USCG Ballast Water Update
Richard A. Everett
Environmental Standards Division
(CG-5224)
US Coast Guard
December 5, 2007
CG Ballast Water Initiatives
• Development of a national BW Discharge
Standard
• BW treatment system approval protocols
• STEP
• International Developments
Why issue a BWD
Standard?
Ballast Water Exchange issues:
-Safety and voyage constraints
-Effectiveness is variable
Benchmark to approve BWM systems:
-Easier to compare to than BWE
Should increase the level of BWM conducted by
vessels
Legislative Authority to
issue a BWD standard
•
National Invasive Species Act of 1996
(NISA):
•
•
Establishes our authority to approve BW treatment
systems
Establishes our ability to implement a BWD standard
•
•
BWE clearly viewed as an initial step
Secretary (USCG) given discretion to promulgate additional
regulations as necessary
Current Rulemaking
Project
The BWD Standard regulation would:
• Set a concentration-based standard (# of
organisms/volume of ballast water)
• Be used to approve BWT technologies
• Be environmentally protective,
scientifically sound, and enforceable
BWD Standard Rulemaking
(cont’d)
• Specifically, the BWD Standard should
address the full range of organisms
including:
-Microbes (pathogens)
-All life stages (adults, juveniles, larvae,
resting stages)
-Those that reproduce asexually
Components of the Regulatory
Project
• Regulatory Analysis
– Cost/benefit
• Environmental Analyses
• Drafting the Regulatory Text
– Notice of Proposed Rule-making
(NPRM)

In progress
– Final Rule
Regulatory Assessment
(Cost-Benefit Analysis)
• Executive Order 12866
-Assess cost and benefits
•
Regulatory Flexibility Act
-Economic impacts to small businesses
• Small Business Regulatory Enforcement
Fairness Act
-Assistance to small businesses
Regulatory Assessment
• Addresses potential costs and benefits
of implementing a BWD standard
• Addresses costs and benefits of
alternatives analyzed in the
Programmatic Environmental Impact
Statement (DPEIS)
• This analysis is completed and is part
of the DPEIS
Environmental Analyses
• Programmatic Environmental
Impact Statement (DPEIS)
• ESA Consultation
• CZMA Consistency Determination
Draft Programmatic
Environmental Impact
Statement (DPEIS)
• Required under:
the National Environmental Policy Act
(NEPA)
• DPEIS consists of:
-Purpose and Need
-Range of Alternatives
Different Standards
-Affected Environment
-Environmental Consequences
DPEIS Approach
• Expert Panel Workshop:
-Comprised of NEPA Experts and
Biologists from the 5 cooperating
agencies
-Finish the DPEIS analysis and obtain
interagency team agreement
-Took place in May 2007 in Charleston,
SC.
DPEIS Status
• Incorporated interagency comments
in Summer 2007
• DPEIS is in CG clearance
• Anticipate publishing DPEIS in Winter
2007 and hold 3 Public Meetings to
solicit comments (WC, GL, DC)
• Incorporate comments into the NPRM
and publish soon thereafter, with
additional Public Meetings
Approving BWT
Technologies
• Must meet the BWD Standard
• Must ALSO meet Engineering and
Operational Requirements (46 CFR)
- Approval of Equipment and Materials
- Approval of Electrical Equipment
- Approval of Engineering Equipment
- Approval of Piping Equipment
Approving BWM Systems
• Type Approval of systems
– Rigorous land-based testing
– Shipboard qualification
• Consistent with existing USCG procedures
and BWM Convention
• Requires development of standard test
protocols
– Efficacy in killing/removing wide range of organisms
(bacteria – fish)
– Under wide range of water quality conditions (blue
water – turbid industrial estuaries – freshwater lakes)
– Under wide range of operating conditions (temp,
humidity, sea state)
EPA Environmental Technology
Verification
Program
Performance Verification of
Ballast Water Treatment Technologies
United States
Coast Guard
NSF International
6/28/2016
slides for sweden.ppt
Coastal Resource and
Environmental Management
16
ETV Tech Panel
Mechanical
Engineers
Naval Architects
Marine Engineer
Ocean
Engineers
Physical
Oceanographer
Microbiologist
ETV Program
Control
Marine
&
Biologists
Automation
Engineer
Independent
Instrumentation
Engineers Consultants
Research and Development
Ballast Water Treatment Test Facility at
NRL Key West
Test facility
operational
• EPA ETV
Protocols largely
validated
•
– Some
Improvements
Req’d
– Severn-Trent
system used in
validation
– Test Report in
Review
STEP
Shipboard Technology Evaluation Program
•
•
•
Intended to facilitate development of effective BW
treatment options
Available to all vessels, foreign and domestic, subject to
USCG regulations (33 CFR 151 Subparts C & D)
Currently reviewing 4 applications
– Significant delays in CG ability to process first 3 applications.
– Environmental Assessments (EAs) will be released soon for first
3 applications.
•
Currently assessing options to streamline and expand
program
– 3rd party review of applications and preparation of EAs?


Applicant expense
Applicant schedule
– Multiple vessels per application?


Increased complexity for EAs…
Distribution of test effort among vessels…
Ballast Water Management
Convention of 2004
Key provisions for U.S.:
• Phase out of BW Exchange
• BW discharge standard
– More protective than BWE, but not as stringent as many in
U.S. want
– Challenges to technology:


meet the standard
wide availability on the desired schedule
• Parties may implement more stringent
measures
• Parties may test discharges to confirm
compliance with the discharge standard
Ballast Water Management
Convention
• Entry into force: 12 months after
ratification by 30 member states
representing 35% of the world’s
merchant shipping tonnage
To date: Ratified by 10 states
representing 3.42% of shipping
tonnage
Guidelines supporting the
Convention
• Status
– 14 of 15 sets of guidelines adopted
– 1 remaining Guideline to be developed further
at BLG 12 (Feb 08)


Sampling (G2)
Divergence of Opinion
– Some Administrations and ship owners

Specify details of sample acquisition, analysis, and
interpretation
Average of samples to be below standard
– U.S. – How to get a sample


Analysis and interpretation left to Administration
No averaging required
Ballast Water Treatment System
Approvals
IMO Active Substance approvals under G9
• Paraclean Ocean System, proposed by Germany;
• Electro Clean System, proposed by the Republic of Korea;
• Special Pipe Ballast Water Management System combined
with ozone treatment, proposed by Japan;
• EctoSys. electrochemical System, proposed by Sweden;
• NK Ballast Water Treatment System, proposed by the
Republic of Korea; and
• PureBallast System, proposed by Norway and Sweden,
which was also given Final Approval.
– Type approval pends successful shipboard tests
Administration Type approvals under G8
• NEI – VOS deoxygenation system by Liberia
Recent and Upcoming Meetings
•
Assembly (November 19-30, 2007)
– Major BW decision


•
Resolution - Ships subject to Reg B-3.3 constructed in 2009 not required
to meet Regulation D-2 until 2nd annual survey,, but no later than 31
December, 2011.
Due to lack of “available” treatment systems; build contracts already in
place.
BLG 12 (February 4 - 8, 2007)
– Sampling Guideline (G2)
– Alignment of G8 and G9
– G9 (Approval of BWT systems using AS)




•
Human Exposure Scenario
Criteria to evaluate systems using same substance (me too)
GESAMP Methodology
Procedure for assessing “same level of protection” when evaluating
“other methods of BW management” under Regulation B-3.7
MEPC 57 (March 31 – April 4)
– Review Group – availability of BWT technology
– Applications for approval under G9 (7+)
– Outcome of BLG 12
Biofouling at IMO
• Biofouling management proposed as a
new work item for MEPC
• Australia, New Zealand, United Kingdom
proposal
• MEPC 56 agreed to proposal in July 2007.
• First phase will be a scoping effort to
determine the best approach for IMO to
take
– New convention
– Amend an existing convention


Ballast Water
Antifouling
– Guidelines
Next Steps
•
Publish and implement the BWD Standard Regulation to include
BWTS test protocols and BWTS approval process
•
Continue and refine STEP
•
Continue to engage actively at IMO
– Refine guidelines
– Address biofouling
– Exchange information on testing and approvals of technologies
•
Update existing BWM Reporting and Recordkeeping Regulations
and NOBOB requirements
•
Develop improved methods and technologies for assessing
compliance with BWD Standard
Further information on the U.S. Coast Guard’s
ANS Program can be found at:
http://www.uscg.mil/hq/g-m/mso/estandards.htm