From the desk of Rear Adm. John Nadeau, assistant commandant for prevention policy
I am pleased to report that since 2015, there has been a dramatic increase in the volume of ballast water being treated before being discharged into U.S. waters. In 2015, about 150,000 cubic meters of treated ballast water was discharged monthly, but by 2017, the monthly discharge of treated water increased more than 10-fold to about 1.8 million cubic meters per month. The Coast Guard has strived to keep pace with this increase with the approval of six ballast water management systems (BWMS) and several additional systems now under review or undergoing testing at one of the Coast Guard-accepted Independent Laboratories (IL). The type approved BWMSs listed below represent a range of technologies and pumping capacities. For additional information on each system, a copy of the type approval certificate can be found under the “Environmental” tab on the Coast Guard Homeport website.
The Marine Safety Center (MSC) verifies that each type approval submission meets the requirements contained within 46 CFR 162.060. Each application undergoes a six-step review process: (1) initial screening, (2) engineering review, (3) land based test review, (4) shipboard test review, (5) component test review, and (6) scaling review. Some of the more common issues encountered during the review process are discussed below.
Alternative evaluation requests: When a required evaluation, inspection, or test is identified as not applicable or impracticable, a request for an alternative evaluation that is equivalent to the requirements can be made under the provision of 46 CFR 162.060-10(b)(1). There is no provision within the regulations to provide a waiver or exemption to a requirement. Each proposed alternative must first be described and justified; in most cases, a literature review and test data are provided to assist with the justification of equivalence. Alternative requests may be submitted by the IL at any time during evaluation and testing. ILs are encouraged to submit requests for alternatives at the earliest opportunity.
Electrical equipment in hazardous areas: With the exception of certain vessels involved in the Maritime Security Program, equipment installed on U.S. flag vessels must comply with the requirements of 46 CFR Subchapters F and J. Although IECEx certificated equipment may be installed in hazardous locations onboard U.S. vessels, equipment certified under the ATEX directive may not, per 46 CFR Subchapter J. Common Marine Equipment already in use for marine applications that is tested or type approved under IACS UR E10 does not require component testing under 46 CFR 162.060-30.
Water quality: In some cases during testing, water quality conditions deviate from the challenge conditions specified in the “Generic Protocol for the Verification of Ballast Water Treatment Technologies,” commonly referred to as the “ETV Protocol”, which is incorporated by reference in the type approval requirements under 46 CFR 162.060. For land-based testing, the ETV Protocol allows for deviations and, in some cases, the Coast Guard will accept 10% deviation from prescribed challenge water conditions found in the ETV Protocols and 46 CFR 162.060-26(d) and 162.060-28(g). The IL must approve the deviation and provide a detailed explanation in the test report for why the required challenge conditions were not met. Deviations from challenge conditions during shipboard testing are not permitted.
Scaling: Scaling studies evaluate the effectiveness of a BWMS over a range of treatment rated capacities without requiring that every unit in the range be tested. At a minimum, scaling submissions should include the following elements: an experimental design and test plan, a model to represent key parameters for each BWMS unit, validation of the model with experimental data, and IL verification of a scaling study. Scaling studies submitted in support of type approval for BWMS models that have not been fully tested are reviewed by subject matter experts familiar with the system type and the modeling approaches used to scale from the base units.
The Coast Guard’s type approval process ensures that the system and its components are tested under a range of challenging conditions. However, satisfying the type approval regulations does not guarantee that the system will work without vessel design or operational modifications. An essential part of any shipping company’s strategy for compliance will be working with the manufacturers to determine which type of BWMS is best suited to a particular vessel and its operational profile.
Read the other posts in our new blog series:
12/1/2017: Ballast Water Series Part 5 – Contingency planning for ballast water management
11/30/2017: Ballast Water Series Part 4 – The “plug and play” ballast water management system
11/29/2017: Ballast Water Series Part 3 – Coast Guard BWMS type approval program update
11/28/2017: Ballast Water Series Part 2 – The Coast Guard’s focus on compliance
11/27/2017: New ballast water series from Coast Guard’s assistant commandant for prevention policy
This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.
Categories: Commercial Vessel Compliance