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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
3
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.
4
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
5
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
6
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)
7
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
9
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
10
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
12
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.
13
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.
14
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”
15
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
16
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
18
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
19
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
20
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
21
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
22
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
23
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
24
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
25
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
27
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
28
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.
30
Final Points
Understand the requirements
Request assistance from ABS
31
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