ballast water management - where we are today … · leading the way; making a difference 1. imo 2....

Leading the way; making a difference

1. IMO

2. US

Ballast Water Management - where we are today

Outline


Desired outcome:Tanker industry is able to achieve compliance with current and future discharge standards (both regionally and internationally)

Focus:1. Installation and Operation of appropriate and

adequate ballast water management systems

2. Compliance and enforcement – need strong, well defined and realistic international regulations

Ballast Water Management

INTERTANKO’s Strategic Plan


Ballast Water Management Convention

• Entry into force, 8 September 2017

• New buildings constructed after 8 Sept ‘17

• Existing vessels first IOPPC renewal after 8 Sept ‘17


1. IMO: Where we are today


Ballast Water Management Convention

MEPC 64 (2012) INTERTANKO et al. submission identified THREE key challenges:

1. Port State Control should not be more rigorous than BWMS Type Approval testing procedures

2. G8 guidelines should be revised to require more rigorous Type Approval testing

3. IMO Assembly resolution should be developed with a realistic schedule for the installation of BWMS when Convention enters into force

Following continued pressure, submissions to MEPCs 65, 66, 67, 68, 69 and now 70!


1. IMO: History



1. Port State Control should not be more rigorous than BWMSType Approval testing procedures

• Trial Period (initially for 3 years) following entry into force

• During this period, port states will ‘refrain from detaining a ship or initiating criminals sanctions in the event a BWMS does not meet the discharge standard’ (USA reserved position)

• Sampling only after clear grounds and any indicative sample should not form the basis for a decision on compliance – 4 Stage approach:

1. Initial inspection2. More detailed inspection3. Indicative sampling4. Detailed sampling

1. IMO



2. Type Approval Guidelines for ballast water management systems (G8)

• Review and revise the type approval guidelines (G8)• Major outstanding items: viable organisms, system design limitations, suspended

and dissolved matter (UV transmittance)

• Protection for early-movers : those owners who’ve installed BWMS approved to current G8 should not be penalized

• Application of the new G8?• When does the application of the revised G8 start?• When they are adopted?• A specified period after they are adopted?• When there are BWMS approved to the revised G8?

1. IMO



3. Logical Implementation schedule

Assembly Resolution A.1088 (28) adopted, Dec 2013 recommends governments to implement the Convention based on the entry into force date of the Convention

• Ships constructed before the date of entry into force of the Convention shall install a ballast water management system (i.e. meet the standard described in regulation D-2) from the date of the first IOPPC renewal survey after the entry into force of the Convention.

• Ships constructed on or after the date of entry into force of the Convention shall have a ballast water management system installed (i.e. conduct Ballast Water Management that at least meets the standard described in regulation D-2).

1. IMO



Going into MEPC 70

1. INTERTANKO, WSC, India et al (70-4-15)- Owners should have the option to install 2nd Generation IMO BWMS- Delay implementation either:

1. For 2 years after EIF for existing vessels, or2. When IMO determines sufficient 2nd Generation IMO BWMS exist

2. Liberia (70-4-17)- Insufficient ship yard capacity- Delay implementation to 2nd IOPPC Renewal and use eBWE in meantime

Both papers seek the same objective.

1. IMO


US Coast GuardFinal regulations issued March 2012 (effective 21 June ‘12)

Main requirements include:

• BWE prior to discharge in US waters

• BWM Plan: reporting and record keeping (fouling management as well)

• BWM discharge standard (same as IMO), review in 4 yrs

• Compliance schedule (similar to IMO), (no intent to align schedule with IMO)

• Acceptance of “Alternative” BWMS for 5 years

• BWMS not required if no discharge in US waters (12 nautical miles)

• All ships must eventually install a CG approved BWMS

• Ships may request an extension to compliance date for installation of CG TA

BWMS

2. US



US Coast Guard – BWMS Approvals (1)

• 34 BWMS manufacturers have submitted “Letter of Intent” (LOI) to pursue USCG approval (58 AMS accepted by USCG)

• USCG “aware of” 20 systems undergoing testing

• Only after the testing is completed by USCG accepted Independent Laboratory (IL) and the results have been evaluated, will a BWMS manufacturer then submit an application to the USCG for approval of their BWMS

2. US



US Coast Guard – BWMS Approvals (2)

• Between 19 - 23 September, 3 BWMS manufacturers submitted applications to the USCG for type approval:1. Optimarin

2. Alfa Laval (Pure Ballast)

3. OceanSaver

• USCG advise they will make a decision 30 days after the application has been received

2. US



US Coast Guard – BWMS Approvals and Extensions

• CG will not wait to issue a type approval certificate if an application demonstrates that all criteria for type approval have been met

• After BWMS are USCG approved, extension program will be modified as necessary using a “practical approach”

• Each ship will be evaluated on a case by case basis, based upon suitability of available USCG approved BWMS for that particular ship and hopefully combined with ship’s next scheduled drydocking

2. US



US Coast Guard - Implementation Schedule

• Decision Tree…

2. US



US Ballast Water Decision Tree


US Coast Guard - Implementation Schedule

• Decision Tree• Model Extension Request (MER) Letter

Still in use and still relevant!

2. US

Ballast Water Management - State of Affairs


EPA – VGP 2013 (1)• To a large extent EPA VGP requirements are the

same as USCG:

• discharge standard• compliance schedule

• Approval of the BWMS is not required

• BWMS monitoring required:

• Functional (equipment) • Biological (effluent)• Biocides

2. US



EPA - VGP 2013 (2) - US COURT OF APPEALS RULING• Decision based in part on the EPA’s Science Advisory Board (SAB) report “which

identified a number of technologies that can achieve standards higher than IMO for one or more organism sizes”

• Court has remanded the matter back to EPA for review

• Court also ruled that the 2013 VGP shall remain in place until EPA issues a new VGP

2. US


ballast water management - where we are today … · leading the way; making a difference 1. imo 2....

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