Challenges and solutions from certification testing and their implications for the practical implementation of ballast water management

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Bartholomew Jordan
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1 Indian Journal of Geo-Marine Sciences Vol. 43(11), November 2014, pp Challenges and solutions from certification testing and their implications for the practical implementation of ballast water management Fuhr, F*.,Veldhuis, M., Brutel de la Riviere, E. van der Star, I. MEA-nlbv, Sluiskolkkade 2, 1779 GP Den Oever, The Netherlands Received 07 March 2014; revised 11 August 2014 The existing guideline G8 of the International Maritime Organisation (IMO) is a generic document that has been compiled based on expert knowledge. Since its first release in 2005, and the revision in 2008, it has proved to be a workable document. However, practical experience gained from certification testing has shown a number of shortcomings. Some of these have been addressed and amended in later regulations while other issues are still unresolved. In this paper the topic is addressed from the point of view of a test facility. Common challenges faced by test facilities and possible solutions thereof are presented in the context of practical application of ballast water management systems on board of ships. The relevance and meaning of taxonomy, organism numbers, temperature, salinity and sediment load, are discussed. Lessons learned from the past 7 years of land-based testing and their relevance for future shipboard operation and compliance control are evaluated. [Keywords: Ballast water; test facility; compliance control] Introduction The certification testing of ballast water management systems (BWMS) is currently conducted at test facilities which can be grouped in one of the following categories: 1. Owned or operated by stakeholders, i.e. BWMS developer, a shipyard, a shipping-line; 2. A commercial enterprise offering the services required for testing; 3. Governmental funded facility, i.e. research institute, offering the services required for testing. How the facilities of the first category will operate in the future is not quite clear yet. Their mode of operation is problematic in terms of US requirements regarding the independence of system developer and test facility. However, due to the ongoing commercialization of the market, it is likely that test facilities of the third category either end their activities or continue to work as spin-off. The latter will group them in the second category. While this is a good thing in terms of fair competition, there is also a risk of reduced information exchange. Commercial test facilities have to operate in a complex web of, sometimes contradicting, interests. They have to be profitable in order to continue operations. While this sounds rather trivial, it directly affects the effectiveness of the implementation of the International Maritime Organisation (IMO) ballast water management convention 1. For the time being and until sufficient BWMS are installed and more importantly operated on board, test facilities provide the knowledge base about BWMS. However, being a commercial entity in a competitive market, test facilities cannot afford to freely share all information. Furthermore, there is an increasing amount of clients (i.e. system developers) that require a non-disclosure agreement (NDA) to protect their own intellectual property. On the other hand there are the representatives of the administrations responsible for compliance control, class societies and last but not the least the shipping industry itself. They want to know as much as possible about the strengths and weaknesses of any system. Especially the latter are of interest, since they determine the likelihood of BWMS to treat ballast water in compliance with the regulation(s). Practical experience Biological data

2 2008 INDIAN J. MAR. SCI., VOL 43, NO.11 NOVEMBER 2014 When the first guideline G8 2 was developed in 2004, a number of theoretically deducted parameters were chosen to evaluate BWMS. A set of minimum values to be met for a variety of parameters upon intake was assigned in an attempt to standardize Certification Testing for Type Approval. At that time no one had actually done a full-scale land-based test series. These were done in the following years and the experience gained was partly incorporated in the revised guideline G8 3. However, for a number of reasons, the parameters and values were left untouched in the revision, even though they do pose a lot of (practical) problems. Fortunately, guideline G8 3 allows for motivated deviations from the proposed procedures. This freedom given for motivated deviations is the true strength of the present document. Moreover, in our view, it is the major factor in making the document practicable and to come to comparable results across test facilities. Standardization can principally be achieved in two ways, either everyone has to perform the same or everyone has to report the same. While guideline G8 3 partly tries to follow the first approach, it does not follow through. For example, there are no requirements for technical infrastructure like standard pumps or piping to be used. This is sensible, since BWMS will be operated on board very different vessels in various set-ups but does prevent standardized testing. Therefore, the guideline G8 3 created a system for standardized reporting. By motivating why something is not or differently done, one has to address all components of a standard list of measurements. Of crucial importance is the fact that there are the requirements on intake values for some parameters. These do follow the idea of a standard test procedure, but unfortunately in a nonstandardized environment it will cause problems. Looking at the requirements for organisms larger than 50 µm, a very high number of organisms on intake is required, namely 10 5 organisms m -3. Unfortunately there has been a lot of attention on how to achieve the 10 5 organism m - 3 on intake requirement, but much less on the relevance of this number. This number is high for marine waters, even in one of the most productive shelf seas of the world, the North Sea, it is not commonly encountered (Fig. 1). Concurrently, for a test to be valid, a mere 100 organisms m -3 needs to be present in the control on discharge. In other words, a survival rate of 0.1% is regarded to be sufficient to demonstrate that the treatment, and not the infrastructure of the test facility, succeeded in reducing organism numbers to below the D2 standard 1. Furthermore, there is no requirement for the analysis and evaluation of the population diversity on discharge. This is neither statistically, nor biologically very robust. In order to achieve the intake requirements, the use of surrogate organisms is suggested. This approach does not only yield the required numbers but seemingly also standardizes test conditions. Unfortunately this view is too simplistic, since every organism has an optimal range of environmental conditions. If one or more of the environmental factors are outside the optimal range, this causes stress to the organism. The degree to which a test is influenced by the stress experienced by the organisms can currently not be judged from the control group, because the required level of survival is too low. In fact all of the added surrogates may die in the control as well, and have no effect on the outcome. It is beyond the scope of this paper to discuss the advantages and disadvantages of using either surrogates or natural plankton communities in any depth. However, regardless whether natural or surrogate organisms are used, robustness of the data will be greatly increased by relaxing the requirement for intake numbers but making the requirement for control survival much stricter. The following, hypothetical example (Table 1) illustrates this problem/issue with the requirements for organisms larger than 50 µm. This would be a valid certification test run. It fulfils the numerical and taxonomical requirements of the guideline. However, these hypothetical data show that phylum 1 is so severely affected by the test conditions that no evaluation of the performance of the BWMS against these organisms is possible. More importantly, two different species, representing another phylum are neither affected by test conditions, nor the treatment.

3 FUHRet al: CHALLENGES AND SOLUTIONS OF BALLAST WATER MANAGEMENT 2009 Table 1: Example for a formally valid test run according to the requirements. Numbers are chosen for sake of argument and are not data from a real test run Discharge treated Discharge control Intake water (organisms.m -3 water water ) (organisms.m -3 ) (organisms.m -3 ) Species A Phylum Species B Phylum Species C Phylum Species D Phylum Species E Phylum Total Table 2: Example for a formally invalid test run according to the requirements. Numbers are chosen for sake of argument and are not data from a real test run Intake water Discharge treated Discharge control (organisms.m -3 ) water water (organisms.m -3 ) (organisms.m -3 ) Species A Phyllum Species B Phyllum Species C Phyllum Species D Phyllum Species E Phyllum Species F Phyllum Species G Phyllum Species H Phyllum Species I Phyllum Species J Phyllum Total

4 2010 INDIAN J. MAR. SCI., VOL 43, NO.11 NOVEMBER ,60,000 Organisms >50μm per m 3 Dutch Wadden Sea 1,40,000 1,20,000 1,00,000 80,000 60,000 40,000 20,000 0 Fig. 1 - Average number of organisms (larger than 50 micrometre) on intake of brackish/marine water from the Dutch Wadden Sea. 2,50,000 Organisms >50μm per m 3 Lake IJssel 2,00,000 1,50,000 1,00,000 50,000 0 Fig. 2 - Average number of organisms (larger than 50 micrometre) on intake of freshwater from Lake IJssel (The Netherlands).

5 FUHRet al: CHALLENGES AND SOLUTIONS OF BALLAST WATER MANAGEMENT 2011 In table 2 on the other hand, a hypothetical example of an invalid certification test run is shown. It does not fulfil the numerical requirements of the guideline G8 3. However, in terms of evaluating the BWMS, this test run is far superior to the first one. It provides information on more different phyla than the first example. This is important since BWMS, once type approved, are used across the globe, while they are only tested in one or two areas. Confidence in the robustness of the BWMS is increased when they are tested against a variety of phyla. A taxonomic phylum represents a certain organisation structure that organisms grouped in this phylum share. If a system therefore is tested against representatives from one phylum, it is plausible to assume that it will perform likewise against similar species from the same phylum in other parts of the world. Data from the 2013 test season further illustrate this. Figure 2 shows that intake numbers for freshwater in our area are higher than those for marine waters (Fig. 1). However, these higher numbers come with lower diversity. During the test season more than 23 different species were encountered in the marine samples. They represented 11 different phyla. Equally, more than 20 different species were encountered in the freshwater samples. They represented six different phyla. Moreover, 14 of the 20 species identified in the freshwater samples represented just one class (Crustacea). Of those 14, 11 were Cladocera, i.e. representing just one type of organisation structure. In this respect the marine tests provide more information on general applicability of a system against biota, than the freshwater test, even though they did not meet the numerical criteria consistently. Freshwater on the other hand has quite different properties than marine water (e.g. surface tension, conductivity, buffer capacity, optical transmission and so on) and often poses more technical challenges to a BWMS. Observations from 2012 and 2013 (MEAnl, unpublished data) show that barnacle cypris larvae as well as certain polychaete larvae in brackish/marine and rotifers in freshwater environments pose a serious challenge for certain ballast water treatment options. Such data, acquired by test facilities could be used to identify areas with a higher risk of certain technologies to fail, based on species distributions. This could help to further minimize the risk of an invasion, improve BWMS faster and more cost efficient and to use the limited port state control resources in a more efficient manner. For this to be a viable option an independent entity would need to take the lead in this due to the constraints on information flow outlined above. Abiotic parameters The standardization issues outlined in the previous section do also apply to abiotic parameters for which guideline G8 3 requires intake values. At the time when the first guideline 2 was drafted, very limited data were available and none from actual test series. Therefore a further definition of the parameters was not possible at the time. However, meanwhile we are almost ten years further and practice shows that the parameters should be defined differently and that some do not give the intended information. Measuring turbidity in Nominal Turbidity Units (NTU) is not useful in unknown fluids, i.e. surface waters with changing particle load and dissolved compounds. The NTU measurement method was basically developed as a mean of product control for fluids of a known (desired) content against a defined standard, e.g. drinking water and beverages. A much more useful and practical measurement for ballast water purposes could be UV-transmission which is more related to dissolved compounds and the use of UV as a disinfection technology. The measurement of Total Suspended Solids (TSS) is another parameter that should be revised. Though it seems straight forward, 50 mg L -1 of coarse sand is something completely different than 50 mg L -1 of fine, organic detritus. A clear definition of the purpose of the measurement is needed, i.e. challenging filtration technology that may be part of the BWMS, higher turbidity, increased background demand for used chemicals of the test water, etc. Only with such a definition in place, suitable substances can be added to the test water, where necessary. Another aspect of this is that any addition is altering the water conditions for the organisms therein. This

6 2012 INDIAN J. MAR. SCI., VOL 43, NO.11 NOVEMBER 2014 may lead to stress for the organisms as outlined before in the section about biological data. Concurrently, organic additions will definitely stimulate the growth of heterotrophic bacteria. Therefore it may be a better option to do a separate test run addressing physical and chemical questions related to TSS and accept the ambient water as is for the biological efficacy test runs. This could also be beneficial for system developers and ship owners as this could be done as component tests for, e.g. filters. Equally, temperature is a required abiotic parameter to be measured, which needs to be better defined in terms of the required information. Temperature does have an impact on, e.g. residual time of certain chemicals. However, these effects are usually observed in the upper and lower temperature ranges, i.e. outside those of the temperate regions. In natural waters these conditions are often associated with a reduced ambient number of organisms and surrogate organisms will be affected by the change from their optimal to a higher or lower temperature regime respectively. Again, better defined information requirements could lead to more effective testing. Finally, the three salinity regimes also need further definition to make for better, more practice orientated testing. Major differences in the performance of BWMS have been observed between fresh water and marine water. Within the latter category, differences in performance between brackish water and full marine water are usually minor, that is, for waters above roughly 10 PSU and certainly above 20 PSU. Low saline brackish water (3 10 PSU) differs from both fresh and more saline waters. However, it usually is also low in organism numbers and often dominated by a single or only a few species, again lending itself for special tests. Many test facilities have access to brackish coastal water of varying salinity and a euryhaline plankton community. Manipulating such waters with brine or fresh water additions solely for the purpose of creating a 10 PSU difference is not adding a lot of information, while it increases the work load and therefore testing costs. It would be a more pragmatic to allow test facilities with such conditions to test with the ambient water and make sure that those tests span an as wide as possible salinity range, e.g. by testing at different tides. Conclusions and recommendations Despite the short-comings described above, the generic guideline G8 3 has given a good account of itself in the past years. When used pragmatic and in a sensible manner, with well documented deviations, it provides both, test facilities and verification organizations with a standard format to bridge the information and knowledge gap between marine science on the one and administrative and legal aspects on the other side. Thus, it does not work well, when it is used as a fixed checklist to tick off parameters. In our view, this is the source for a lot of the frequently heard criticism dismissing the guideline altogether. The parameters given in the guideline 3 were theoretical deducted by experts with the best available data at the time. Re-evaluating these with the newer, real world data collected by test facilities around the world could help to better define the parameters. This could lead to more efficient, practice orientated testing, increasing acceptance in the industry. The latter is crucial in order to implement the ballast water management convention 1. By better defining the purpose of the required information/testing, BWMS developers, verification organizations and test facilities could easier evaluate the relevance of a parameter for a technology, reducing unnecessary manipulation of test waters. Furthermore, by communicating these evaluations, ship owners receive a tool to evaluate BWMS for their own fleet s situation. Port state control could also use such information in order to have a more directed, resourceful compliance control scheme. References 1 International Maritime Organisation (IMO), International convention for the control and management of ship s ballast water and sediments, Anonymous, Guidelines for approval of ballast water management systems (G8). Resolution MEPC.125 (53), Anonymous, Guidelines for approval of ballast water management systems (G8). Annex 2 ResolutionMEPC.174 (58), 2008.

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