BALLAST WATER TREATMENT IN PORTS. FEASIBILITY STUDY

Transcription

1 BALLAST WATER TREATMENT IN PORTS. FEASIBILITY STUDY This study investigates the possibilities and feasibility of the port based ballast water treatment by mobile units

2 TITEL: BALLAST WATER TREATMENT IN Projektgruppe: A consortium of Danish Ship Owners Association, Maersk A/S, DFDS A/S and Danish Ports PORTS. FEASIBILITY STUDY Udgiver: Naturstyrelsen Haraldsgade København Ø Redaktion [evt. fotos og illustrationer]: Danish Partnership on Ballast Water År: ISBN nr Ansvarsfraskrivelse: Naturstyrelsen offentliggør rapporter inden for vandteknologi, medfinansieret af Miljøministeriet. Offentliggørelsen betyder, at Naturstyrelsen finder indholdet af væsentlig betydning for en bredere kreds. Naturstyrelsen deler dog ikke nødvendigvis de synspunkter, der kommer til udtryk i rapporterne. Må citeres med kildeangivelse.

3 ADDRESS COWI A/S Parallelvej Kongens Lyngby Denmark TEL FAX WWW cowi.com NOVEMBER 2012 DANISH SHIPOWNERS' ASSOCIATION, MAERSK, DFDS, DANISH PORTS BALLAST WATER TREATMENT IN PORTS. FEASIBILITY STUDY PROJECT NO. A DOCUMENT NO. A27616-FS-01 VERSION 3.0 DATE OF ISSUE PREPARED CKI,MHO,LEGL, JNAN, JOVP, PSP CHECKED CKI, PSP APPROVED PSP

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5 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 5 CONTENTS 1 Executive Summary 7 2 Introduction Methodology 11 3 Treatment of ballast water in ports a possibility General Modes of operation Environmental considerations 15 4 Logistical challenges - Equipment, operation, costs General Principles of treatment Equipment Mode of operation Capital investments (Capex) Operating cost (Opex) Conclusion 37 5 Scenarios, business cases Scenario A-1 - Esbjerg Scenario A-2 - Esbjerg Scenario A-3 - Service ships Summary Esbjerg Scenario B-1 - Fredericia Scenario A-4 - Treatment from barge Scenario A-5 - Supply of treated water Summary 52 A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

6 6 Financial analyses Basic assumptions Results Evaluation and sensitivity check Comparative scenario Scenario A-4 - Treatment from barge Scenario A-5 - Supply of treated water Cost and price Recapitulation 58 7 Summary - conclusions The study results Conclusions 60 8 Testing the concept Description Programme 63 APPENDICES Appendix A Regulations D-1 and D-2 64 Appendix B Regulation B-3 65 Appendix C Guideline G-5 66 Appendix D Regulation A-3 72 Appendix E Regulation A-4 73 Appendix F Ships at berth 1/1-31/

7 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 7 1 Executive Summary The spreading of possible harmful invasive aquatic organisms from one region to another caused by discharge of ship s ballast water, represents a threat to the world s oceans and has gained increasing awareness worldwide. Since 1992 voluntary guidelines have been issued and adopted by the UN for prevention of the spread of invasive species from ship s ballast water. In 2004 the International Maritime Organisation (IMO) adopted the International Convention for the Control and Management of Ships Ballast Water and Sediments. When the convention enters into force all ships in international traffic will be required to manage and treat their ballast water to certain standards and regulations. The convention will enter into force 12 months after a total of 30 states, representing 35% of the world s shipping tonnage, have ratified it. (At the end of 2012 in total 36 states with 29% of the world s tonnage have ratified the convention). In general, the convention s requirements for ballast water management and treatment will, within a certain time line, require special treatment units onboard the ships navigating internationally. The convention also mentions the option of establishing treatment facilities in ports, as an alternative to the onboard treatment. This study investigates the possibilities and feasibility of the port based ballast water treatment by mobile units. The study was carried by COWI A/S assigned by a consortium of Danish Ship Owners Association, Maersk, DFDS and Danish Ports. The study has been based on two Danish ports and several scenarios and business cases have been addressed, mainly involving freight ferries and service ships in regular service. The investigations have covered the following main issues: Conditions and process for the environmental approvals A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

8 Technical and operational challenges and feasibility Financial feasibility of the business cases The results and conclusions of the study can be summarized as follows: Environmental approvals by the authorities can probably be obtained The technical and operational concepts can be considered feasible The port based treatment seems only realistic for ships in regular sailings and with a yearly minimum amount of ballast water treated of 0.2 mill. ton per unit The business case with best results includes several selected Ro-Ro ferry routes in the North Sea, operated by one company The estimated cost of the onboard treatment seems somewhat lower than the calculated treatment cost of the best case, however that needs to be investigated further, taking all conditions into account, to reach a more solid base for comparison between the concepts.

9 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 9 2 Introduction In February 2004 the International Maritime Organization (IMO) adopted the International Convention for the Control and Management of Ships Ballast Water and Sediments (BWM). The convention aims to prevent the spread of harmful aquatic organisms from one region to another, by establishing standards and procedures for the management and control of ships ballast water and sediments. Under the convention and when entering into force all ships in international traffic will be required to manage and treat their ballast water to certain standards especially regulations D-1 & D-2. These set the requirements for ballast water exchange (D-1) and the final requirements for treatment of ballast water (D-2). Regulations D-1 and D-2 can be found in Appendix A. The convention will enter into force 12 months after a total of 30 states, representing 35 % of the world s shipping tonnage, have ratified it. At mid year 2012 in total 36 states have ratified the convention, representing 29 % of the world s shipping tonnage. The time-frame for implementation depends on whether the ship is newly built or existing and when the construction took place. The rules are as follows: In general, the convention s requirements for ballast water management and treatment according to regulation D-2, within a certain time line, will require special treatment units onboard the ships navigating internationally in several biological zones. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

10 Regulation B-3.6 refers to the option of establishing reception facilities for ballast water in ports. If implemented the planning and design of those facilities should follow the guidelines G5 of the Convention. Regulation B-3 can be found in Appendix B, and the guidelines G-5 in Appendix C. Certain exceptions are listed in Regulations A-3 (mainly concerning situations of distress and if the ballast water is discharged where it was taken in, see Appendix D) and possibilities for exemptions are described in A-4 (see Appendix E). The consortium of Danish Ship Owners Association, Maersk A/S, DFDS A/S and Danish Ports has engaged COWI A/S to carry out a feasibility study with the purpose of investigating and clarifying the possibilities of treatment of ballast water from ships in ports, as an alternative to the treatment onboard the ships. There are various reasons for taking an interest in this option. Retrofitting equipment in existing vessels is expensive and may lead to suboptimal operation and maintenance conditions. One on-quay plant may service many ships and thereby use the invested capital better. If the process takes place on land, the authorities environmental monitoring will be easier; and a dedicated organization can ensure better management than if the process is an addition to ship crews many other duties. Finally, although Regulation A-4 allows exemptions for ships operating exclusively between specified locations, it is far from certain that such exemptions will be granted. The consortium envisages that for ships sailing in fixed routes with regular calls at few ports or for ships with rare exchange of ballast water, mobile treatment units could be employed in the ports to service the ships. In this way the installations on each ship could be avoided, with the anticipated resulting savings in space, cost of installations and operational costs. Establishing and operating land based mobile treatment plants is envisaged as a possible approach to ballast water treatment, as a relatively small number of treatment plants can service a greater number of ships. The principal purpose of this study is to investigate and clarify the possibilities and the feasibility of implementation of port based mobile treatment units for ships ballast water, hereunder: The conditions and process for the environmental approvals of the land based treatment solution The technical and operational challenges of the mobile treatment facilities in the ports The financial basis and the feasibility of the realistic business cases Presenting conclusions and the basis for carrying out tests of a prototype plant

11 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY Methodology Two major ports in Denmark have been selected as case studies Esbjerg Port located on the west coast of Jutland and Fredericia Port, located on the east coast of Jutland. The port of Esbjerg has been chosen because of the high frequency of calls from ships on fixed routes between the port and a limited number of other ports. Furthermore, the port of Esbjerg is the base for the service ships to the offshore platforms in the North Sea. Such shipping activities seem the most likely to be able to utilize land based ballast water treatment facilities instead of onboard treatment units. The port of Fredericia services shipping lines with more random calls at the port and by various types of vessels. The port also includes a major terminal for export of crude oil. As concerns equipment, DESMI s OceanGuard TM has been chosen. It has been developed by DESMI Pumping Technology A/S in Nørresundby, Denmark, and it has received approval from IMO for treatment of ballast water Main approach The main approach of the study and investigations has been the following: Investigation of the conditions and the main changes with regard to regulations and environmental approvals by adopting the land based treatment of ballast water instead of the onboard treatment plants. Clarification of the possible barriers and solutions related to the environmental aspects and approvals. On the basis of two Danish ports, selected as case studies, investigation of the logistics and the technical possibilities, challenges and solutions. Development of the concepts of the mobile treatment units and their mode of operation. Selection of realistic scenarios for the treatment operations with regard to the frequency and number of ship-calls at the ports and the operational aspects. Financial analyses for the chosen business cases. Evaluation and conclusions It must be noted that the described equipment and technical processes are on a conceptual base and shall be further investigated and designed for a development of a prototype plant, if so decided Structure The investigations and analyses have been structured as follows: A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

12 Initial assessments, selection of the ports for the case studies Meetings with the port organisations for discussions of the conditions and logistics in the ports including the data for ship-calls at the ports Data and registration of calls at the ports for the ships involved. Meetings with the selected supplier of treatment plants in Denmark, DESMI A/S Development with DESMI of the preliminary features and concept of operation of the mobile treatment unit Environmental considerations and investigations of the possible solutions for handling of residual material. Evaluation of barriers for approvals Establish the cost data and economical basis for the mobile units Interviews with the relevant parties Development of the various possible scenarios for the implementation of the mobile units at the two ports and the connecting ports of call Perform the financial analyses for the scenarios selected and the assessment of the comparable solution with the treatment onboard the ships Summary evaluation - conclusions Interviews, in addition to the meetings, have been made with among others: Maersk Maritime Technology, Copenhagen DFDS Technical org., Esbjerg; DFDS Stevedore, Esbjerg; Danbor, Esbjerg; OW Bunkers, Ålborg; Bek & Verburg, Rotterdam, (barge services); Shell Terminal, Fredericia; Fredericia Shipping; Unifeeder, Århus; IMO, London.

13 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 13 We thank all the interviewed parties for their valuable contributions. Terminology This study has used the following terminology for the main elements: The convention: Ballast Water Management Convention IMO Ballast water treatment: Treatment process by filtering and UV irradiation as approved by IMO and under approval of the flag state, Denmark. Mobile treatment unit: The complete treatment plant mounted on a flatbed trailer, with truck unit. Residue / filtrate: The residual material from the backflushing of filters. Slurry: The slurry pumped to the tank on the trailer via a hydrocyclone contained in the treatment unit. The content of suspended material will be around 5 %. Barge: Self-propelled harbour barge, 35 40m in length. Operator: The stevedoring company which carries out the operation of the mobile treatment units. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

14 3 Treatment of ballast water in ports a possibility 3.1 General Of the various options for managing ballast water, on-quay treatment at arrival is not an obvious one. It means that ships will carry potentially invasive species in their ballast tanks and that emergency dumping of ballast water, although rare, will entail environmental risks. If de-ballasting before entering a port is necessary, due to e.g. tidal conditions, on-quay treatment is not an option. Reasonable guarantees of availability are also needed to avoid costly waiting time. On the other hand, on-board treatment has drawbacks. The space needed for the equipment could be used for cargo; retrofitting equipment can be inconvenient in terms of working conditions under installation, operation and maintenance; and operation will require crew s attention at moments when this attention is required elsewhere. Capital is invested in equipment with little operating time. Environmental authorities monitoring of the activities is difficult. On-quay treatment of ballast water therefore merits a study. 3.2 Modes of operation Various types of equipment, based on different technologies, have been developed for this purpose. At present, 22 types of approved equipment are available on the market. Of these, 12 are based on UV irradiation and filtration, 7 on electrolysis and filtration, one on de-oxygenation, one on chemical injection and one on pure ozone. The present study considers only DESMI s OceanGuard TM, a system based on UV irradiation and filtration. For the onboard plants with filters, which probably will be installed in many vessels not sailing in regular routes, the treatment takes place both during ballasting and during de-ballasting. In this way the backflushing material is dumped into the sea where it was taken from. During the de-ballasting in the port of arrival the ballast water contains only a small amount of suspended material and

15 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 15 the backflushing material is returned to ballast tanks or the filters are bypassed. This is the modus operandi for which DESMI s equipment is intended. The principal difference between ballast water treatment onboard ships and on the quay by mobile treatment units lies in the process of handling the return material from the backflushing of the filters of the treatment units in question. The treatment process itself within the units will be similar, both in the onboard plants and in the land based units. The land based treatment units will have to treat the ballast water in one single operation during de-ballasting and the backflushing material must be handled in a safe and appropriate way. This means that in most cases the operation of the mobile treatment units in ports must be approved by the local environmental authorities. This is in addition to the required testing and approvals of the treatment plants by IMO and the flag state in Denmark the Danish Nature Agency and the Danish Maritime Authority. 3.3 Environmental considerations According to regulation D-2 of the Convention, "Ballast water performance standard", the ballast water from ships must comply with certain quality standard before it can be discharged it into coastal waters or ports. To meet the standards some sort of treatment prior to discharge will be necessary. The IMO standards are summarized in the table below. IMO D-2 Standard for Discharge Ballast Water Microorganism category Regulation Plankton, size > 50 μm < 10 viable cells / m 3 Plankton, size μm Toxicogenic Vibrio Cholerae Escherichia Coli Intestinal Enterococci < 10 viable cells / ml < 10 Colony Forming Unit / 100 ml < 250 Colony Forming Unit / 100 ml < 100 Colony Forming Unit / 100 ml The supplier of the treatment plant chosen for this study, DESMI A/S, has informed that the proposed mobile treatment plant (OceanGuard TM, capacity 300 m 3 /h) can meet the above IMO quality standards. The system has now obtained approval from IMO. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

16 3.3.1 Environmental aspects for port based ballast water treatment outside the ship Environmental aspects Environmental aspect Pollution sources Air pollution Air pollution from plant s generating set. Noise Noise from plant operation Waste Filtration residue of suspended matter or sediment from treatment plant Wastewater Treated ballast water Risk for soil, ground water or surface water Spill or leakage from fuel store storage Table 1: Important environmental aspects for a treatment plant placed outside the ship. The noise and air pollution from operating the plant is not expected to exceed the guidelines for port areas from the Environmental Protection Agency. The supplier of the power generating set for the treatment unit shall document that its emission requirements are fulfilled and that the fuel tank fulfils the safety requirements for the equipment. The aspect likely to be critical in the eyes of the authorities is noise. According to the data sheet of the proposed generating set, SMDO J77K, the source level is 92L wa. At a distance of 100 meters, the noise contribution from this source is estimated to be approximately 35dBA, and if two sets are operating next to each other, 38dBA. The recommended limit for mixed residential and industrial areas is 40 DBA at night (22-07) and higher in daytime. It is thus very likely that the noise emission criteria can be met, both day and night. It is the handling of the treated water and the treatment residue that poses the challenges as can be seen in the section below Relevant legislation and regulation Environmental matters are the subject of three laws, generally called the Planning Act, the Environmental Protection Act and the Marine Environment Act. These acts and the related executive orders and guidelines are described below: The Planning Act ( Planloven ) This law has been passed in response to a number of European Union directives. The law prescribes the rules to be followed by public authorities in planning, including: To reconcile societal interests

17 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 17 To contribute to protecting nature and environment through prevention of pollution To create and conserve valuable buildings To involve the public in the planning process. This act is supplemented by VVM-bekendtgørelsen, executive order 1510 of 15 December 2010 of the Ministry of the Environment on environmental impact assessments (EIA). The order aims at ensuring that such assessments are made and used as the basis for according or refusing permission to build plants that may have a substantial influence on the environment. Public involvement is an important part of the decision process. The order s Appendix 1 contains a list of plant that is considered always to have a substantial impact on the environment and therefore always requires an EIA. A clear majority of cases are found in Appendix 2. These will not necessarily have a substantial impact on the environment and only an environmental screening is mandatory. Guideline 9339 of 12 March 2009 from the Environmental Protection Agency (Ministry of the Environment) on EIA in the Planning Act gives general guidelines for carrying out EIA s and environmental screenings. The Environmental Protection Act ( Miljøbeskyttelsesloven ) Also this law has been passed as a response to various European Union directives. It is a framework law which gives the ministry wide powers to comply with the requirements. Its purpose is to contribute to protect nature and environment so that society can develop on a sustainable basis respecting the conditions for human life and the protection of plant and animal life. The law aims particularly at: Preventing and abating pollution of air, water, soil and sub-soil as well as vibration and noise. Establishing hygiene-based rules relating to environment and humans Limiting use and wastage of raw materials and resources Promoting cleaner technology Promoting recycling and limiting problems related to disposal of waste. The act is supplemented by a number of executive orders and guidelines. Executive order 486 of 25 May 2012 (Ministry of the Environment) on approval of listed businesses ( Godkendelsesbekendtgørelsen ) prescribes that major businesses and businesses that may pollute their surroundings need an environmental permit. The approval specifies requirements to design and operation to ensure that they are run without environmental impacts on the environment. Such businesses are referred to as listed businesses ( listevirksomheder ). A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

18 Guideline 9339 of 12 March 2009 from the Environmental Protection Agency (Ministry of the Environment) on external noise from businesses ( Støjvejledningen ) prescribes i.a. that if a business that is not subject to environmental approval creates noise nuisances the municipality may order it to reduce the noise. The order describes how noise conditions are to be formulated and gives guidelines for noise limits. Executive order 1415 of 12 December 2011 (Ministry of the Environment) on waste ( Affaldsbekendtgørelsen ) concerns handling and disposal of waste from households and businesses. Executive order 1448 of 11 December 2007 (Ministry of the Environment) on waste water permissions ( Spildevandsbekendtgørelsen ) applies to all private and public waste water treatment plants. It applies to all installations for transport or treatment of waste water prior to discharge. It also applies to emission of substances directly to the ground water. Guideline 2, 2006 from the Environmental Protection Agency (Ministry of the Environment) on connecting sewers from industries to public waste water treatment plants ( Spildevandsvejledningen ) gives general guidelines on administration of permits for industries to discharge sewage to public waste water treatment plants. Executive order 1650 of 13 December 2006 (Ministry of the Environment) on the use of waste for agricultural purposes ( Slambekendtgørelsen ) determines the types of waste that may be used for agricultural purposes. In order to be used, the waste must improve the quality of the soil. The order also sets rules for the quality of the waste, including its content of heavy metals and substances extraneous to the environment, as well rules for handling and treatment so that the use of waste will not endanger the health of humans or animals. The Marine Environment Act ( Havmiljøloven ) Similarly passed in response to European Union directives, the intention of the law is to prevent and reduce pollution of and other impacts on the marine environment from Danish and foreign ships, aircraft, platforms and pipelines; and to maintain a preparedness for combating pollution on the sea, along coasts and in ports. As far as this report s subject is concerned, the act is supplemented by two executive orders. Executive order 32 of 07 January 2011 (Ministry of the Environment) on dumping marine excavation material ( Klapbekendtgørelsen ) contains an exception to the general prohibition of dumping at sea, and a definition of material that may be dumped. Executive order 654 of 15 June 2012 (Ministry of the Environment) on handling ballast water and sediments from ships ballast water tanks sets rules for handling ballast water and sediments in order to prevent invasive species from spreading.

19 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY Handling of ballast water treated in the Danish ports, outside the ships The technology of the system from DESMI chosen for this study is based on a combination of mechanical filtration and UV irradiation, including treatment with self-produced ozone. It will, apart from the discharge of treated ballast water back into the sea, lead to production of a filter residue (filtrate) by the backflushing of the filters. This residue must be handled, treated and disposed of in an environmentally acceptable manner. It cannot be excluded that viable aquatic organisms are still present in the residue material. Disinfection could be achieved by chlorination in reception tanks in which the slurry shall be kept for at least 24 hours. After this treatment, the slurry could be deposited in storage tanks for settlement of the suspended residue material. That material could then be delivered to a controlled depot or a land reclamation area. The amount of chloride due to the chlorination can be considered negligible compared with the chloride content due to the natural salinity of the water. The amounts of residue to be handled following the treatment of ballast water from one vessel will depend on the concentration of suspended solids in the ballast water and the total volume. Based on the ongoing tests of the equipment, and given the volume of backflushing water of 1% of the total containing 5% dry matter, it is expected that the production of slurry will be in the range of t per day, corresponding to approx kg dry residue per day. This is for the treatment of ballast water volumes within 1,000-1,500 m 3 per day in Esbjerg Port. Table 2 below shows the investigated possibilities for handling treated ballast water and filter residue as well as the approvals or permits required for the feasible and possibly feasible solutions according to Danish law and regulations. The authority for the approvals of the land based treatment of ballast water is the municipality where the port is located. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

20 Ballast water taken in outside the port of destination A: Treatment onboard ship Ship s own treatment plant or plant borrowed from the port or from another ship Approvals/permits Approval of plant according to executive order 654 of 15/06/2012. Final approval by IMO and type approval certificate by the flag state to be obtained. Feasible handling of treated waste water Port basin Treated ballast water may be discharged to the port basin if the ballast water has been handled according to chapter 2 of executive order 654 of 15/o6/2012. Feasible handling of filtrate from treatment No filtrate may be discharged to the port basin, cf. chapter 3 of executive order /06/2012. The municipality has an obligation to indicate a way of disposing of the filtrate, see below C. Filtrate handling. B: Treatment outside the ship Approvals/permits Possibly feasible and obvious handling of treated water Mobile unit or fixed plant on land or barge Before establishing a treatment plant, an environmental screening has to be carried out. If the screening so indicates, an environmental impact assessment (EIA) shall be made. The screening concerns environmental effects on air, noise, recipient, soil and groundwater. The treatment plant is subject to point 12 C in executive order 1510 of 15/15/2010. Discharge to port basin, land based treatment units. It may be difficult to obtain a discharge permit according to the Environmental Protection Act 28 as the content of pollutants is unknown. However, the authorities may grant permission without removal of pollutants based on a BAT (best available technology) consideration. The discharge permit is established according to executive order 1022 of 25/08/2010. Discharge to port basin, treatment plants on barges The plants on barges are considered as onboard treatment plants and shall be approved as such. Non-feasible handling of treated water To a sewer discharging to a public sewage treatment plant In case of discharge to the sea, a discharge permit as per 28 of the Environmental Protection Act is required. It is not a listed activity The treated ballast water cannot be discharged to a sewer as it will not fulfil the requirement of less than 1000 mg/l of chloride. This requirement has been set due to the risk of corrosion in the sewer system. The concentration of chloride in the filtrate is approximately 19,400 mg/l (corresponding to the salinity of the North Sea).

21 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 21 cf. executive order BEK 486 of 25/05/2010 so no environmental permit is required according to 33 of the Environmental Protection Act, cf. executive order 879 of 26/06/2010. The authorities may, after the establishment of the plant, issue orders according to 42 of the Environmental Protection Act if the plant causes significant environmental pollution incl. generation of waste, cf. executive order 879 of 26/06/2010. Directly to a waste water treatment plant Not an obvious possibility due to the problems of transporting the water to the plant. Probably the chloride content of the treated water is too high to allow it to be discharged to a plant. The activated sludge in the plant is sensitive to chloride as these impair nitrification. The guidelines of the Environmental Protection Agency. no. 2, 2006 do not indicate a contents of chloride acceptable for the activated sludge. Port basin The residue may not be discharged to the port basin. Feasible handling of filtrate The municipality has an obligation to indicate a way of disposing of the sludge, see below C. Sediment handling. C. Filtrate, the residue from the backflushing of filters Approvals/permits The filtrate is considered as waste, cf. executive order 1415 The filtrate requires an environmental permit according to 33 of the Environmental Approval Act as per list item K204 if biological or physicalchemical treatment of waste water sludge takes place before disposal, cf. executive orders 879 and 486. Feasible and obvious handling of filtrate Ordinary landfills and spray fields The filtrate may be disposed of in an ordinary landfill or spray field. Normally, at a landfill a content of at least 15% dry matter is required. The filtrate must be listed on the site s positive list. Possibly feasible handling of filtrate Kommunekemi: The filtrate may be disposed of at Kommunekemi (hazardous waste incineration facility). Expensive option. Incineration The dry matter content must be at least 25-30% for the filtrate to be received at an approved incineration plant. The filtrate has a high content of chlorides. It will be A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

22 difficult to find a plant that will receive the filtrate as plants cope with the emission requirements for HCl. Directly to a waste water treatment plant: Probably the chloride content of the treated water is too high to allow it to be led to directly to a plant. The activated sludge in the plant is sensitive to chloride as chlorides impair nitrification. The guidelines of the Environmental Protection Agency no. 2, 2006 do not indicate a content of chloride acceptable for the activated sludge. Non-feasible handling of filtrate To a sewer discharging to a public water treatment plant The filtrate cannot be discharged to a sewer as it will not fulfil the requirement of less than 1000 mg/l of chloride. This requirement has been set due to the risk of corrosion in the sewer system. The concentration of chloride in the filtrate is approximately 19,400 mg/l (corresponding to the salinity of the North Sea). The sea: It is forbidden to dump the filtrate at sea, cf. Marine Environment Act. Nor is it possible to dump it at designated dumping sites (for dredged material) at sea, as it is not dump-able material, cf. executive order 32 of 07/01/2011. Agricultural use: The treated water cannot be used as waste for agricultural purposes. The water has no fertilizing or soil-improving properties, cf. executive order 1650 of 13/12/2006. Table 2: Handling of treated ballast water and filter residue. Approvals or permits required according to Danish regulations and guidelines From the above it may be seen that the treatment in the ports outside the ships will require various approvals by the local environmental agencies. In Denmark it would be the local municipality which is the central authority for the required approvals.

23 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 23 The approvals required for the land based treatment of ballast water are related to the discharge of the treated ballast water and the handling of the filtrate. To summarize it can be concluded that a number of disposal options exist for ballast water taken up in international waters and treated on the quay or on a barge in the port of call. Among these it is likely that the environmental authorities approval can be obtained for discharging the treated water to the port basin and for disposing of the treated slurry in an approved land-fill or spray field. It should, however, be noted that the implementation of the IMO ballast water regulations will create a new type of waste to be handled, namely slurry from the possible land based treatment units, from cleaning of ship s ballast tanks, from ship yards, etc. Since no generic regulations for this waste exist it would be recommendable that the environmental authorities and the other relevant authorities coordinate to address this issue for common regulations and guidelines. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

24 4 Logistical challenges - Equipment, operation, costs. 4.1 General The investigations and the study have been based on the ports of Esbjerg and Fredericia located on the west coast respectively east coast of Jutland in Denmark. The ballast water treatment operations in the ports by mobile units on the quays are the main focus of this study. However, also treatment units placed on barges have been envisaged for the treatment services to ships in the ports. Furthermore, this study addresses the use of mobile treatment units and not any possible fixed treatment plants in the ports. Although that may be a possibility at some dedicated berths and terminals for tankers, the logistics of most port operations, like those of the Esbjerg and Fredericia, would require treatment by mobile units. Ballast water treatment Treatment in ports Treatment on ships Mobile units Units on barges Fixed land plants Figure 4-1 Possibilities for treatment The main technical, logistical and operational challenges of the planning and implementation of the ballast water treatment in the ports instead of the onboard treatment include:

25 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 25 The technical concepts concerning installation of the equipment on a 40 trailer, connection to the ship and the safe handling of the backflushing residual material. The planning of the facilities and operations for the treatment so that all ships in question can be serviced without causing delays. Selection of realistic scenarios for the business cases which the financial analyses may prove to be feasible. This relates to both the shipping companies and the operators for the treatment services 4.2 Principles of treatment The requirements of the Convention can be fulfilled in two ways by the mobile units: Ballast water is treated at the port of departure and discharged at destination without further treatment. Ballast water is taken in without treatment and treated immediately before discharge at the destination. To make a system based on the first principle operational, the environmental authorities at the destinations must trust the treatment at the point of departure and the ship s cleaning of its tanks. This would require an internationally accepted certificate system which is not considered a realistic scenario for ships in general. However, with regard to ships sailing in certain fixed routes the provision ( sale ) of treated water to the ships could a feasible solution. This has been included as scenario A-5 addressed in section 5.7. The second principle has treatment and discharge permits under the same environmental authorities. This is the one principally considered in the present study. 4.3 Equipment The mobile units envisaged for the treatment of ballast water in the ports are based on the technology of a Danish manufacturer, DESMI A/S. This treatment technology is under testing and final approval by the relevant authorities. Like several of the systems developed by other suppliers world-wide, this system is based on two stages filtration followed by disinfection. The filtration is realized by use of fixed screens or stacked discs with automatic backflushing. The disinfection is carried out by use of ultraviolet irradiation (UV) treatment. Ozone as a by-product of the UV treatment is introduced into the stream and acts as additional treatment. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

26 This study shall not go into details and assessment of the proper treatment methods but will focus on the general operation and production of the treatment units in ports, including the capital and operational costs of the facilities. The treatment capacity of the unit in question is 300 t / h. This corresponds to the average expected de-ballasting of the Ro-Ro ships per call at the ports, according to information from the ship s masters. The discharge amount varies considerably from ship to ship and from call to call and the normal range for the ships included in this study is expected to be t per treatment The mobile unit The treatment equipment consists of pumps, filters and UV units. The equipment is installed in a 20 ft standard container mounted on a 40 flatbed trailer with a tugmaster or truck unit for hauling in the ports and on the roads. The power consumption is approximately 90 kw during operation and for some ports, as the case study ports, this will require an independent power source due to limited power supply at the quay, which in Esbjerg and Fredericia is 63 Amps, corresponding to approximately 43 kw. The independent power supply will be by a generator mounted on the trailer. The connection to the ship s ballast water piping system will be trough a 8 hose coiled up on a reel and with a special dry disconnect coupling (DDC). The fixed part of the coupling will be installed on the discharge pipe at the side of the ship. This coupling type can be quickly disconnected without any spillage. At the back of the trailer a 4 m 3 tank receives the backflushing slurry from the filters via a hydrocyclone.

27 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 27 Figure 4-2 Top view of mobile treatment unit (concept) A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

28 Figure 4-3 3D rendering of mobile treatment unit (concept) The total estimated weight of the treatment equipment on the trailer amounts to 8.5 t dry and 12.0 t during operation. In ports with many operations, a reserve unit shall be kept ready in cases of breakdowns or for assistance during peak periods Other installations These consist of: A reception tank of approximately 2 x 16 m 3 (20 container), with agitators, for reception and chlorination of the residual backflushing slurry. A storage tank of 150 m 3 capacity for the temporary storage of the treated slurry. Those tanks are to be located in a location near the quay areas conveniently for the operation of the units Modifications on ships The piping arrangement onboard the ships shall be modified so that the discharge pipe is terminated near the side of ship at least 1m above the quay level when the ship is fully loaded at low water. The ship s ballast pumps normally provide a working pressure of min. 3.0 bar at sea level and the pressure at the higher level discharge after the modification shall be at least 1.5 bar at 300 t/h for the proper operation of the treatment unit on the quay. Discharge points shall be provided at both sides of the ship and located near the stern for flexibility regarding the different berth conditions in the ports of call.

29 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 29 The owner of the RoRo freight ferries (DFDS) investigated in this study is carrying out an outline design of the modifications needed on the ships. 4.4 Mode of operation Mobile units operation (the operation process) The mobile units, as described in section 3.2, are connected to a tugmaster or truck for the hauling in the port and on the road. In ports with many operations a reserve unit shall be kept ready in cases of breakdowns or assistance during peak periods. The typical activities for the treatment service to a ship with short stay at berth would be as follows: The ship calls the service provider for the required treatment When de-ballasting takes place during the hours at berth, the mobile unit is parked at the side of the ship and the hose is hoisted by use of a winch to the ship s discharge pipe for ballast water. The connection is established by use of the dry disconnect coupling. The ballast water is then pumped though the unit by the ship s pumps and treated. With the capacity of 300 t / h of the treatment unit, the flow will be controlled by valves so that with higher capacity pumps on the ship, say 500 t/h, the treatment process will go on with the optimal flow through the unit. During the treatment process the filters in the unit are automatically being backflushed and the residual product is pumped via a hydrocyclone to the slurry tank mounted at the back of the trailer. When the treatment is completed the hose is disconnected from the ship s discharge pipe and rolled up on the reel mounted on the trailer. The unit is then hauled to the reception tank where the backflushing slurry is pumped to one of its chambers. Here chlorine is added to the slurry for disinfection. By alternating between the two chambers the chlorination process can take place over 24 hours, which should be sufficient for the disinfection process. After disinfection the slurry it is pumped to the storage tank, where it settles with overflow or drainage of the water content. When the storage tanks are full the concentrated slurry is transported to a reclamation area or disposal site. Regarding the needed approvals and regulations for that see section 2.2. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

30 Figure 4-4 Rendering of the operation with mobile treatment unit (concept) Taking 250 t/h as the estimated average amount of ballast water to be treated per ship, the time for a complete cycle for the operation as described above is estimated to be hours, as follows: Operation Hauling of unit to the side of the ship Connection of the hose Treatment operation Disconnection and hauling to the slurry tank Pumping of the slurry to the tank Return to base, cleaning, etc. Total time for complete treatment operation Duration 10 min 10 min 50 min 15 min 10 min 15 min 110 min

31 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 31 That means that one unit will be able to service max. 4 ships during an 8 hours work shift. During special peak hours when more ships have to be serviced at the same time the reserve treatment unit can be mobilized with short notice. The conditions at the quays of Esbjerg and Fredericia Port in general would allow the mobile units to be parked alongside the ships during the treatment process. The stevedoring companies operating in these ports see no major obstacles to such parking. In cases where the freight ferries moor at a single pier without space for vehicles alongside, the treatment unit could be driven onboard the ferry and do the treatment or use a connection hose to the ship s discharge pipe, although this option is likely to hamper loading and unloading activities. Figure 4-5 Ro-Ro ship at quay The ports The infrastructure of the ports selected for case studies, Esbjerg and Fredericia, does not present any barriers or major problems for the operation of the mobile treatment units. The quays areas are adequate for the hauling and parking of the mobile units and suitable spaces can be provided for the base and the tanks. The power supply at the quays of both ports can provide only 63 amps and this necessitates the use of an independent power supply by a generating set installed in the mobile unit. The depth conditions at both ports are sufficient so that the ships in question will not have to discharge ballast water to reduce draft before entering the ports. At several other ports many ships will have to discharge ballast water at sea to reduce draft, and ships calling those ports will need the onboard treatment plant. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

32 At Esbjerg Port the main traffic consists of the RoRo freight ferries of DFDS line and Sea Cargo line and furthermore the service ships operating between the port and the offshore platforms in the North Sea. These ships in regular sailings represent in total 1,175 calls per year at the port of Esbjerg. These are described in the case study scenarios, section 4. At the quays where the service ships are loaded / unloaded the space will be limited for the mobile units during the treatment process, which in many cases shall take place concurrently with the normal daily cargo handling. However, the stevedoring company (Danbor) considers this to be manageable, especially since the mobile treatment unit can be placed at the stern of the ship, by using the full length of 25 m of the hose. At the port of Fredericia the traffic consist of more random calls by various types of ships, including large tankers at the crude oil export terminal operated by Shell. The normal traffic apart from the large tankers includes (based on registered calls): Type of ship Calls per year Container (feeder) ships 240 RoRo 90 Small tankers 150 General cargo 40 Total 520 The container (feeder) ships, Ro-Ro ferries and general cargo ships can be serviced by the mobile units placed at the side of the ships. This would only cause minor and acceptable hampering of the normal activities by cranes and other equipment on the quays. This again is mainly due to the possibility of placing the mobile units near the stern of the ships and the fact that these container ships are serviced by mobile cranes and not rail-bound cranes travelling along the quayside, as is the case in the ports servicing the large container ships. The small tankers will normally need to be serviced with the mobile unit placed at least 20 m away from the ship, due to safety requirements. This can be managed by using an extension of the hose between the ship and the treatment unit and this will naturally increase somewhat the operation time for those ships as the extension hose has to be rolled in and out. This is based on oral information from the port management. The particular safety requirements applicable to oil and gas installations in ports have not been studied.

33 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY Operators The scenarios addressed in this study presume that the treatment operations are carried out by a company, independent of the ship owners and the ports. That company may provide the treatment services in one or several ports and may develop the business of treatment services in ports internationally. For some ports it may be feasible to operate the treatment services within their own organisations. However, in most ports the most practical and feasible solution seems to be that the existing stevedore companies, already operating in the ports, take on the treatment service business. Those companies have their organization and the experience being able to optimize the added business activity of the treatment services. The staff costs of operation of one mobile unit (incl. reserve unit) in ports like Esbjerg and Fredericia are estimated to be DKK 1,500,000 per year. This is based on preliminary estimates from stevedore companies. The services are to be paid for by the ship owners based on a combination of the actual amounts of ballast water treated and number of treatments. The prices to be expected per ton and per treatment for each business case are indicated in the results of the financial analyses (section 6) Treatment units on barges The use of barges for the ballast water treatment in ports has been envisaged as alternative to the land based mobile units. This possibility has been investigated and based on the experience of the port organisations and operators of barges for supply of bunker fuel to ships, the findings and conclusions were: Addition of ballast water treatment to the fuel supply activities of an established supply company was found not to be realistic, due to the frequent treatment demands compared to the fuel supply events to ships in the ports. In large ports like Hamburg and Rotterdam barge services are already provided to ships for taking solid waste and special tasks. The barge operator in Rotterdam interviewed expressed interest in the services of ballast water treatment, using barges with the treatment units installed. Especially providing the treatment services to large container ships seems to be a business possibility for barge operators, since those ships cannot be serviced from the mobile units, due to the travelling container cranes. An operation of barges especially for ballast water treatment in ports like Esbjerg and Fredericia was considered to be to costly, complicated and not feasible compared to the mobile land based units. This was the opinion of both the port organisations and the barge operators. The cost of a barge before installation of the treatment plant would be around 2.5 million EUR. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

34 However, the alternative scenario of using barges in Esbjerg has been addressed and analysed for comparison. Here the cost of long term rental of a barge with crew as informed by the barge operator in Rotterdam is used in the financial analysis. In general, the possible pros of using barges say in Esbjerg port access to ships, larger capacity of equipment and tanks, space for additional equipment and services - were found to be far from balancing or justifying the disadvantages in capital investment, inflexible operations and a heavy organization. Furthermore, none of the case study ports would be interested in the treatment operation with barges, by themselves or by others. Figure 4-6 Example of barge service Delivery of treated water (treatment at the source) Principles Instead of treating the ballast water in the port of arrival by the mobile units before discharge in the port, the possibility of treatment at the moment of taking it on board has been considered. Treatment at the source and delivery to ships has two important advantages: Spillages of ballast water are innocuous as the water contains no invasive or non-invasive species The filter residue can be led back to the sea as it contains only native species. It is therefore not necessary to include the treatment, handling and disposal of residual slurry as in the case of treatment at discharge of the ballast water.

35 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 35 The inconvenience is that the environmental permit for discharging the water at the destination would depend on the authorities accepting the treatment at the source and the storage on the way in the (clean) ballast tanks. A system of certificates would have to be established and mutually accepted by the authorities in the departure and destination ports. If for some reason a certificate were rejected, the plant at the destination (intended for delivery of ballast water for departing ships) would have to handle also water from arriving ships. It must be noted that this concept of supply of treated water to ships may only be implemented for ships in fixed routes between 2 ports, where the time between supply and discharge of the ballast water is limited to few hours. That is due to the risk of growth of zoo-plankton which, at the allowable low level, still may be present in the treated water. Equipment Technically, the set-up of the mobile treatment unit would not be very different from that treating at discharge, except that as mentioned above, the treatment equipment would also have to be able to handle incoming ballast water from other ships and if for some reason its purity certificate were rejected by the authorities. In ports like Esbjerg an additional unit could be employed only for supply of treated water. The additional equipment needed in the mobile unit would be a submersible pump to pump the water from the port basin through the treatment unit to the ship s tanks. Storage The treatment unit could treat water round the clock for storage near the berth dedicated to fixed route ships and those ships could be supplied from stock rather than directly from the mobile unit. This would provide high level of flexibility but at higher capital cost. Due to the risk of growth of the small amount of plankton remaining in the treated water, the certain level of chlorination will be needed. 4.5 Capital investments (Capex) The capital investments needed for each mobile treatment unit have been calculated based on prices from suppliers and general cost estimation. The basis is a DESMI unit mounted on a trailer equipped with a generating set, tank, hose, etc., a truck for hauling it and a set of tanks for storage of the slurry from the backflushing. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

36 4.5.1 Equipment cost Mobile treatment unit Item Cost, thousand DKK Treatment unit, capacity 300 t / hour, complete, at port 2,400 Flatbed trailer, complete with platform and adjustments 200 Set of spare parts, flexible pipe, hoses, etc. 150 Truck unit for transport 750 Generating set installed 200 Total with truck unit 3,700 Total without truck unit 2,950 Tanks etc. installed: Item Cost, thousand DKK 2 x 16 m3 container tank m 3 open tank with overflow 300 Various costs (ground slab at base, etc.) 150 Total, fixed facilities Capital investment The capital investment for one operating unit amounts to: DKK 4,200,000 with truck unit and tanks etc. DKK 2,950,000 for a reserve unit The period for depreciation is set to 15 years for all equipment. 4.6 Operating cost (Opex) Under operating costs, staff and administration are considered, as well as power for the unit, fuel for transport and disposal fees for slurry.

37 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY Fixed operating cost The fixed operating cost per year (opex fixed) of one station in a port in Denmark has been estimated at: Personnel Item Cost, DKK/year Stevedore operator s personnel 1,200,000 Administration, management 300,000 Opex fixed, total 1,500,000 For the ports in England, Holland and Germany the fixed operating cost shall be considered 20% lower in the economic analyses, due to lower personnel cost Variable operating cost The variable operating costs, (Opex var.) for the treatment of one ton of ballast water have been calculated based on information from the supplier and the test runs carried out by the supplier of the equipment: Item Cost, DKK/t Power, 91 kw; 300 t/h; 1.50 DKK/kWh 0.50 Use of spares and maintenance 0.60 Various (fuel for truck, maintenance) 0.40 Estimated cost of transport of slurry to depot (5 kg/t) 0.40 Depot fee 0.20 Opex variable, total 2.10 The variable operating costs are considered equal for the operation of all mobile treatment units. 4.7 Conclusion After an overview of the selected ports, Esbjerg and Fredericia, and their traffic the operating mode for treating of ballast water in the port has been established and the capital and operating costs have been estimated. The concept design of the mobile A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

38 treatment unit includes: the treatment equipment in a 20 container mounted on a 40 flatbed trailer together with the generator set, slurry tank and hose reel and, hauled by a truck, (figure 3-2). In addition, a set of tanks are required for temporary storage of filter slurry. The investment cost amounts to DKK 4,200,000 for a unit including truck and tanks and DKK 2,950,000 for a reserve unit, i.e. without truck and slurry tanks. The fixed operating cost amounts to DKK 1,500,000 per year, and the variable operating cost to DKK 2.10 per m 3 of ballast water.

39 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 39 5 Scenarios, business cases For both of the ports of Fredericia and Esbjerg, the main scenarios for this study have been determined based on the actual registered daily and yearly calls of ships which have regular calls to each port and which have been sailing outside Danish waters. The registration of ship calls at the ports over a period of 3 months has been the basis for the definition of the main scenarios. These scenarios are investigated and analysed as business cases for the operator: Esbjerg Port Scenario A-1: One operator handles all ships calling the port regularly. Those are Ro-Ro freight ferries by DFDS and Sea Cargo and the service ships for offshore platforms. Scenario A-2: One operator DFDS Stevedore handles all DFDS ships in the ports of the selected North Sea routes and the service ships in Esbjerg. Scenario A-3: One operator - Danbor - handles the service ships in Esbjerg Scenario A-4: A barge operator provides the treatment services to all ships calling the port regularly. Scenario A-5: The ships of the selected DFDS North Sea routes are provided with treated water to clean ballast tanks. Fredericia Port Scenario B-1: One operator handles all ships which make regular calls at the port, excl. of the large tankers. Scenarios A-1 and B-1 are seen from the port s perspective only. They include all ships with regular calls at the port and do not take into account the needed treatment operations in the ship s other ports of call. Thus it is for these scenarios presumed that those ports all have treatment facilities in operation. (Only ships with regular calls at maximum two ports other than the case study ports have been taken into consideration in the scenarios.) A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

40 The other scenario A-2 is seen from the perspective of the shipping companies. This scenario includes the treatment operations in all the ports of call of ships of the selected DFDS North Sea routes and the service ships of Esbjerg. The ship types are freight ferries (Ro-Ro and Ro-Pax) and service vessels for the offshore platforms. Figure 5-1 The selected North Sea routes of DFDS. Scenario A -2 As mentioned earlier the scenarios are based on the assumption that the treatment facilities are established and operated by companies separate from the shipping companies and the ports. However, a close cooperation shall be established between the parties to ensure the optimal economical operation. 5.1 Scenario A-1 - Esbjerg For the port of Esbjerg, scenario A includes all ships which call the port in regular sailings: Ro-Ro ships in regular shipping to Harwich and Immingham, DFDS Seaways A/S Service ships for offshore activities with Esbjerg Port as base. Ro-Ro ships in regular sailings to Norwegian and Dutch ports, Sea Cargo This scenario (A-1) is thus based on the assumption that all other ports of call for the ships will have operating treatment facilities for ballast water.

41 Number of calls/ 3 months ,5-1 day 1-2 days 2-3 days >3 days Number of ships at berth BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY Pattern of ships calls and mooring times In Esbjerg Port the calls registered during a representative 3 months period show a pattern of ships calls and times at berth, which would allow for treatment service to all ships by one mobile unit. See Figure 5-2 and Figure 5-3. Ships at berth I II III Route ships Supply ships Figure 5-2 Ships at berth in Esbjerg Port calculated at every hour. See Figure 5-4 and Figure 5-5 Mooring time Route ships Supply ships Mooring time[hr] Figure 5-3 Number of calls at Esbjerg Port in the time period from 1/ to 31/ with a given mooring time. Figure 5-2 shows that up to 9 ships are at berth at the same time and Figure 5-3 shows that the mooring time is down to a couple of hours and that it is primarily the route ships that have a short mooring time. At moments with a high number of ships at berth most of the ships are service ships, which generally have a longer mooring time. This is therefore most likely not to be the most critical moment with regards to treatment of ballast water with only one mobile unit. In Appendix F, graphs show ships at berth in Esbjerg Port in the time period from 1/ to 31/ for supply and route ships with more A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

42 : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : :00 than 5 arrivals within the time period. From this the three most critical situations (I- III) with regard to treatment capacity is found. See Figure 5-4 and Figure 5-5. TROMS CASTOR REM VISION MÆRSK FRONTIER HAVILA NEPTUNE HAVILA HERØY HAVILA FANØ ESVAGT OMEGA ESVAGT GAMMA EDDA SPRINT EDDA FREYA TRANS CARRIER JUTLANDIA SEAWAYS FIONIA SEAWAYS DANA SIRENA AMBER Ships at berth Figure 5-4 Ships at berth in Esbjerg Port in the time period from 21/ to 22/ (Situation I) TROMS CASTOR REM VISION MÆRSK FRONTIER HAVILA NEPTUNE HAVILA HERØY HAVILA FANØ ESVAGT OMEGA ESVAGT GAMMA EDDA SPRINT EDDA FREYA TRANS CARRIER JUTLANDIA SEAWAYS FIONIA SEAWAYS DANA SIRENA AMBER Ships at berth Figure 5-5 Ships at berth in Esbjerg Port in the time period from 1/ to 2/ (Situation II + III) The figures show that the most critical situation would be situation III where there are four ships at berth in the same 8 hours time period. These figures for the registered calls confirm that that one mobile treatment unit will be able to service all ships calling regularly at Esbjerg Port Ships in regular shipping service The relevant ships with regular calls comprise in total 5 ships, freight ferries Ro-Ro and Ro-Pax, which each make between 100 and 150 calls yearly at the port. This includes 3 ships from DFDS and 2 ships from Sea Cargo line with regular calls at 4 other ports, 3 in Norway and one in Holland.

43 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 43 These ships represent in total 655 calls at Esbjerg Port per year. The average discharge of ballast water to the sea at port is estimated to 300 t / call / ship. This is based on information from DFDS ships chief officers. The total amount of ballast water to be treated for those ships in Esbjerg can thus be estimated at 196,000 t per year. The freight ferries of DFDS sail to Harwich (one Ro-Pax) and to Immingham (two Ro-Ro) in England. The Ro-Pax ferry has 148 calls / year at Harwich and the Ro- Ro ferries have 308 calls / year at Immingham. The ships from Sea Cargo make regular calls at 3 ports in Norway and at one in Holland Service ships The service ships operating out of Esbjerg regularly include 7 ships, which mainly provide service to the offshore platforms in the North Sea. These service ships make in total approx. 520 regular calls at Esbjerg Port per year. The average amount of ballast water, taken in at the platforms and discharged to the sea at port, is estimated to 200 t / ship / call. The total amount of ballast water to be treated for those vessels can thus be estimated at 104,000 t per year Treatment units The capacity of the treatment units is 300 t / h each. The operation time of the unit for each ship is estimated to be 1½ -2 hour, including preparation, connection, treatment process (½-1 hour), disconnection and transport. Based on the registered calls and the time at berth of the ships in Esbjerg it is assessed that even in peak hours one unit will be able to provide the treatment service to the ships without causing delays of departures. However, taking into account time for maintenance, extreme demand events and possible breakdowns a reserve unit shall be considered Ballast water to be treated The total amount of ballast water to be treated in this scenario can be assumed as follows: Esbjerg Port: Item t/year Ro-Ro / Ro-Pax ferries (DFDS) 136,000 Service ships 104,000 A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

44 Item t/year Ro-Ro ferries (Sea Cargo) 60,000 Total amount in the this scenario 300,000 Total number of treatment units in operation 1 unit (+ one as reserve) Capital investment (Capex) For scenario A the capital investment the mobile treatment units in Esbjerg is estimated as follows: Item DKK One operating unit with truck 4,200,000 One unit in reserve 2,950,000 Total Capex 7,150, Operating cost (Opex) Item Cost Fixed operating cost (Opex fixed) 1,500,000 DKK/year Variable operating cost (Opex var.) 2.10 DKK/t 5.2 Scenario A-2 - Esbjerg This scenario covers the service ships for the offshore platforms of Maersk and five of the North Sea routes of DFDS. In addition to the DFDS sailings included in scenario A-1, the following regular freight ferry routes are considered. Three Ro-Ro ferries (DFDS) between Rotterdam (Vlaardingen) and Felixstowe. 15 calls per week at each port. Two Ro-Ro ferries (DFDS) between Rotterdam and Immingham. 6 calls per week at each port.

45 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 45 Three Ro-Ro ferries between Gothenburg and Immingham. 6 calls per week at each port. This scenario takes into account the operations of the treatment facilities in all the ports involved. As a conservative measure the possible treatment service of ballast water to other lines are not considered. The selection of routes for this scenario and business case of the operator has been made based on evaluation of each route and especially the combined effect on the turn over of the treatment services in each port. Other routes of DFDS could be included in case the ship owner wishes to have greater flexibility in the employment of the ships Gothenburg Immingham This route with 3 Ro-Ro ferries involves 6 calls per week in Immingham and Gothenburg. Although this would add to the treatment services in Immingham the business in Gothenburg would not be economically feasible with service only to the DFDS ferries. However, the total amount of treated ballast water on this route would be approx t /year and it would include one treatment unit in Gothenburg with the possibility of additional services for other lines. Therefore the route is included in this scenario A Rotterdam Immingham This route with 2 Ro-Ro ferries involves 6 calls per week at each port. The total amount of treated ballast water would be 180,000 t per year and it would include one unit in Rotterdam, which will also service the ferries to Felixstowe Rotterdam Felixstowe This route with 3 Ro-Ro ferries involves 15 calls per week at each port. The total amount of treated ballast water would be 450,000 t per year Ballast water to be treated The estimated total amount of ballast water to be treated is based on the assumed amount per call / ship, namely in average 300 t / call. The total amount of ballast water to be treated in this scenario can be assumed as follows: Item t/year Esbjerg Port, Ro-Ro ferries (DFDS) 136,000 Esbjerg Port, service ships 104,000 A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

46 Item t/year Harwich port, Ro-Pax ferry (DFDS) 44,000 Immingham port, Ro-Ro ferries (DFDS) 270,000 Gothenburg port, Ro-Ro ferries (DFDS) 90,000 Rotterdam port, Ro-Ro ferries (DFDS) 315,000 Felixstowe port, Ro-Ro ferries (DFDS) 225,000 Total amount in the this scenario 1,184,000 Total number of treatment units in operation 5 units (+ 3 as reserve) It is presumed in this scenario that the mobile treatment unit in Felixstowe can service the Ro-Pax ferry calling Harwich from Esbjerg with only 148 calls per year. The unit with truck can make the return drive of 2 x 55 km on road between Felixstowe and Harwich 3 times per week Capital Investment (Capex) For this scenario A-2 the capital investment for the mobile treatment units in all ports involved is estimated as follows: Item Unit cost, DKK Nos. DKK Operating units 4,200, ,000,000 Reserve units 2,950, ,850,000 Total Capex 29,850, Operating cost (Opex) Due to the lower cost of labour in UK and Holland the yearly fixes operating cost for the ports in those countries is 20% lower than the Danish calculated cost. Item Cost Fixed operating cost (Opex fixed) (4 x 1, mill. DKK) 6,300,000 DKK/year Variable operating cost (Opex var.) 2.10 DKK/t

47 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY Scenario A-3 - Service ships This is a variant of scenario A-1 and addresses the treatment of ballast water of the service ships for the offshore platforms in the North Sea at Esbjerg Port, which are handled by one operator exclusively. The operator, Danbor, handles the 7 service ships which make in total 520 calls at Esbjerg per year. The total estimated treated amount is 104,000 t / year with one mobile unit. The capital investment will be 4,200,000 DKK for one mobile unit including truck and tanks. The operating costs will be similar to those for scenario A-1. Item Fixed operating cost (Opex fixed) Variable operating cost (Opex var) Cost 1,500,000 DKK/year 2.10 DKK/t 5.4 Summary Esbjerg Table 5-1 Yearly treatment amounts Scenario A-1 Scenario A-2 Scenario A-3 Esbjerg 300,000 t 240,000 t 104,000 t Harwich (44,000 t)* 44,000 t Immingham (123,000 t)* 270,000 t Gothenburg Rotterdam Felixstowe 90,000 t 315,000 t 225,000 t Totals 300,000 t 1,184,000 t 104,000 t *Not included in the financial analyses A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

48 Table 5-2 Number of units Scenario A-1 Scenario A-2 Scenario A-3 Esbjerg 1 (+1) 1 (+1) 1 Harwich (1)* 1 (+1) Immingham (1)* - Gothenburg - 1 Rotterdam - 1 (+1) Felixstowe Totals 1 (+1) 5 (+3) 1 *Not included in the financial analyses 5.5 Scenario B-1 - Fredericia The traffic in the port of Fredericia consists of tankers, container ships, freight ferries and a mix of various bulk and cargo ships. By far the largest through put in the port is the export by large tankers of the North Sea oil arriving to the port by pipelines. The amounts of ballast water exchange from those ships vary considerably and are much larger than those from the other types of ships investigated. As an example, a large tanker of 100,000 ton dead weight often exchanges 40,000 tons ballast water when sailing between Gothenburg and Fredericia. The capacity of the ballast pumps is up to 2 x 2200 t / h. The large terminal, Skanseoddehavn, at Fredericia Port handles all the oil export operations, managed by Shell. For safety reasons no vehicles are allowed onto the quays during the operations and thus no treatment can be done by mobile units. A solution which could be considered for the treatment of ballast water from large tankers moored at terminals would include a fixed land based facility, receiving the ballast water via pipelines on the jetty. A large tank may be used as a buffer to make up for insufficient peak capacity of treatment plant. Scenario B-1 for Fredericia includes all ships which make regular calls at the port, except the large tankers at the Shell terminal. Thus this scenario presumes all other ports of call on the ships routes do have the treatment facilities in operation. This assumption is probably only realistic in the future, since it requires that the shipping companies all establish or arrange for the facilities in the relevant ports of call.

49 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 49 The total registered number of ship calls at Fredericia in a typical 2 months period includes: Type of ship Calls per year Container (feeder) ships 240 RoRo freight ferries 90 Small tankers 150 Various freighters 40 Total Ballast water to be treated With the assumption that the average treatment of ballast water per ship corresponds to that of the DFDS freight ferries 300 t /ship/ call, the total estimated amount of ballast water to be treated will be 156,000 tons per year. The feeder line Unifeeder, which operates small to medium size container ships (feeder ships) calling the port, has informed that the above assumed figure of 300 t / ship / call in average corresponds well to that of their container ships. A scenario seen from the shipping company s perspective, i.e. arranging their own system of treatment units in the ports of call, similar to scenario A-2, would not be realistic at Fredericia Port due to the few calls at the port by the ships of each company Capital investment (Capex) For scenario B-1 the capital investment in the mobile treatment units in Fredericia Port is estimated as follows: Item DKK One operating unit with truck 4,200,000 One unit in reserve 2,950,000 Total Capex 7,150,000 A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

50 5.5.3 Operating cost (Opex) Item Fixed operating cost (Opex fixed) Variable operating cost (Opex var.) Cost 1,500,000 DKK/year 2.10 DKK/t 5.6 Scenario A-4 - Treatment from barge This scenario is based on the treatment of the ballast water from the ships included in scenario A-1 and that a barge operating company handles all ships by use of one barge. The size of the barge corresponds to those used in Rotterdam port for services to ships of disposal of solid waste etc. The length of the barge would be approximately 40 m Ballast water to treated Ballast water to be treated t/year Total yearly amount 300,000 Total yearly amount 300, Capital investment (Capex) Item DKK Barge, flat deck type 18,000,000 Treatment unit, complete incl. generator 2,800,000 Modifications of barge 500,000 Total Capex 21,300,000

51 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY Operating cost (Opex) Fixed operating cost: Item DKK/year Rental cost of barge, incl. crew, 200 EUR x 8 x 365 4,300,000 Administration, port fees etc. 400,000 Total Capex 4,700,000 Variable operating cost Item Cost Variable operating cost (Opex var) 2.10 DKK/t 5.7 Scenario A-5 - Supply of treated water This scenario includes the supply of treated sea water from the mobile units to the ships of the DFDS North Sea routes selected for the scenario A Ballast water to be supplied The total estimated yearly amount of treated sea water to be supplied to the ships would be: Amount of water t/year Total from section ,184,000 Less service ships, Esbjerg Port 104,000 Total yearly amount 1,080, Capital investment (Capex) For this scenario A-5 the capital investment for the mobile treatment units in all ports involved is estimated as follows: A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

52 Scenario Description Units Water, 000 t/year Capex, MDKK Opex fix, MDKK/year Opex var, DKK/y Item Unit cost, DKK Nos. DKK Operating units 3,700, ,500,000 Reserve units 2,950, ,850,000 Total Capex 27,350, Operating cost (Opex) Due to the lower cost of labour in UK and Holland the yearly fixed operating cost for the ports in those countries is 20% lower than the Danish calculated cost. Item Fixed operating cost (Opex fixed), 4 x mill. DKK Variable operating cost (Opex var) Cost 6,300,000 DKK/year 1.20 DKK/t 5.8 Summary Based on the pattern of ship calls and mooring times, assumed amounts of ballast water, and a set of configurations of target ships and equipment operators, a number of scenarios (business cases) have been described. The results are summarized below: A-1 Esbjerg, one operator, all ships calling regularly: Ro- Ro ferries by DFDS and Sea Cargo and service ships for offshore platforms A-2 Esbjerg, DFDS Stevedore handles all DFDS ships in the ports of the selected North Sea routes and the 5+3 1,

53 Scenario Description Units Water, 000 t/year Capex, MDKK Opex fix, MDKK/year Opex var, DKK/y BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 53 service ships in Esbjerg A-3 Danbor stevedoring handles the service ships in Esbjerg A-4 A barge operator provides the treatment services to all ships calling Esbjerg regularly , A-5 Ships of selected DFDS North Sea routes are provided with treated water to clean ballast tanks 5+3 1,080 27, B-1 Fredericia, : one operator handles all ships which make regular calls at the port, excl. large tankers These scenarios are subject to a financial analysis in the following chapter. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

54 6 Financial analyses The financial analyses are based on a simple financial model. 6.1 Basic assumptions Table 6-1 Basic assumptions Interest rate (debt) 6,5% Return on equity 15% Depreciation Operating period Tenor on debt 15 years 15 years 10 years Debt financed 80% Equity financed 20% These assumptions may not match the current market situation or the exact terms under which a private service provide would operate, but they are fairly reasonable and are primarily aimed at providing a homogenous base for comparison of the scenarios presented above. Changing these assumptions will not change the ranking between the scenarios, i.e. the most expensive scenario under these assumptions will be the most expensive under any other reasonable assumptions. 6.2 Results The result of the analysis is a treatment price per ton ballast water. The prices reported are based on the assumption of an internal rate of return (IRR) on equity of 15%. Given the financing structure of 80% debt financing, the IRR of the entire project will be lower.

55 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY Treatment cost, Esbjerg Table 6-2 Financial results Esbjerg Esbjerg Port Investment NPV Project Equity Treatment cost Ballast water Treatment cost Total DKK DKK IRR IRR DKK/t t/call DKK/call Scenario A1-7,150,000 2,192,311 10% 15% ,115 Scenario A2-29,850,000 2,649,479 10% 15% ,084 Scenario A3-4,200,000 1,285,174 10% 15% Scenario A4-21,300,000 6,515,438 10% 15% ,264 Scenario A5-27,350,000 8,380,606 10% 15% ,157 Scenarios A-1, A-2 and A5 are almost identical in terms of the cost of treatment. Scenario A-3, which only covers the service ships, is significantly more expensive, as the yearly volume of ballast water treated is very low. Scenario A4, which is the barge in Esbjerg, is likewise very expensive as the ballast water treated is the same as in scenario A1 while the capital investment is much higher Treatment cost, Fredericia Table 6-3 Financial result, Fredericia Fredericia Port Investment NPV Project IRR Equity IRR Treatment cost Ballast water Treatm ent cost Total DKK DKK DKK/t t/call DKK/c all Scenario B-1-7,150,000 2,187,080 10% 15% ,409 The treatment cost in scenario B-1 is high. This is mainly due to the low total yearly volume of ballast water for treatment. 6.3 Evaluation and sensitivity check The amounts of ballast water estimated to be treated at each ship call may vary considerably between ships and from time to time. Especially the amounts may be reduced due to the effect of the price to be paid by the shipping lines and thus causing more economical operations managed by each ship. However, variations in the amounts of treated ballast water will affect the price per ton, but only marginally the price per call. This is due to the relative low variable operating cost compared with the total fixed costs. This is especially the case for scenarios A-1 and A-2. The system to be implemented for the treatment charges A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

56 should therefore consist of a combination of a fixed charge per call and a charge per ton of water treated. 6.4 Comparative scenario For comparison with the above analyses for treatment of ballast water by mobile units in the ports, the following brief assessment has been carried out of the financial aspects regarding treatment by units installed onboard the ships. The following assumptions have been made: The cost of units installed on the ships is approximately 3.0 million DKK, including the price of the treatment units. The fixed operating cost (crew) is set to nil, since the crew members are assumed to be able to carry out the treatment activities during the sailings and at berth The variable operating cost is estimated to be equal to that of the quayside operation minus the cost of the treatment and handling residual material The units on board will take up space and depending of the location of the plant in the ship an opportunity cost may be incurred Capital cost (Capex) The ships involved in this scenario are the same as in scenario A-2, namely the 5 routes of DFDS and the service ships operating out of Esbjerg Port. The number of vessels on which the treatment units shall be installed amounts to 11 Ro-Ro ships from DFDS and 7 service ships, in total 18 vessels. These ships represent a total of 4260 calls at ports yearly. Total capital expenditure (Capex) 3,000,000 x 18 = 54,000,000 DKK Operating cost (Opex) Variable operating cost for treatment of a yearly total of 1,184,000 t ballast water: 1,184,000 t/y x 1.20 DKK/t = 1,342,000 DKK / year Cost of on-board treatment The assessment of the ballast water treatment with on board installed units indicates the following estimated treatment costs.

57 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 57 Table 6-4 Financial result, onboard treatment Investment NPV Project Equity Treatment cost Ballast water Treatment cost Total DKK DKK IRR IRR DKK/t t/call DKK/call Onboard treatment -54,000,000 16,539,886 10% 15% ,244 These estimated figures do not take into account any cost incurred for the space allocation for the units onboard, nor any manpower cost of the crew. The estimated treatment cost of an on board facility is 27% lower than the main scenarios A-1 and A-2 of the land based solutions examined above. This is mainly due to the high fixed operating costs on land. 6.5 Scenario A-4 - Treatment from barge The cost of the treatment charged by an independent operator in this scenario is estimated to be: Cost per ton of treated ballast water Cost per call with treatment (300 t / treatment) DKK / t 8,264 DKK The high cost is due to the relative small amount of business turnover for the ballast water treatment for such a barge operation in the port. That is evidently the reason why there are no services by barges in Danish ports, except by the large companies for bunker supply using large barges operating from few base ports. 6.6 Scenario A-5 - Supply of treated water The cost of the treated water supplied by the treatment units is estimated to be: Cost per ton of treated water Cost per supply of 300 t DKK / t 3,157 DKK As may be seen the cost per ton for the supply of treated water is around 10 % lower than the cost of treatment at discharge of the ballast water. 6.7 Cost and price The prices charged by the operators in the various ports will probably differ from the calculated costs, as the operator will have to ensure a reasonable level of profits and that fixed operating costs are recovered even if the amounts of water to be treated are small. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

58 Scenario Port Description Tons/call Cost, DKK/ton Cost, DKK/call 6.8 Recapitulation A-1 Esbjerg One operator, all ships ,115 A-2 Esbjerg DFDS stevedore handles DFDS ships and service ships ,084 A-3 Esbjerg Danbor handles service ships ,418 A-4 Esbjerg Barge operator, all ships ,264 A-5 Esbjerg DFDS ships buy treated water from land ,157 B-1 Fredericia One operator, all ships except large tankers ,409 Onboard n/a Ship s own plant on board ,244 These results are discussed in the next chapter.

59 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 59 7 Summary - conclusions 7.1 The study results The investigations and financial analyses show the following key points: Treatment of ballast water by mobile units in ports seems to be a realistic alternative to treatment onboard the ships, both technically and financially. However, this would mainly be feasible for ships in regular shipping service between few ports. The calculated cost of treatment, which would be charged by independent operators in scenarios A-1 & A-2 in Esbjerg Port is 10.4 DKK per ton of ballast water and 3,100 DKK per call at the ports. These scenarios cover services to all ships which regularly call the port (A-1) and all ships of selected DFDS North Sea routes and the service ships for offshore platforms (A-2). The calculated cost of treatment for scenario A-3 with one operator for the service ships only, amounts to 22.1 DKK per ton of ballast water. This high cost, due to the low turnover of treatment, renders this scenario clearly unacceptable. The calculated cost of treatment for scenario A-4, with treatment operation by use of barge, amounts to 27.5 DKK per ton of ballast water. The high cost renders this scenario clearly not interesting as a business case in ports like Esbjerg and Fredericia. The calculated cost of treatment for scenario B-1 in Fredericia Port amounts to 18.0 DKK per ton of ballast water. This relatively high cost, due to the low turnover of treatment, renders this concept uninteresting given the present traffic volume in Fredericia. The calculated cost of treatment for scenario A-5, supply of treated water to ships, is 10.5 DKK per ton of ballast water and 3,157 DKK per call at the ports. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

60 Treatment of ballast water onboard the ships, which is expected to be the case for most of the ships world vide, has been evaluated, although outside the scope of this study. The estimated expected cost price was 7.5 DKK per ton of ballast water treated. 7.2 Conclusions The main conclusions which can be drawn from the study are: It can be considered with a reasonable degree of certainty that the implementation of treatment of ballast water by mobile units in ports can be approved by the relevant environmental authorities in Denmark. The conceptual technical and operational solutions as described can be considered feasible. However, the concept of supplying treated water to ships (scenario A-5) is only realistic for certain ships in fixed routes between 2 ports, due to the possible growth of plankton in the ship s tanks. Scenario A-1, with treatment service to all ships regularly calling the port, can only be realistic business case if all other ports of call implement the same treatment services simultaneously. This is not likely to happen, since some ports would have to operate with small turnover of treatment and thus with unacceptable financial results. Scenario A-4, with treatment services from barges, would only be financially feasible in large ports like Rotterdam, with expected large volumes of ballast water to be treated and where barge operators at present provide various services to ships. Barge may be used for treatment ballast water from large container ships, where the treatment services from the quay would be difficult due to the travelling ship to shore cranes. The scenario and business case which seems most realistic, operationally and financially, is scenario A-2. This includes establishment of treatment services in Esbjerg and the ports of call of selected North Sea routes of DFDS. The mobile units with its facilities will service all the RO-RO ferries and the services ships for offshore platforms in the North Sea. The calculated cost of treatment is moderate and may be lower at time due to expected more business of providing treatment services to other ships calling the ports in question. It is recommended to consider and pursue this business case further by carrying out comparative analyses with the generally considered concept of the onboard treatment of the ships ballast water. Naturally, the decisions regarding which concept to select will depend to a high degree on the total cost of the installation of the treatment plants onboard the ships and furthermore on the operational conditions of the ships, with regard to flexibility, reliability, etc. When the ongoing technical design and cost estimations for the onboard treatment plants are completed the decision can be taken regarding the further

61 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 61 steps to be taken, including carrying out testing of the ballast water treatment by mobile units. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

62 8 Testing the concept 8.1 Description In order to ensure that the treatment by mobile units can be implemented in general as described and that the technical and operational problems can be identified and mitigated, a full-scale test of the system is necessary. Such a test of the system with one ship and one mobile unit could be carried out in Esbjerg Port and would comprise: Design of the necessary modifications to the ship s ballast water system: ballast water discharge pipe at a suitable height relative to the unit parked on the quay, determination of required pump size and decision on whether existing pumps can be used (depending on available pump characteristics, pressure requirement from unit and head loss in piping, valves, pipes, control and instrumentation Approval of modified design by classification agency It may be wished to submit the working arrangement on land to the Danish Working Environment Authority (Arbejdstilsynet) for comment Agreement with stevedore company on operation and storage of the unit Application for environmental permit for discharging the treated ballast water into the port basin. This permit is not expected to represent an obstacle as the alternative is that the ship, without need for a permit, discharges the nontreated water into the basin, Arrangement for disposal of slurry from the trial:

63 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 63 As the first choice, the slurry will be disposed of in the port basin If an environmental permit cannot be obtained, disposal of the slurry at a controlled depot or similar will be necessary In this trial period the sludge will not be chlorinated due to the H&S complications of handling chlorine or hypochlorite and the difficulty of obtaining an environmental permit for discharging the chlorinated material into the port basin. Modification of ship s ballast water piping system (by the ship-owner) Order of the mobile unit complete installed on the flatbed trailer Rental of slurry tank (if slurry cannot be discharged into the port) Delivery of the mobile unit Trial period as such one month s operation time is proposed to allow for a substantial number of treatments and adjustments Evaluation and conclusion. 8.2 Programme A plausible time schedule could be as follows: Table 8-1 Tentative test program Test operation Environmental permit, purified water Slurry disposal arrangement Design of ship's modification Class approval of ship's modification Modifications on ship Consultation with "Arbejdstilsyn" on set-up Agreement with steevedore Order of mobile unit Rental and installation of slurry tank Delivery of mobile unit Test period Evaluation Month A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

64 Appendix A Regulations D-1 and D-2 Regulation D-1 Ballast Water Exchange Standard 1 Ships performing Ballast Water exchange in accordance with this regulation shall do so with an efficiency of at least 95 percent volumetric exchange of Ballast Water. 2 For ships exchanging Ballast Water by the pumping-through method, pumping through three times the volume of each Ballast Water tank shall be considered to meet the standard described in paragraph 1. Pumping through less than three times the volume may be accepted provided the ship can demonstrate that at least 95 percent volumetric exchange is met. Regulation D-2 Ballast Water Performance Standard 1 Ships conducting Ballast Water Management in accordance with this regulation shall discharge less than 10 viable organisms per cubic metre greater than or equal to 50 micrometres in minimum dimension and less than 10 viable organisms per millilitre less than 50 micrometres in minimum dimension and greater than or equal to 10 micrometres in minimum dimension; and discharge of the indicator microbes shall not exceed the specified concentrations described in paragraph 2. 2 Indicator microbes, as a human health standard, shall include: 2.1 Toxicogenic Vibrio cholerae (O1 and O139) with less than 1 colony forming unit (cfu) per 100 millilitres or less than 1 cfu per 1 gram (wet weight) zooplankton samples ; 2.2 Escherichia coli less than 250 cfu per 100 millilitres; 2.3 Intestinal Enterococci less than 100 cfu per 100 millilitres.

65 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 65 Appendix B Regulation B-3 Regulation B-3 Ballast Water Management for Ships 1 A ship constructed before 2009: 1.1 with a Ballast Water Capacity of between 1500 and 5000 cubic metres, inclusive, shall conduct Ballast Water Management that at least meets the standard described in regulation D-1 or regulation D-2 until 2014, after which time it shall at least meet the standard described in regulation D-2; 1.2 with a Ballast Water Capacity of less than 1500 or greater than 5000 cubic metres shall conduct Ballast Water Management that at least meets the standard described in regulation D-1 or regulation D-2 until 2016, after which time it shall at least meet the standard described in regulation D-2. 2 A ship to which paragraph 1 applies shall comply with paragraph 1 not later than the first intermediate or renewal survey, whichever occurs first, after the anniversary date of delivery of the ship in the year of compliance with the standard applicable to the ship. 3 A ship constructed in or after 2009 with a Ballast Water Capacity of less than 5000 cubic metres shall conduct Ballast Water Management that at least meets the standard described in regulation D-2. 4 A ship constructed in or after 2009, but before 2012, with a Ballast Water Capacity of 5000 cubic metres or more shall conduct Ballast Water Management in accordance with paragraph A ship constructed in or after 2012 with a Ballast Water Capacity of 5000 cubic metres or more shall conduct Ballast Water Management that at least meets the standard described in regulation D-2. 6 The requirements of this regulation do not apply to ships that discharge Ballast Water to a reception facility designed taking into account the Guidelines developed by the Organization for such facilities. 7 Other methods of Ballast Water Management may also be accepted as alternatives to the requirements described in paragraphs 1 to 5, provided that such methods ensure at least the same level of protection to the environment, human health, property or resources, and are approved in principle by the Committee. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

66 Appendix C Guideline G-5

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68 Side 2

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72 Appendix D Regulation A-3 Regulation A-3 Exceptions The requirements of regulation B-3, or any measures adopted by a Party pursuant to Article 2.3 and Section C, shall not apply to: 1 the uptake or discharge of Ballast Water and Sediments necessary for the purpose of ensuring the safety of a ship in emergency situations or saving life at sea; or 2 the accidental discharge or ingress of Ballast Water and Sediments resulting from damage to a ship or its equipment: 2.1 provided that all reasonable precautions have been taken before and after the occurrence of the damage or discovery of the damage or discharge for the purpose of preventing or minimizing the discharge; and 2.2 unless the owner, Company or officer in charge wilfully or recklessly caused damage; or 3 the uptake and discharge of Ballast Water and Sediments when being used for the purpose of avoiding or minimizing pollution incidents from the ship; or 4 the uptake and subsequent discharge on the high seas of the same Ballast Water and Sediments; or 5 the discharge of Ballast Water and Sediments from a ship at the same location where the whole of that Ballast Water and those Sediments originated and provided that no mixing with unmanaged Ballast Water and Sediments from other areas has occurred. If mixing has occurred, the Ballast Water taken from other areas is subject to Ballast Water Management in accordance with this Annex.

73 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 73 Appendix E Regulation A-4 Regulation A-4 Exemptions 1 A Party or Parties, in waters under their jurisdiction, may grant exemptions to any requirements to apply regulations B-3 or C-1, in addition to those exemptions contained elsewhere in this Convention, but only when they are: 1.1 granted to a ship or ships on a voyage or voyages between specified ports or locations; or to a ship which operates exclusively between specified ports or locations; 1.2 effective for a period of no more than five years subject to intermediate review; 1.3 granted to ships that do not mix Ballast Water or Sediments other than between the ports or locations specified in paragraph 1.1; and 1.4 granted based on the Guidelines on risk assessment developed by the Organization. 2 Exemptions granted pursuant to paragraph 1 shall not be effective until after communication to the Organization and circulation of relevant information to the Parties. 3 Any exemptions granted under this regulation shall not impair or damage the environment, human health, property or resources of adjacent or other States. Any State that the Party determines may be adversely affected shall be consulted, with a view to resolving any identified concerns. 4 Any exemptions granted under this regulation shall be recorded in the Ballast Water record book. A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

74 Appendix F Ships at berth 1/1-31/ The graph shows ships at berth in Esbjerg Port in the time period from 1/ to 31/ for supply and route ships with more than 5 arrivals within the time period.

75 BALLAST WATER TREATMENT IN PORTS, FEASIBILITY STUDY 75 A Feasibility Study. December 2012 C:\Users\UCB\Desktop\NST-mobile BWMS report.docx

76 The principal purpose of this study is to investigate and clarify the possibilities and the feasibility of implementation of port based mobile treatment units for ships ballast water