©2016 American Bureau of Shipping. All rights reserved.

Ballast Water Management -

The Convention and US Requirements

Stamatis Fradelos Principal Engineer, Operational & Environmental Performance

Athens, Greece

9 June 2016

BALLAST WATER MANAGEMENT SUMMIT 2016

2

United States BWM Requirements

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) – Part 6 of VGP

BWMS require specific testing and

type approval by the USCG

Compliance dates are based on

vessel drydocking

3

Implementation Schedule

IMO Implementation Schedule

USCG/EPA Implementation Schedule

USCG extensions, EPA low enforcement priority for USCG extensions

Revised Scheme – Draft Revision of Resolution A.1088(28)

Keel Laying DateComplianceon/after EIF

Compliance on/after First IOPP

Renewal Survey after EIF

< EIF D-1 or D-2 D-2

>EIF D-2 D-2

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

4

BWM Convention vs. EPA VGP Requirements

IMO US EPA

Discharge Standards Numeric Values are the same

Terminology in

Discharge Standards

Organism discharge

standards

“viable organisms”

Organism discharge

standards

“living organisms”

Testing AuthoritiesFlag Administration

determination

USCG accepted Independent

Laboratory

Testing Protocol

Following BWM Convention

Guidelines (G8).

Provides general guidelines

for testing and sample

analysis.

G8: “When available, widely

accepted standard methods

…should be used.”

ETV Protocol identifies

specific test requirements

and methods for identification

of organisms

5

Effluent Limits for BWMS (VGP 2.2.3)

Effluent limits for BWMS that use active substances

Biocide or ResidualLimit

(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

6

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 manufacturer

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 © USCG

7

VGP Functionality Monitoring Metrics

8

VGP Ballast Water Sampling Frequency

BWMS with High Quality Data

Any BWTS type approved by the USCG or

Granted Alternate Management System status by the USCG

Biological Indicator Organism Monitoring 2 times during first year

– One sample may be conducted as part of the installation testing

– One sample may be conducted as part of a vessels annual or other survey

If sampling results below permit limits for 2 consecutive events, reduce monitoring to once per year after the first year

If permit limit exceeded, must return to 2 times per year until 2 additional results below permit limits

Residual Biocide and Derivative Monitoring for BWMS that use Active Substances Initial Monitoring

– 3 times in first 10 discharge events (not to exceed a 180 day period)

Maintenance Monitoring– 2 times per year

9

2013 VGP Annual Report

Completed once each calendar year

All analytical monitoring results must be in the Annual Report

Must be submitted electronically, unless waiver is granted

Example of Annual Report form is included in Appendix H of VGP

Annual report due by 28 February of the following year

EPA VGP does not include a provision for USCG extensions.

Vessels are technically out of compliance with VGP

EPA published Enforcement Memorandum with “Low Priority Enforcement” statement.

10

USCG Type Approval Process

IL Review and Test Report Generation

(~90 days)

USCG Marine Safety Center

Review

(~90 days)

USCG Type Approval

Awarded

IL

Land-based Testing

(20 weeks)

Shipboard Testing

(minimum 6 months) Component

Testing

(~35 days)

Design & Construction

Review

(~90 days)

Vendor

makes a

contract

with IL

Testing may

occur in

parallel, but

the same

exact model

needs to be

used for all

testing.

Approximately

18 – 24 months

Note: Process is confidential until award of USCG type approval – no interim reports

11

USCG Type Approval Process

All testing in accordance with Environmental Technology Verification (ETV) Protocol and Shipboard Testing Requirements (46 CFR 162.060-28)

Testing and evaluation of existing data needs to be conducted by USCG accepted independent laboratory (IL)

USCG accepted ILs: NSF International, DNV-GL AS, Korean Register of Shipping (KR), Control Union Certifications BV and Lloyd’s Register EMEA

Existing data for most BWMS cannot be used due to differences in testing requirements between ETV and BWM Convention Guidelines

USCG has specific requirements for:

Test plans and quality assurance project plans

Operation and maintenance evaluation

Biological efficacy evaluation

Diagnostics evaluation

System documentation evaluation

Technical data package submission

Counting organisms (i.e., FDA/CMFDA method)

12

USCG Type Approval Status

No BWMS has received USCG Type Approval

34 Letters of Intent (LOI) are listed by USCG by 33 BWMS vendors

Numerous BWMS are being tested

UV Most Probable Number (MPN):

March 2015: 3 UV-based BWMS Vendors submitted type approval

packages to the USCG Marine Safety Center (MSC) for review

16 December 2015: USCG MSC denied request to use Most Probable

Number (MPN) for evaluation of 4 different BWMS manufacturers.

FDA/CMFDA test method:

Three BWMS Vendors announced test completion.

Estimated earliest USCG type approved BWMS – late 2016

Note: USCG stated shipowners will not be forced to purchase the first

BWMS receiving type approval. Extension approvals will continue.

www.eagle.org