## United States Environmental Protection Agency
Office of Wastewater Management Washington, DC 20460

EPA 800

‐ R

‐ 11

‐ 003
November 2011 

# Ballast Water Self MonitoringBallast Water Discharges from Vessels Contents



### i Contents

Page

1 I NTRODUCTION 

### .................................................................................................................... 1

1.1 What is Ballast Water? ............................................................................................ 1

1.2 Environmental Impacts of Ba llast Water Discharges ............................................. 2

1.3 Current Ballast Water Discharge Regulations ........................................................ 3

2 B ALLAST WATER 

### T REATMENT TECHNOLOGIES 

### .................................................................... 7

3 B ALLAST 

### W ATER 

### C OMPLIANCE 

### M ONITORING 

### ................................................................... 11

3.1 Physical-Chemical Indicators of Treatment Performance .................................... 11

3.2 Biological Indicators of Exceedances ................................................................... 17

3.3 Effluent Monitoring for Residual Biocides ........................................................... 18

3.4 Effluent Monitoring for Biocide Derivatives ........................................................ 22

3.5 Ballast Water Sampling Methods ......................................................................... 22

4 B ALLAST 

### W ATER 

### T REATMENT 

### M ONITORING 

### C OSTS 

### ......................................................... 23

5 R EFERENCES 

### ...................................................................................................................... 26Ballast Water Discharges from Vessels List of Tables



### ii LIST OF TABLES

Page

1 Select Ballast Water Discharge Standards for Organisms ...................................................4

2 Anticipated Ballast Water Treatment System Sensors and Measurement Equipment for Physical/Chemical Indicator Monitoring ...................................................12

3 List of Possible Treatment Performan ce Measures and Analytical Methods for Biological Indicator Compliance Monitoring ....................................................................17

4 Possible Biological Indicator Complian ce Monitoring Analytical Methods and

Effluent Limits ............................................................................................................... ....20

5 Residual Biocides Compliance Monito ring Sampling Analyt ical Methods and

Possible Action Levels .......................................................................................................2 1

6 Biocide Derivative Monitoring Analytical Methods .........................................................22

7 Estimated Capital Cost for Vessels Needing Additional Ballast Water Treatment System Monitoring Equipment ..........................................................................................23

8 Estimated Labor and Analytical Cost s for Ballast Water Treatment System Discharge Sampling ...........................................................................................................2 4

LIST OF FIGURES

Page

1 Generic Ballast Water Treatment Technology Options .......................................................7

The EPA technical contact for this do cument is Ryan Albert (202) 564-0763.Ballast Water Discharges from Vessels Section 1 - Introduction



### 1 

## SECTION 1

INTRODUCTION

The 2008 Vessel General Permit (VGP) regulates discharges incidental to the normal operation of vessels operating as a means of transportation. The VGP, like other general permits, is issued by the permitting authority (in this case , EPA) and covers multiple facilities within a specific category for a specific period of time (not to exceed 5 years). The 2008 VGP includes the following limits or requirements: general e ffluent limits; technology-based effluent limits applicable to 26 specific discharge streams; narrative water-quality based effluent limits; inspection, monitoring, recordkeep ing, and reporting requirements; and additional requirements applicable to certain vessel types (USEPA, 2010b).

Because EPA plans to reissue the VGP, the Agency continues gathering information on vessel wastewater sources while examining treat ment technologies that can be used before discharge into waters of the United States. 1 

### This document contains updated information on both recent developments in ballast water treatment technologies and the monitoring requirements to verify ballast water treatment sy stems are functioning properly.

1.1 W HAT IS 

### B ALLAST 

### W ATER 

### ?

Ballast water is fresh or saltwater held in th e ballast tanks and cargo holds of ships. It is used to provide stability and maneuverability during a voyage when ship s are not carrying cargo, not carrying heavy enough cargo, or when more st ability is required due to rough seas. Ballast water may also be used to add weight so that a ship sinks low enough in the water to pass under bridges and other structures. Ball ast water is taken from port areas and transported with the ship to the next port of call where the water may be discharged. If a ship is receiving or delivering cargo to a number of ports, it ma y release or take on a portion of ballast water at each port. In such cases, the ships ballast wa ter contains a mix of waters from multiple ports (MIT, 2002).

Large commercial vessels (e.g., container ship s, bulk carriers, other cargo vessels, tankers, and passenger vessels) normally have ballas t tanks dedicated to th is purpose, and some vessels may also ballast empty cargo holds. The di scharge volume varies by vessel type, ballast tank capacity, and type of deballasting equipmen t. Volumes of ballast water discharged are significant and can be several hundred or thousand cubic meters of water. For instance, passenger vessels have an average ballast cap acity of about 2,600 c ubic meters (about 686,850 gallons) while ultra large crude carriers (ULCCs) have an aver age ballast capacity of about 93,000 cubic meters (about 24,568,000 gallons) (USEPA , 2008). A modern tanker ship working

on the Great Lakes can contain as much as 53,000 cubic meters (14,000,000 gallons) (USEPA, 2001). Its estimated that tank vessels like ULCCs account for approximately 40 percent of all ballast water discharged, follo wed by bulk carriers and containe r ships. Passenger vessels account for only about 1 percent of ballast water discharges (Faulkner, 2009).

1 “Waters of the United States” as defined in 40 CFR 122.2.Ballast Water Discharges from Vessels Section 1 - Introduction



### 2 1.2 E NVIRONMENTAL 

### I MPACTS OF 

### B ALLAST 

### W ATER 

### D ISCHARGES



### Ballast water discharges have been cited as one of the primary sources or vectors for the spread of aquatic nuisance species (ANS) (Carlt on et al., 1995). The transfer of alien water species in ships ballast tanks at modern rates, sc ales and shipping routes facilitates very fast and practically global distribution of some speci es (Kasyan, 2010). Depending on where ships take on ballast water, virtually all organisms in the water column, either swimming or stirred up from bottom sediments, can be taken into ships’ ba llast tanks. These organi sms include holoplakton (free-floating), meroplakton (larval stages of bottom dwelling organisms), upper water column nekton (active swimming), and demersal (near bottom dwelling nekton) organisms (California EPA, 2002). Well known examples of ANS or pat hogens that have been introduced to U.S.

waters include Hydrilla , European Loosestrife, Eurasian wate r milfoil, melaluca, salt cedar, and Viral Hemorrhagic Septicemia (VHS).

One of the best known examples of ANS is the zebra mussel ( Dreissena polymorpha ),

which was introduced from the Black Sea to the Great Lakes in the mid-1980s and was discovered in California in 2008. This tiny striped mussel attaches to hard surfaces in dense populations that clog municipal water system s and electric generating plants, causing approximately $1 billion a year in damage and control for the Great La kes alone (California State Lands Commission, 2010) . In San Francisco Bay, the overbite clam ( Corbula amurensis ) is believed to be a major contributor to the dec line of several pelagic fish species in the Sacramento-San Joaquin River Delta by reduci ng the plankton food base of the ecosystem (California State Lands Comm ission, 2010). Because of the global shipping network, it is possible that new ANS could arrive from virt ually any port world-wide (Keller and Drake, 2011).

ANS can enter new aquatic environments when the vessel operator discharges ballast tanks. These organisms may also be released when vessel operators load ballast water into ballast tanks with residual water or sediment, mix the ne w ballast water with these residuals, and then later discharge this ballast water. On any gi ven day, approximately 7,000 individual species may be “in motion” in ballast tanks (Carlton, 2001). There is no evidence that ship age, seasonal timing, or age of ballast water affects the abundance of individuals or specie s in the ballast tanks (Drake and Lodge, 2007).

When ANS in ballast tanks are transported between water bodies and discharged, they have the potential for establishing new, non-indi genous populations that ha ve the potential to cause physical and behavioral disturbances to native organisms, out competing them for food, space and other valuable resources (Hayes and Landis, 2004). Although pelagic marine systems appear to be least susceptible to invasion by ANS, mixed island sy stems and lake, river and nearshore marine systems are especially vulnera ble (Deines et al., 2005 and Perings, 2002). Potentially, this can cause severe economic and ecological damage (Lodge and Finnoff, 2008 and Lovell and Drake, 2009). Associated damages a nd costs of controlling aquatic invaders in the United States are estimated to be $9 billi on annually (Pennsylvania Sea Grant, 2003). The spread of ANS can be mitigated if either their introducti on to the receiving water is prevented, or if the ANS cannot establish a population.Ballast Water Discharges from Vessels Section 1 - Introduction



### 3 1.3 C URRENT 

### B ALLAST 

### W ATER 

### D ISCHARGE 

### R EGULATIONS



### A thorough evaluation of the availability of ba llast water treatment technologies requires an understanding of the regulatory framework associated with the development and implementation of performance standards for the discharge of ballast wa ter, including knowledge of mechanisms for the testing a nd evaluation of treatment systems to meet those standards. This

section summarizes the ballast wa ter regulations currently in e ffect. A more robust regulatory analysis of the current ballast water regulations is available in the Science Advisory Board’s Background and Issue Paper on the Availability and Efficacy of Ballast Water Treatment Technologies (Albert et al., 2010).

At the international level, ballast water discharges from vessels are primarily addressed under provisions established thr ough the auspices of the Intern ational Maritime Organization (IMO). Beginning in 1991, the IMO, which is th e principal UN body that addresses pollution from ships, adopted a series of resolutions cont aining recommended practices to help prevent the introduction of ANS by ballast water. The curre nt resolution was adopted in 1997 and contains guidelines calling for mid-ocean ballast wate r exchange (BWE) and other ballast water management practices.

Following adoption of the resolution, a ba llast water working group was regularly convened as part of the meetings of the IMO’s Marine Environment Protection Committee (“MEPC”), with a charge of developing lega lly binding requirements for a ballast water management treaty. Over the course of these m eetings, there was a gradual evolution away from reliance on BWE as the primary control mechan ism to one requiring co mpliance with ballast water discharge standards stated in the form of concentrations of organi sms per unit of volume of ballast water discharged. The culm ination of this effort was a Diplomatic Conference held at IMO, which adopted the International Conventio n for the Control and Management of Ships’ Ballast Water and Sediments in February 2004. Among its provisions, the Convention contains performance standards for the discharge of ballast water (Regulation D-2) with an associated implementation schedule based on vessel ballast water capacity and date of construction (see Table 1). During development of the 2004 Conven tion, the U.S. took a negotiating position that the discharge standards for the two larger size groupings of organisms in the D-2 regulation should be 1,000 times more stringent than adopted (see Table 1). As of November 30, 2011, the 2004 Convention is not in force, nor is the U.S. a party.

At the federal level, there are two principa l statutes of interest : (1) the Nonindigenous Aquatic Nuisance Prevention and Control Ac t, as amended (“NANPCA,” 16 U.S.C. §§ 4701 et

seq. ); and (2) the Federal Water Po llution Control Act (commonly refe rred to as the Clean Water Act or “CWA,” 33 U.S.C. §§ 1251 et seq. ). The principal ballast water management requirements under NANPCA and the applicable VGP requirements that implement the Clean Water Act presently rely on use of BWE. However, since ballast water exch ange is of variable effectiveness and cannot always be carried out due to safety concerns, effo rts are underway at the federal level to develop a regulatory regime that will phase out use of exchange in favor of treatment to meet a ballast water discharge standard specified in terms of concentrations of living organisms per unit of volume of ballast wa ter discharged. The USCG issued proposed regulations in August, 2009 containing such stan dards, and these USCG proposed Phase I and

Phase II standards are shown in Table 1.Ballast Water Discharges from Vessels Section 1 - Introduction



### 4 Both NANPCA and the CWA preserve state auth ority to more stringently regulate ballast water discharges that occur in state waters. At the state level, regul ation of ballast water discharges varies, as shown in Table 1.

Table 1. Select Ballast Water Discharge Standards for Organisms

Regulation Organism

Size: ≥ 50

(μm)* Organism

Size: < 50μm, but

≥ 10 μm Bacteria Viruses Lakers

Covered?** Compliance Date

IMO BW

T REATY (Reg. D-2) < 10
“viable” organisms

per m 3 < 10
“viable” organisms

per ml Vibrio cholera < 1 CFU per 100 ml;

E. coli < 250 CFU per

100 ml; Intestinal

enterococci < 100 CFU per 100 ml ---- N/A 2009 – 2019 (varies by vessel
construction date/BW capacity/survey date

as per Reg B-3)

US

N EGOTIATING

P OSITION < 0.01 “living” organisms

per m 3 < 0.01 “living” organisms

per ml Vibrio cholera < 1 CFU per 100 ml;

E. coli < 126 CFU per

100 ml; Intestinal

enterococci < 33 CFU per 100 ml ---- N/A ASAP

USCG

P ROPOSED
R ULE (74 FR 44632) P HASE 1 S TANDARD
< 10 organisms

per m 3 < 10 organisms

per ml Vibrio cholera < 1 CFU per 100 ml;

E. coli < 250 CFU per

100 ml; Intestinal

enterococci < 100 CFU per 100 ml ---- Yes Vessels constructed on or after 01/01/12 on delivery; All other

vessels varies by BW capacity & drydock

cycle with latest compliance date of

1st drydock after
01/01/16

P HASE 2 S TANDARD < 1 organism per 100 m 3 < 1 organism per 100 ml Vibrio cholera < 1 CFU per 100 ml;

E. coli < 126 CFU per

100 ml; Intestinal

enterococci < 33 CFU per 100 ml

< 10 3 “living” bacterial cells per 100 ml < 10 4

viruses

or virallike particles per 100

ml Yes Vessels constructed on or after 01/01/16 on delivery; All other

vessels 1st drydocking after 01/01/2016, unless prior installation of Phase 1 BW system, in which case 5 years
from such installation

California (VGP 401

cert) I NTERIM S TANDARD 0 detectable

“living” organisms US negotiating

position Vibrio cholera IMO Reg D-2; E. coli US negotiating position;

Intestinal enterococci US

negotiating position <

10 3 bacteria per 100 ml < 10 4

viruses per 100

ml N/A 01/01/10 – 01/01/16 (varies by vessel

construction date/BW capacity)

F INAL S TANDARD 0 detectable

“living” organisms 0 detectable “living” organisms 0 detectable “living” organisms 0
detectable “living” organisms N/A 01/01/2020Ballast Water Discharges from Vessels Section 1 - Introduction



### 5 Table 1. Select Ballast Water Discharge Standards for Organisms

Regulation Organism

Size: ≥ 50

(μm)* Organism

Size: < 50μm, but

≥ 10 μm Bacteria Viruses Lakers

Covered?** Compliance Date

Illinois (VGP 401

cert) IMO Reg D2 (as daily average) IMO Reg D2 (as daily average) Vibrio cholera; a E. coli IMO Reg D-2 (as daily

average); Intestinal

enterococci IMO Reg D2 (as daily average) ---- Yes Vessels constructed before 01/01/12 01/01/16; Vessels constructed after

01/01/12 prior to operation

Indiana (VGP 401

cert) IMO Reg D2 b (as daily

average) IMO Reg D2 b (as daily

average) Vibrio cholera a ; E. coli IMO Reg D-2 (as daily average); Intestinal

enterococci IMO Reg D2 (as daily average) ---- No Vessels constructed before 01/01/12 01/01/16; Vessels constructed after

01/01/12 prior to operation Michigan (VGP 401

cert) Use a

treatment

process approved by

MI DEQ Use a

treatment

process approved by

MI DEQ Use a treatment process approved by MI DEQ Use a

treatment

process approved

by MI DEQ No 01/01/07

Minnesota (VGP 401

cert) IMO Reg D2 b (as daily

average) IMO Reg D2 b (as daily

average) Vibrio cholera a ; E. coli IMO Reg D-2 (as daily

average); Intestinal

enterococci IMO Reg D2 (as daily average) --- Yes Vessels sonstructed before 01/01/12 01/01/16; Vessels constructed after

01/01/12 prior to operation

New York (VGP 401

cert) I NTERIM S TANDARD < 1 “living” organism per

10 m 3 < 1 “living” organism per

10 ml Vibrio cholera IMO Reg D-2;

E. coli US negotiating

position; Intestinal

enterococci US negotiating position ---- Yes (vessels operating exclusively
within Lakes

Ontario and

Erie are exempt) 01/01/12 (extended to August 1, 2013 in subsequent state action)

F INAL S TANDARD
Same as CA

#s US negotiating

position Vibrio cholera IMO Reg D-2;

E. coli US negotiating

position; Intestinal

enterococci US negotiating position;

Other bacteria CA

interim standard Same as

CA
interim

#s Yes (vessels operating exclusively

within Lakes
Ontario and

Erie are exempt) Vessels constructed

on or after 01/01/13 (extended to August 1, 2013 in subsequent State action)

Ohio (VGP 401

cert) IMO Reg D2 b (as daily

average) IMO Reg D2 b (as daily

average) Vibrio cholera a ; E. coli IMO Reg D-2 (as daily

average); Intestinal

enterococci IMO Reg D2 (as daily average) --- Yes (in part --
see column to right) Lakers “launched” after 01/01/16 immediate; NonLakers “launched”

before 01/01/12 01/01/16; NonLakers “launched” after 01/01/12 prior to operationBallast Water Discharges from Vessels Section 1 - Introduction



### 6 Table 1. Select Ballast Water Discharge Standards for Organisms

Regulation Organism

Size: ≥ 50

(μm)* Organism

Size: < 50μm, but

≥ 10 μm Bacteria Viruses Lakers

Covered?** Compliance Date

Wisconsin (11/18/09 State Permit) IMO Reg D2 (as daily average) IMO Reg D2 (as daily average) Vibrio cholera a ; E. coli IMO Reg D-2 (as daily average); Intestinal

enterococci IMO Reg D2 (as daily average) ---- No c Vessels constructed after 01/01/12 d

i mmediate; Vessels constructed before

01/01/12 d 01/01/14

Source: Modified from Albert et al., 2010. * For some standards, groupings are stat ed as organisms > 50 μm and organisms ≤ 50 μm but > 10 μm. For sake of simplicity, this table uses the IMO groupings throughout as the default column header. ** “Lakers” are vessels which generally vo yage exclusively in the Great Lakes. a Indicator microbes specified by State do not include Vibrio cholera

. b State has defined “viable” as living and able to reproduce. In contrast, IMO G8 (type approval) Guidelines (para 3.12) define viable as living. c Standards apply to oceangoing vessels only. However, WI permit does provide that La kers shall implement BMPs as specified in § 2.2.3 of EPA’s 2008 VGP (uptake and discharge practices). d WI DNR conducted a review to determine if BWT technology wa s available to meet WI standards more stringent than those finalized in 2009; that review concluded such BWT technology was not available and therefore, Wisconsin instead determined that the IMO Reg D-2 standards appl ied (subject to footnotes a & b). ASAP – As soon as possible.
BW – Ballast water.

CA – California. N/A – Not applicable.Ballast Water Discharges from Vessels Section 2 - Ballast Water Treatment Technologies



### 7 

## SECTION 2

BALLAST WATER TREATMENT TECHNOLOGIES

Two general platform types have been explored for the development of ballast water treatment technologies. Shore-side ballast water treatment would o ccur at a barge- or land-based facility following transfer from a vessel; to date, such shore side treatment facilities for ANS in ships’ ballast water do not exis t at U.S. ports. Shipboard treatment occurs onboard vessels through the use of technologies th at are integrated into the ballasting system; a number of such systems have been developed or are in devel opment. The remaining discussions in this document address such shipboard treatment systems.

To be effective, ballast water treatment systems must operate under a wide range of challenging environmental conditions, including va riable temperature, sa linity, nutrients and suspended solids. They must also function under difficult operational cons traints, including high flow-rates of ballast water pumps, large water volu mes, and variable retention times (time ballast water is held in tanks). Treatment systems shoul d be capable of eradicating a wide variety of organisms ranging from viruses a nd microscopic bacteria, to fr ee-swimming plankton, and must operate so as to minimize or prevent impairment of the water quality cond itions of the receiving waters. The development of effective treatment sy stems is further complicated by the variability of vessel types, shipping routes and port geogr aphy (California State Lands Commission, 2010).

Most vessel owner/operators treating ballast water have indicated that they will select shipboard ballast water treatment systems. Treatment systems generally include physical separation, biocidal treatment, and physical-c hemical processes (Alber t et al., 2010). Most commercial systems comprise two stages of trea tment with a physical solids-liquid separation followed by biocidal disinfection as show n in Figure 1 (Lloyds Register, 2010).

Source: Lloyds Register, 2010.



### Figure 1. Generic Ballast Water Treatment Technology OptionsBallast Water Discharges from Vessels Section 2 - Ballast Water Treatment Technologies



### 8 Different treatment processes are more eff ective for certain types or size classes of organisms. Larger size classes of organisms typica lly require a filtr ation system or other physical process to limit their intake into the ships ball ast tanks; however, smaller size classes of living organisms typically require additi onal chemical, physical or heat treatment to kill organisms that bypass the filtration system (Prince William Sound Regional Advisory Council, 2005).

The filtration processes used in ballast water treatment systems are generally of the automatic backwashing type using either discs or fixed screens. Removal of larger organisms such as plankton by filtration requires a filter of equivalent mesh size between 10 and 50 μm. Such filters are the most widely used solid-liquid separation process employed in ballast water treatment, and their effective operation relates ma inly to the flow capacity attained at a given operating pressure. Maintaining th e flow normally requires that th e filter is re gularly cleaned, and it is the balance between flow, operating pressu re and cleaning frequency that determines the efficacy of the filtration process. In principle, surface filtration (membrane filtration) can remove sub micron (i.e., less than 1μm in size) micro-orga nisms; however, such processes are not viable for ballast water treatment due to the relatively low permeability of the membrane material (Lloyds Register, 2010).

Hydrocyclone technology is used as an alternative to filtration. This technology provides enhanced sedimentation by injec ting the water at high velocity to impart a rotational motion which creates a centrifugal force, increasing the velocity of particles relative to the water, allowing them to be separate d and removed. The effectivenes s of the separation depends upon the difference in density of the particle and the surrounding water, the partic le size, the speed of

rotation and residence time.

A number of different chemical biocides or chemical processes have been employed in the ballast water treatment systems for disinfection including:

 

### Chlorination

 

### Electrochlorination

 

### Ozonation

 

### Chlorine dioxide

 

### Peracetic acid

 

### Hydrogen peroxide

 

### Menadione/Vitamin K

The efficacy of these processes varies by wa ter conditions such as pH, temperature and, most significantly, the type of organism. While relatively inexpensive, chlorine is a highly effective disinfectant for most organisms, but is virtually ineffective against cysts unless concentrations of at least 2 mg/l are used (Lloyds Register, 2010). Chlorine also reacts to form undesirable chlorinated byproducts, particularly chlorinated hydrocarbons and trihalomethanes. Ozone yields far fewer harmful byproducts, the most prominent being bromate, but requires relatively complex equipment to both produce ozone and dissolve it into the water. Chlorine dioxide is normally produced in situ, although this pres ents a challenge since the reagents used are themselves chemically hazardous. Peracetic aci d and hydrogen peroxide (provided as a blend of the two chemicals in the form of the proprieta ry product Peraclean®) are infinitely soluble in water, produce few harmful byproducts and are relatively stable. However Peraclean® isBallast Water Discharges from Vessels Section 2 - Ballast Water Treatment Technologies



### 9 relatively expensive, is dosed at quite high levels, has been do cumented to have unacceptable toxicity in cold waters, and require s considerable storage facilities.

For all these chemicals, pre-treatment of the water using solid- liquid separation (i.e., filtration or hydrocyclones) is de sirable to reduce the ‘demand’ on the disinfectant, because the chemical can also react with organic and other ma terials in the ballast water. In addition, while chemical biocides may be effective for disinfect ion of organisms in the water column, they may be relatively ineffective in disinfecting species bu ried in sediment in ba llast tanks, especially invertebrates in resting stages (Raikow and Rei d, 2006). Vessel owners/operators should consult with technology vendors to ensure the selected system is appropria te for the vessel of interest under normal ballasting conditions (Dobroski et al., 2009).

According to EPA’s Science Advisory Bo ard (USEPA, 2011a), five ballast water management system types (listed below) have be en demonstrated to meet the IMO D-2 discharge standard, when tested under th e International Maritime Organi zation G8 guidelines (IMO, 2008), and will likely meet USCG Phase 1 standard s, if tested under EPA’s more detailed Environmental Technology Verifica tion (ETV) Protocol (USEPA, 2010a). 2 

### No current ballast water treatment technologies are demonstrated to meet standards more stringent than IMO D2/Phase 1 (USEPA, 2011a).

 

### Deoxygenation + cavitation;

 

### Filtration + chlorine dioxide;

 

### Filtration + UV;

 

### Filtration + UV + TiO 2 

### ; and

 

### Filtration + electro-chlorination.

Deoxygenation is a physical-chemical process that kills organisms by creating severe hypoxia (through lowered pressure via venturi or v acuum, or lowered partial pressure via gas sparging with inert gasses). Cavitation is a physic al-chemical process that kills organisms by the high pressure, shear forces, and shock waves gene rated by the collapse of vapor bubbles induced

into the ballast water. Filtration describes a va riety of physical separation processes, including screening to remove sediment a nd larger organisms resistant to disinfection, reduction of organic matter to reduce oxidant demand, and reduction of turbidity to increase transmittance of UV

radiation. Chlorine dioxide and electro-chlorinat ion are biocidal technol ogies that disinfect ballast water using the chemical disinfectants chlo rine dioxide and chlorine ; chlorine is generated by electrolytic processes using s ea water as the source of ions. UV is a physical-chemical process

that disinfects ballast water using photochemical reactions generated by ultraviolet light
radiation. In the UV + TiO 2 

### physical-chemical process, UV light also activates the surface of the titanium catalytic semiconductor, disinfecting ballast water using both photochemical and photocatalytic reacti ons (USEPA, 2011a).

2 Of the 15 individual ballast water treatment systems for which information was provided, the Panel concluded that nine ballast water treatment systems had reliable data for an assessment of performance and that five categories of ballast water treatment systems had been evaluated with sufficient rigor to permit a credible assessment of performance capabilities. (Source: USEP A, Science Advisory Board (SAB), Ecological Processes and Effects Committee, Efficacy of Ballast Water Treat ment Systems, June 2011). This lis t does not exclude other technologies that may provide similar treatment results but were not evaluated by the panel due to lack of available data.Ballast Water Discharges from Vessels Section 2 - Ballast Water Treatment Technologies



### 10 While ballast water treatment technologies reduce the probability of invasion of ANS, such treatment may introduce other water quality im pacts, such as toxicity. For example, the addition or in-process generation of disinfecting ch emicals may result in an effluent with some residual toxicity. Depending on the predicted or m easured oxidant levels in the ballast water, a chemical neutralizing agent may need to be app lied before ballast water discharge to comply

with effluent limitati ons (USEPA, 2011a).Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring



### 11 

## SECTION 3

BALLAST WATER COMPLIANCE MONITORING

Ballast water treatment systems are designed to reduce the number of living organisms discharged in ballast water. Such reductions in these organisms will help reduce the risk of ANS establishing viable populations in new water bodies. To ensure th e treatment systems are being operated properly once installed on a vessel, sample s of ballast water effluent can be collected and analyzed, and specific treatment system operati ng parameters can be m onitored, to indirectly verify the treatment system is achieving the in tended effluent levels on an ongoing basis.

Measures of treatment performance for balla st water systems can include a variety of techniques ranging from collection of ballast wa ter effluent samples for analysis of target organisms to monitoring operational parameters fo r the treatment technologies to verify they are within predetermined limits. Monitoring system s may also include features that provide automated operation and alarms, plus reporting and data logging to ensure treatment systems are continuously operating according to the manufacture r’s specifications (Hurley et al., 2001). The three categories of comp liance monitoring are:

 

### Physical/chemical indicators of treatment performance;

 

### Biological indicators of exceedances; and

 

### Effluent monitoring for residual bi ocides and biocide derivatives.

3.1 P HYSICAL 

### -C HEMICAL 

### I NDICATORS OF 

### T REATMENT 

### P ERFORMANCE



### Physical/chemical indicators of treatment pe rformance can be used to verify that the ballast water treatment system is operating accord ing to the manufacturer s’ requirements. Most ballast water treatment systems have control and self diagnostic equipment such as sensors that continuously measure treatment parameters to verify performance (Tamburri, 2011). Sensors commonly incorporated into the most frequently installed systems incl ude flow meters, pH sensors, dissolved oxygen sensors, OPR and ampero metric (TRO) sensors, and on-line chlorine analyzers (Tamburri, 2011). All of these meters a nd sensors have broad a pplication in the water and wastewater treatment industry and are ava ilable off-the-shelf from many major equipment suppliers. Other ballast water treatment systems are provided with testing meters or kits, such as portable chlorine and dissolved ozone monitors, to verify adequate levels of treatment chemicals are being maintained within the ballast tanks. Ve ssel operators can monitor and record this data and make adjustments, maintenance, or repairs to the ballast water treatment system to ensure the equipment is functioning properly. Table 2 prov ides the anticipated control equipment and potential monitoring and reporting metrics for physical/chemical indicators by treatment technology.Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring12Table 2. Potential Ballast Water Treatment System Sensorsand Measurement Equipment for Physical/Chemical IndicatorMonitoringTechnology TypeMeasurementPotential Control Sensor,Equipment, or ProcedurePossible ComplianceMonitoringPossible Metrics to beReportedAlkylamines pH pH sensor pH pH readingsAlkylamines Chemical analysis andtreatment monitoring-Alkylamines concentration atinjection-Alkylamines dosage andusage-Alkylamines sampleconcentration-Alkylamines dosage andusageBioremediation Treatment chemical Chemical analysis andtreatment monitoring-Treatment chemicalconcentration at injection-Treatment chemical dosageand usage-Treatment chemical sampleconcentration-Treatment chemical dosageand usageCavitation Acoustic Passive acoustic sensor oracoustic interferometryAcoustic Acoustic readingsPressure Pressure sensors (before/after) Pressure Pressure readingsChlorination:electrochlorination orchlorine addition (e.g.,hypochlorite or chlorinedioxide)Oxidation reduction potential(ORP)ORP sensor ORP at injection OPR readingsTotal residual oxidizers(TRO)Amperometric sensor TRO at injection TRO readingsChlorine On-line N,N diethyl-pphenylenediamine (DPD) sensor, sampleanalysis, and treatmentmonitoring-Chlorine concentration atinjection-Chlorine dosage and usage (ifchlorine addition)-Chlorine readings from bothon-line sensor and sampleanalysis-Chlorine dosage and usage (ifchlorine addition)Chlorine Dioxide On-line chlorine dioxideamperometric sensor,Lissamine Green B (LGB)sample analysis, and treatmentmonitoring-Chlorine dioxideconcentration at injectionChlorine dosage and usage (ifchlorine addition)-Chlorine dioxide readingsfrom both on-line sensor andsample analysisChlorine dioxide dosage andusage (if chlorine addition)Power consumption, voltageand currentSystem power diagnosticsConductivity/salinity Conductivity and temperaturesensorConductivity and temperatureat injectionConductivity/salinity andtemperature readingsColored dissolved organicmatter (CDOM)Fluorometer (before/after)Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring13Table 2. Potential Ballast Water Treatment System Sensorsand Measurement Equipment for Physical/Chemical IndicatorMonitoringTechnology TypeMeasurementPotential Control Sensor,Equipment, or ProcedurePossible ComplianceMonitoringPossible Metrics to beReportedCoagulation (flocculent) Coagulant Chemical analysis andtreatment monitoring-Treatment chemicalconcentration at injection-Treatment chemical dosageand usage- Treatment chemical sampleconcentration-Treatment chemical dosageand usageTurbidity Turbidity sensor Coagulation effluent turbidity Coagulation effluent turbiditiesDeoxygenation Dose of inert gas (if used) Treatment monitoring Deoxygenation gas dosage andusageDeoxygenation gas dosage andusagepH (if CO2used) pH sensor pH pH readingsDissolved Oxygen (DO) DO sensor Deoxygenation moduledissolved oxygenconcentrationDissolved oxygenconcentrationsElectric pulse Power consumption, voltageand currentSystem power diagnostics Electric pulse module powerconsumption, voltage andcurrentElectric pulse module powerconsumption, voltage andcurrent readingsFiltration Water clarity Sight glass, water sample,turbidity sensor,transmissometerFilter effluent clarity Clarity readingsFlow rate Flow meter Filter effluent flow Flow readingsPressure Pressure sensors(before/after) Filter pressures (before/after) Filter pressures (before/after)Back flush frequency Treatment monitoring Filter backwash frequency Filter backwash frequenciesHeat Temperature Thermistors Treatmenttemperature Temperature readingsHydrocyclone Water clarity Sight glass, water sample,turbidity sensor,transmissometersHydrocyclone effluent clarity Clarity readingsBack flush frequency Treatment monitoring Hydrocyclone back flushfrequencyHydrocyclone back flushfrequenciesPower consumption, voltageand currentSystem power diagnostics Hydrocyclone powerconsumption, voltage andcurrentHydrocyclone powerconsumption, voltage andcurrentMenadione/Vitamin K Menadione Chemical analysis andtreatment monitoring-Menadione/Vitamin Kconcentration at injection-Menadione/Vitamin K dosageand usage-Menadione/Vitamin Kconcentration at injection-Menadione/Vitamin K dosageand usageBallast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring14Table 2. Potential Ballast Water Treatment System Sensorsand Measurement Equipment for Physical/Chemical IndicatorMonitoringTechnology TypeMeasurementPotential Control Sensor,Equipment, or ProcedurePossible ComplianceMonitoringPossible Metrics to beReportedOzone ORP ORP sensor ORP at ozone injection OPR readingsTRO Amperometric sensor TRO at ozone injection TRO readingsOzone On-line ozone sensor (if used)and sample analysisOzone concentration atinjectionOzone readings from both online sensor (if used) andsample analysisBromate Sample analysis Bromate atozone injection Bromate measurementsPower consumption, voltageand currentSystem power diagnosticsConductivity/salinity Conductivity and temperaturesensorConductivity and temperatureat injectionConductivity/salinity andtemperature readingsCDOM Fluorometer (before/after)Peracetic acid Hydrogen peroxide On-line sensor, chemicalanalysis, treatment monitoring-Hydrogen peroxideconcentration at injection-Hydrogen peroxide dosageand usage-Hydrogen peroxide readingsfrom both on-line sensor andsample analysis-Hydrogen peroxide dosageand usagePeracetic acid On-line sensor, chemicalanalysis, treatment monitoring-Peracetic acid concentrationat injection-Peracetic acid dosage andusage-Peracetic acid readings fromboth on-line sensor and sampleanalysis-Peracetic acid dosage andusagepH pH sensor pH at injection pH readingsCDOM Fluorometers (before/after)Plasma pulse Power consumption, voltageand currentSystem power diagnostics Plasma pulse module powerconsumption, voltage andcurrentPlasma pulse module powerconsumption, voltage andcurrent readingsTemperature Thermistors Treatmenttemperature Temperature readingsShear Acoustic Passive acoustic sensor oracoustic interferometryAcoustic Acoustic readingsPressure Pressure sensors (before/after) Pressure Pressure readingsBallast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring15Table 2. Potential Ballast Water Treatment System Sensorsand Measurement Equipment for Physical/Chemical IndicatorMonitoringTechnology TypeMeasurementPotential Control Sensor,Equipment, or ProcedurePossible ComplianceMonitoringPossible Metrics to beReportedUltrasound Power consumption, voltageand currentSystem power diagnostics Ultrasound powerconsumption, voltage andcurrentUltrasound module powerconsumption, voltage andcurrent readingsAcoustic Passive acoustic sensor oracoustic interferometryAcoustic Acoustic readingsUV and UV+TiO2Power consumption, voltageand currentSystem power diagnostics UV module powerconsumption, voltage andcurrentUV module powerconsumption, voltage andcurrentLamp status and age Treatment monitoring UV lamp status and ageUV dose, intensity,transmittanceUV sensors and monitors UV dose, intensity,transmittanceUV dose, intensity,transmittanceFlow rate Flow meter UV effluent flow Flow readingsCDOM CDOM fluorometerSource: Adapted from USCG, Proceedings of Ballast Water Discharge Standards Compliance Subject Matter Expert (SME) Workshop, August 2011.Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring



### 16 Treatment Equipment Inspection and Maintenance

Ballast water treatment systems are designed and manufactured with various sensors and other control equipment to automatically monitor and adjust system operating conditions to ensure proper operation and to al ert vessel personnel when interven tion, maintenance, or repair is required. Sensors and other control equipment, interfaced to monitoring equipment to record operating parameters, also help vessel operators determine data trends while providing a mechanism for EPA to verify continuous complia nce. The vendor’s Operating and Maintenance Manual typically specifies the ap plicable sensors and other cont rol equipment for the ballast water treatment system, what constitutes a range of stable operating conditions for the system, factors that may affect operating conditions, and any adjustments requ ired to reach or to maintain stable operating conditions (USEPA, 2010a). System monitoring and recording is expected to be continuous during discharge.

When alarms are initiated, or when sensors indicate the ballast water treatment system is not functioning properly, adhere nce with effluent limitations cannot be assured. To ensure effluent quality, consistent with vessel and crew safety, vesse ls should not discharge ballast water during alarm or upset conditions and shoul d resume discharge only after correcting the problems with the system and reesta blishing stable operating conditions.

Routine maintenance of the ballast wate r treatment system and troubleshooting procedures are typically defined in the syst em’s Operating and Maintenance Manual kept

onboard the vessel. All maintenan ce activities related to the ballast water monitoring system and overboard discharge control unit can be recorded and the inform ation can be retained on board for inspection purposes. In addition, vessel staff training could include familiarization with the operation and maintenance of th e ballast water overboard disc harge control and monitoring equipment. Ballast water treatment systems coul d be inspected on a monthly basis to determine both short-term and long-term maintenance needs as specified in the vendor’s Operating and

Maintenance Manual.

Monitoring Equipment Calibration

All applicable sensors and other control e quipment could be calibrated when warranted based on device drift and as recommended by sensor and equipment manufacturers, or by ballast water treatment system manufactur ers. Due to the operating characte ristics of sensors and control equipment, many sensor types (e.g., pH probes) ma y need to be calibrated on a more frequent

basis to correct for instrument drift and ensure the measurement system is functioning properly. Calibration of the sensors and equipment could be conducted on-board the vessel, or the sensors and equipment could be removed and shipped to the manufacturer fo r calibration. During the period when the sensors are not in stalled and operating on the ballast water treatment system, the vessel should not discharge ballast water.

Ballast water treatment systems that are equipped with automated control systems that initiate a sequence to stop the overboard discharge of the effluent in alarm conditions could be subjected to an annual functional test to verify they are workin g correctly. The detailed program

for a functional test of such equipment would typically be developed by the manufacturer, taking

into account the features and f unctions of the specific design of the equipment and the operatingBallast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring



### 17 and discharge conditions monitore d. A copy of the functional test protocol could be carried

onboard the vessel at all times so that functional testing can be conducted any time it is suspected the system is not operating as designed.

3.2 B IOLOGICAL 

### I NDICATORS OF 

### E XCEEDANCES



### Biological indicators of treatment performa nce are estimates of the number of living organisms or biomass in the ballast water effluent following treatment, regardless of species. The intent of biological indicator monitoring is to measure the number of living organisms or

biomass in a small volume of treated ballast wate r. If there are signif icant levels of living organisms or biomass in a small volume of ballast water, then the ballast water treatment system is likely ineffective and monitori ng large volumes of treated ballast water to enumerate specific organism numbers is of little value. Table 3 lists possible treatment performance measures for biological indicators compliance m onitoring that could serve as in direct measurements of the numbers of living organisms remaining in ballast water following treatment.

Table 3. List of Possible Treatment Perf ormance Measures and Analytical Methods for Biological Indicator Compliance Monitoring

Analyte Measurement Instrument or Analysis EPA

Method Standard

Method ASTM ISO Other

Biomass

Estimates Adenosine triphosphate (ATP) ATP firefly(luciferinluciferase)
method ASTM

D4012 –

81

Chlorophyll
fluorescence Chlorophyll
fluorometer Method

445.0 SM 10200

H ASTM

D3731 –

87

Live Organisms,

10-50 um Chlorophyll

fluorescence Chlorophyll

fluorometer Method

445.0 SM 10200

H ASTM

D3731 –

87

Bacteria Total heterotrophic
bacteria Plate counts SM 9215 ASTM

D5465 ISO

6222:1999

E. coli Selective
substrate EPA
Method

1103.1
and 1603 SM 9223B ASTM

D5392 –

93 ISO 9308-

1:2000 Colilert ®

Enterococci Selective

substrate EPA
Method

1106.1
and 1600 SM 9230C ASTM

D5259 – 92(2006) ISO 7899-

2:2000 Enterolert ®

V. cholerae (toxigenic) Colorimetric immunoassay
kits SM 9260



### As indicated in Table 3, only E. coli and enterococci have approved EPA analytical methods. Analytical methods for ATP, total live bacteria and V. cholera are available from Standard Methods, ASTM, or ISO.Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring



### 18 Care should be taken when collecting ballast water samples to enumerate living organisms. For example, sample volumes as large as 6,000 liters are necessary to measure organisms between 10 and 50 microns at levels as low as 0.01 individuals per milliliter (USEPA, 2010a). Due to the large sample volumes required for analysis and the anticipated costs when enumerating large organisms, self monitoring by counting large classes of living organisms of ballast water could be expensive, and it coul d be challenging to find sufficient numbers of qualified scientists and laboratories. For more in formation about the state of science enumerating living organisms in ballast water, see USEPA, 2010a or USEPA, 2011a.

Sampling for Exceedance

Biological indicator compliance monitoring samp ling is intended to verify the treatment system is operating properly by collecting a small volume sample and analyzing the sample for

concentrations of certain indicator parameters. Analysis of co ncentrations of indicator organisms

should include at least E. coli and enterococci bacteria as thes e tests are cost effective and the methods are well developed. Biological indicato r compliance monitoring sampling of ballast water effluent should be conducted over multiple sampling events to verify the system is operating properly. Vessels that enter U.S. wa ters on only a limited basis (e.g., one time per year), should conduct ballast wa ter effluent monitoring within the previous three months and upon discharge into U.S. waters. Table 4 list s possible biological indicator compliance monitoring sampling analytical methods and the le vels of indicator organisms (IMO, 2008) for

treated ballast water. Vessel ow ners/operators could also samp le and analyze ballast water discharges for other performance measur es previously listed in Table 3.

If any of the biological indicat or compliance monitoring efflue nt limits is exceeded, this is a clear indicator that the system is not meeting its discharge limits.

3.3 E FFLUENT 

### M ONITORING FOR 

### R ESIDUAL 

### B IOCIDES



### Some ballast water treatment systems generate or use biocides (e.g., ch lorine dioxide) to reduce living organisms present in the ballast water tank. In the 2008 VGP, EPA required that any ballast water technology must not use any biocid e that is a “pesticide” within the meaning of the Federal Insecticide, Fungicide, Rodenticide Ac t unless that biocide ha s been registered for

use in ballast water treatment under such Act. A dditionally, EPA required that vessels that used active substances must conduct additional monitoring as conditions of that permit (see Part 5.8 of the 2008 VGP) (USEPA, 2010b).

To assure that vessels are not discharging harmful quantities of active substances, for those vessels which have ballast water treatment sy stems that either add or generate biocides for treatment (e.g., chlorine, chlorine dioxide, ozone , etc.), the vessel should conduct monitoring of the vessel ballast water discharge fo r any residual biocides. For exampl e, if chlorine is used as a

biocide in ballast water treatment , the vessel owner/opera tor could test for re sidual chlorine in the vessel ballast water discharg e. Table 5 provides a list of residual biocides and possible

effluent limits 3 

### for ballast water discharges. To verify re sidual biocide concen trations in ballast treatment effluent, vessel operators could initiall y collect a number of samples over the first few

3 Please see the 2013 proposed VGP fact sheet (EPA, 2011c) for discussion regarding the development of proposed
effluent limits for the 2013 VGP.Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring



### 19 months of system operation (e.g., 3 to 5 samples spread over 3 months) and then continue to collect additional samples each year (e.g., 2 to 4 samples per year) to verify residual biocide levels are below discharge standards.

All sampling and testing for residual biocides should be conducted using sufficiently

sensitive 40 CFR Part 136 methods or other methods if specifically listed to assure that high quality data are generated. Sens ors or other test equipment th at continuously monitor residual biocide in ballast water discharg e would need to be sufficiently sensitive to measure biocide

concentrations before and after any neutralization process to veri fy discharge concentrations and

to control the neutralizer dose.Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring20Table 4. Possible Biological Indicator Compliance Monitoring Analytical Methods and Effluent LimitsAnalyteAnalytical MethodSampleVolumeSampleHolding TimeMethod DetectionLimitPossibleEffluent LimitsLimit TypeE. ColiEPA Method 1103.1 and1603; SM 9223B; ASTMD5392 – 93; or ISO 9308-1:2000; Colilert®100 mL 6 hours 1 MPN or cfu/100 mL<250 cfu/100 mLaDailyMaximumEnterococci EPA Method 1106.1 and1600; SM 9230C; ASTMD5259 – 92(2006); or ISO7899-2:2000; Enterolert®100 mL 6 hours 1 MPN or cfu/100 mL<100 cfu/100 mLaDailyMaximumTotal heterotrophicbacteriaSM 9215; ASTM D5465;ISO 6222:1999100 mL 6 hours 1 MPN or cfu/100 mL N/A DailyMaximuma USCG Phase I Standardb USCG Phase II StandardBallast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring21Table 5. Residual Biocides Compliance Monitoring Sampling Analytical Methods and PossibleAction LevelsBiocide orResidualAnalyticalMethodsSampleVolumeSampleHolding TimeMDLPossibleEffluentLimitLimit TypeAlkylamines EPA Method8360B and8270D25 mL (8260B) 14 days(8260B)Varies by compound(8260D); 10 μg/L(8270C)Report NAChlorine(expressed as TotalResidual Oxidizers(TRO as TRC))SM 4500-Cl G;ISO 7393/250 mL 15 minutes 10 μg/L, under idealconditions100 μg/L InstantaneousMaximumChlorine dioxide EPA Method327.0-1; SM4500 ClO2E16 mL (327.0-1) 4 hours (327.0-1); As soon aspossible (SM)Varies (327.0-1); 10to 100 μg/L (SM)200 μg/L InstantaneousMaximumOzone (expressedas Total ResidualOxidizers (TRO asTRC))SM 4500-O3B 50 mL As soon aspossible10 μg/L 100 μg/L InstantaneousMaximumPeracetic Acid ISO / DIS 7157 25 ml As soon aspossible500 μg/L 500 μg/L InstantaneousMaximumHydrogen Peroxide(for systems usingPeracetic Acid)ISO / DIS 715725 ml As soon aspossible500 μg/L 1,000 μg/L InstantaneousMaximumSM: Standard MethodsMDL: Method detection limitNA: Not applicableBallast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring



### 22 3.4 E FFLUENT 

### M ONITORING FOR 

### B IOCIDE 

### D ERIVATIVES



### Biocides can also generate derivatives dur ing ballast water treatment that can have

harmful effects when released to the environment. For example, chlorine combined with organic material can generate short chain volatile hydr ocarbons (e.g., trihalomethanes) which have human health implications (New Hampshire De partment of Environmental Services, 2006). Table 6 lists biocide derivatives expected in ballast water treatment effluent along with the derivatives analytical methods. To verify biocid e derivative concentrations in ballast treatment

effluent are below levels harmful to the envir onment, vessel operators could initially collect a number of ballast water treatment effluent samp les over the first few months of system operation (e.g., 3 to 5 samples spread over 3 months) to determine biocide derivative concentrations. Vessel operators could collect ballast water tr eatment effluent samples periodically throughout the year (e.g., 2 to 4 samples per year) to verify biocide derivative concen trations remain below

harmful levels.

Table 6. Biocide Derivative Mo nitoring Analytical Methods

Biocide Measured

Biocide

Derivative Analytical Methods Sample

Volume Sample Holding

Time MDL

Chlorine or

chlorine
dioxide Total
trihalomethanes a EPA Method 8260 40 mL 14 days Varies

Haloacetic acids b EPA Method 552.2 40 mL 14 days Varies by Compound

Chlorine
dioxide Chlorite EPA Method 327.0-1; SM
4500 ClO 2 E 250 mL 28 days Varies

Chlorate EPA Method 300.1 250 mL 28 days Varies

Ozone Bromate EPA Method 317; ASTM

D 6581-00 250 mL 28 days (317) Varies (317)

Bromoform EPA Method 8260 40 mL 14 days Varies

a Total trihalomethanes is the sum of the concentrations of chloroform, bromodichlorome thane, dibromochloromethane,

and bromoform.
b Haloacetic acids is the sum of the co ncentrations of mono-, di-, and trichlor oacetic acids and mono- and dibromoacetic

acids.
MDL: Method detection limit



### 3.5 B ALLAST 

### W ATER 

### S AMPLING 

### M ETHODS



### EPA has developed and published techniques for sampling ballast water discharges (USEPA, 2010a). In accordance with EPA’s ET V Program, samples should be collected on a time-integrated basis such that a composite sample of the entire discharge is acquired. To assure that samples reflect actual discharge concentratio ns, effluent samples fo r biological indicators (i.e., E. coli , enterococci, total heterotrophic bacteria), residual biocides and biocide derivatives would need to be collected during an actual ballas t water discharge. The sample flow rate should be appropriately controlled to maintain an even distribution of sample collection over the entire ballast water discharge period, and the sample should be coll ected at a location where the discharging ballast water is representative of the entire ballast water stream. hBallast Water Discharges from Vessels Section 4 - Ballast Water Treatment Monitoring Costs



### 23 

## SECTION 4

BALLAST WATER TREATMENT MONITORING COSTS

There are three main categories of costs fo r ballast water treatment and monitoring as contemplated in this document: 1) costs associ ated with the purchase, installation, and operation of the treatment system; 2) cost s associated with ballast water treatment system functionality monitoring and equipment calibration; and 3) co sts associated with discharge monitoring.

Although ballast water treatment systems shoul d include the necessary sensors, probes and monitoring equipment needed for performance monitoring, EPA decided to be conservative

and estimate the incremental cost for a vessel to purchase and install additional monitoring equipment. Using a filtration and chlorine ballas t water treatment system as an example, EPA estimated costs to add additional pressure transd ucers to monitor pressure drop across the filter and costs for an on-line chlorine analyzer. Ta ble 7 provides these example capital costs. EPA estimated that capital costs for installation of a dditional monitoring equipment for a filtration and chlorine system would be approximately $10,000.

Table 7. Estimated Capital Cost for Ve ssels Needing Additional Ballast Water Treatment System Monitoring Equipment

Treatment Unit Monitoring Equipment Equipment

Purchase Cost Installation

Cost Factor c 

### Installed Capital Cost

Filter Pressure

Transducers $1,550 a 2 $3,100

Chlorine On-line DPD Chlorine Analyzer $3,448 b 2 $6,900

Total Installed Capital Cost $10,000 a Costs provided by Sentra for two pressure transducers with ranges from 15 to 1,000 psi. b Costs provided by Hach Company for the CL 17 Free Chlorine Analyzer with AquaTrend Network. c Installation cost factor developed by Ea stern Research Group, Inc. for installation of wastewater treatment equipment on cru ise ships.



### Annual monitoring costs would be incurred for monthly inspection of the system,

quarterly sampling for performance indicators and residual biocides, annual sampling for biocide derivatives, and annual recordk eeping and reporting. EPA estimated the total labor needed to conduct monthly inspections of the ballast water treatment sy stem, annually recalibrate any monitoring equipment, and complete the necess ary recordkeeping amounts to about 22 hours per year. Labor estimates assume equipment inspect ion requires approximately 1 hour per month plus an additional 9 minutes per month to record the inspection information. Recalibration of the monitoring equipment is estimated to be 8 hours per year with an additional 15 minutes to record

the recalibration information.

The third potential cost compone nt relates to discharge mon itoring from the ballast water treatment system. For these estimates, EPA assumed three types of discharge monitoring: biological indicators, residual bi ocides and biocide de rivatives. EPA’s assumptions regarding the parameters to be analyzed and the frequency of monitoring differ depending on the type of treatment system installed. The total cost of each sampling even t would consist of both laborBallast Water Discharges from Vessels Section 4 - Ballast Water Treatment Monitoring Costs



### 24 hours for vessel staff to collect samples and either on-board sample analysis or send the samples to an onshore laboratory for analysis. EPA assu med that compliance testing of ballast water

effluent would be conducted 2 ti mes per year for vessels with type approved ballast water treatment systems and 4 times per year for non-ty pe approved ballast water treatment systems.

EPA also assumed discharge testing for the presence of residual biocides and biocide derivatives, if applicable , several times during the initial 90 days of permit coverage, followed by maintenance monitoring thereafter. The number of sampling events assumed during the first 90 days (3 to 5 events) and the frequency of subseque nt monitoring events (2 or 4 events per year) is dependent on the type of system.

EPA estimated that each sampling event woul d require 2 hours to complete and 0.5 hour to record. Additional sampling for biocides and biocide derivatives, in the case of vessels equipped with systems that have the potential to discharge residual biocides or biocide derivatives, is estimated to require an additi onal 1 hour to complete, and 0.5 hours to record. Table 8 presents the estimated costs for discharge sampling and analytical testing of ballast water discharges.

Table 8. Estimated Labor and Analytical Costs for Ballast Water Treatment System Discharge Sampling

Monitoring Requirement Sample Collection Labor (hrs/event) Sample Analysis and

Incidentals Cost ($/event) Sampling Frequency (#

events/yr) Annual Cost a
If using type approved ballast wa ter treatment systems for which a ll type approval data is available Biological Indicator Sampling and Testing b 2.5 $150 2 $468

Initial Biocide Derivative Monitoring c,d 1.5 $150 3 $98 e

Biocide Derivatives Monitoring d 1.5 $150 2 $401

If using non-type approved balla st water treatment systems or ty pe approved systems which type approval data a re not available Biological Indicator Sampling and Testing b 2.5 $150 4 $937

Initial Biocide Derivative Monitoring c,d 1.5 $150 5 $196 e

Biocide Derivatives Monitoring d 1.5 $150 4 $802

a Annual cost calculated as burden hours times the average labor rate of $33.72/hour plus lab and incidental costs times the frequency. b Costs for analysis of E. coli , enterococci and total live bacteria from Energy Laboratories c Analysis of residual biocide oxidizers such as chlorine, ozone and chlorine diox ide performed onboard due to short sample

hold time d Cost for analysis of trihalomethanes or bromoform from Energy Laboratories

e Annual cost represents one-time costs of initial testing annual ized over 5 years of the VGP (assumes that the initial round of biocide sampling and testing replaces one periodic monitoring event).Ballast Water Discharges from Vessels Section 4 - Ballast Water Treatment Monitoring Costs



### 25 Note that EPA assumed that vessels would test for the presence of residual biocides and their corresponding derivatives and analytes li sted in Tables 5 and 6, namely: alkylamines, bromated, chlorate, chlorine or chlorine dioxide, hydrogen peroxi de, ozone, and peracetic acid.

More information on the costs associated with ballast water treatment system monitoring are provided in EPA’s Economic and Benefits Analysis of the 20 13 Vessel General Permit (USEPA, 2011b).Ballast Water Discharges from Vessels Section 5 - References



### 26 

## SECTION 5

REFERENCES

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California Environmental Protection Agency. (2002). Evaluation of Ballast Water Treatment Technology for Control of Nonindigenous Aquatic Organisms, December 2002.

Carlton, J.T. (2001). The Scale of Ecological C onsequences of Biological Invasions in the
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Carlton, J.T., Reid, D.M., and van Leeuwen, H. (1995). Shipping Study: The Role of Shipping in the Introduction of Nonindigenous Aquatic Or ganisms to the Coas tal Waters of the United States (other than the Great La kes) and an Analysis of Control Options (USCG Report No. CG-D-11-95).

Deines, A.M, Chen, V.C, and Landis, W.G. (2005). Modeling the Risks of Nonindigenous Species Introductions Using a Patch-Dynami cs Approach Incor porating Contaminant

Effects as a Disturbance. Risk Analysis, 25(6): 1637-1651

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Dobroski, N. Scianni, C., and Takata, L. (2009). October 2009 Update: Ballast Water Treatment Technologies for Use in California Waters . Prepared for the California State Lands Commission by the Marine Invasive Species Program, October 2009.

Drake, J.M., and Lodge, D.M. (2007). Rate of Speci es Introductions in th e Great Lakes via Ships

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299 – 325

.Ballast Water Discharges from Vessels Section 5 - References



### 27 Hurley, W., Schilling, S.S, and Mackey, T. (2001). Contract Designs for Ballast Water Treatment Systems on Container Ship R.J. Pfeiffer and Tanker Polar Endeavor. Marine Environmental Engineering Technology Symposium (MEETS) . Arlington, VA. June 1,

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International Maritime Orga nization (IMO). (2008). Resolution Marine Environmental Protection Committee (MEPC) 174(58), Guide lines for Approval of Ballast Water Management Systems (G8)

.

Kasyan, V. (2010). Holoplankton of ship ballast wate r in the Port of Vladivostok . Russian Journal of Marine Biology. 36(3):167-175.

Keller, R.P. and Drake, J.M. (2011). Linking En vironmental Conditions and Ship Movements To Estimate Invasive Species Transpor t Across the Global Shipping Network. Journal of Conservation Biogeography, 17, 1.

Lodge, D., and Finnoff, D. (2008). Invasive Species in the Great Lakes: Costing Us Our Future

. Preliminary Results. University of Notre Dame.

Lovell, S.J., & Drake, L.A. (2009) Tiny stowaway s: analyzing the economic benefits of a U.S. Environmental Protection Agency permit regulating ballast water discharges. Environmental Management, 43, 546-555.

Lloyd’s Register. (2010). Ballast water treatment technology: current status . London, England: Lloyd’s Register. February, 2010.

MIT Sea Grant. (2002). Marine Bio-Invasion Fact Sheet: Ballast Water . Retrieved from http://massbay.mit.edu/exoticspecies/ballast/fact.html

New Hampshire Department of Environmental Services. (2006). Trihalomethanes: Health Information Summary (ARD-EHP-13).

Pennsylvania Sea Grant. (2003). Proceedings Aquatic Invaders of the Delaware Estuary Symposium . Penn State Great Valley Campus.

Perrings, C. (2002). Biological Invasions in Aquatic Systems: The Economic Problem. Bulletin of Marine Science, 70(2), 541-552

.

Prince William Sound Regional Citizens’ A dvisory Council. (2005). Prince William Sound Alaska Crude Oil Tankers, Fact Sheet. Ballast Water Treatment Methods

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Raikow, D.F. and Reid, D. (2006). Sensitivity of A quatic Invertebrate Eggs to SeaKleen: A Test of Potential Ballast Tank Treatment Options. Environmental Toxicology and Chemistry, 25, 2, 552-559

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Sentra. (2011). AccuSense Model ASM High Accuracy Pressure Transducer

.Ballast Water Discharges from Vessels Section 5 - References



### 28 Tamburri, M. (2011). Personal Communication . Maritime Environmental Resource Center (MERC), University of Maryland Chesapeake Biological Laboratory.

USCG. (2011). Draft Proceedings of Ballast Water Discharge Standards Compliance Subject Matter Expert (SME) Workshop

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USEPA. (2011a). Science Advisory Board (SAB), Ecologi cal Processes and Effects Committee, Efficacy of Ballast Water Treatment Systems

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USEPA. (2011b). Economic and Benefits Analysis of the 2013 Vessel General Permit

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USEPA. (2010a) Generic Protocol for the Verification of Ballast Water Treatment Technologies (EPA/600/R-10/146). Environmental T echnology Verification (ETV) Program

USEPA. (2010b) Vessel General Permit

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USEPA. (2008). Vessel General Permit Fact Sheet

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USEPA. (2001). Aquatic Nuisance Species in Ballast Water Discharges: Issues and Options

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USEPA. (1986). Quality Criteria for Water [Gold Book]

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