Ballast Water Management

Dietrich Dabels

TBD Northern Europe

Ship Management Konferenz

Hamburg

25 September 2014

2

Overview

IMO Ballast Water Convention

U.S. Regulatory Scheme

U.S. Ballast Water Regulations

U.S. Environmental Protection Agency Vessel General Permit

U.S. Port State Control Inspections

Ballast Water Management System Information

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Worldwide Requirements

Additional locations that have local BWM regulations

Antarctica, Argentina, Australia, Bermuda, Brazil, Canada, Chile,

China, Colombia, Croatia, Egypt, Georgia, Israel, Lithuania,

Namibia, New Caledonia, New Zealand, Norway, Northwest

Europe, Panama, Peru, Persian Gulf, Portugal, ROPME Sea Area

(RSA), Russian Federation, Turkey, Turks and Caicos Islands,

Ukraine, United Kingdom, United States of America, Orkney

Islands, and Vanuatu.

Additional locations that have local BWM regulations

Antarctica, Argentina, Australia, Bermuda, Brazil, Canada, Chile,

China, Colombia, Croatia, Egypt, Georgia, Israel, Lithuania,

Namibia, New Caledonia, New Zealand, Norway, Northwest

Europe, Panama, Peru, Persian Gulf, Portugal, ROPME Sea Area

(RSA), Russian Federation, Turkey, Turks and Caicos Islands,

Ukraine, United Kingdom, United States of America, Orkney

Islands, and Vanuatu.

Countries that have ratified the BWM Convention

Albania, Antigua and Barbuda, Barbados, Brazil, Canada, Cook

Islands, Congo, Croatia, Denmark, Egypt, France, Germany,

Iran, Jordan, Kenya, Kiribati, Lebanon, Liberia, Malaysia,

Maldives, Marshall Islands, Mexico, Mongolia, Montenegro,

Netherlands, Nigeria, Niue, Norway, Palau, Republic of Korea,

Russian Federation, Saint Kitts and Nevis, Sierra Leone, South

Africa, Spain, Sweden, Switzerland, Syrian Arab Republic,

Tonga, Trinidad and Tobago, and Tuvalu.

Countries that have ratified the BWM Convention

Albania, Antigua and Barbuda, Barbados, Brazil, Canada, Cook

Islands, Congo, Croatia, Denmark, Egypt, France, Germany,

Iran, Jordan, Kenya, Kiribati, Lebanon, Liberia, Malaysia,

Maldives, Marshall Islands, Mexico, Mongolia, Montenegro,

Netherlands, Nigeria, Niue, Norway, Palau, Republic of Korea,

Russian Federation, Saint Kitts and Nevis, Sierra Leone, South

Africa, Spain, Sweden, Switzerland, Syrian Arab Republic,

Tonga, Trinidad and Tobago, and Tuvalu.

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BWM Convention Status

As of 15 September 2014, ratified by:

41 Member States/Parties

30.25% of World Tonnage

Entry into Force – 12 months after ratification by:

30 States

35% of World Tonnage

Needed

4.75 % of World Tonnage

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BWM Convention Implementation Schedule

28th IMO Assembly resolution adjusts the implementation schedule of the BWM Convention

Ballast Water Capacity

(m3) Keel Laying Date

Year & Applicable Standard

2014 2015 2016 2017

1,500 < or > 5,000 < 2009

(B-3.1.2)

D-1 (Ballast Water Exchange) or D-2 (Ballast Water Performance

Standard) D-2*

1,500 ≤ C ≤ 5,000 < 2009

(B-3.1.1) D-2 Compliance required at first

IOPP Renewal Survey after Entry Into Force (EIF)

< 5,000

>EIF D2 Compliance at Delivery

2009 ≤ K < EIF (B-3.3)

D-2 Compliance required at first IOPP Renewal Survey after EIF

≥ 5,000

2009 ≤ K < 2012 (B-3.4)

D-1 or D-2 D-2*

2012 ≤ K < EIF (B-3.5)

D-2 Compliance required at first IOPP Renewal Survey after EIF

≥ EIF D2 Compliance at Delivery

*D-2 Compliance required at first IOPP Renewal Survey following the Anniversary Date of Ship Delivery or,

if EIF is after 2016, D-2 Compliance at first IOPP Renewal Survey following the date of EIF

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U.S. Regulatory Scheme

States States

Control Mechanisms

Control Mechanisms

Government Agencies

Government Agencies

Federal Federal Federal Laws

EPA

Individual Permits

General Permit (e.g., VGP)

USCG

Standards for Living Organisms in Ships’ Ballast Water

Discharged in U.S. Waters

Many States have separate regulations for

vessel discharges.

NPDES: National Pollutant Discharge Elimination System

NANPCA: Non-indigenous Aquatic Nuisance Prevention and Control Act

NISA: National Invasive Species Act

Federal Water

Pollution Act

(i.e., Clean Water Act)

NANPCA

(as amended by

NISA)

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BWM Requirements in the United States

The United States has not ratified the BWM Convention and

has established independent ballast water regulations

In the US, ships must be in compliance with:

USCG Ballast Water Regulations;

US EPA VGP; and

Individual State requirements –

16 States have ballast water

requirements (California is the

most stringent)

BWMS require new testing and

type approval by the USCG

Compliance dates are based on

vessel drydocking

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USCG: Ballast Water Management Options

No ballast water discharge

Use a USCG Type Approved BWMS

Discharge to a facility onshore or another vessel for purposes of

treatment

Use only water from a US public water system

Temporary Compliance Options

Perform a complete ballast water exchange (BWE) up to the date

required to be in compliance with BWDS

Use an Alternate Management System (AMS) for no longer than 5

years from the date required to be in compliance with BWDS

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USCG: BWDS Implementation Schedule

New vessel – constructed on or after 1 December 2013

Keel laid

Construction identifiable with the specific vessel

Assembly commenced with 50 tons or 1% whichever is less; or

Major conversion

Drydocking means “hauling out of a vessel or placing a vessel in a drydock or slipway for an examination of all accessible parts of the vessel’s underwater body and all through-hull fittings”.

Vessel Ballast Capacity Compliance Date

New All Delivery

Existing

< 1,500 m3 First Scheduled Drydocking

after 1 January 2016

1,500 – 5,000 m3 First Scheduled Drydocking

after 1 January 2014

> 5,000 m3 First Scheduled Drydocking

after 1 January 2016

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USCG -

Extensions to Implementation Schedule Basis for request:

Limited availability of USCG Type-Approved BWMS

Constrained shipyard capability and capacity to install BWMS

Information to be provided:

Name of Vessel and vessel IMO or other official number

Total ballast water capacity

Scheduled delivery date (new vessels) or last drydocking date and first scheduled drydocking after applicable compliance date (existing vessels)

Extension requests must be submitted not less than 12 months prior to the vessel-specific compliance date.

Maximum duration of request requests will not exceed 5 years.

Please note these are Extension Requests – not Exemption Requests. USCG does not give exemptions to BWDS – other than those listed in the regulation.

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USCG - Extensions Issues

As of 19 September 2014, USCG has published over 200

approved extension requests.

Period for Extensions: 1 January 2016 or 1 January 2017 – firm date,

not related to drydocking

Issues with Extensions: EPA VGP does not include a provision

for USCG extensions. EPA published Enforcement Memorandum

with “Low Priority Enforcement” statement.

ABS developed templates available for use.

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USCG Sediment Management Requirements

Sediment from ballast water tanks or holds is to be disposed of

ashore in accordance with local requirements

Clean ballast tanks regularly to remove sediment

Dispose of sediment in accordance with applicable regulations

Document practices, removal and disposal in BWM Plan

USCQ FAQ Response:

Sediment disposed of as far from

shore as practicable, but must be

outside 12 nm, and in

accordance with Coast Guard’s

"Guidance on verification of

Fouling Maintenance and

Sediment Removal Procedures”

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USCG Recordkeeping &

Reporting Requirements Records contain information on:

Vessel,

Voyage,

Total ballast water system,

BWM practices (including BWM methods and BWM plans onboard),

Ballast water tanks to be discharged into US waters or reception facility and

Sediment discharge

Submittals with 24 hours of arrival to port or prior to departing port or place of departure for shorter voyages

Information to be sent to:

National Ballast Information Clearinghouse;

USCG COTP Buffalo, Massena Detachment for any vessel bound for the Great Lakes outside of the EEZ; or

USCG COTP New York for any vessel bound for the Hudson River north of the George Washington Bridge entering from outside the EEZ

USCG Notice of Proposed Rulemaking – 5 June 2013

Amend existing BWM reporting and recordkeeping requirements

– Vessels that operate within one COTP to submit annual report of BWM practices

– Allow most vessels to submit ballast water reports after arriving to port

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USCG Enforcement & Compliance

Access to the vessel for samples of ballast water and sediment,

examine documents, and other appropriate inquires

Provide records to the Captain of the Port (COTP) upon request

Penalties

Person violating requirements in US regulations is subject to a civil

penalty not to exceed 35,000 USD. Each day of a continuing a

violation constitutes a separate violation.

A person who knowingly violates the regulations is guilty of a class

“C” felony

Shipboard sampling protocol for compliance is currently being

developed

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2013 VGP: Ballast Water (Section 2.2.3)

Ballast water requirements generally align with USCG and IMO.

VGP includes same discharge standards and options for ballast

water management as USCG.

Additional effluent limits for BWMS that use active substances.

Biocide or Residual

Limit

(Instantaneous Maximum)

Chlorine Dioxide 200 μg/l

Chlorine

(Total Residual Oxidants (TRO as TRC)) 100 μg/l

Ozone

(Total Residual Oxidants (TRO as TRC)) 100 μg/l

Peracetic Acid 500 μg/l

Hydrogen Peroxide

(for systems using Peracetic Acid) 1,000 μg/l

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2013 VGP: BWM Components

BWM Options – same as USCG

Training

Promptly upon installation of system and significant change to practices or equipment

BWM Plans

Required to include written training plan describing the training and recording training dates and personnel.

Mandatory BWM Practices

Specific Mandatory BWM Practices for “Lakers”

– “Confined Lakers” modified to “Lakers” and the definition revised to be “existing bulk carriers that operate exclusively on the Laurentian Great Lakes, regardless of whether their operation is or is not beyond the Welland Canal.”

– Annual inspections to assess sediment accumulation and sea chest screens required

Monitoring

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2013 VGP: Ballast Monitoring

Functionality Monitoring

Performance indicators verify BWMS operating to manufacturer’s specifications

EPA provided list of required metrics for 18 technology types

Required at least once per month

Equipment Calibration

Sensors and other control equipment must be calibrated annually and as recommended by the system manufacture

Biological Organism Monitoring

Small volume samples analyzed for three specific biological indicators – total heterotrophic bacteria, E. coli, and enterococci.

Residual Biocide and Derivative Monitoring for BWMS that use Active Substances

Records of sampling and testing maintained on board for 3 years

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US States with Specific Requirements

- State with specific BW requirements in 2013 VGP (i.e., CWS 401 Certification or state law)

- State requiring additional reporting directly to state

- State requiring live organism monitoring

- State-specific BW requirements - not in 2013 VGP CWA 401 Certification

- State requires separate permit

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California

Most stringent of State requirements

Two prong approach to preventing and

minimizing marine invasive species:

BWM

Hull Fouling

Implementation

Focus on dockside inspection of vessels

- paperwork and samples.

Vessel must conduct BWE, regardless

of whether BWE would result in vessel

deviation or delay of the voyage.

Waiting for public release of July 2014

report on assessment of BWMS

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California Ballast Water Treatment

Performance Standards

Interim

Organism Size Class Performance Standard

Larger than 50 μm

(micrometer or one millionth of a meter) in

minimum dimension

No detectable living organisms

10 – 50 μm in minimum dimension Less than (<) 0.01 living organisms per ml (milliliter)

Less than 10 μm in minimum dimension

Escherichia coli

Intestinal enterococci

Toxicogenic Vibrio cholera

(human cholera)

Less than 103 (1,000) bacteria per 100 ml

Less than 104 living viruses per 100 ml

Less than 126 cfu (colony forming units) per 100 ml

Less than 33 cfu per 100 ml

Less than 1 cfu per 100 ml OR

Less than 1 cfu per gram of wet weight biological

material

Final – Effective 1 January 2020

Zero detectable living organisms for all organism size classes

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BW Capacity of Vessel

(metric tons)

New Vessels

(Built on or after)

Existing Vessels

(Operating in CA waters)

< 1,500 1 January 2016 1 January 2018

1,500 – 5,000 1 January 2016 1 January 2016

> 5,000 1 January 2016 1 January 2018

California – Revised Interim Performance

Standards Schedule

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U.S. Port State Control Inspection

Review NVIC USCG Navigation and Vessel Inspection Circular

07-04 (CH-1) and new Marine Inspection Notice 05-12

Port State Control Officer (PSCO) will verify the BWM,

biofouling, and sediment plans are onboard

PSCO may question the master, operator, person-in-charge,

and crew involved

PSCO may spot check BWM records with deck log entries:

BWM records onboard for all voyages to U.S. ports or places where

the vessel anchored or moored.

Records must be retained on board for 2 years

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BWMS for Use in US Waters

USCG Type Approved BWMS

USCG accepted Alternate Management System (AMS)

Temporary solution

USCG Accepted AMS – 41 BWMS by 38 Manufacturers

Aquarius™-UV

AquaStar™

ARA PLASMA

BalClor™

BallastMaster UltraV

BALPURE®

BIO-SEA®

Blue Ocean Shield

BSKY™

CleanBallast®

CrystalBallast®

Cyeco BWMS

EcoBallast™

Ecochlor®

Electro-Cleen™

ERMA FIRST

FineBallast MF

GloEn-Patrol™

HiBallast (including Ex Models)

Hyde GUARDIAN™

HY™-BWMS

JFE BallastAce®

(using NEO-CHLOR MARINE™ and

TG Ballastcleaner)

KBAL

MICROFADE™

MMC BWMS

NEI VOS

NiBallast™

NK-O3 BlueBallast®

Ocean Protection System

OceanDoctor

OceanGuard™

OceanSaver®

Optimarin

OxyClean

PureBallast

(Models 250 to 2500, 2.0/2.0Ex,

and 3.0)

Purimar™

SeaCURE

Smart Ballast

Trojan Marinex As of 19 September 2014

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BWMS Statistics

Category

All Type

Approved

BWMS

USCG

AMS

No. of BWMS 52 41

No. of BWMS requiring treatment during intake and

de-ballasting 48 39

No. of BWMS using active substances 27 22

No. of BWMS requiring storage of chemicals 23 19

No. of BWMS requiring storage of waste products 1 0

Maximum Capacity (m3/hr)* 16,200 16,200

*Maximum capacity only includes specific models listed in documentation.

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Final Points

Understand the requirements

Request assistance from ABS

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Recent ABS Environmental Publications

2014 ABS Ballast Water Treatment

Advisory

2014 ABS Guide for Ballast Water

Treatment (including BWMP

template)

ABS Trends on:

2013 VGP Sampling and Analysis

Requirements (June 2014)

2013 Requirements for EALs

(May 2014)

New Requirement for the

Upcoming 2013 VGP (October

2013)

US Ballast Water Management

Requirements (May 2013)

www.eagle.org