO has announced that meeting postponements are currently applicable in the light of the COVID-19 pandemic. A revised meeting programme for the remainder of 2020 will be issued as soon as it is available. A priority list has been drawn up and will be considered by the thirty-second extraordinary session of the Council, which is meeting by correspondence from May-July. The proposal give priority to a regular session of the IMO Council, followed by meetings of the Marine Environment Protection Committee (MEPC)
-which will be preceded by the 7th meeting of the Intersessional Working Group on Reduction of GHG Emissions from Ships - and to the Maritime Safety Committee (MSC). Resuming physical meetings will depend on guidance from the World Health Organization (WHO) and UK Government guidance as well as the national situation of IMO Member States.
For any updated information navigate in IMO Official website.
3
02.
Can you provide some recommendations on the commissioning testing and
some instructions to avoid non-compliance?
The main objective of commissioning testing is not to validate the Type Approval but to demonstrate that the principle treatment methods of the system are capable of functioning as installed. It is based on the Guidance for the commissioning testing of ballast water management systems (BWM.2/Circ.70), and it will be required by the Flag State of the vessel or the Recognized Organizations (ROs) acting on their behalf.
Recommendation to Shipowners:
a. Liaise withvessel’sFlag and/or RO (Recognized Organization) and request the latest Instructions /Guidance/Acceptance regarding Commissioning and Issuance of the Ballast water Management Certificate.
b. Update your Training Program to include latest Circulars related to Commissioning (Designated Officer familiar with the Procedures, Resources could be added to Ballast Water Management Plan).
i. BWM.2/Circ.42/Rev.1 Guidance on ballast water sampling and analysis for trial use in accordance with the BWM Convention and Guidelines (G2) and
ii. BWM.2/Circ. 70 Guidance for the commissioning testing of ballast water management systems are the basic Resources to fulfill the Requirements.
iii. Amendments to the Guidelines for ballast water management and development of ballast water management plans (G4)”
02.
Can you provide some recommendations on the commissioning testing and
some instructions to avoid non-compliance?
Instructions to avoid non-compliance:
1) Avoid Contamination in examined ballast tanks - Make sure that the tank or tanks in which the treated water will be stored is/ are empty from untreated water. In case those tanks contain untreated water, please make sure that this has been discharged.
Confirmation from crew that ship is able to ballast and de-ballast into a clean tank for operations. If not, recommend to use of 3 treated cycles of Ballasting/De-ballasting;
2) Make sure that water which will be stored in the ballast tank or tanks from which the samples will be taken is properly treated; 3) System is functioning –The System must be functional and no critical alarm during event;
4) Condition of filter’s screens – Make sure that Filter’s screens were inspected and found in good condition.;
5) Check valve arrangement andStatus of any vessel’s valves that could lead to system’s by-pass 6) Make sure that there is no valve leakage/open in your Ballast Water Piping
5
03.
What is the first input for data collection in experience building phase and
how long will it continue?
Until now there is no Flag submission to contribute to experience building phase. Member Governments and international organizations are encouraged to gather, prepare and submit data to the experience-building phase (EBP).
The EBP consists of a data gathering stage, a data analysis stage and a Convention review stage. The EBP begins with the entry into force of the Convention and ends with the entry into force of a package of priority amendments. The priority amendments are those that implement improvements to the Convention needed before the end of non-penalization measures specific to the EBP
As per current EBP timeline is Autumn 2022. Until now there is no Projection of Postponement.
The equipment that is best fitting to your Vessel, Trade and Operation. Select an efficient BWTS and not just a Type Approved one The quest for a reduced overall equipment cost needs to be bound by performance and endurance requirements. The initial savings from the purchase and installation of a BWTS can be easily spent to cover operation delay charges or fines. The correct process design and engineering combined with a proper material selection are the primary cornerstones for high performance and durability of a
BWTS in the demanding marine environment. Performing compliance testing during commissioning will ensure that the shipowners’
investment is successful and hopefully will act as a screen to keep the non sound but approved systems out of the market.
05.
Can you give us your personal view/ thoughts for the expected deadline for
the BWTS installations?
Till 2024 all vessels with 400 gross tonnage and above should manage their ballast water and sediment with a D2 Performance Standard.
06.
Are you expecting USCG to request full compliance testing, including the
above 50 microns?
US is working on Vessel Incidental Discharge Act (VIDA). This could be the case so as to align with the Commissioning Testing Regime by IMO.
07.
Can you please elaborate a bit more about the operational limitation of 0.9 PSU?
7
08.
How many tests should be carried out on annual basis to satisfy EPA VGP and
IMO requirements?
EPA VGP and IMO are different regulatory regimes.
IMO Requirement: One during commissioning as per Flag/Class requirement and in case a major change is applicable consultation with Flag/Class, repeat it.
EPA VGP Requirement:
Biological indicator compliance monitoring sampling of ballast water effluent must be conducted 2 times during the first year the system is installed or used for vessels with devices for which high quality data are available. For vessels with high quality data, if sampling results are below permit limits for two consecutive events, the vessel owner/operator may reduce monitoring to one time per year after the first year. However, if the vessel owner/operator exceeds a permit limit on any sampling event, they must return to monitoring two times per year until they have two additional results below permit limits. For vessels for which high quality data are not available, monitoring must be conducted 4 times per year. For all vessels, one of those samples may be conducted as part a
vessel’s annual or other survey, and during the first year, one of those sampling events may be conducted as part of the installation of the system to ensure it is functioning properly. Records of the sampling and testing results must be retained onboard for a period of 3
years in the vessel’s recordkeeping documentation consistent with Part 4.2. Each sample must be testedindependently, and the individual results must be reported and not averaged. Monitoring must be conducted at least 14 days apart from different discharge events.
09.
During loading the ballast system stops working and we take untreated ballast
water. According to the contingency measures we have to report the defect to the port
authorities. The question is whether we should report the deficiency in the discharging
ballast port or in port were we load the ballast as well.
Port of Discharging water (destination port) is the reporting Port. If you discharge water in the Ballasting port the same is applicable as well. The ship is required to do its best to correct the malfunction of the BWTS as soon as possible and submit its repair plan to the PSC authorities and the flag state.
A very useful Guidance is provided by USCGvia’sthe following link: https://mariners.coastguard.dodlive.mil/2017/12/01/1212017-ballast-water-series-part-5-contingency-planning-for-ballast-water-management/.
Thank you for Attending!
Follow us on:
ERMA FIRST ESK Engineering Solutions S.A. ERMABWTS
ERMABWTS
