A panel of experts consider the common mistakes resulting in failed tests, and resolve confusion around BWMS commissioning testing
Shipping’s D-Day for ballast water management systems (BWMS) arrived on June 1 with much still to be done if operators want to avoid negative commissioning tests.
This is the overall finding from the Riviera Maritime Media webinar Out of commission: how to respond to a negative BWMS commissioning test,which took place early this year prior to the implementation of D-2 standards.
And, as the experts explained, the consequences of negative tests are well worth avoiding.
The obvious main one is that the vessel will not be given the all-important International Ballast Water Management Certificate that allows the water to be legally discharged on the coast of another country under the jurisdiction of the local port authorities, some of whom applied the D-2 regulations before they became official.
But in these early stages of D-2 standards, common mistakes are being made that lead to negative results and failures in certification, according to panellists at the webinar, which was sponsored by Control Union and Chelsea Technologies.
As CTI Maritec’s business development manager for the EU, Andreas Lougridis, explained, a primary reason for a failed test is contamination from dirty tanks and ballast lines. Hence, it is vital that shipowners and operators clean the sludge and sediment before the test takes place.
Other contributing reasons for negative commission tests are clogged water filters, issues with chemicals, incorrect installation of the BWMS leading to operational issues, and the crew failing to follow procedures in what the experts warn is a big learning curve for them.
To take just the issue of filters, Intertanko has identified 192 ports with muddy – officially “challenging” – water conditions that make the choice of the correct filter a priority in the prevention of clogging in these high-sediment waters.
In over 250 commission tests [as of early 2022] conducted through CTI Maritec’s worldwide operations, Mr Lougridis also identified problems with leaking valves. “During de-ballasting and commission testing, faulty valves [may be] a source of unplanned suction,” he said, leading to a variety of unwanted consequences. “Unplanned suction from sea chest becomes a source of contamination within the system and [can lead] to the failure of the test.” In short, the valves must be thoroughly checked beforehand.
Of all these pitfalls though, the experts are clear that a clean tank is the biggest. Maritec’s laboratory results reveal a massively higher density of marine organisms per cubic metre from the results of first testing of a tank before cleaning, compared with the results of a second test after cleaning. The first test revealed a density per cubic metre of over 69m picograms – or a trillionth of a gram – compared with the 108,000 picograms from the second test.
As the experts point out, the absence of standards would mean that all these foreign organisms would be dumped in other waters.
Be prepared
The common denominator in a system gaining a clean bill of health is early and thorough preparation, pointed out Lloyd’s Register in a white paper provided by Sahan Abeysekara, the class society’s principal specialist in ballast water: “Preparation is fundamental for successful and timely completion of the test, both from the shipowner as well as from the service provider.”
And on the subject of early preparation, Lloyd’s Register has found, if at all possible, that the ideal scenario is for installation, survey and commissioning to be completed in the same location within a similar time frame. This would result in the prompt issuance of the required certificate. However, if there are design limitations in the BWMS, or longer holding time requirements than the ship’s schedule permits, then the certificate will have to wait.
As the experts point out, if the ballast water is held too long it may not be possible to discharge it under local port regulations.
Confusion
Meantime, there may be a fundamental confusion about what commission testing is, as Mr Abeysekara explained in the webinar. It is not at all the same thing as the testing that takes place as part of the installation of the system.
Commission testing is all about establishing the all-important “biological efficacy”, a term that will quickly become familiar to ship operators. The confusion is understandable. As Mr Abeysekara said, there is a subtle but important technical difference: “Although the same terminology is used, the commission test refers to the amendments to regulation E-1 of the BWMC adopted by MECP 74 requiring biological efficacy testing when commissioning a BWTS on board a vessel.”
The commission test also sets a higher standard than installation tests. Conducted onboard only by independent parties, it is considered successful only when the indicative analysis shows the discharge samples do not exceed the D-2 standard for the size classes analysed and if the self-monitoring equipment indicates it is operating correctly.
“Commission testing is all about establishing the all-important biological efficacy”
The precise wording of the new regulation says: ‘‘This survey shall confirm that a commissioning test has been conducted to validate the installation of any ballast water management system to demonstrate that its mechanical, physical, chemical and biological processes are working properly, taking into account guidelines developed by the organisation.’’
In short, the test is designed to demonstrate the system is working properly. It is not intended to validate the design of systems that are approved by the administration. That is why the manufacturer or the supplier is not permitted to conduct a commission test.
The fundamental principle behind D-2 is to preserve the integrity of the oceans as much as possible.
As Lloyd’s Register explains: “When ships take in ballast water in a port, they also take in a variety of local organisms. These are later released into other ports or locations, outside of their natural habitats. On any given day, the ballast water in transit aboard the world’s fleet contains up to 10,000 different marine species.”
In another recent Riviera Maritime Media webinar entitled Ballast water: no time to lose, the size of the challenge was highlighted by Capt Sanjeev Verma, managing director of Landbridge Ship Management who said: “Approximately 10Bn tonnes of ballast water are transported worldwide every year, which could fill about 4M Olympic-sized swimming pools. An estimated 7,000 aquatic species are transferred in ballast water every hour of every day, with one new invasion occurring every nine weeks.”
