For those companies scoping how to start with United States Coast Guard (USCG) Type Approval for their ballast water treatment systems (BWTS), insight into the experiences of others that have advanced through the process can prove invaluable.
Ecochlor is a company that has been very active in pursuing regulatory approvals and are very much a front runner in the race for USCG Type Approval. In May this year, they announced that they had successfully completed all land-based and shipboard testing for their ballast water treatment system (BWTS) at the Golden Bear Facility in preparation for submission of the application for United States Coast Guard (USCG) Type Approval.
The first shipboard installations of their filtration and disinfection treatment-based ballast water treatment system (BWTS) were performed in 2004. They received Type Approval from the International Maritime Organization (IMO) in 2011, following a testing period of over one year and USD 1 million investment. The first step that the company took on their quest to gain USCG Type Approval was their BWTS achieving USCG acceptance as an Alternate Management System (AMS) in 2013. Fast forward to 2016 and the company is yet to receive USCG Type Approval for their BWTS, despite being the one of the companies closest to clinching the accolade. However, they do expect to be granted USCG Type Approval in 2016.
The first action for Ecochlor when starting their journey toward USCG Type Approval for their BWTS was to select an Independent Laboratory (IL) for testing. At the time, Ecochlor only had two ILs to choose from – one was DNV GL and the other NSF. As DNV GL was the only IL to be associated with a classification society and with Ecochlor being interested in getting class approval, they chose DNV GL’s IL.
Under the IL, Ecochlor then had to select test facilities for the 3 major tests that must be conducted under the USCG Type Approval requirements; shipboard testing, land-based testing and environmental testing.
In 2014, Ecochlor selected the Golden Bear Facility for the shipboard and land-based testing. This facility gave them the opportunity to conduct two types of testing at one institution, something which saved them time and meant that testing could be completed sooner. Ecochlor was required to conduct the testing of three water types: brackish, high saline and fresh. This ensures that their BWTS will hold approval from the USCG, once Type Approved, to operate in all water qualities.
Towards the end of 2014, once their testing facilities and IL were selected, Ecochlor submitted their letter of intent (LOI) to the USCG. Any BWTS manufacturers that want to pursue USCG Type Approval must submit an LOI no less than 30 days prior to the initiation of testing. The LOI must outline as much information as possible about the IL selected, the test facilities selected and
the general schedule for testing. Thus far, 32 BWTS manufacturers have submitted LOIs and out of the 32, 16 are currently engaging in testing, say the USCG. In February 2015, the Ecochlor BWTS was lifted on the Golden Bear Facility (GBF) vessel, via a 20 ft shipping container as per the GBF requirements, that state all BWTS equipment must fit into this size container unit.
In April 2015, the Ecochlor BWTS underwent its first commissioning test. For this, manufacturers are allowed to be present, but are not allowed to operate the system. This first commissioning test was used as the first of five shipboard tests for the Ecochlor BWTS. These tests have to be conducted throughout a period of at least 6 months. The Golden Bear vessel was in port from April to May 2015 and it was during this time that the Ecochlor BWTS was subjected to tests with brackish and high saline water. Under the USCG rules five tests conducted for each water type. In May to August 2015, the Golden Bear sailed from the west coast of the US to the east coast of the US and then on to Europe. The ship board tests were performed when the vessel called at ports in California (US), Boston (US), Barcelona (Spain) and Naples (Italy).From September 2015 to March 2016, Ecochlor began the final process of land-based testing of the BWTS with fresh water.
With all testing complete, Ecochlor is now finalising environmental testing at Retlif Laboratory. Once these tests are complete and data has been reported and summarised DNV GL as the IL will review the test data and submit a report of their findings for compliance with the Final Rule to the USCG. Ecochlor will then submit an official application to the USCG within the next few months. If successful, their journey to USCG Type Approval will be complete, a mere three years after it first began.
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