Section 3 Best practice for commissioning testing

3.1 General

3.1.1 The service supplier carrying out the commissioning testing of the BWMS is to be familiar with the system, in terms of its operation principles and its System Design Limitations/operational limitations. These will be clearly defined in the IMO Type Approval Certificate.

3.1.2 It is advisable that the shipowner discusses the System Design Limitations/operational limitations of the BWMS and intended uptake water with the service supplier and provides the service supplier with all necessary documentation, such as copies of Type Approval certificates, the Operation, Maintenance & Safety Manual, etc. Some systems will have limitations for salinity, temperature, UV transmissions, etc. of the uptake water, for example.

3.1.3 The shipowner should ensure that the ballast tanks have been cleared of sediment prior to the commencement of commissioning testing. Sediment is to be disposed of responsibly and in accordance with local regulations. The ship’s crew are to operate the BWMS during commissioning testing. It is therefore important the crew are familiar with and trained in the correct operation of the BWMS before commissioning testing commences.

3.1.4 Some BWMS, such as UV types, are able to operate in different modes which can alter the dosing. The shipowner should ensure that during commissioning testing the system is operated in its IMO Type Approved mode, which may use a lower dose compared to United States Coastguard (USCG) Type Approved mode.

3.1.5 The safety of persons involved in the commissioning testing is essential, and due consideration should be given to the BWMS technology used. For example, some BWMS use active substances which can have harmful effects. Material Data Safety sheets are to be available and consulted.

3.1.6 Commissioning testing comprises two assessments. In addition to assessing the biological performance by sampling and analysis of the ballast water, it is required to assess the system’s self-monitoring parameters for correct operation of BWMS. Service suppliers are to perform both assessment of the biological sampling and assessment of self-monitoring parameters and submit findings in the form of a report. It is therefore important the ship’s crew are familiar with self-monitoring details and able to assist in providing access to gather the required information to perform the commissioning testing effectively.

3.2 Sampling and analysis assessment for commissioning testing

3.2.1 The sampling and analysis of the ballast water for commissioning testing is to verify that the BWMS is installed and functioning correctly. The purpose is not to revalidate the Type Approval testing.

3.2.2 Sampling

Sampling should be conducted for compliance with the IMO International Convention for the Control and Management of Ships' Ballast Water and Sediments, 2004, regulation D-2. Samples should be collected to conduct analysis on two of the defined organism size classes, greater than or equal to 50 µm and greater than or equal to 10 µm–50 µm, in accordance with IMO BWM.2/Circ.70, rev1.
A representative sample should be collected, in accordance with Guidelines for Ballast Water Sampling (G2). The only exception is during sampling at uptake, where ambient water is collected.
Discharge sampling is to be conducted in a way that minimises mortality of organisms, with a sample volume of at least 1 m³. This will result in using a standard plankton net arrangement, or ISO standard sample collection devices for ballast water sampling. Time integrated sampling over the whole discharge operation would be recommended. Smaller sampling volumes may be acceptable, provided they are validated and accepted by LR. It is advisable for service suppliers to submit validation reports and get approval in advance of commissioning testing.
Typically, indicative analysis equipment requires a small volume of water for analysis. It should be demonstrated that the concentration of sub-samples is representative of the sample volume collected. Full information, including methodology and mixing for sub-samples, should be provided to LR and the shipowner.

3.2.3 Analysis

Samples should be analysed using indicative analysis equipment. Indicative analysis is defined in BWM.2/Circ.42/Rev.1, as may be amended. This is a minimum requirement as per BWM.2/Circ.70, rev1, as amended.
Detailed analysis may be used, in place of indicative analysis, as detailed analysis provides more accurate results. The detailed analysis methodology should be suitably validated and approved by LR. Should samples be sent to a laboratory, for preparation and subsequently to conduct detailed analysis, then the detailed analysis should be carried out under an approved method(s) in accordance with ISO/IEC 17025, or equivalent.
LR requires indicative analysis equipment to be approved for its intended purpose. It is understood that currently there are few types of indicative analysis equipment available for the analysis of the greater than or equal to 50 µm organism size class. As an alternative, a combination of detailed and indicative analysis may be used.
Uptake water does not need to meet specified challenge conditions. The uptake water should be suitable for treatment by the BWMS, i.e. not outside of its System Design Limitation. Hence, characterising the physical water condition of uptake water is important.

3.3 Self-monitoring parameters assessment for commissioning testing

3.3.1 The BWMS may have a range of self-monitoring parameters that are fundamental to monitoring the correct biological performance and system operation, and these are to be monitored and recorded simultaneously, as part of the commissioning test. Self-monitoring parameters should be recorded on both the uptake and the discharge cycles during the commissioning testing. Often, the set points for the self-monitoring parameters are set during the commissioning of the system and can be ship-specific. The Operation, Maintenance and Safety Manual, Type Approval certificate and other documentation from the manufacturer, will provide information on self-monitoring parameters.

3.3.2 The set points for the self-monitoring parameters should be recorded as part of the commissioning test. When the system is in operation, comparison against these set points can be made. The Human Machine Interface (HMI) screen of the BWMS should provide real-time updates of the parameters. Subsequently, these will be recorded in the system’s log. Some parameters will be BWMS technology specific, others generic. Table 1.3.1 Parameter examples gives a non-exhaustive list of parameters that might be relevant:

Table 1.3.1 Parameter examples

Parameter	Unit (s)	Applicable system example
Flow rate	m³/hr	Most inline systems
Treated volume	m³	In-tank systems
Ultraviolet (UV) dose (UVD)	mJ/cm², J/m²	UV systems
UV intensity (UVI)	mw/cm², w/m²	UV systems
UV transmission (UVT)	%	UV systems
Filter inlet pressure	Bar, mbar	System with filter
Filter differential pressure	Bar, mbar	System with filter
Total residual oxidant (TRO)	ppm	Active substance systems
Dissolved ozone	ppm	Ozone systems
Conductivity	µs/cm	Systems with salinity restriction
Salinity	PSU	Systems with salinity restriction

3.3.3 Depending upon the design of the BWMS, it may be necessary for some of these self-monitoring parameters to be verified by sampling. For example, TRO measurement can be verified by analysing discharge water with a portable calorimeter. This would verify that the BWMS discharge does not exceed the Maximum Allowable Discharge Concentration (MADC) limit, and that it is installed and functioning correctly.

3.3.4 The self-monitoring parameters will be displayed and available in the BWMS control and monitoring system. Photographic evidence of the BWMS HMI screen with above parameters and BWMS alarm log should be submitted with the report. These photos should be taken periodically throughout the commissioning test.