Liberian Administration s Proposals to Amend the Ballast Water Management Convention (an update): The concerns of retrofitting BWMS on existing ships and a possible solution Erhan Esinduy Regional Manager LISCR Istanbul
TOPICS OF DISCUSSION µ Background µ Challenges in implementa5on of BWMS Demand for BWMS retrofi<ng Dockyard capacity Technology difficul5es in retrofi<ng BWMS µ Ballast Water Exchange µ Proposed alternate means to acain D-2 standard µ Update from MEPC 70 and plans for MEPC 71 and 72 µ Conclusion and sugges5ons for shipowners
BACKGROUND The Liberian Administration first submitted a proposal to MEPC 69 on the concerns of retrofitting BWMS on existing ships. The proposal consisted of three parts: Challenges in implementation of BWMS; Ballast water exchange; and Alternate solution in attaining D-2 standard.
DEMAND FOR RETRO FITTING 10000 9000 8000 7000 6000 5000 4000 3000 2000 1000 0 6654 6232 NUMBER OF SHIPS DUE FOR RENEWAL SURVEY (Based on original delivery date vs actual due date) 6869 6589 5647 5833 6921 6553 2016 2017 2018 2019 2020 9491 7460 Original delivery year Actual due date Data from IHS Fairplay ship database (January 2016), essmated approximately 34,000 ships would be required to install BWMS.
DEMAND FOR RETRO FITTING The difference between the two distribusons show that a large number of ships conducted the renewal survey in 2015, ahead of their original schedule. This increases demand by 2,000+ ships in 2020.
DOCKYARD CAPACITY It is challenging to evaluate the dockyard capacity in 2020 and the Liberian Administra5on is unable to verify the number of exis5ng dockyards which may be u5lized for retrofi<ng work. Therefore, we es5mated the dockyard capacity by using the total number of ships which carried out dry docking in 2015. The world s exis5ng docks for retrofi<ng can only accommodate 4,800 ships annually. With some addi5onal u5liza5on they could manage 6,000 maximum, but even this is s5ll well short of the peak demand es5mate of 9,500 ships.
TECHNOLOGY DIFFICULTIES IN RETROFITTING µ Older exis5ng ships: Significantly difficult (and imprac5cal in some cases) to fit BWMS. For example, if a ship uses gravity for discharge from the top-side tank, a new discharge line from the ballast water tank to BWMS will be needed. At the 5me of developing the BWMC (pre-2004), it was expected that BWMS would conduct a single treatment only at intake. BWMS using a UV need a second treatment at discharge. BWMS using ac5ve substances need a neutraliza5on process at discharge.
TECHNOLOGY DIFFICULTIES IN RETROFITTING µ Nega5ve effect on the surface of ballast water tank with a non-pspc coa5ng. µ For installa5on of thousands of exis5ng ships, dockyard will require exper5se to address such poten5al concerns. µ Almost all dockyards expected to carry out retro-fi<ng are presently only used for repair and survey. µ Concern regarding poten5al hazards of ac5ve substances and by chemical product: Exposure to personnel during maintenance, sampling and inspec5on work. Effects on environment, marine life and humans.
BALLAST WATER EXCHANGE The basic purpose of the Ballast Water Management Conven5on is to control the transfer of harmful aqua5c organisms and pathogens through ships ballast water. The Liberian Administra5on made an assessment to see if the discharged ballast water from exis5ng ships could comply with the D-2 standard by Ballast Water Exchange (BWE). The results of the assessment used a sta5s5cal analysis of densi5es of L-size and S-size planktons at commercial port areas in Tokyo Bay. Data was collected over a eight year period by the Tokyo Metropolitan Government. The original data counted whole organisms regardless of whether it was dead or alive.
BALLAST WATER EXCHANGE The Liberian Administra5on considered that the current efficiency of BWE of at least 95% (20 fold dilu5on) is not sufficient to comply with the D-2 standard. A higher requirement for efficiency of BWE of at least 99% would be needed. The Tokyo study showed that a higher efficiency would be achieved by two sequen5al BWE (twice 20-fold dilu5ons results in 99.75% efficiency), which is reasonably prac5cal under current vessel opera5ons. It should be noted that the actual efficiency of one BWE on a bulk carrier is in the range of 98.86-99.56%.
PROPOSED ALTERNATIVE MEANS TO ATTAIN D-2 STANDARD The Liberian Administra5on proposed at MEPC 69, a new ballast water management methodology described as extended ballast water exchange, E-BWE. Liberia suggested that if extended ballast water exchanges were appropriately conducted on exis5ng ships for the purpose of acaining D-2 standard, then the dura5on of the implementa5on schedule could be extended, giving sufficient 5me for the technology to stabilize and ensuring smooth implementa5on of the Conven5on.
MEPC 69 and Second Study The Liberian Administra5on received support at MEPC 69 for further study and submission at MEPC 70 (October 2016). The Liberian Administra5on conducted a second study on oceangoing ships sailing the Pacific Ocean. The study was not fully successful, but the data showed that acaining the D-2 standard would possible under the right condi5ons (this is true also of current BWTS).
MEPC 70 October 2016 The Liberian Administra5on submiced a second paper with the results of the second ship study and obtained wide support for a possible amendment to the BWMC. India and the World Ship Counsel (industry associa5ons) also submiced a paper reques5ng an extension on the implementa5on dates because of commercial availability (low supply) of BWTS. During MEPC 70, the Liberian Administra5on and India collaborated on preparing an alterna5ve joint proposal that suggested that for all new and exis5ng ships, the implementa5on deadline be extended to the first IOPP renewal survey afer 8 September 2019. There was wide support for extending the implementa5on dates, with the excep5on of the USA, EU and Japan. MEPC 70 ended with the expecta5on that a proposal would be agreed at MEPC 71 (July 2017) and the BWMC would be amended at MEPC 72 (first MEPC afer entry into force).
Post-MEPC 70 Proposal A new proposal is emerging that could gain the support of a majority of States and the industry. This proposal may maintain the requirement for new ships to have systems at delivery (afer 8 Sept 2017). Exis5ng ships would possibly be under a two-5er approach with regard to implementa5on dates (s5ll under discussion).
BWMC Amendment Timeline MEPC 71 (July 2017): Amendment proposal to be agreed upon by the Committee and MEPC Resolution adopted. MEPC 72 (April/May 2018): BWMC has entered into force by this meeting, so amendment to B-3 implementation dates can now be adopted. 18 months after adoption at MEPC 72: Amendment to BWMC takes effect. During the interim period between 8 September 2017 and when amendment takes effect, the Resolution would provide guidance - however it would be up to each PSC whether they would accept the resolution or not.
CONCLUSIONS & SUGGESTIONS FOR SHIPOWNERS The global dockyard capacity and the commercial availability of systems is likely to fall short of the peak demand in 2020. Proposals to amend the BWMC s implementation dates are underway at IMO. The Liberian Administration suggests that shipowners decouple their IOPP certificate by 7 Sept 2017, HOWEVER, should also watch for a compromise paper at the end of March and official amendment wording at MEPC 72.
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