Lecture 1.

1- Background to Ballast Water

The carrying of additional weight onboard a ship as “ballast” goes back well over 100
years. The primary purpose of ships carrying ballast onboard is to manipulate the
center of gravity and center of buoyancy, to improve the stability of the vessel. However,
the use of ballast also allows for manipulation of the draught, heel and trim of the vessel
where required.

In the olden days, stone, sand or iron was used as the primary ballast onboard. In more
recent times, water has been used as ballast, carried within purposely designated
“ballast tanks.” The ready availability of water provided a significantly more economic
and efficient method of ballasting ships.

Lecture 2.1- Invasive species the problem

Whilst ballast water is a critical aspect of the safe operation of ships, many studies have
shown that the aquatic organisms taken onboard from the surrounding water at the
point of “ballasting” can, and do, survive the ship’s voyage, and are subsequently
discharged in a foreign location during the “de-ballasting” of the ship.

With likely over 35,000 ballast carrying vessels sailing on frequent international
voyages, taking on ballast water in one location and discharging in another, it is
estimated that an average of 7,000 different aquatic species are transported in ships’
ballast water each year.

Subsequent discharge of ballast water with thriving aquatic species to foreign waters is
severely hazardous to the marine environment, as the foreign species can quickly
become predators to the local species, spreading efficiently and often, rapidly.
Whatsmore, the transfer of viruses and airborne toxins can cause significant risks to
human health, and has done in the past.

Lecture 2.2- Examples of Invasive species

Invasive alien species are recognized as one of the greatest threats to biodiversity
globally – causing serious environmental and health impacts, as well as resultant
commercial consequences.

In marine and coastal environments, invasive species have been identified as one of the
four greatest threats to the world's oceans along with land–based sources of marine
pollution, over–exploitation of living marine resources and physical
alteration/destruction of marine habitats.

Some examples of invasive species include:

Lecture 2.2.1

EXAMPLES OF INVASIVE SPECIES: The Asian Shore Crab

The Asian Shore Crab (Hemigrapsus Sanguineus) is a species of crab native to Eastern
Asia, thought to have been transported via ballast water, and is now an invasive species
of various parts of Europe & North America. On the European side, this invasion spreads
from the coast of France up along the northern coasts of mainland Europe, as well as the
UK. These little critters are creating issues in alien environments by competing with
local, native species of crab, fish & shellfish for food. They are also known to preditate
on local, native species.

Native to: Eastern Asia

Found in: Northern Europe & North America

Problem Created: Compete with and preditate on native species

Lecture 2.2.2

EXAMPLES OF INVASIVE SPECIES: The Killer Shrimp

The Killer Shrimp (Dikerogammarus Villosus) is actually an amphipod, rather than a

shrimp, but earns its reputation from its aggressive and vicious behaviour. Native to the
Black and Caspian seas, it is thought to have been transported to Western Europe and,
most recently, the United Kingdom via the ballast water and hulls of ships. The Killer
Shrimp lives up to its name, using its large and powerful mouth to shred and maim its
prey, often without purpose. In many cases, the killer shrimp doesn’t eat its prey after
attacking.

The Killer Shrimp’s ability to reside in a wide range of water conditions and its varied
diet makes it more than capable of surviving in most aquatic climates. This, coupled
with its vicious behaviour, makes the Killer Shrimp an extremely dangerous invasive
threat, which currently has no means of eradication.

Native to: Black & Caspian Seas

Found in: Northern Europe & United Kindom

Problem Created: Viciously preditates on native species

Lecture 2.2.3

EXAMPLES OF INVASIVE SPECIES - CHINESE MITTEN CRAB

Native to the Yellow Sea region of China and Korea, the Chinese Mitten Crab were first
found in Germany in 1912. Before long, droves of this eight-legged army had spread to
Denmark, Poland, Belgium, Sweden, the UK and Ireland. By the 1960’s they we’re found
to have traveled as far as the Great Lakes.

The Chinese Mitten Crab eats everything its path. On the list of casualties so far is the
native Blue Crab in the Hudson River, along with the Crayfish, wreaking havoc on
commercial fisheries. To top that, their love of burrowing into stream beds promotes
corrosion and they clog pumps and screens leading to overheating in natural gas power
plants.

Keeping these invaders in check is an expensive business.

Native to: Yellow Sea

Found in: Northern Europe, Mediterranean, UK and USA

Problem Created: Seriously disrupts local aquatic lifecycle & clogging/fouling of
civil/industrial sites

Lecture 2.3

BALLAST TANK SEDIMENT

A common problem in all ballast tanks is the build up of sediment. When a ship takes on
ballast water it also takes on any and all material contained in the water (smaller than
the minimum mesh size of the sea strainers of course). In shallow or heavily sedimented
waters this often includes solid material. When this material enters the ballast tank it
settles to the bottom as 'sediments' and provides a substrate for a variety of marine
species to thrive.

Thanks to this sediment substrate, many invasive species are able to thrive in the ballast
tanks, even during voyages of several months without discharge.

Lecture 4.1

BALLAST WATER EXCHANGE

Ballast water exchange, in compliance with the D-1 standard, is a temporary measure
introduced by the IMO BWM Convention, to reduce the spread of harmful aquatic
organisms in lieu of worldwide compliance with D-2.

Ballast Water Exchange Process

The process of ballast water exchange involves the substitution of the water in the
vessel’s ballast tanks using one of the following methods:

 Sequential method
 Flow-through method
 Dilution method

Sequential Method:

The sequential method of ballast water exchange is a process by which a ballast tank
intended for carriage of ballast water is first emptied and then refilled with replacement
ballast water to achieve at least a 95% volumetric exchange.

Flow-Through Method:

The flow–through method consists of pumping in additional water to overfill the tanks.
It has been established that it is necessary to pump in three times the volume of the
tank to achieve a 95% change of water.

Dilution Method:

The dilution method is a process by which replacement ballast water is filled through
the top of the ballast tank, with simultaneous discharge from the bottom of the tank. It is
critical that the same flow rate is maintained during filling and discharge, and that a
constant level in the tank is maintained throughout the ballast exchange operation.
IMO Requirements

The IMO requirements state that any exchange procedures must be carried out,
whenever possible, at least 200 nautical miles from the nearest land, and in water at
least 200 metres in depth. Where that is not possible, the procedures must be at least 50
nautical miles from the nearest land, and, again, in water at least 200 metres in depth.

However, at MEPC 71 in July 2017, agreements were made to allow vessels that are
"geographically constrained" in complying with the geographical requirements of the D-
l standard, to simply record the justification for being unable to comply in their record
book, and continue trading.

Key Ballast Water Exchange Considerations

Ballast exchange procedures can have adverse effects on the shear strength and bending
moments of the vessel, particularly on vessels which are sensitive to longitudinal
strength - such as tankers and bulk carriers.

In addition to this, the procedures could result in slack water within the tanks, with
additional free surface moment impacting the vessel’s dynamic stability. It is therefore
crucial that the ballast water management plans be developed, implemented and
operated with the vessel’s safety in mind. It is for this reason that the IMO developed the
G4 guidelines; titled “Guidelines for ballast water management and development of
ballast water management plans,” which outline the specific stability and strength
calculations that must be checked during the development of a vessel’s ballast water
management plan.

Lecture 4.2-- BALLAST WATER TREATMENT

Various Ballast Water Management System (BWMS) technologies have been developed
to treat the ballast water – hence providing compliance with the various legislation. The
most common method of compliance is the permanent installation of a BWMS.

BWMS Technologies  Perhaps the most common method of compliance is the

permanent installation/retrofit of a BWMS to the vessel.

There are in excess of 40 BWMS on the market, using a mixture of various technologies
and processes. In general terms, the technologies can be split into two groups:
separation technologies and disinfection technologies. The former are typically in-line
treatment technologies that treat the ballast water in-flow during ballasting or de-
ballasting. The latter essentially kill organisms or render them unviable (unable to re-
produce).

Separation Technologies :Separation technologies typically aim to remove the

organisms from the ballast water using apparent physical differences between the
organisms themselves, and the ballast water.

The most common example of separation technology is the physical filtration of the
ballast water - essentially removing organisms, sediment, silt and suspended matter
below the filter mesh size. The filter technologies themselves vary and can include disk,
mesh, screen, drum and stacked disk - and typically contain meshes between 10pm and
200pm.
Many of the filter technologies used in BWMS also have the ability to automatically
back-flush the filter mesh using a proportion of the incoming ballast water flow.

In addition to physical filters, some BWMS make use of other / additional filtration
technologies such as hydrocyclonic separators which use centrifugal force to separate
different density matter and organisms from the ballast water. Others make use of other
technologies such as flocculation or coagulation.

Ultraviolet (UV) Treatment: Arguably the most commonly used disinfection technology,
UV treatment uses UV lamps to break down cell membranes - killing (or rendering
unviable) the organisms. The effectiveness of UV disinfection can depend on the
turbidity of the ballast water, as this impacts the ability of the UV lamps to transmit the
UV light through particularly heavily sedimented water.

Electro-Chlorination Treatment: Electro-chlorination is a method whereby an electrical

current is applied to the sea-water, generating free chlorine, sodium hypochlorite,
hydroxyl radicals and additional by-products. In BWMS applications, the process is
typically conducted on a low volume side stream of the ballast water during ballasting
operations, where 1 to 2 percent of the ballast water is routed through the electro-
chlorination system and back in to the ballast flow - treating the entirety of the ballast
water thereafter, although some “full flow” electro-chlorination systems are available on
the market. On de-ballasting electro-chlorination systems typically require a
neutralisation agent be applied to the discharging ballast water, and are less effective in
waters of lower salinity - as salinity is a key part of the chemical process.

Ozone Treatment: Ozone treatment essentially produces ozone and injects it into the
ballast water. In fresh water the ozone decomposes, creating strong oxidants which
destroy organisms. In sea water, the ozone forms highly effective biocides which
destroy organisms.

Chemical Treatment: The injection of chemicals into the ballast water to destroy
organisms is a method used by a small number of BWMS manufacturers - with the
common chemical of choice being chlorine dioxide. Chemical based systems offer
comparatively lower cost treatment per m3 of ballast water, but present additional
difficulties in the bunkering, storage and safe handling of potentially volatile chemicals.

 Lecture 4.3

ALTERNATIVE COMPLIANCE METHODS

With the significant capital expense in mind, many alternative methods of compliance
have been developed over the past few years. These alternatives often offer
commercially or technically more attractive compliance solutions that those of
conventional BWMS retrofits, and can loosely be broken down into the following
groups:

 Mobile Solutions
 Port Solutions
 Legislative Solutions
 Operational Solutions
 Other Solutions
Mobile Solutions  

Mobile ballast water treatment systems are now, finally, coming to the fold and
represent one of the most commercially efficient methods of compliance - but only for
owners of particular types of vessels, or vessels operating on fixed trading routes.
Indeed, mobile ballast water management solution provider, Ballast Water Containers,
claims that mobile treatment solutions could save vessel owners up to 80% of their
compliance costs.

Mobile treatment systems are particularly suitable for vessels with low utilisation - such
as barges, or minimal, and predictable, ballasting operations - such as fixed route
container vessels, liner services etc. An owner investing in a small number of mobile
treatment systems, theoretically, could share them between multiple vessels - avoiding
having to retrofit each vessel individually.

Mobile treatment systems offer the flexibility to be stored in various ports, and
temporarily mobilised to the vessels as they call in - again, avoiding the need to retrofit
each vessel.

Mobile treatment systems, however, would be highly unlikely to be suitable for vessels
that conduct ballast operations frequently, or are involved in irregular trade.

Port Solutions  

Beyond traditional retrofitting, a permanent (or semi-permanent) port based treatment

system offers many vessel owners and operators with a convenient, and presumably
cost effective, method of compliance. Companies such as Damen, who have developed
their InvaSave port based treatment option, are seeking to offer the industry port based
solutions.

With many other effluents and discharges from vessels handled by shore based
treatment systems, the concept makes sense - however, where the concept is let down,
is its likely lack of global availability.

With ballast water management compliance such an important aspect of day to day
vessel operation, owners and operators are currently averse to relying on third party
service companies, around the world, to manage their ballast water for them. Lack of
availability in a specific port, for example, would render the vessel unable to discharge
ballast.

Things also start to get particularly complicated when ballast water management
legislation is applied. In the USA, for example, effluents discharged from a vessel to a
shore based facility, are thereafter governed by the Environmental Protection Agency
(EPA), which has a completely different set of requirements to those of the USCG, and
which, to date, have still to be determined for ballast water.

Legislative Solutions  

There remain a number of legislative methods for achieving compliance - including

exemptions, under IMO, and extensions, under USCG. Exemptions have been a hot topic
within MEPC, and associated IMO related industry bodies, of recent times, and they
broadly fall under two specific aspects:
  Fixed Route Exemptions
 Same Risk Area Exemptions

Fixed route exemptions essentially apply to vessels such as passenger ferries or shuttle
freighters - vessel trading exclusively on a dedicated route, between two or more
international ports. The Convention allows for owners and operators of such vessels to
apply for an exemption, if they are capable of demonstrating the appropriate level of
risk of transfer of invasive species.

The concept of same risk area is a somewhat new proposal, and covers vessels trading
within a particular geographical region. The theory is that if vessel owners / operators
can demonstrate an appropriate level of risk of transfer of invasive species within the
geographical region, then all vessels operating exclusively within said region could be
granted an exemption.

In either scenario, the process of undertaking scientific studies for each potential port,
either within a fixed route, or within a geographical area, is currently a time consuming
and expensive endeavor and owners should bear this in mind if considering exemptions
as their compliance method.

Operational Solutions  

Perceived as being one of the most invasive methods of alternative ballast water
management compliance, operational adjustment can actually offer owners and
operators with a low up-front investment solution for achieving compliance.

Concepts such as captive ballast are, indeed, sensible and viable compliance options for
particular types of vessels. Vessels such as passenger ferries, for example, tend to ballast
so seldom that investing significantly to achieve compliance conventionally is somewhat
unpalatable. Simply re-configuring the classification of the ballast tanks, re-working the
tank plan and gaining Class Approval for the methodology may be the most viable
compliance solution. At the very least, it is worth pursuing prior to making significant
investment decisions.

Similarly, for vessels such as barges, that only ever conduct ballast operations in one
particular body of water at a time (for loading/unloading heavy lift cargoes), owners or
operators could, theoretically, achieve compliance by segregating their tanks and
ensuring tanks are always fully emptied (and cleaned if required) prior to leaving a
particular geographic location.

Operational compliance solutions are always worth investigating, as minimal impact

operational changes may present ideal compliance solutions - and avoid significant
investment.

Other Solutions  

Even within the term "alternative ballast water management compliance,” there are
some solutions that do not fall under any sub-category. Concepts such as using potable
water, theoretically represent a convenient compliance solution - avoiding significant
capital investment. However, owners and operators should ensure they understand the
implications of ballasting/de-ballasting using shore provided potable water. Such
infrastructure is often unreliable, with varying, and often very low, flow rates - which
can have a significant impact on vessel ballasting operations.
One final alternative concept, which the industry has not discussed at length, is the idea
of re-using ballast water that has already been treated. Of course, for some technologies
this is not a viable solution (UV for example is sensitive to the issues of re-growth), but
for technologies that have ongoing residual treatment effects - re-using already treated
ballast water between different vessels seems like a sensible, and environmentally
friendly, proposition. Of course, the practicalities, both technically and commercially,
may be difficult to overcome, as could the legislative constraints, but it is an intriguing
solution nonetheless.

Lecture 5.1-PLANNING FOR COMPLIANCE

The ballast water management plan (BWMP) which is required to be held onboard and
followed as part of the ballast water management process, will outline the required
steps for compliance. Beyond this, however, there are a number of critical
considerations worth addressing when planning for compliance.

Regional / Environmental Considerations  

Any information provided by the local port state concerning known areas where ballast
water should not be taken onboard or discharged

 The current and anticipated weather conditions

 Local anchorage/pilotage/berthing timelines and/or requirements
 Any local designated areas for BWE or BWT
 Sampling / measurement requirements

Technical & Safety Considerations  

 The compliance method to be used – which should be identified and made clear
to all parties
 The time required to complete the management of ballast water – and
implications on vessel operations
 The existing ballast system onboard - including number of ballast pumps and
capacities including any limitations and constraints imposed by their current
operational condition
 The number of ballast tanks and any subsequent stability / longitudinal strength
issues associated
 The available capacity of tanks vents and overflow arrangements
 The need to open any watertight enclosures or openings to conduct BWE, which
may affect watertight integrity
 Contingency measures and considerations such as loss of power or pumps

Lecture 5.2-COMPLIANCE CHECKLISTS

Cleanship Solutions has produced a number of invaluable compliance planning

checklists which are useful for all parties involved in ballast water management. These
are applicable to specific scenarios, as follows:

 IMO D-1 Compliance – Planning & Checklist

 IMO D-2 Compliance – Planning & Checklist
 USCG Compliance – Planning & Checklist

Check these checklists out below:

Page 30 - D-1 Compliance - Planning & Checklist.docx

Page 31 - D-2 Compliance - Planning & Checklist.docx

Page 31 - USCG Compliance - Planning & Checklist.docx

Lecture 5.3- RESPONSIBILITIES ONBOARD

In accordance with the BWMP – the primary responsibility for ensuring the BWMP is
followed lies with the designated officer. The designated officer is usually appointed by
the Master, and, as per the BWMP, must ensure that all other officers and crew
members are fully knowledgeable and trained in the planning and execution of ballast
water management.

Different officers and crew members onboard will likely be involved in ballast water
management in varying capacities, including:

Deck Officers

The conducting of any form of ballast water management will have an impact on
ballasting operations, flow rates and stability / strength – all of which fall under the
onboard responsibilities of the deck officers.

Deck officers must be familiarised and trained by the designated person onboard, and
be fully capable of conducting ballast water management in line with the appropriate
compliance methods onboard.

Engineers

The engineers will be responsible for the technical condition and ongoing functionality
of the ballast water management systems onboard. The engineers must have a thorough
working knowledge of any ballast water management systems onboard, as well as the
vessels existing ballast system onboard – including pumps, valves, control, automation,
tanks and operation.

It is critical that the engineering department ensure any and all other engineering
related works ongoing onboard do not adversely affect the ability of the vessel to safely
conduct ballast water management – and ensure the designated officer is kept abreast
of all such scenarios at all times.

The engineers will likely conduct regular checks of the equipment as per the
manufacturer’s maintenance schedule and on random basis or under designated officer
request.

Lecture 5.4:-

DOCUMENTATION & REPORTING

Both the IMO BWM Convention and the USCG Final Rule require specific documentation
be carried onboard each ship, and that each ship carry out reporting on its respective
ballast operations accordingly.
Ballast Water Management Plan (BWMP)

It is a requirement of both the IMO BWM Convention and USCG Final Rule that each ship
shall have on board and implement a BWMP. Such a plan shall be approved by the
Administration taking into account Guidelines developed by IMO and USCG.

Each BWMP shall be tailored to the respective ship and shall at least:

 detail safety procedures for the ship and the crew associated with ballast water
management
 provide a detailed description of the actions to be taken to implement the ballast
water management requirements
 detail the procedures for the disposal of sediments at sea and to shore
 include the procedures for coordinating shipboard ballast water management
that involves discharge to the sea with the authorities of the State into whose
waters such discharge will take place
 designate the officer on board in charge of ensuring that ballast water
management and the BWMP is correctly implemented
 contain the reporting requirements
 be written in the working language of the ship. If the language used is not
English, French or Spanish, a translation into one of these languages shall be
included.

Ballast Water System Schematics

A piping diagram of the ballast system and a layout diagram of the ballast control
system including air pipes and tank sounding arrangements shall be included within the
BWMP.

The diagrams should show the valve positions as well as identification number, position
and capacity of each ballast pump.

Ballast Water Record Book

It is a requirement of both the IMO BWM Convention and USCG Final Rule that each ship
have onboard a ballast water record book, either in hard copy format, or in electronic
form, for the recording of any and all ballast operations that occur onboard.

When taking on or discharging ballast water, as a minimum, the dates, geographical

locations, ship's tanks and cargo holds, ballast water temperature and salinity, as well as
the amount of ballast water loaded or discharged, should be recorded in the BWRB.

The record book shall also be used to document any instances where ballast water
management, in accordance with the approved procedure within the ship’s BWMP,
could not be followed, owing to safety concerns or similar. Justifications for such
breaches should be included within the record book. These instances should be
reported to the applicable port state as soon as possible, and, where appropriate, prior
to entering waters under said port state’s jurisdiction.

The International Ballast Water Management Certificate

The IBWMC is the certificate issued by the ship’s Flag State, or on its behalf by another
duly authorised Party to the BWM Convention, or recognised organisation, which
indicates it has the necessary equipment and procedures onboard in order to comply
with the IMO BWM Convention.

The IBWMC will join the other primary certificates onboard, demonstrating the ship's
compliance with international regulations.

The certificates shall usually only be issued after successful completion of an onboard
survey by the Flag State / Class Society. Certificates issued on behalf of the Flag State by
another duly authorised Party to the BWM Convention or a recognised organisation
(Class Society) shall be fully accepted, although the Flag Administration assumes full
responsibility for issuance of such a Certificate (see Regulation E–3).

The validity of an IBWMC is for a period not exceeding 5 years and is generally
determined by the relevant Flag State.

Equipment Approals & Certification

Where a ship is complying with either the IMO BWM Convention or USCG Final Rule
through the use of a ballast water treatment system, the appropriate documentation
and approval certificates will be required to be held onboard.

For IMO compliant systems only, the appropriate IMO Type Approval certificates, as
issued by the appropriate Flag State and Class Society, shall be carried onboard.

Lecture 6.1

THE FOUR STAGE INSPECTION PROCESS

Stage 1 – Initial Inspection

The first stage of any inspection process undertaken by Port State is likely to be the
initial inspection. During this initial inspection, the Port State Control Officer (PSCO) will
likely check the validity of all documentation onboard, as referenced in the BWMP,
including the IBWMC. The condition of the vessel’s ballast system, any BWT onboard,
and the abilities of the crew to correctly operate, shall also be checked.

If the PSCO believes there are clear grounds that the vessel condition and/or equipment
do not comply with the relevant documentation onboard, the port State has a
responsibility to "take such steps as will ensure that the ship shall not discharge ballast
water until it can do so without presenting a threat of harm to the environment, human
health, property or resources".

Clear grounds also justify the PSCO carrying out a detailed inspection.

A list of clear grounds under BWM Convention is available in the Guidelines for Port
State Control under the BWM Convention (Resolution MEPC.252(67)), however can be
summarised as follows:

"Evidence that the ship, its equipment, or its crew does not correspond substantially
with the requirements of the relevant conventions or that the master or crew members
are not familiar with essential shipboard procedures relating to the safety of ships or
the prevention of pollution."
Stage 2 – Detailed Inspection

The second stage of the inspection process, where required, is the detailed inspection.
The Procedures for Port State Control, 2011 define the more detailed inspection as: "an
inspection conducted when there are clear grounds for believing that the condition of
the ship, its equipment or its crew does not correspond substantially to the particulars
of the certificate."

During a detailed inspection, the PSCO is likely to follow include the following criteria:

 Does the ballast water management equipment onboard match that listed in the
BWMP?
 Are the crew following the procedures as detailed in the BWMP?
 Does the ballast system piping and equipment remain intact (i.e. free of
subsequent alteration?)
 Is the ballast water management equipment onboard operating correctly?
 Has the equipment been bypassed at any point?
 Are the crew adequately trained in the operation of any ballast water
management equipment onboard?
 Are adequate records of ballast operations being maintained?
 Are there any records of training of onboard personnel?
 Is sampling of the ballast water necessary?

Stages 3 and 4 – Indicative & Detailed Analysis

Stages 3 and 4 involve the sampling of the ballast water onboard.

Indicative analysis involved a compliance test that is quick, and can be either a direct or
indirect measurement of a representative sample of the ballast water. The time
required to conduct an indicative analysis should not unduly delay the operations or
departure of the ship.

In the event of the indicative analysis exceeding the permissible discharge criteria for
the relevant legislation, by a predetermined threshold pertinent to the analysis method
utilised, a detailed analysis can be carried out.

The detailed analysis essentially involves a validated compliance test, using a test
method or analysis that is a direct measurement of a representative sample. Such
detailed analysis aim to accurately quantify the concentration of the viable organisms in
the ballast water volume.

Lecture 6.2-OBTAINING SAMPLES

Ballast water samples are typically obtained using the ballast water sampling point
onboard. Such sampling points are a necessary Class approval point during any retrofit
installations of BWT systems. Where a ballast water sampling point is not installed, the
samples may be taken directly from a relevant ballast tank.

The location of suitable access points for sampling ballast should be described in the
ship's BWMP. This will likely include lists of sampling points, or diagrams of the type
and arrangement of sampling points onboard.