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Ballast water management developments


Recent BWMS developments include IMO’s plans at MEPC 81; an explanation for suspended solids; Q88 updates; fines in Conakry; US penalties; LR record keeping alert; warning about unqualified testing companies

The IMO’s Marine Environment Protection Committee (MEPC 81) meeting on 18-22 March 2024 will review developments with ballast water regulations to date.

In more detail, the Ballast Water Convention (full name “International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004”) entered into force in September 2017.

At the last MEPC meeting, MEPC 80 in July 2023, plans were approved to review how well the ‘experience building phase’ had gone, and what issues need to be considered now.

This will lead to development of a package of amendments to the convention.

Issues of concern with the regulations as they stand include a need for clearer regulations for what happens when ships operate in challenging water quality [see next section]; guidance of temporary storage of sewage and grey water in ballast tanks; how to approve modifications to ballast systems which already have type approval; and use of electronic record books.


Understanding suspended solids

Ballast water filter equipment company Filtersafe published a blog post and illustration showing why so many ports see ‘suspended solids’ (muck) in their water. A high level of suspended solids is sometimes referred to as “challenging water quality” (see previous section).

The IMO’s D-2 standard requires that ballast systems can treat water with suspended solids up to fifty parts per million (the jargon is ‘Total Suspended Solids, or TSS).

But some of the world’s busiest ports have much higher levels of suspended solids that this Shanghai, for example, has seen 1,000 parts per million of solids (0.1 per cent solids).

This means that the regulations as they stand cannot be properly applied in many ports in the world, because the ports have more suspended solids than the systems were required to be designed to handle.

High levels of suspended solids can be caused by water running off soil and into rivers upstream (known as soil erosion).

A faster flowing river will carry more suspended particles than a slower one, because with a slower one there is more time for them to settle out.

The river may also be fed from a sewage or wastewater system, which is not removing all the solids, or has been overwhelmed due to heavy rain.

With densely populated areas, there is a lot of pavement which accumulates dust and other debris. When it rains, the water washes the pavement, and the dirty water runs into nearby bodies of water.


Q88 updates

Version 6 of the tanker industry standard questionnaire, Q88, has been released, with questions about the ballast water management system.

Users of the Q88 will now be asked to provide input on their vessel’s ballast water treatment systems, as well as greenhouse gas performance data, scrubbers, energy and consumption ratings, and NOx emissions compliance data.

The questionnaire is for sharing data between charterers and owners, to support pre-fixture decision making.

This revision is the work of a collaborative effort between the Q88 group at Veson Nautical and the INTERTANKO Vetting Committee, Q88 Working Group chaired by Captain Ashley Cooper, Group Marine Director, Scorpio Ship Management S.A.M.

The questionnaire was originally developed by INTERTANKO, and a company called Q88, since acquired by Veson in 2022.


Fines in Conakry

Vessel operators have been given heavy fines for doing ballast and de-ballasting operations in Conakry Port, Guinea, without getting permission, according to reports from Africa P+I services, passed on by Japan P+I Club.
Fines can be as large as 150 per cent of total port disbursement costs.

The Maritime Code of the Republic of Guinea specifies that oil tankers of 150 gt or less, and other ships of four hundred gt or less, must retain polluted ballast water onboard until it can be discharged in reception facilities ashore.

For bigger tankers and ships, there are further requirements for oil filtering, alarm devices and automatic stopping of hydrocarbon discharge.

Clean ballast water cannot be discharged to the sea unless treated by an approved process.

Further information is here https://www. piclub.or.jp/en/news/39225 Shipowner pays $248k US penalties The US Environmental Protection Agency settled with an unnamed US shipping company in February 2024 to pay $248k penalties for ballast water related violations for two general cargo ships, reports Singapore marine environmental services company Maritec.

The violations included untreated ballast water discharge, vessel inspections, and discharge monitoring.

Between January 2019 and August 2020, Vessel A discharged untreated ballast water eight times in water. It also failed to conduct comprehensive annual vessel inspections at least once every 12 months in 2020 and 2021. The penalty ‘agreed’ was $111k.

Between May 2018 and September 2020, Vessel B discharged untreated ballast water seven times. It also failed to report biological indicator compliance monitoring after a treated ballast water discharge in December 2021.

Vessel B also failed to conduct comprehensive annual vessel inspections at least once every 12 months in 2018, 2019, and 2021. The ‘agreed’ penalty was $137,250.


LR – make sure you fill in the form

Lloyd’s Register issued a “Statutory Alert” in January 2024 about ballast water record keeping, based on IMO’s BWM.2/Circ.80 – Guidance on ballast water record-keeping and reporting (July 2023).

The circular includes an updated example ballast water reporting form (BWRF) and guidance on how to complete the form.

It says some port states may require the submission of a form for ships bound for its ports, offshore terminals, or anchorage areas.

The circular also includes an example form for logging ballast water operations by tank. It is not required, but keeping tank by tank logs is a best practise, LR says.

Warning - ballast testing companies Marcie Merksamer, Vice President of EnviroManagement, Inc. and Chair of the IMAREST Ballast Water Special Interest Group, says she has increasingly seen new market entrants to the testing market who “appear to have limited or no experience with the relevant ballast water regulations,” and may not follow the specifications of IMO, or the US regulations.

She has also seen IMO commissioning testing reports which miss out basic information such as the make and model of the ballast water management system that was tested, or the sampling and analysis methods employed.
For testing under the US Environmental Protection Agency requirements for a VGP [US Vessel General Permit for Discharges Incidental to the Normal Operation of a Vessel] there have been cases where the incorrect parameters were analysed, samples exceed holding times, and reports do not list the critical information, she said.

Shipowners should bear in mind that IMO’s commissioning testing requirement was created to protect the interest of shipowners, at the request of their industry associations, to ensure that they have a correctly installed and functioning system. But if the systems are not tested properly, because shipowners go to a poor-quality provider to save money, it is all wasted.

Companies are required to become approved testing service providers under IMO’s 2020 Guidance for the commissioning testing of ballast water management systems (BWM.2/ Circ.70/Rev.1).

This review should confirm their qualifications, the sampling and testing methodologies they employ, and their quality control and assurance practices, she said.

Scanjet’s tank monitoring system Scanjet PSM, a Swedish tank equipment company, reports that its new “Connect” monitoring system was used on a refit of oil tanker Cactus, a 164,000-dwt vessel flagged in Panama. The tanker operator was not disclosed.

As part of the refit, Scanjet provided replacement APT1000 data transmitters in titanium for all the vessel’s ballast tanks.

These transmitters were configured to operate in analogue mode (4 to 20mA), which meant that cabling from the existing system could be re-used, making the upgrade much easier.

All the tank level data is brought into a main processing unit and displayed on a 22-inch touch screen.

The entire system and equipment could be sent to the vessel preconfigured and customised for immediate installation.

 

 

 

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