United States Environmental Protection Agency

Office of Wastewater Management

Washington, DC 20460

EPA 800‐R‐11‐003

November 2011

Ballast Water Self Monitoring
Ballast Water Discharges from Vessels Contents 

i 

Contents 

Page 

1 INTRODUCTION .................................................................................................................... 1

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

1.2 Environmental Impacts of Ballast Water Discharges ............................................. 2

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

2 BALLAST WATER TREATMENT TECHNOLOGIES .................................................................... 7

3 BALLAST WATER COMPLIANCE MONITORING ................................................................... 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 BALLAST WATER TREATMENT MONITORING COSTS ......................................................... 23

5 REFERENCES ...................................................................................................................... 26
Ballast 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 Performance Measures and Analytical Methods for 

Biological Indicator Compliance Monitoring ....................................................................17

4 Possible Biological Indicator Compliance Monitoring Analytical Methods and 

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

5 Residual Biocides Compliance Monitoring Sampling Analytical Methods and 

Possible Action Levels .......................................................................................................21

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 Costs for Ballast Water Treatment System 

Discharge Sampling ...........................................................................................................24

LIST OF FIGURES 

Page 

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

The EPA technical contact for this document 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 effluent limits; technology-based effluent limits 

applicable to 26 specific discharge streams; narrative water-quality based effluent limits; 

inspection, monitoring, recordkeeping, 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 treatment 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 systems are functioning properly. 

1.1 WHAT IS BALLAST WATER? 

Ballast water is fresh or saltwater held in the ballast tanks and cargo holds of ships. It is 

used to provide stability and maneuverability during a voyage when ships are not carrying cargo, 

not carrying heavy enough cargo, or when more stability 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. Ballast 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 may release or take on a portion of ballast water at each port. In 

such cases, the ships ballast water contains a mix of waters from multiple ports (MIT, 2002). 

Large commercial vessels (e.g., container ships, bulk carriers, other cargo vessels, 

tankers, and passenger vessels) normally have ballast tanks dedicated to this purpose, and some 

vessels may also ballast empty cargo holds. The discharge volume varies by vessel type, ballast 

tank capacity, and type of deballasting equipment. 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 capacity of about 2,600 cubic meters (about 686,850 

gallons) while ultra large crude carriers (ULCCs) have an average 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, followed by bulk carriers and container 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 ENVIRONMENTAL IMPACTS OF BALLAST WATER DISCHARGES

Ballast water discharges have been cited as one of the primary sources or vectors for the 

spread of aquatic nuisance species (ANS) (Carlton et al., 1995). The transfer of alien water 

species in ships ballast tanks at modern rates, scales and shipping routes facilitates very fast and 

practically global distribution of some species (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’ ballast tanks. These organisms 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 pathogens that have been introduced to U.S. 

waters include Hydrilla, European Loosestrife, Eurasian water 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 systems and electric generating plants, causing 

approximately $1 billion a year in damage and control for the Great Lakes alone (California 

State Lands Commission, 2010). In San Francisco Bay, the overbite clam (Corbula amurensis) is 

believed to be a major contributor to the decline of several pelagic fish species in the 

Sacramento-San Joaquin River Delta by reducing the plankton food base of the ecosystem 

(California State Lands Commission, 2010). Because of the global shipping network, it is 

possible that new ANS could arrive from virtually 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 new ballast water with these residuals, and then 

later discharge this ballast water. On any given 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 species 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-indigenous populations that have 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 systems and lake, river and nearshore marine systems are especially vulnerable (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 and costs of controlling aquatic invaders in 

the United States are estimated to be $9 billion annually (Pennsylvania Sea Grant, 2003). The 

spread of ANS can be mitigated if either their introduction 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 CURRENT BALLAST WATER DISCHARGE REGULATIONS

A thorough evaluation of the availability of ballast water treatment technologies requires 

an understanding of the regulatory framework associated with the development and 

implementation of performance standards for the discharge of ballast water, including knowledge 

of mechanisms for the testing and evaluation of treatment systems to meet those standards. This 

section summarizes the ballast water regulations currently in effect. 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 through the auspices of the International Maritime Organization 

(IMO). Beginning in 1991, the IMO, which is the principal UN body that addresses pollution 

from ships, adopted a series of resolutions containing recommended practices to help prevent the 

introduction of ANS by ballast water. The current resolution was adopted in 1997 and contains 

guidelines calling for mid-ocean ballast water exchange (BWE) and other ballast water 

management practices. 

Following adoption of the resolution, a ballast 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 legally binding requirements for a ballast water 

management treaty. Over the course of these meetings, there was a gradual evolution away from 

reliance on BWE as the primary control mechanism to one requiring compliance with ballast 

water discharge standards stated in the form of concentrations of organisms per unit of volume of 

ballast water discharged. The culmination of this effort was a Diplomatic Conference held at 

IMO, which adopted the International Convention 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 Convention, 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 principal statutes of interest: (1) the Nonindigenous 

Aquatic Nuisance Prevention and Control Act, as amended (“NANPCA,” 16 U.S.C. §§ 4701 et 

seq.); and (2) the Federal Water Pollution Control Act (commonly referred 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 exchange is of variable 

effectiveness and cannot always be carried out due to safety concerns, efforts 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 water discharged. The USCG issued proposed 

regulations in August, 2009 containing such standards, 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 authority to more stringently regulate ballast 

water discharges that occur in state waters. At the state level, regulation 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

TREATY (Reg. 

D-2)

< 10 

“viable” 

organisms 

per m3

< 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

NEGOTIATING 

POSITION

< 0.01 

“living” 

organisms 

per m3

< 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

PROPOSED 

RULE (74 FR 

44632) 

PHASE 1 STANDARD

< 10 

organisms 

per m3

< 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 

PHASE 2 STANDARD

< 1 organism 

per 100 m3

< 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 

< 103

 “living” bacterial 

cells per 100 ml 

< 104

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) 

INTERIM STANDARD

0 detectable 

“living” 

organisms 

US 

negotiating 

position 

Vibrio cholera IMO Reg 

D-2; E. coli US 

negotiating position; 

Intestinal enterococci US 

negotiating position < 

103

 bacteria per 100 ml 

< 104

viruses 

per 100 

ml 

N/A 01/01/10 – 01/01/16 

(varies by vessel 

construction date/BW 

capacity) 

FINAL STANDARD

0 detectable 

“living” 

organisms 

0 detectable 

“living” 

organisms 

0 detectable “living” 

organisms 

0 

detectable 

“living” 

organisms 

N/A 01/01/2020 
Ballast 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 D2b

 (as daily 

average) 

IMO Reg D2b

 (as daily 

average) 

Vibrio choleraa

; 

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 D2b

 (as daily 

average) 

IMO Reg D2b

 (as daily 

average) 

Vibrio choleraa

; 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) 

INTERIM STANDARD

< 1 “living” 

organism per 

10 m3

< 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) 

FINAL STANDARD

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 D2b

 (as daily 

average) 

IMO Reg D2b

 (as daily 

average) 

Vibrio choleraa

; 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 operation 
Ballast 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 choleraa

; 

E. coli IMO Reg D-2 (as 

daily average); Intestinal 

enterococci IMO Reg D2 (as daily average) 

---- Noc Vessels constructed 

after 01/01/12d 

i

mmediate; Vessels 

constructed before 

01/01/12d 01/01/14 

Source: Modified from Albert et al., 2010. 

* For some standards, groupings are stated 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 voyage 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 Lakers 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 was 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 applied (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 occur 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 exist at U.S. ports. Shipboard treatment occurs onboard vessels 

through the use of technologies that are integrated into the ballasting system; a number of such 

systems have been developed or are in development. 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 variable temperature, salinity, nutrients and 

suspended solids. They must also function under difficult operational constraints, including high 

flow-rates of ballast water pumps, large water volumes, and variable retention times (time ballast 

water is held in tanks). Treatment systems should be capable of eradicating a wide variety of 

organisms ranging from viruses and microscopic bacteria, to free-swimming plankton, and must 

operate so as to minimize or prevent impairment of the water quality conditions of the receiving 

waters. The development of effective treatment systems is further complicated by the variability 

of vessel types, shipping routes and port geography (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-chemical processes (Albert et al., 2010). Most 

commercial systems comprise two stages of treatment with a physical solids-liquid separation 

followed by biocidal disinfection as shown in Figure 1 (Lloyds Register, 2010). 

Source: Lloyds Register, 2010. 

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

8 

Different treatment processes are more effective for certain types or size classes of 

organisms. Larger size classes of organisms typically require a filtration system or other physical 

process to limit their intake into the ships ballast tanks; however, smaller size classes of living 

organisms typically require additional 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 mainly to the flow capacity attained at a given 

operating pressure. Maintaining the flow normally requires that the filter is regularly cleaned, 

and it is the balance between flow, operating pressure 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-organisms; 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 injecting 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 separated and removed. The effectiveness of the separation depends upon 

the difference in density of the particle and the surrounding water, the particle 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 water 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 presents a challenge since the reagents used 

are themselves chemically hazardous. Peracetic acid and hydrogen peroxide (provided as a blend 

of the two chemicals in the form of the proprietary product Peraclean®) are infinitely soluble in 

water, produce few harmful byproducts and are relatively stable. However Peraclean® is 
Ballast Water Discharges from Vessels Section 2 - Ballast Water Treatment Technologies

9 

relatively expensive, is dosed at quite high levels, has been documented to have unacceptable 

toxicity in cold waters, and requires considerable storage facilities. 

For all these chemicals, pre-treatment of the water using solid-liquid separation (i.e., 

filtration or hydrocyclones) is desirable to reduce the ‘demand’ on the disinfectant, because the 

chemical can also react with organic and other materials in the ballast water. In addition, while 

chemical biocides may be effective for disinfection of organisms in the water column, they may 

be relatively ineffective in disinfecting species buried in sediment in ballast tanks, especially 

invertebrates in resting stages (Raikow and Reid, 2006). Vessel owners/operators should consult 

with technology vendors to ensure the selected system is appropriate for the vessel of interest 

under normal ballasting conditions (Dobroski et al., 2009). 

According to EPA’s Science Advisory Board (USEPA, 2011a), five ballast water 

management system types (listed below) have been demonstrated to meet the IMO D-2 discharge 

standard, when tested under the International Maritime Organization G8 guidelines (IMO, 2008), 

and will likely meet USCG Phase 1 standards, if tested under EPA’s more detailed 

Environmental Technology Verification (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 + TiO2; and 

 Filtration + electro-chlorination. 

Deoxygenation is a physical-chemical process that kills organisms by creating severe 

hypoxia (through lowered pressure via venturi or vacuum, or lowered partial pressure via gas 

sparging with inert gasses). Cavitation is a physical-chemical process that kills organisms by the 

high pressure, shear forces, and shock waves generated by the collapse of vapor bubbles induced 

into the ballast water. Filtration describes a variety of physical separation processes, including 

screening to remove sediment and 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-chlorination are biocidal technologies that disinfect 

ballast water using the chemical disinfectants chlorine dioxide and chlorine; chlorine is generated 

by electrolytic processes using sea 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 + TiO2 physical-chemical process, UV light also activates the surface of the 

titanium catalytic semiconductor, disinfecting ballast water using both photochemical and 

photocatalytic reactions (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: USEPA, Science Advisory Board (SAB), Ecological Processes and Effects 

Committee, Efficacy of Ballast Water Treatment Systems, June 2011). This list 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 impacts, such as toxicity. For example, the 

addition or in-process generation of disinfecting chemicals may result in an effluent with some 

residual toxicity. Depending on the predicted or measured oxidant levels in the ballast water, a 

chemical neutralizing agent may need to be applied before ballast water discharge to comply 

with effluent limitations (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 the treatment systems are being 

operated properly once installed on a vessel, samples of ballast water effluent can be collected 

and analyzed, and specific treatment system operating parameters can be monitored, to indirectly 

verify the treatment system is achieving the intended effluent levels on an ongoing basis. 

Measures of treatment performance for ballast water systems can include a variety of 

techniques ranging from collection of ballast water effluent samples for analysis of target 

organisms to monitoring operational parameters for the treatment technologies to verify they are 

within predetermined limits. Monitoring systems 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 manufacturer’s specifications (Hurley et al., 2001). The 

three categories of compliance monitoring are: 

 Physical/chemical indicators of treatment performance; 

 Biological indicators of exceedances; and 

 Effluent monitoring for residual biocides and biocide derivatives. 

3.1 PHYSICAL-CHEMICAL INDICATORS OF TREATMENT PERFORMANCE 

Physical/chemical indicators of treatment performance can be used to verify that the 

ballast water treatment system is operating according to the manufacturers’ 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 include flow meters, pH 

sensors, dissolved oxygen sensors, OPR and amperometric (TRO) sensors, and on-line chlorine 

analyzers (Tamburri, 2011). All of these meters and sensors have broad application in the water 

and wastewater treatment industry and are available 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. Vessel 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 provides 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 Wate

12 

Table 2. Potential Ballast Water Treatment System Sensors and Measurement Equipment for Physical/

Monitoring

Technology Type Measurement

Potential Control Sensor, 

Equipment, or Procedure

Possible Compliance 

Monitoring

P

Alkylamines pH pH sensor pH pH 

Alkylamines Chemical analysis and 

treatment monitoring 

-Alkylamines concentration at injection -Alkylamines dosage and usage 

-Alcon-Alusa

Bioremediation Treatment chemical Chemical analysis and 

treatment monitoring 

-Treatment chemical concentration at injection -Treatment chemical dosage and usage 

-Trcon-Trand 

Cavitation Acoustic Passive acoustic sensor or 

acoustic interferometry 

Acoustic Aco

Pressure Pressure sensors (before/after) Pressure Pre

Chlorination: electrochlorination or chlorine addition (e.g., hypochlorite or chlorine dioxide) 

Oxidation reduction potential (ORP) 

ORP sensor ORP at injection OP

Total residual oxidizers (TRO) 

Amperometric sensor TRO at injection TR

Chlorine On-line N,N diethyl-pphenylene 

diamine (DPD) sensor, sample analysis, and treatment monitoring 

-Chlorine concentration at 

injection

-Chlorine dosage and usage (if 

chlorine addition)

-Ch

onan

-Ch

ch

Chlorine Dioxide On-line chlorine dioxide 

amperometric sensor, Lissamine Green B (LGB) sample analysis, and treatment monitoring 

-Chlorine dioxide 

concentration at injection

Chlorine dosage and usage (if chlorine addition) 

-Ch

frosam

Chlusa

Power consumption, voltage and current 

System power diagnostics 

Conductivity/salinity Conductivity and temperature 

sensor 

Conductivity and temperature at injection 

Contem

Colored dissolved organic matter (CDOM) 

Fluorometer (before/after) 
Ballast Water Discharges from Vessels Section 3 - Ballast Water 

13 

Table 2. Potential Ballast Water Treatment System Sensors and Measurement Equipment for Physical/

Monitoring

Technology Type Measurement

Potential Control Sensor, 

Equipment, or Procedure

Possible Compliance 

Monitoring

P

Coagulation (flocculent) Coagulant Chemical analysis and 

treatment monitoring 

-Treatment chemical concentration at injection -Treatment chemical dosage and usage 

- Trcon-Trand 

Turbidity Turbidity sensor Coagulation effluent turbidity Coa

Deoxygenation Dose of inert gas (if used) Treatment monitoring Deoxygenation gas dosage and 

usage 

Deousa

pH (if CO2 used) pH sensor pH pH Dissolved Oxygen (DO) DO sensor Deoxygenation module 

dissolved oxygen concentration 

Discon

Electric pulse Power consumption, voltage 

and current 

System power diagnostics Electric pulse module power 

consumption, voltage and current 

Eleconcur

Filtration Water clarity Sight glass, water sample, 

turbidity sensor, transmissometer 

Filter effluent clarity Cla

Flow rate Flow meter Filter effluent flow FloPressure Pressure sensors (before/after) Filter pressures (before/after) FiltBack flush frequency Treatment monitoring Filter backwash frequency Filt

Heat Temperature Thermistors Treatment temperature TemHydrocyclone Water clarity Sight glass, water sample, 

turbidity sensor, transmissometers 

Hydrocyclone effluent clarity Cla

Back flush frequency Treatment monitoring Hydrocyclone back flush 

frequency 

Hyfreq

Power consumption, voltage and current 

System power diagnostics Hydrocyclone power 

consumption, voltage and current 

Hyconcur

Menadione/Vitamin K Menadione Chemical analysis and 

treatment monitoring 

-Menadione/Vitamin K concentration at injection -Menadione/Vitamin K dosage and usage 

-Mcon-Mand 
Ballast Water Discharges from Vessels Section 3 - Ballast Water 

14 

Table 2. Potential Ballast Water Treatment System Sensors and Measurement Equipment for Physical/

Monitoring

Technology Type Measurement

Potential Control Sensor, 

Equipment, or Procedure

Possible Compliance 

Monitoring

P

Ozone ORP ORP sensor ORP at ozone injection OP

TRO Amperometric sensor TRO at ozone injection TROzone On-line ozone sensor (if used) 

and sample analysis 

Ozone concentration at injection 

Ozoline sam

Bromate Sample analysis Bromate at ozone injection BroPower consumption, voltage and current 

System power diagnostics 

Conductivity/salinity Conductivity and temperature 

sensor 

Conductivity and temperature at injection 

Contem

CDOM Fluorometer (before/after) 

Peracetic acid Hydrogen peroxide On-line sensor, chemical 

analysis, treatment monitoring 

-Hydrogen peroxide concentration at injection -Hydrogen peroxide dosage and usage 

-Hyfrom sam-Hyand 

Peracetic acid On-line sensor, chemical 

analysis, treatment monitoring 

-Peracetic acid concentration at injection -Peracetic acid dosage and usage 

-Pebotana-Peusa

pH pH sensor pH at injection pH CDOM Fluorometers (before/after) 

Plasma pulse Power consumption, voltage 

and current 

System power diagnostics Plasma pulse module power 

consumption, voltage and current 

Placoncur

Temperature Thermistors Treatment temperature Tem

Shear Acoustic Passive acoustic sensor or 

acoustic interferometry 

Acoustic Aco

Pressure Pressure sensors (before/after) Pressure Pre
Ballast Water Discharges from Vessels Section 3 - Ballast Water 

15 

Table 2. Potential Ballast Water Treatment System Sensors and Measurement Equipment for Physical/

Monitoring

Technology Type Measurement

Potential Control Sensor, 

Equipment, or Procedure

Possible Compliance 

Monitoring

P

Ultrasound Power consumption, voltage 

and current 

System power diagnostics Ultrasound power 

consumption, voltage and current 

Ultconcur

Acoustic Passive acoustic sensor or 

acoustic interferometry 

Acoustic Aco

UV and UV+TiO2 Power consumption, voltage 

and current 

System power diagnostics UV module power 

consumption, voltage and current 

UV concur

Lamp status and age Treatment monitoring UV lamp status and age UV dose, intensity, transmittance 

UV sensors and monitors UV dose, intensity, 

transmittance 

UV tran

Flow rate Flow meter UV effluent flow FloCDOM CDOM fluorometer 

Source: Adapted from USCG, Proceedings of Ballast Water Discharge Standards Compliance Subject Matter Expert (SME) Workshop
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 alert vessel personnel when intervention, 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 compliance. The vendor’s Operating and Maintenance 

Manual typically specifies the applicable sensors and other control 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 required 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, adherence with effluent limitations cannot be assured. To ensure 

effluent quality, consistent with vessel and crew safety, vessels should not discharge ballast 

water during alarm or upset conditions and should resume discharge only after correcting the 

problems with the system and reestablishing stable operating conditions. 

Routine maintenance of the ballast water treatment system and troubleshooting 

procedures are typically defined in the system’s Operating and Maintenance Manual kept 

onboard the vessel. All maintenance activities related to the ballast water monitoring system and 

overboard discharge control unit can be recorded and the information can be retained on board 

for inspection purposes. In addition, vessel staff training could include familiarization with the 

operation and maintenance of the ballast water overboard discharge control and monitoring 

equipment. Ballast water treatment systems could 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 equipment could be calibrated when warranted 

based on device drift and as recommended by sensor and equipment manufacturers, or by ballast 

water treatment system manufacturers. Due to the operating characteristics of sensors and control 

equipment, many sensor types (e.g., pH probes) may 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 for calibration. During the 

period when the sensors are not installed 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 working correctly. The detailed program 

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

into account the features and functions of the specific design of the equipment and the operating 
Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring

17 

and discharge conditions monitored. 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 BIOLOGICAL INDICATORS OF EXCEEDANCES 

Biological indicators of treatment performance 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 water. If there are significant levels of living 

organisms or biomass in a small volume of ballast water, then the ballast water treatment system 

is likely ineffective and monitoring 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 monitoring that could serve as indirect measurements of the 

numbers of living organisms remaining in ballast water following treatment. 

Table 3. List of Possible Treatment Performance 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 could be challenging to find sufficient numbers of 

qualified scientists and laboratories. For more information about the state of science enumerating 

living organisms in ballast water, see USEPA, 2010a or USEPA, 2011a. 

Sampling for Exceedance 

Biological indicator compliance monitoring sampling 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 concentrations of indicator organisms 

should include at least E. coli and enterococci bacteria as these tests are cost effective and the 

methods are well developed. Biological indicator 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. waters on only a limited basis (e.g., one time per 

year), should conduct ballast water effluent monitoring within the previous three months and 

upon discharge into U.S. waters. Table 4 lists possible biological indicator compliance 

monitoring sampling analytical methods and the levels of indicator organisms (IMO, 2008) for 

treated ballast water. Vessel owners/operators could also sample and analyze ballast water 

discharges for other performance measures previously listed in Table 3. 

If any of the biological indicator compliance monitoring effluent limits is exceeded, this 

is a clear indicator that the system is not meeting its discharge limits. 

3.3 EFFLUENT MONITORING FOR RESIDUAL BIOCIDES 

Some ballast water treatment systems generate or use biocides (e.g., chlorine 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 biocide that is a “pesticide” within the meaning of 

the Federal Insecticide, Fungicide, Rodenticide Act unless that biocide has been registered for 

use in ballast water treatment under such Act. Additionally, 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 systems 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 for any residual biocides. For example, if chlorine is used as a 

biocide in ballast water treatment, the vessel owner/operator could test for residual chlorine in 

the vessel ballast water discharge. Table 5 provides a list of residual biocides and possible 

effluent limits3

 for ballast water discharges. To verify residual biocide concentrations in ballast 

treatment effluent, vessel operators could initially 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. Sensors or other test equipment that continuously monitor residual 

biocide in ballast water discharge would need to be sufficiently sensitive to measure biocide 

concentrations before and after any neutralization process to verify discharge concentrations and 

to control the neutralizer dose.
Ballast Water Discharges from Vessels Section 3 - Ballast Wate

20 

Table 4. Possible Biological Indicator Compliance Monitoring Analytical Methods and Efflue

Analyte Analytical Method 

Sample 

Volume 

Sample 

Holding Time

Method Detection 

Limit 

Possib

Effluent L

E. Coli EPA Method 1103.1 and 

1603; SM 9223B; ASTM D5392 – 93; or ISO 9308-1:2000; Colilert®

100 mL 6 hours 1 MPN or cfu/100 mL <250 cfu/10

Enterococci EPA Method 1106.1 and 

1600; SM 9230C; ASTM D5259 – 92(2006); or ISO 7899-2:2000; Enterolert®

100 mL 6 hours 1 MPN or cfu/100 mL <100 cfu/10

Total heterotrophic bacteria 

SM 9215; ASTM D5465; ISO 6222:1999 

100 mL 6 hours 1 MPN or cfu/100 mL N/A 

a USCG Phase I Standard b USCG Phase II Standard 
Ballast Water Discharges from Vessels Section 3 - Ballast Wate

21 

Table 5. Residual Biocides Compliance Monitoring Sampling Analytical Methods and Pos

Action Levels

Biocide or 

Residual 

Analytical 

Methods 

Sample 

Volume 

Sample 

Holding Time MDL 

Possible 

Effluent 

Limit Limi

Alkylamines EPA Method 

8360B and 8270D 

25 mL (8260B) 14 days 

(8260B) 

Varies by compound (8260D); 10 μg/L (8270C) 

Report NA 

Chlorine (expressed as Total Residual Oxidizers (TRO as TRC)) 

SM 4500-Cl G; ISO 7393/2 

50 mL 15 minutes 10 μg/L, under ideal 

conditions 

100 μg/L Instantaneo

Maximum 

Chlorine dioxide EPA Method 

327.0-1; SM 4500 ClO2 E 

16 mL (327.0-1) 4 hours (327.0-

1); As soon as possible (SM) 

Varies (327.0-1); 10 to 100 μg/L (SM) 

200 μg/L Instantaneo

Maximum 

Ozone (expressed as Total Residual Oxidizers (TRO as TRC)) 

SM 4500-O3 B 50 mL As soon as 

possible 

10 μg/L 100 μg/L Instantaneo

Maximum 

Peracetic Acid ISO / DIS 7157 25 ml As soon as 

possible 

500 μg/L 500 μg/L Instantaneo

Maximum 

Hydrogen Peroxide (for systems using Peracetic Acid) 

ISO / DIS 7157 25 ml As soon as 

possible 

500 μg/L 1,000 μg/L Instantaneo

Maximum 

SM: Standard Methods MDL: Method detection limit NA: Not applicable 
Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring 

22 

3.4 EFFLUENT MONITORING FOR BIOCIDE DERIVATIVES

Biocides can also generate derivatives during 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 hydrocarbons (e.g., trihalomethanes) which have 

human health implications (New Hampshire Department of Environmental Services, 2006). 

Table 6 lists biocide derivatives expected in ballast water treatment effluent along with the 

derivatives analytical methods. To verify biocide derivative concentrations in ballast treatment 

effluent are below levels harmful to the environment, vessel operators could initially collect a 

number of ballast water treatment effluent samples 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 treatment effluent samples periodically throughout 

the year (e.g., 2 to 4 samples per year) to verify biocide derivative concentrations remain below 

harmful levels. 

Table 6. Biocide Derivative Monitoring Analytical Methods 

Biocide 

Measured 

Biocide 

Derivative Analytical Methods 

Sample 

Volume

Sample 

Holding 

Time MDL 

Chlorine or 

chlorine 

dioxide 

Total 

trihalomethanesa

EPA Method 8260 40 mL 14 days Varies 

Haloacetic acidsb EPA Method 552.2 40 mL 14 days Varies by 

Compound 

Chlorine 

dioxide 

Chlorite EPA Method 327.0-1; SM 

4500 ClO2 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, bromodichloromethane, dibromochloromethane, 

and bromoform. 

b Haloacetic acids is the sum of the concentrations of mono-, di-, and trichloroacetic acids and mono- and dibromoacetic 

acids. 

MDL: Method detection limit 

3.5 BALLAST WATER SAMPLING METHODS

EPA has developed and published techniques for sampling ballast water discharges 

(USEPA, 2010a). In accordance with EPA’s ETV 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 concentrations, effluent samples for biological indicators 

(i.e., E. coli, enterococci, total heterotrophic bacteria), residual biocides and biocide derivatives 

would need to be collected during an actual ballast 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 collected at a location where the 

discharging ballast water is representative of the entire ballast water stream. h 
Ballast 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 for ballast water treatment and monitoring as 

contemplated in this document: 1) costs associated with the purchase, installation, and operation 

of the treatment system; 2) costs associated with ballast water treatment system functionality 

monitoring and equipment calibration; and 3) costs associated with discharge monitoring. 

Although ballast water treatment systems should 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 ballast water treatment system as an example, EPA 

estimated costs to add additional pressure transducers to monitor pressure drop across the filter 

and costs for an on-line chlorine analyzer. Table 7 provides these example capital costs. EPA 

estimated that capital costs for installation of additional monitoring equipment for a filtration and 

chlorine system would be approximately $10,000. 

Table 7. Estimated Capital Cost for Vessels Needing Additional Ballast Water 

Treatment System Monitoring Equipment 

Treatment Unit 

Monitoring 

Equipment 

Equipment 

Purchase Cost 

Installation 

Cost Factorc

Installed 

Capital Cost 

Filter Pressure 

Transducers 

$1,550a 2 $3,100 

Chlorine On-line DPD 

Chlorine Analyzer 

$3,448b 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 Eastern Research Group, Inc. for installation of wastewater treatment equipment on cruise 

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 recordkeeping and reporting. EPA estimated the total labor needed to 

conduct monthly inspections of the ballast water treatment system, annually recalibrate any 

monitoring equipment, and complete the necessary recordkeeping amounts to about 22 hours per 

year. Labor estimates assume equipment inspection 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 component relates to discharge monitoring from the ballast water 

treatment system. For these estimates, EPA assumed three types of discharge monitoring: 

biological indicators, residual biocides and biocide derivatives. 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 event would consist of both labor 
Ballast 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 assumed that compliance testing of ballast water 

effluent would be conducted 2 times per year for vessels with type approved ballast water 

treatment systems and 4 times per year for non-type 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 subsequent monitoring events (2 or 4 events per year) is 

dependent on the type of system. 

EPA estimated that each sampling event would 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 additional 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 Costa

If using type approved ballast water treatment systems for which all type approval data is available

Biological Indicator 

Sampling and Testingb 2.5 $150 2 $468 

Initial Biocide 

Derivative Monitoringc,d 1.5 $150 3 $98e

Biocide Derivatives 

Monitoringd 1.5 $150 2 $401 

If using non-type approved ballast water treatment systems or type approved systems which type 

approval data are not available 

Biological Indicator 

Sampling and Testingb 2.5 $150 4 $937

Initial Biocide 

Derivative Monitoringc,d 1.5 $150 5 $196e

Biocide Derivatives 

Monitoringd 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 dioxide 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 annualized 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 listed in Tables 5 and 6, namely: alkylamines, 

bromated, chlorate, chlorine or chlorine dioxide, hydrogen peroxide, 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 2013 Vessel General Permit (USEPA, 

2011b). 
Ballast Water Discharges from Vessels Section 5 - References 

26 

SECTION 5 

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California Environmental Protection Agency. (2002). Evaluation of Ballast Water Treatment 

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Drake, J.M., and Lodge, D.M. (2007). Rate of Species Introductions in the Great Lakes via Ships 

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Ballast Water Discharges from Vessels Section 5 - References 

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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 

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Keller, R.P. and Drake, J.M. (2011). Linking Environmental Conditions and Ship Movements To 

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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 stowaways: analyzing the economic benefits of a U.S. 

Environmental Protection Agency permit regulating ballast water discharges. 

Environmental Management, 43, 546-555. 

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28 

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