The most significant BWM Convention issue that shipowners and operators are facing is the need, for ballast water treatment systems that have been type approved, to enable vessels equipped with such technologies to meet the D-2 treatment standard wherever the vessel calls.
In order to meet this basic need, the IMO developed the G8 Guidelines to establish an orderly process whereby candidate technologies are tested in land based and shipboard tests and certified (i.e. type approved) by IMO member states if compliant with the applicable provisions.
Since between 60 and 70 thousand vessels will need to be equipped with ballast water treatment technology worldwide at a combined cost exceeding $100 billion, it is important that the G8 Guidelines demonstrate that type approved technologies are fit for purpose.
Unfortunately, there have been cases in which IMO type approved ballast water treatment systems have failed to meet the D-2 standard when subject to additional testing and/or evaluation. This was one of the reasons leading U.S. Coast Guard to adopt, in August 2009, a stricter type approval testing protocol based, in part, on the EPA/USCG Environmental Technology Verification (ETV) protocol.
At IMO level the following areas were identified by several stakeholders as the basis for amendment to the G8 Guidelines:
1. Testing should use waters representing the full range of salinities a vessel might encounter during normal voyages;
2. Testing should consider the effect of temperature on system operation and treatment efficacy;
3. Testing facilities should employ a standardized set of test organisms to enhance consistency;
4. Testing should incorporate higher levels of suspended solids in test water to simulate real-world water conditions;
5. Testing should require that all test-runs—passes and failures—be reported in the system evaluation so as to eliminate “cherry-picking” of only passing results to earn type approval;
6. Testing should use flow rates (i.e. the rate at which water is pumped through the treatment system) that are realistic for the types of vessels in which the system will be installed.
Following these suggestions MEPC 67, in October 2014, adopted a MEPC Resolution requesting a comprehensive review and subsequent revision of the G8 guidelines in force at that time (MEPC.174(58)). This review process was concluded in October 2016 by MEPC 70 with the adoption of the “2016 Guidelines for approval of ballast water management systems (G8)” (MEPC.279(70)). MEPC 70 agreed to keep the 2016 Guidelines (G8) under review in the light of experience gained with their application.
The “lack of robustness” of the old G8 Guidelines demonstrates that novel technology is generally not adequately covered by established codes and procedures. Novel technology may therefore be required to be qualified through an approach herein denominated Technology Qualification (TQ). TQ is the process of verification that the novel technology meets the specified requirements for its intended service, through a systematic and documented process of qualification that will include examination of the design, engineering analyses and testing programs.
TQ is to be based on specified safety, availability and reliability criteria, boundary conditions and interface requirements defined in the TQ basis.
TQ should be consistent with the following general philosophy:
• the TQ process is to be based on a systematic approach,
• a risk assessment is to be conducted to identify, rank and control failure modes affecting the fitness for service of the novel technology, with particular care to the interfaces with the other systems,
• engineering analyses can be used to demonstrate that the design fulfils the specified requirements for the intended service,
• measurements and tests are to be used, to demonstrate that the novel technology fulfils the specified requirements for the intended service.
Alternative methods to demonstrate the fitness for service may be used, provided that they are supported by proper justification.
The purpose of Technology Assessment is to divide the technology into manageable elements in order to assess those elements that involve aspects of novel technology and identify the key challenges and uncertainties.
The technology assessment should include the following issues.
• subdivision of the technology into manageable elements (i.e., subsystems and components, processes or operations, manufacturing, installation etc.),
• assessment of the technology elements with respect to their novelty classification,
• identification of the main challenges and uncertainties related to the novel technology aspects.
The level of detail in the subdivision of the technology should be appropriate to focus the novel or uncertain aspects that subsequently will be subjected to risk assessment.
RINA has successfully applied the Technology Qualification Process and issued the related certificates to some significant complex systems such as mooring systems, LNG transfer systems, Regasification systems (tri-ex vaporizers), FMC ATOL system for LNG transfer, exhaust gas cleaning systems, and it’s ready to support ballast water treatment system’s producers in the process of applying the TQ to their novel technologies.
* RINA Services S.p.A. Technical Services Machinery & Automation