Katie Weaver, Ecochlor described the process ‘’Towards USCG Type Approval’’during the 2016 GREEN4SEA Conference & Awards. She said that Ecoclor’s BWTS uses a two-step process to treat ballast water – filtration followed by disinfection with the well-known biocide, chlorine dioxide. The system’s effectiveness is not impaired by variations in salinity, temperature, turbidity, organics, and vibration, which can impact other treatment options. In March, Ecochlor BWTS completed testing for USCG Type Approval. After review by the independent lab, a Letter of Recommendation will be sent to the USCG and the Ecochlor team will prepare and submit a USCG Type Approval application.
My presentation focuses on the steps that Ecochlor has taken as moves towards the USCG type approval and our expectations in the future as we move closer to USCG type approval.
The whole process started in 2013 with a selection of an independent laboratory (IL). The USCG uses that independent laboratory to ensure the independence in the test process. The IL oversees the test process and they are actually operating the system and ensure that manufacturer isn’t involved as testing is performed. In 2013, when we started to look into selecting our independent laboratory, there were two to choose from, one of them was NSF and the second was DNV-GL. One of our motivation as we were going through USCG type approval was to also secure class society approval if possible, so for that reason we selected DNV-GL as our independent laboratory that we have been working with since the process begun. Then, after we had selected our IL, we turned to select the actual test facilities where our tests would perform. There are three major types of testing performed under USCG type approval similar to the IMO process. Land based testing, shipboard testing and then environmental testing.
We selected the Golden Bear Facility in Vallejo California for our land based and shipboard testing. We selected the GBF for two reasons. First, it was located in the US and we were familiar with the facility and comfortable with the staff of the scientists that were working there. They also give us the ability to do both our land based and shipboard tests at the same location. Some manufacturers are performing land based testing at a land based facility and then they are using a commercial installation for their shipboard testing. We, however, were able to perform it in one location, expecting that it would hopefully save us some time and money.
We selected Retlif Laboratories in New York to perform our environmental testing. Similarly, they were located in the United States, so they were fairly close to our manufacturing which is in the east coast of the United States. Over the course of 2014, we chose those facilities and we also started to put together the system that we would be using for land based and shipboard testing.
In the end of 2014 we submitted our letter of intent to the USCG. That letter gave in the USCG an overview of our testing program, the test facilities that we were up to use when we initiate testing. For my understanding and from what I have seen recently, 32 manufacturers have submitted letters of intend to the USCG but recent presentation, actually in February of 2016, has indicated that only 16 manufacturers are currently undergoing testing.
Once we had all lined up and had our system built, our installation occurred in February of 2015, so just the beginning of last year and here you can see our system as it is being delivered to the golden bear facility.
Our system is located in that shipping container, you can see (1.1) being lifted onto the vessel below, with the ecochlor logo on it.
The image below (1.2) gives you an idea of a typical shipboard installation.
Normally, our filter would be installed in close proximity to the ballast pumps either in the engine room or in cargo pump room and then our treatment system was consisted of these two chemical storage tanks, as they depicted, a generator cabinet and a control panel. Those are installed in any kind of convenient location on the vessel where we can find available space.
However, for the installation at the Golden Bear everything had to fit into that twenty-foot shipping container. Our system is modular and the two chemical storage tanks, the generator cabinet and the control panel, can be all reoriented to fit into available space that we have to work with.
The image below(1.3) depicts what we actually use for the installation in the Golden Bear. This is the engineering design and you can see how we took the typical installation and then reworked to fit in the available space. Thus, our chemical storage tanks are over on the right hand side of the image, the filters in the front towards the left, the control panel is in the back left and then the generator cabinet is somehow fitted in between there. This is the same installation you see in a commercial vessel, the only difference is that we use temporary tanks for chemical storage tanks rather than stainless steel tanks that we would use on a permanent installation.
The system was installed in February of 2015 and in April of 2015 was commissioned. At that point, it was turned over to the Golden Bear facility – there is a lot of independence in this testing, once that happened Ecochlor was not involved in the test process. We performed our first commissioning test in April 2015 and it was successful. It was actually a shipboard test so it was counted as the first of our shipboard testing program. Under the USCG process, shipboard testing has to be performed over a period of six months, so that started our six-month timeclock for shipboard testing.
Between April and May of 2015 the vessel was in port of Vallejo California and performed some of the land based testing, so our land based testing consisted of a series of 15, five tests in three different water qualities, in fresh, saline and brackish water. Ten of these tests were performed in that spring, five test in brackish water and then five tests in saline water.
Between May and August of 2015 the vessel left for its summer cruise, so the GBF is used as a training vessel for cadets from the California maritime academy, thus the vessel sailed from the west coast of the US to the east coast of the Mediterranean and back. At the ports of call that they called on they performed our shipboard tests. Shipboard tests were performed in Vallejo California, Boston Massachusetts, Barcelona Spain and Naples Italy where a couple of different water temperatures and their requirements for shipboard testing covered.
In September of 2015 the vessel returned to Vallejo California where she has been over the winter and spring. We performed four of our freshwater land based test in the fall of 2015 and we performed our last shipboard in October.
Our results have been very consistent with our IMO tests results, chlorine dioxide is very highly effective during our IMO testing, there were actually no measured organisms in our shipboard tests results for any of our shipboard cycles and we have been very pleased to share those tests results. We are currently seeing similar results as we are undergoing the USCG testing which is what we had expected due to the efficacy of chlorine dioxide.
We have scheduled an environmental testing for April of 2016 and then at that point our testing program will be completed, there will be report writing to be done by both subcontractors and Ecochlor. DNV-GL will be reviewing all this data that has been gathered and making a recommendation to the USCG, and then Ecochlor will submit its application to USCG. Our expectation is that we will submit it towards the summer of 2016. At that point, it is up to the USCG to review our application and we expect that they will issue Ecochlor USCG Type Approval.
Above text is an edited article of Katie Weaver presentation during the 2016 GREEN4SEA Conference & Awards.
You may view his presentation by clicking here
On May 2016, Ecoclor announced the completion of all land-based and shipboard testing at the Golden Bear Facility (GBF) in preparation for submission of the application for USCG Type Approval. The system was verified in all three salinities, 5 test cycles each, for a total of 15 consecutive and successful cycles to meet the USCG requirements.
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About Katie Weaver, Technical Sales Manager, Ecochlor
Katie Weaver joined Ecochlor in 2014 as the Technical Sales Manager. She has 12 years of experience in environmental science working in ecological research; environmental remediation; and, human health and ecological risk assessment. In this capacity Ms. Weaver has performed environmental sampling, reviewed laboratory data, and managed environmental remediation projects. Prior to Ecochlor, she served as a human health risk assessor, quantifying the effects of environmental contaminants on human health. Ms. Weaver holds a B.A. in Biology from Bucknell University.