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Ballast Water Management - State of Affairs
Overview
1. The Regulatory Environment1. IMO2. USA
2. Ballast Water Technology1. Approved Systems2. Approval Process
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Ballast Water Management - State of Affairs
INTERTANKO’s Strategic Plan
1. Tanker industry is able to achieve compliance with current and future discharge standards (bothdischarge standards (both regionally and internationally)
2 Installation and Operation of2. Installation and Operation of appropriate and adequate ballast water management systemswater management systems
3. Compliance and enforcement – need strong well defined and realisticstrong, well defined and realistic international regulations
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Ballast Water Management
State of the Regulatory Environment
Remaining challenges and uncertainty:
1. Implementation timelines2 T l id li2. Type approval guidelines 3. Port State Control Sampling and Analysis
4. Regional Regs: the US..( )5. ..and local conflicts (Coastguard vs EPA)
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Ballast Water Management - State of Affairs
1. The Regulatory Environment : IMO
Ballast Water Management Convention
• Adopted in 2004• Entry into force requires ratification by
30 countries, 35% world’s grt• Currently, 38 countries, 30.38% grt
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Ballast Water Management - State of Affairs
1. Implementation Schedule
1. The Regulatory Environment : IMO
1. Implementation ScheduleScenario 1 - Assuming Entry into Force of the Convention 1st June 2015
Vessel Keel Laid Delivered BWMS Installation DateFirst renewal survey* after 17 May
Suezmax A 5 Nov 2003 17 May 2004
y y2016 (i.e. first renewal survey following the anniversary date of delivery of the ship in the year ofdelivery of the ship in the year of compliance with the standard applicable to the ship)
S B 5 N 2010 16 J 2012 Fi l f 16 J 2016Suezmax B 5 Nov 2010 16 Jan 2012 First renewal survey after 16 Jan 2016
Suezmax C 25 Dec 2010 1 Mar 2012 First renewal survey after 1 Mar 2016
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* Renewal survey associated with the International Oil Pollution Prevention Certificate under MARPOLAnnex I
Ballast Water Management - State of Affairs
1. Implementation Schedule
1. The Regulatory Environment : IMO
1. Implementation ScheduleScenario 2 - Assuming Entry into Force of the Convention 1st June 2016
Vessel Keel Laid Delivered BWMS Installation Date
First renewal survey* following the 1stSuezmax A 5 Nov 2003 17 May 2004
First renewal survey following the 1st June 2016 (i.e. Entry into Force of the Convention).First renewal survey following the 1stSuezmax B 5 Nov 2010 16 Jan 2012 First renewal survey following the 1June 2016
Suezmax C 25 Dec 2010 1 Mar 2012 First renewal survey following the 1stJ 2016June 2016
* Renewal survey associated with the International Oil Pollution Prevention Certificate under MARPOLAnnex I
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Ballast Water Management - State of Affairs
1. The Regulatory Environment : IMO
2. Ballast Water Management System (BWMS) Type Approvals
• Notwithstanding progress at MEPC 65 with greater quantity and quality of information with increasing transparency there remains a needincreasing transparency, there remains a need to review and revise the IMO’s Type ApporvalGuidelines (G8)
• INTERTANKO Council, G8 Guidelines, ‘still not adequate in providing tanker operators with reliable dependable BWMS to install on boardreliable, dependable BWMS to install on board their tankers’.
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Ballast Water Management - State of Affairs
1. The Regulatory Environment : IMO
3. Port State Control
• Trial Period (initially for 3 years) following entryTrial Period (initially for 3 years) following entry into force
• To trial sampling and testingTo trial sampling and testing
• During this period, port states will refrain from detaining a ship or initiating criminals sanctionsdetaining a ship or initiating criminals sanctions in the event a BWMS does not meet the discharge standard’.
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Regulatory Requirements
Ballast Water Management for owners:Ballast Water Management for owners:
BWM Pl d R d B k f h l• BWM Plan and Record Book for each vessel• BWM System & discharge standards• Compliance schedule to install BWMS• Compliance schedule to install BWMS• Addl. Survey and certification requirements• Addl Port State Control proceduresAddl. Port State Control procedures
=> Uncertainty, Time & Resourcesy,
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Ballast Water Management - State of Affairs
1. The Regulatory Environment : USA
1. US Coast Guard
• Implementation ScheduleImplementation Schedule• Ballast Water Management Systems
approval
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Ballast Water Management - State of Affairs
1. The Regulatory Environment : USA
1. US Coast Guard
• Implementation Schedule• Decision Tree
M d l E t i R t (MER)• Model Extension Request (MER) Letter
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Ballast Water Management - State of Affairs
1. The Regulatory Environment : USA
2. EPANPDES VGP 2013
• New ships (keel laid after December 1, 2013) will need to install a BWMS to comply with the VGPy
• A BWMS “which has been shown to be effective by testing conducted by an independent third party laboratory, test facilityconducted by an independent third party laboratory, test facility or test organization
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BW Systems – Owners’ RealityChoosing equipment:
Suitable systems/treatment types ?y / yp
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Ballast Water Treatment Guidance
Choosing, installing and operating systems
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Ballast Water Management - State of Affairs
2. Ballast Water Technology
1. Approved Systems• IMO
T A d (G8) 33 *• Type Approved (G8) 33 *• US
• Coast Guard approved 0• Coast Guard approved 0• Alternate Management Systems (AMS) 13 (+3)
**
* As at 24 May 2013 (MEPC 65)
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y ( )** As at 26 September
Ballast Water Management - State of Affairs
2. Ballast Water Technology
2. Approval Process• IMO
• Update requirements for manufacturers submitting• Update requirements for manufacturers submitting information to Administrations (BWM.2/Circ.43)
• Updated information to be included in Type Approval Certification, e.g. BWMS limitations (Resolution MEPC.228(65))
• No Review of G8 plannedNo Review of G8 planned• US
• 2 independent laboratories authorised (US and Norway)
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Ballast Water Management - State of Affairs
Overview
1. The Regulatory Environment1. IMO2. USA
2. Ballast Water Technology1. Approved Systems2. Approval Process
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BW Systems – Owners’ Reality
Planning & Design Costs, Installation & downtime
Running Costs‐Energygy‐Consumables
Crew training time & focusSource: ABS Ballast Water Treatment Advisory
Maintenance & SparesCrew training, time & focus
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Fear of non compliance & criminalisation
BW Systems – Owners’ Reality
Sources of Uncertainty:Sou ces o U ce ta ty:Robustness of Type approved Systems ‐ need to reflect real world on board
• e.g. Total Rated Capacity tested 60m3/hr but approved to 6000m3/hrEffi i i diff li i i (b ki h d f h )• e.g. Efficiency in different salinities (brackish and freshwater tests)
• e.g. Varying water temperatures• e.g. Waters with high sediment loads or high tannin contentg g g
Ongoing concern that Type Approval process separate from PSC process, so approved Systems may not meet PSC analysis once installed on boardapproved Systems may not meet PSC analysis once installed on board
Energy Consumption of Systems: considerations in relation to other IMO instruments, e.g. MARPOL Annex VI and energy efficiency.
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Ballast Water Treatment Guidance
INTERTANKO Guidance on the Selection and Installation of Ballast Water Management Systems for Tankers
• Physical Installation• Pumping• Control – system approval and
certification• Treatment type• Operating practicalities
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Ballast Water Management
Concluding remarks
1. Positive developments at IMO, but more work needs to be done and the draft Assembly resolution needs to be adopted !
2. Sharing of operational experience between stakeholders (acceptance of treated discharges by Admin. & PSC essential)
• Do systems work the way they were approved to work ?• Do they meet the discharge standards ?
Wh i l i d b id d f h ?• What operational issues need to be considered for each ?
3. Need a international, uniform approach with strong, well f l l l l ldefined and realistic international regulations, clear timelines
and the political will of States to solve remaining issues and align regional requirements for a global industry
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regional requirements for a global industry
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