Availability and Efficacy of Ballast Water Treatment Technology:

Background and Issue Paper

June 2010

Ryan Albert1, Rich Everett2, John Lishman3, and Daniel Smith4 

1

US Environmental Protection Agency, Water Permits Division

2

US Coast Guard, Environmental Standards Division (CG-5224) 

3

US Environmental Protection Agency, Oceans and Coastal Protection Division 

4

US Environmental Protection Agency, Oak Ridge Institute of Science and Education 

Fellow, Oceans and Coastal Protection Division 

Prepared to Assist the Science Advisory Board Review of the

Availability and Efficacy of Ballast Water Treatment Technology

Washington, D.C. 
 
Table of Contents: 

1. Introduction ................................................................................................................. 1

2. Regulatory Background .............................................................................................. 3

2.1. United States Federal Regulation............................................................................ 4

2.2. State Regulation ...................................................................................................... 8

2.3. International Regulation........................................................................................ 14

3. General Overview of Ballast Water Treatment System Design ............................... 15

3.1. Treatment Processes.............................................................................................. 16

3.2. Treatment Systems ................................................................................................ 18

3.3. Treatment System Requirements .......................................................................... 18

3.4. Treatment System Flow Capacities ...................................................................... 19

3.5. Availability of Treatment Systems ....................................................................... 19

4. Technical Documents Provided to the Committee ................................................... 20

4.1. Third Party Reports or General Evaluations ......................................................... 22

4.2. Available Information for Specific Ballast Water Treatment Systems ................ 26

4.3. G9 Papers and Other Information ......................................................................... 33

4.4. Implications of Sampling Protocols for Data Quality........................................... 43

5. Conclusion – How this Report could be used ........................................................... 45

6. Bibliography ............................................................................................................. 46

Appendix I – Science Advisory Board Charge ................................................................. 58

Appendix II. National Academy of Sciences Charge ...................................................... 62

Appendix III. List of Acronyms Used in this Paper ........................................................ 63

Appendix IV. Table of Contents for all documents provided to the Committee. ............ 65

List of Tables and Figures: 

Table 1. Selected Ballast Water Discharge Standards for Organisms (Current as of June 

28, 2010). ............................................................................................................................ 9

Table 2. System Space and Power Characteristics for Ballast Water Treatment Systems 19

Table 3. Additional G9 Decisions Made Subsequent to BWM.2/Circ.23 (List of ballast 

water management systems that make use of Active Substances which received Basic and 

Final Approvals). .............................................................................................................. 25

Table 4. Ballast Water Treatment Systems for which we have provided additional 

information. ....................................................................................................................... 28

Table 5 Summary Status of Ballast Water Treatment Systems which use Active 

Substances (Current as of June 16, 2010, through MEPC 61/2/13). ................................ 35

Table 6 Acronyms and Abbreviations used in Table 5. .................................................... 43

Figure 1. Number of systems approved by year. .............................................................. 20
Disclaimer: 

This paper has been written to provide background information for EPA’s Science 

Advisory Board in their evaluation of the technological availability of ballast water 

treatment systems. It has been drafted by EPA and USCG staff to assist the SAB board 

in its review. The contents of this paper do not necessarily reflect the views of the U.S. 

Environmental Protection Agency or the United States Coast Guard. 

Acknowledgements: 

The authors wish to thank the following individuals for their review and contributions to 

this paper: Robin Danesi, Shirley Fan, Elizabeth Fine, Tyler Linton, Dawn Messier, 

Amanda Sage, Juhi Saxena, Craig Voros, and Marcus Zobrist. 

On the Cover - the Port of Baltimore. Photo taken by Ryan Albert.
1 

1. Introduction

Ballast water discharges have historically been a major source of nonindigenous species 

introductions to marine, estuarine, and freshwater ecosystems in the United States. 

Aquatic organisms may be discharged when the vessel discharges ballast tanks that 

contains such species, or when the vessel adds ballast water to tanks that contain such 

organisms in the residual water or sediment in the tank, and later discharges that mixture. 

When such organisms in ballast tanks are transported between waterbodies and 

discharged, the organisms may have the potential to establish viable new populations of 

species in waterbodies to which they are not native. Potentially, this introduction of nonnative aquatic nuisance species (ANS) via ballast water discharge can cause significant 

economic and ecological damage. Numerous studies and reports have documented the 

impacts of such discharges, a select few of which include Bolch & Salas, 2007, Dobbs et 

al., 2006, Doblin et al., 2007, Drake & Lodge, 2007, Drake et al., 2007, Endresen et al., 

2004, Knight et al., 1999, Reynolds et al., 1999, Roman, 2006, Ruiz et al., 2000a, Ruiz et 

al., 2000b, Smayda, 2007, and US EPA, 2001. 

Ballast water is necessary for the safe operation of the vast majority of larger vessels to 

assist with vessel draft, trim, and stability. Almost all large vessels have ballast tanks, 

pumps, piping and other equipment dedicated to this purpose. In lieu of or in addition to 

such dedicated systems, some vessels may also carry ballast water in otherwise empty 

cargo holds. Ballast water is typically drawn in from, and discharged directly to, ambient 

waters. The ballast water discharge rate and constituent concentrations of ballast water 

from vessels will vary by vessel type, ballast tank capacity, type of deballasting 

equipment, the quality of the ambient water from which the ballast water is drawn, the 

amount and quality of residual water or sediment in the tank, the efficacy of any ballast 

water management practices and/or ballast water treatment employed, and other factors. 

Vessels may discharge anywhere from less than a hundred cubic meters of ballast to tens 

of thousands of cubic meters. For instance, passenger vessels have a representative

ballast capacity of about 3,000 cubic meters (about 792,516 gallons) while ultra large 

crude carriers (ULCCs) representative ballast capacity is about 95,000 cubic meters 

(about 25,096,345 gallons) (ABS, 2010). The discharge rate of ballast water is generally 

proportional to the size of the tanks, although there are notable exceptions (e.g., bulk 

carriers on the Great Lakes are often designed to load and unload cargo and ballast water 

quickly). 

Under current US regulation and permitting requirements (discussed in greater detail 

below), existing best management practices are required to help reduce the potential 

impacts of ballast water discharges. These include ballast water exchange1

 

1 “Ballast Water Exchange” means to replace the water in a ballast tank using either “Flow through 

exchange” or “Empty/refill exchange”. “Flow through exchange” means to flush out “ballast water” by 

pumping in water from the “mid-ocean” or “coastal exchange zone” (as applicable) into the bottom of the 

tank and continuously overflowing the tank from the top until three full volumes of water has been changed 

to minimize the number of original organisms remaining in the tank. “Empty/refill exchange” means to 

pump out the “ballast water” taken on in ports, estuarine, or territorial waters until the tank is empty, then 

refilling it with water from the “mid-ocean” or “coastal exchange zone” (as applicable); when conducting 

and saltwater 
2

flushing2 for certain vessels/voyages (collectively referred to as Ballast Water Exchange 

or BWE in this paper). These practices have been shown to offer some protection in 

mitigating the transfer and potential introduction of invasive species (Ruiz and Reid, 

2007; McCollin et al., 2007a). While useful in reducing the presence of potentially 

invasive organisms in ballast water, BWE is not feasible for all vessels (e.g., vessels that 

cannot voyage off-shore), can have variable effectiveness, and in some circumstances 

may not be feasible due to vessel safety concerns. 

One way to address these limitations associated with BWE is to require treatment of 

ballast water prior to discharge to meet an established standard for the concentration of 

living organisms. The United States Environmental Protection Agency (EPA) and the 

United States Coast Guard (USCG) both desire a stronger federal ballast water 

management program that will be more effective than current BWE-based requirements 

in preventing the ballast water-mediated spread of ANS (Silva and Salerno, 2009; Hanlon 

et al., 2010). 

Several peer-reviewed publications have evaluated the efficacy of ballast water treatment 

systems, a small sampling of which include Gracki et al., (2002), Gregg & Hallegraeff, 

(2007b), McCollin et al. (2007b), Quilez-Badia et al. (2008), Perrins et al. (2006), 

Raikow et al. (2007), and Tamburri et al. (2002). Other reviews have used vendor 

supplied survey information or data to evaluate the availability and/or potential efficacy

of these systems (Lloyds, 2010; Dobroski et al., 2009). However, there are also several 

complications associated with evaluating ballast water treatment technologies, including 

issues with sampling size, sufficient volume, and sufficient replicates (Lee et al., 2010), 

limited availability of valid third party data, potential uncertainties regarding data quality 

control, and logistical difficulties of demonstrating these systems work onboard ships. 

These complications are not trivial and affect the ability to evaluate the efficacy of ballast 

water treatment systems and, in some ways, how Agencies would be able to utilize 

existing effluent data (these issues are discussed in greater detail in Section 4). 

EPA is specifically asking the committee to provide a written report assessing the 

availability and efficacy of ballast water treatment systems in neutralizing (killing or 

removing) living organisms contained in the ballast water that would otherwise be 

discharged.3

 empty/refill exchange, masters/operators should pump out as close to 100 percent of the “ballast water” as 

is safe to do so (adapted from 33 C.F.R 151.2025(b) (definition of “exchange”)).

 The scope of ballast water treatment technologies we are asking the 

committee to consider includes both systems that have been indentified as currently 

2 “Saltwater flushing” means the addition of “mid-ocean” or “coastal exchange zone” water to empty 

ballast water tanks; the mixing of the added water with residual ballast water and sediment through the 

motion of the vessel; and the discharge of the mixed water until loss of suction, such that the resulting 

residual water remaining in the tank has either a salinity greater than or equal to 30 parts per thousand (ppt) 

or a salinity concentration equal to the ambient salinity of the location where the uptake of the added water 

took place (adapted from 33 C.F.R. 401.30(f)(1)). 3 EPA and USCG also recognize there is a need to better understand and relate the concentration of living 

organisms in ballast water discharges to the probability of introduced organisms successfully establishing 

populations in, and impacting, U.S. waters. EPA and USCG are currently sponsoring a separate study to 

address those types of issues by the National Academy of Sciences’ National Research Council (NRC) (see 

Appendix II). 
3

available and systems that are known to be in the development process. Because of the 

current uncertainties and inherent complexities in determining the efficacy of ballast 

water treatment systems, an independent and credible review of the capabilities of such 

systems would be very helpful to EPA and USCG as they implement their respective 

authorities. A copy of the specific questions on these matters as included in the SAB 

charge is provided in Appendix I.

2. Regulatory Background 4

Ballast water discharges from vessels are presently subject to regulation at the federal, 

state, and international level.5 This section provides a general summary of such 

regulatory frameworks to provide the SAB with contextual background on the 

requirements currently in place or under development.

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 permit requirements that 

implement the Clean Water Act presently rely on use of mid-ocean BWE. However, as

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. 

Both NANPCA and the CWA preserve state authority to more stringently regulate ballast 

water discharges that occur in state waters. See, 16 U.S.C. § 4725 (NANPCA); 33 

U.S.C. § 1370 (CWA). At the state level, regulation of ballast water discharges varies, 

not only as to whether there are applicable state requirements, but also as to the 

substantive content of such requirements where they do exist. For examples of state 

numeric limits for ballast water discharges, See, Table 1. 

At the international level, ballast water discharges from vessels are primarily addressed

under provisions established through the auspices of the International Maritime 

Organization (IMO). At present, the principal ballast water management practice at the 

international level involves the voluntary use of mid-ocean exchange. However, as will 

be further discussed, the text of a ballast water management Convention was adopted in 

February 2004. Once that Convention enters into force, it will in effect result in the 

phase out of the use of exchange in favor of treatment to meet a ballast water discharge 

 

4 Note that throughout this section, and where feasible in other sections, several references are hyperlinked 

for readers viewing this document electronically.

5 Pursuant to § 657.1 of the Canada Shipping Act, Canada also has adopted Ballast Water Control and

Management Regulations that are applicable in waters under Canadian jurisdiction, including Canadian 

waters of the Great Lakes.
4

standard specified in terms of concentrations of living organisms per unit of volume of 

ballast water discharged. 

2.1. United States Federal Regulation 

a) NANPCA

In light of growing awareness and concern about the impacts of invasive species 

introduced via discharges of ships’ ballast water, Congress enacted NANPCA in 

November 1990. Pub. L. 101-646; 104 STAT 4761. As enacted in 1990, NANPCA 

provided for the USCG to issue regulations to prevent the introduction and spread of 

ANS into the Great Lakes through the ballast water of vessels.6 In particular, the Act 

directed that these regulations require vessels carrying ballast water that enter a US port 

on the Great Lakes after operating beyond the exclusive economic zone (“EEZ”) either 

carry out ballast water exchange prior to such entry or use environmentally sound 

alternative ballast water management methods that the USCG determines to be as 

effective as ballast water exchange in preventing and controlling ANS infestations (§ 

1101(b) of P.L. 101-646; 104 STAT 4763). The Coast Guard issued final mandatory 

ballast water management regulations applicable to the Great Lakes in 1993 (Federal 

Register, Vol. 58, No. 66, April 8, 1993, page 18330). 

Subsequent to NANPCA of 1990, Congress enacted the National Invasive Species Act 

(“NISA”), which amended and reauthorized NANPCA. Pub. L. 104-332; 110 STAT 

4073. Among other things, the amendments made by NISA directed the USCG to 

address waters besides the Great Lakes by developing a voluntary national ballast water 

management program. Following development of that voluntary program, NISA directed 

the USCG to submit a report to Congress evaluating the effectiveness of the voluntary 

program. On June 3, 2002, USCG submitted that report to Congress, concluding that low 

participation in the voluntary program resulted in insufficient data for an accurate

assessment of its effectiveness. This finding in turn triggered a requirement in NISA that 

the voluntary ballast water management program be made mandatory. As a result, the 

USCG issued final mandatory ballast water management regulations applicable to US 

waters. 69 Fed. Reg. 44952 (July 28, 2004). 

The existing USCG ballast water management requirements specific to the Great Lakes 

are codified in regulations at 33 C.F.R. Part 151, Subpart C. Those regulations apply to 

“each vessel that carries ballast water and that after operating on the waters beyond the 

Exclusive Economic Zone during any part of its voyage enters the Snell Lock at 

Massena, New York, or navigates north of the George Washington Bridge on the Hudson 

River” (33 C.F.R. 151.1502). They generally require that such vessels either: 

● Carry out an exchange of ballast water beyond the EEZ using exchange water from 

an area more than 200 nautical miles from any shore and more than 2,000 meters 

 

6

 With respect to non-Great Lakes waters, NANPCA of 1990 did not establish ballast water management 

requirements, but instead called for several studies, including one to determine the need for controls on 

vessels entering US waters other than the Great Lakes. § 1102 of P.L. 101-646; 104 STAT 4764.
5

deep, such that any tank from which ballast water will be discharged contains 

water with a minimum salinity level of 30 parts per thousand; 

● Retain the ballast water on board the vessel, with authority for the USCG to 

temporarily seal any tank or hold containing ballast water to ensure compliance; or

● Use an alternative environmentally sound method of ballast water management 

that has been submitted to, and approved by, the USCG prior to the voyage. 

33 C.F.R. 151.1510(a). 

Recognizing that vessels declaring No Ballast On Board or “NOBOB” (i.e., vessels with 

unpumpable residuals of ballast water) can nonetheless potentially introduce ANS if they 

uptake and then discharge ballast water after entry into the Great lakes, the USCG also 

issued a policy directing such vessels to conduct saltwater flushing prior to entry onto the 

Great Lakes. 70 Fed. Reg. 51831 (Aug. 31, 2005). Saltwater flushing requirements for 

“NOBOBs” entering the Great Lakes via the St. Lawrence Seaway were later made 

mandatory in regulations issued by the St Lawrence Seaway Development Corporation. 

73 Fed. Reg. 9950 (Feb. 25, 2008). 

The existing USCG ballast water management requirements for all US waters are 

codified in regulations at 33 C.F.R. Part 151, Subpart D. Those regulations, with limited 

exception, apply to all vessels, US and foreign, equipped with ballast tanks that operate in 

US waters and are bound for ports or places in the US. 33 C.F.R. 151.2005. With 

respect to Great Lakes vessels, both the Great Lakes-specific provisions of Subpart C as 

well as the relevant national provisions of Subpart D are applicable. See, 33 C.F.R 

151.2040(a). 

Among other things, these regulations establish a number of operational requirements 

with respect to ballast water uptake or discharge practices and other vessel related vectors 

for ANS, such as: 

● Avoiding the discharge or uptake of ballast water in areas within or that may 

directly affect marine sanctuaries, marine preserves, marine parks, or coral reefs

● Minimizing or avoiding uptake of ballast water in areas known to have infestations 

or populations of harmful organisms, areas near sewage outfalls or dredging

operations, or areas with poor tidal flushing 

● Regular cleaning of ballast tanks to remove sediments 

● Discharge only the minimal amount of ballast water essential for vessel operations 

while in the waters of the United States

● Rinsing of anchors and anchor chains remove organisms and sediments at their 

place of origin

● Removal of fouling organisms from hull, piping, and tanks on a regular basis 

● Development of a ballast water management plan and training of master and crew 

on application of ballast water and sediment management and treatment 

procedures 

33 C.F.R. 151.2035(a) 
6

In addition, for those vessels carrying ballast water that was taken on in areas less than 

200 nautical miles from any shore into US waters after operating beyond the EEZ, the 

regulations require at least one of the following ballast water management practices7

● Perform complete ballast water exchange in an area no less than 200 nautical miles 

from any shore prior to discharging ballast water in U.S. waters;

: 

● Retain ballast water onboard the vessel; or

● Use an alternative environmentally sound method of ballast water management 

that has been approved by the Coast Guard. 

33 C.F.R. 151.2035(b) 

As previously noted, there are limitations inherent in a BWE-based framework. The 

USCG has issued a notice of proposed rulemaking that would gradually replace the 

current exchange-based regime with a regime requiring, treatment of ballast water to 

meet a concentration-based discharge standard – a standard that will increase in 

stringency over time. 74 Fed. Reg. 44632 (Aug. 28, 2009); See also, Table 1. 

b) CWA 

Section 301(a) of the CWA provides that “the discharge of any pollutant by any person 

shall be unlawful” unless the discharge is in compliance with certain other sections of the 

Act. 33 U.S.C. 1311(a). The CWA defines “discharge of a pollutant” as “(A) any 

addition of any pollutant to navigable waters from any point source, (B) any addition of 

any pollutant to the waters of the contiguous zone or the ocean from any point source 

other than a vessel or other floating craft.” 33 U.S.C. 1362(12). A “point source” is a 

“discernible, confined and discrete conveyance” and includes a “vessel or other floating 

craft.” 33 U.S.C. 1362(14). One way a person may discharge a pollutant without 

violating the prohibition in CWA § 301 is by obtaining authorization to discharge under a 

section 402 National Pollutant Discharge Elimination System (NPDES) permit (33 

U.S.C. 1342). Under that section, EPA may issue a permit for the discharge of any 

pollutant, or combination of pollutants subject to certain conditions specified by the Act. 

The CWA requires that point source discharges meet technology-based effluent 

limitations representing the applicable levels of technology-based control and further 

requires water quality-based effluent limitations as necessary when the technology-based 

limitations are not sufficient to meet applicable water quality standards. For a more 

detailed discussion of technology-based and water-quality based effluent limits and 

NPDES permitting refer to chapter 5 and chapter 6 of EPA’s NPDES Permit Writer’s 

Manual (US EPA, 1996). 

Shortly after the CWA was enacted, EPA promulgated a regulation that excluded 

discharges incidental to the normal operation of vessels from NPDES permitting. 38 Fed. 

Reg. 13528 (May 22, 1973). Following subsequent amendments, that regulation was 

codified at 40 C.F.R. 122.3(a) and identified several types of vessel discharges as being 

 

7

 The regulations in Subpart D also contain certain exceptions that allow for the discharge of the minimum 

amount of unmanaged ballast water that is operationally necessary. However, in the case of vessels subject 

to the ballast water management requirements of Subpart C, the discharge of unmanaged ballast water into 

the Great Lakes or Hudson River is not allowed. See, 33 C.F.R. 151.2037; See also, 33 C.F.R. 401.30(g).
7

subject to NPDES permitting, but specifically excluded discharges incidental to the 

normal operation of a vessel (e.g., ballast water) from NPDES permitting, as follows: 

 The following discharges do not require NPDES permits: 

(a) Any discharge of sewage from vessels, effluent from properly functioning 

marine engines, laundry, shower, and galley sink wastes, or any other discharge 

incidental to the normal operation of a vessel. This exclusion does not apply to 

rubbish, trash, garbage, or other such materials discharged overboard; nor to other 

discharges when the vessel is operating in a capacity other than as a means of 

transportation such as when used as an energy or mining facility, a storage facility 

or a seafood processing facility, or when secured to a storage facility or a seafood 

processing facility, or when secured to the bed of the ocean, contiguous zone or 

waters of the United States for the purpose of mineral or oil exploration or 

development. 

In December 2003, that regulatory exclusion became the subject of a lawsuit in the U.S. 

District Court for the Northern District of California. In March 2005 the Court 

determined that the exclusion exceeded the agency’s authority under the CWA. The 

Court subsequently issued an order in that case that vacated (struck down) the vessel 

NPDES exclusion in 40 CFR 122.3(a) as of February 6, 2009. As a result, discharges 

incidental to the normal operation of vessels, such as ballast water, that were excluded 

from NPDES permitting by that regulation became subject to CWA § 301’s prohibition 

against discharge unless authorized by an NPDES permit. See generally, Northwest

Environmental Advocates et al. v. EPA, 573 F.3d 1006 (9th Cir 2008). 

In light of the court’s decision, EPA developed two draft general NPDES permits for 

public comment addressing discharges incidental to the normal operation of vessels – one 

for commercial vessels and those recreational vessels greater than or equal to 79 feet, and 

one for recreational vessels less than 79 feet. 73 Fed. Reg. 34296 (June 17, 2008). 

Subsequently, Congress enacted two laws exempting certain vessels from NPDES 

permitting. The first of these, the “Clean Boating Act,” amended the CWA to provide 

that discharges incidental to the normal operation of recreational vessels are not subject 

to NPDES permitting, and instead creates a new regulatory regime to be implemented by 

EPA and the USCG under new § 312(o) of the CWA. Pub. L. 110-188; 122 STAT 2650. 

The second of these enactments provided for a temporary moratorium on NPDES 

permitting for: (1) commercial fishing vessels regardless of size and (2) those other nonrecreational vessels less than 79 feet in length. Pub. L. 110-299; 122 STAT 2995. 

However, that temporary moratorium is not applicable to ballast water discharges from 

such vessels.

As a result of the above legislation, EPA did not finalize the recreational vessel general 

permit and revised the other vessel general permit (for commercial vessel and large 

recreational vessels) to exclude recreational vessels. EPA’s final vessel general permit 

(VGP) was issued in December 2008, and addresses 26 discharges incidental to the 

normal operation of commercial vessels, including ballast water. 73 Fed. Reg. 79473
8

(Dec. 29, 2008). The final VGP is accompanied by a detailed Fact Sheet explaining its 

terms and conditions. 

With respect to ballast water discharges, the VGP includes, among other things, 

technology-based effluent limits that generally reflect the ballast water exchange 

requirements contained in the USCG regulations implementing NANPCA, as previously 

described. The VGP also includes several additional requirements not found in the 

USCG regulations, such as requirements for near-shore exchange by vessels engaged in 

Pacific near-shore voyages and a national requirement for saltwater flushing by 

NOBOBs. See, VGP § 2.2.3 and Fact Sheet § 4.4.3. In addition, the VGP includes water 

quality-based effluent limits to control discharges as stringently as necessary to meet 

applicable water quality standards. See, VGP § 2.3 and Fact Sheet § 4.5. 

Under § 402(b)(1)(B) of the CWA, NPDES permits are issued for fixed terms that may 

not exceed five years. The existing VGP will expire on December 19, 2013. 

2.2. State Regulation 

A number of States (e.g., California, Michigan, Minnesota, Wisconsin) have specific 

State laws and regulations establishing ballast water discharge standards or management 

programs. In addition, other States without such specific ballast water related laws have 

included ballast water discharge standards as part of their Clean Water Act (CWA) 

section 401 certifications8

 of the VGP (e.g., Illinois (see, VGP § 6.10), Indiana (see, VGP 

§ 6.11), New York (see, VGP § 6.22), Ohio (see, VGP § 6.23), Pennsylvania (see, VGP § 

6.24)). 

The standards contained in state requirements applicable to ballast water vary in terms of 

their stringency, schedules for implementation, and types of vessels covered. While this 

paper will not attempt to describe state requirements in detail, readers can refer to Table 1

for a summary of selected state ballast water discharge standards for organisms. 

 

8 As explained in the VGP Fact Sheet: “Part 6 of the final VGP identifies provisions provided to EPA by 

States and Tribes in their CWA § 401 certifications that the States and Tribes deemed necessary to assure 

compliance with applicable provisions of the CWA and any other appropriate requirements of State and 

Tribal law. See 33 U.S.C. 1341(d); 40 C.F.R. § 124.53(e)(1). Pursuant to CWA § 401(d), EPA has attached 

those State and Tribal provisions to the final VGP; those that constitute effluent or other limitations or 

monitoring requirements are enforceable conditions of the federal permit. American Rivers, Inc. v. FERC, 

129 F.3d 99, 107 (2nd Cir. 1997).”
9 

Table 1. Selected Ballast Water Discharge Standards for Organisms (Current as of June 28, 2010). 

Size: ≥ 50 

micrometers 

(μm)*

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

(BWM/CONF/

13 & 14)

< 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 NPRM

(74 FR 

44632)

[PHASE 1 

STANDARD]

< 10 

organisms 

per m3

[PHASE 1 

STANDARD]

< 10 organisms 

per ml

[PHASE 1 STANDARD]

Vibrio cholera

< 1 CFU per 100 ml

E. coli

< 250 CFU per 100 ml

Intestinal enterococci

< 100 CFU per 100 ml

[PHASE 1 

STANDARD]

----

Yes

On delivery for all 

vessels constructed 

on or after 01/01/12

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

[PHASE 2 

STANDARD]

< 1 organism

per 100 ml

[PHASE 2 STANDARD]

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

[PHASE 2 

STANDARD]

< 104 viruses 

or viral-like 

particles per 

100 ml

Yes

On delivery for all 

vessels constructed 

on or after 01/01/16

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
10

Size: ≥ 50 

micrometers 

(μm)*

Size: < 50μm, but 

≥ 10 μm Bacteria Viruses “Lakers**” Covered? Compliance Date

CALIFORNIA

(VGP 401 

cert/State 

regulations)

[INTERIM 

STANDARD]

0 detectable 

“living” 

organisms

[INTERIM 

STANDARD]

US negotiating 

position

[INTERIM STANDARD]

Vibrio cholera 

IMO Reg D-2 #

E. coli

US negotiating position

Intestinal enterococci 

US negotiating position

< 103 bacteria per 100 ml

[INTERIM 

STANDARD]

< 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

[FINAL 

STANDARD]

0 detectable 

“living” organisms

[FINAL STANDARD]

0 detectable “living” 

organisms

[FINAL 

STANDARD]

0 detectable 

“living” 

organisms

N/A 01/01/2020

ILLINOIS

(VGP 401 

cert)

IMO Reg D-2 

# 

(as daily 

average)

IMO Reg D-2 #

(as daily 

average)

Vibrio choleraa

----

E. coli

IMO Reg D-2 #

(as daily average)

Intestinal enterococci

IMO Reg D-2 #

(as daily average)

---- Yes

Constructed before 

01/01/12: 

01/01/16

Constructed after 

01/01/12: 

Prior to operation

INDIANA

(VGP 401 

cert)

IMO Reg D-2 

# b

 

(as daily 

average)

IMO Reg D-2 # b

(as daily 

average)

Vibrio choleraa

----

E. coli

IMO Reg D-2 #

(as daily average)

Intestinal enterococci

IMO Reg D-2 #

(as daily average)

---- No

Constructed before 

01/01/12: 

01/01/16

Constructed after 

01/01/12: 

Prior to operation
11

Size: ≥ 50 

micrometers 

(μm)*

Size: < 50μm, but 

≥ 10 μm Bacteria Viruses “Lakers**” Covered? Compliance Date

MICHIGAN

(VGP 401 

cert/State 

permit)

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/State 

permit)

IMO Reg D-2 

# b

(as daily 

average)

IMO Reg D-2 # b

(as daily 

average)

Vibrio choleraa

- 

E. coli

IMO Reg D-2 #

(as daily average)

Intestinal enterococci

IMO Reg D-2 #

(as daily average)

---- Yes

Constructed before 

01/01/12: 

01/01/16

Constructed after 

01/01/12: 

Prior to operation

NEW YORK

(VGP 401 

cert)

[INTERIM 

STANDARD]

< 1 “living” 

organism 

per 10 m3

[INTERIM 

STANDARD]

< 1 “living” 

organism 

per 10 ml

[INTERIM STANDARD]

Vibrio cholera

IMO Reg D-2 #

E. coli

US negotiating position 

Intestinal enterococci

US negotiating position

[INTERIM 

STANDARD]

----

Yes 

(vessels operating 

exclusively within 

Lakes Ontario and 

Erie are exempt)

01/01/12 

(subject to case-bycase time extension)

[FINAL 

STANDARD]

Same as 

California #s

[FINAL 

STANDARD]

US negotiating 

position

[FINAL STANDARD]

Vibrio cholera

IMO Reg D-2 #

E. coli

US negotiating position 

Intestinal enterococci

US negotiating position 

Other bacteria: 

Same as CA interim #s

[FINAL 

STANDARD]

Same as 

California 

interim #s

Yes 

(vessels operating 

exclusively within 

Lakes Ontario and 

Erie are exempt)

Constructed on or 

after 01/01/13

(subject to case-bycase time extension)
12

Size: ≥ 50 

micrometers 

(μm)*

Size: < 50μm, but 

≥ 10 μm Bacteria Viruses “Lakers**” Covered? Compliance Date

OHIO

(VGP 401 

cert)

IMO Reg D-2 

# b

(as daily 

average)

IMO Reg D-2 # b

(as daily 

average)

Vibrio choleraa

----

E. coli

IMO Reg D-2 #

(as daily average)

Intestinal enterococci

IMO Reg D-2 #

(as daily average)

----

Yes 

(in part -- see 

column to right)

Lakers “launched” 

after 01/01/16: 

Immediate

Non-Lakers 

“launched” before 

01/01/12: 01/01/16

Non-Lakers 

“launched” after 

01/01/12: Prior to 

operation

PENNSYLVANIA

(VGP 401 

cert)

[INTERIM 

STANDARD]

IMO Reg D-2 #

[INTERIM 

STANDARD]

IMO Reg D-2 #

[INTERIM STANDARD]

IMO Reg D-2 #

[INTERIM 

STANDARD]

----

Yes 

(vessels 

operating 

exclusively within 

Lake Erie are 

exempt)

Constructed before 

01/01/12: 

01/01/16

(subject to case-bycase time 

extension)

[FINAL 

STANDARD]

Same as 

California #s

[FINAL 

STANDARD]

< 0.01 “viable” 

organism per ml

[FINAL STANDARD]

Vibrio cholera

IMO Reg D-2 #

E. coli

US negotiating position 

Intestinal enterococci

US negotiating position 

Other bacteria:

Same as CA interim #s

[FINAL 

STANDARD]

Same as 

California 

interim #s

Yes 

(vessels 

operating 

exclusively within 

Lake Erie or PA 

waters are 

exempt)

Constructed after 

01/01/12: 

Immediate

(subject to case-bycase time 

extension)
13

Size: ≥ 50 

micrometers 

(μm)*

Size: < 50μm, but 

≥ 10 μm Bacteria Viruses “Lakers**” Covered? Compliance Date

WISCONSIN 

(11/18/09 

State permit)

< 1 “viable” b

organisms 

per 

10 m3 

(as daily 

average)

< 1 “viable” b 

organisms per 

10 ml 

(as daily 

average)

Vibrio choleraa 

---

-E. coli

US negotiating position 

(as daily average)

Intestinal enterococci

US negotiating position 

(as daily average)

---- Noc

Constructed after 

01/01/12:d 

Immediate

Constructed before 

01/01/12:d 01/01/14

* For some standards, the groupings actually 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 vs. IMO G8 (type approval) Guidelines (para 3.12) simply 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 VGP 

(uptake and discharge practices). 

d WI DNR intends to conduct a review by 12/31/10 to determine if BWT technology is available to meet the WI standards; if review concludes such BWT 

technology not available, the IMO Reg D-2 # will apply (subject to footnotes a & b). WI permit must be modified for this change to occur. 
14 

2.3. International Regulation 

The role of ships’ ballast water in introducing or spreading ANS has been a concern in 

the international community since the early 1990s. 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 and other ballast water management practices. IMO 

Assembly Resolution A.868(20). (Many of the practices contained in that resolution are 

now, in effect, mandatory with respect to vessels with ballast tanks that operate in US 

waters by virtue of their inclusion in the previously discussed USCG ballast water 

regulations at 33 C.F.R. Part 151, Subpart D.) 

Following adoption of that resolution in 1997, a ballast water working group was then 

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 such meetings, there was a gradual 

evolution away from reliance on ballast water exchange 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 the IMO in February 

2004 which adopted the text of a ballast water management Convention. International 

Convention for the Control and Management of Ships’ Ballast Water and Sediments, 

2004 (hereinafter referred to as “the BW Treaty”). The BW Treaty will not enter into 

force until it has been signed (and, if necessary, ratified) by at least 30 countries 

representing not less than 35% of the gross tonnage of the world’s merchant shipping. 

BW Treaty Article 18(1). The US is presently not a signatory, nor, as of the date of this 

paper, has the treaty entered into force internationally. Information on the status of IMO 

Conventions (as posted on the IMO website http://www.imo.org/home.asp) indicates that 

as of May 31, 2010, the BW Treaty has 25 Parties, representing 24.28% gross tonnage of 

the world’s merchant shipping. 

In effect, the provisions of the BW treaty will apply to Parties’ commercial ships that 

engage in international voyages. See, BW Treaty Article 3. Subject to certain exceptions 

as set out in BW Treaty Regulations A-3 through A-5, such vessels must conduct ballast 

water exchange, and over time, according to a schedule dependent on vessel build date 

and ballast water capacity, comply with the Treaty’s ballast water discharge standards. 

BW Treaty Regulation B-3. Those discharge standards address three size groupings of 

organisms, and as previously noted, are expressed as a concentration of organisms per 

unit of volume discharged. BW Treaty Regulation D-2; see also Table 1 (summarizing 

those standards). The three size groupings used in Regulation D-2 are based on 

minimum dimension and are as follows: 1) organisms >50 microns (to address 

macrofauna and zooplankton); (2) organisms >10 but <50 micron (to address 

phytoplankton); and (3) specified indicator bacteria (to address pathogens). During 

development of the 2004 treaty, the US took a negotiating position that the standards for 
15

the two larger size groupings, ought to be 1,000 times more stringent than those 

ultimately adopted (see Table 1). However, the treaty does preserve the ability of Parties 

to adopt more stringent standards as necessary. BW Treaty Regulation C-1; see also, BW 

Treaty Article 2(3). 

Under the Treaty, ballast water treatment systems are subject to a review and approval 

process, taking into account Guidelines developed by MEPC for such reviews. BW 

Treaty Regulation D-3. With respect to systems using “Active Substances” (biocidal 

agents) to comply with the BW Treaty, review and approval by the MEPC is conducted 

as to the environmental and safety aspects related to the system's use of biocides. The 

technical procedures for that review (commonly referred to as the “G9 Guidelines” or 

“G9 Procedure”) are set forth in Resolution MEPC.169(57). Under the G9 Procedure, 

systems using Active Substances are subject to an initial “Basic Approval” and then a 

“Final Approval” by MEPC as to the environmental and safety aspects of the biocide’s 

use. In addition, all systems (whether or not using Active Substances) are subject to a 

separate testing and approval process, this time by the Administration (typically the Flag 

state), as to the ability of the system to kill or remove organisms such that the results of 

the tests conducted on the system indicate it can meet the BW Treaty Regulation D-2 

discharge standards (this type of testing is commonly referred to in IMO as “typeapproval testing”). That type-approval testing is conducted under guidelines developed 

by the MEPC (the “G8 Guidelines”) for evaluating compliance with the Regulation D-2 

standards. MEPC Resolution MEPC.174(58). Typically, for those systems using Active 

Substances, final approval by MEPC under the G9 Procedure will precede flag state typeapproval under G8. 

Although the BW Treaty is not yet in force, a number of systems nonetheless have been 

submitted for review under the processes described above. The outcome of such reviews 

provides some third-party perspective regarding the development of the technologies so 

reviewed. Copies of such IMO documents have been provided to the SAB and are 

discussed in greater detail in Section 4.3. 

3. General Overview of Ballast Water Treatment System Design 

Treatment of ships’ ballast water can take place either on the vessel or off the vessel 

following discharge of the ballast to a reception/treatment vessel (where the water would 

no longer be considered ballast water) or to a land-based reception facility. Treatment 

systems intended for onboard use by vessels discharging their ballast water directly into 

receiving waters have received the most attention by technology developers. Information 

in this overview section comes from the Lloyd’s Register Review of Ballast Water 

Treatment Technology (February 2010) (hereinafter referred to as “Lloyd’s Register 

Review”). While providing the most comprehensive summary of the current status of 

treatment technology, that review is based entirely on information supplied by the 

technology vendors. It is not based on an independent analysis or verification of claims 

made by the authors of the Lloyd’s Register Review. 
16

3.1. Treatment Processes

BWT systems are broadly based on three main processes: physical separation, biocidal 

treatment, and physical-chemical processes. Some BWT systems incorporate a 

combination of these processes. A brief description of each process is below. 

Physical separation

While separation in the broader water treatment industry includes several different 

processes, for ballast water treatment it is essentially limited to screen and disk filters 

and/or hydrocyclonic separators. The former are almost all self-backwashing designs. 

Some media filters have been examined, but weight and cleaning issues have generally 

proved discouraging – although at least one novel concept for use of compressed crumb 

rubber has been published (Tang et al., 2006; Tang et al., 2009). 

In general, hydrocyclones have not proven to be very effective, and only a few BWT 

systems using them are still in active development (Gregg et al., 2009). Separation is 

used as part of a process train to both remove larger organisms (generally, pore sizes of 

25 – 100 um are used), and represent a balance between the need to remove organisms, 

the need to move large amounts of BW very rapidly (hundreds to many thousands of 

cubic meters per hour), and the need to reduce the amount of solids in ballast water to 

facilitate the action of various biocidal processes. As nominal pore size decreases, backwash cycling increases, and effective pumping rates decrease. Lowered pumping rates 

can significantly slow cargo operations, with consequent economic impacts to carriers 

(vessel owners/operators) and shippers (the companies paying vessels to carry cargo). 

At least one system developer (the Hitachi Ballast Water Purification System

(“Clearballast”)) has incorporated flocculants or coagulants to facilitate the separation 

processes. This is particularly important for the use of hydrocyclones, which work on the 

basis of differential density, and most of the organisms that need to be removed from 

ballast water are not much denser than the water.

Biocidal treatment

Biocides used in BWT systems include chemicals such as oxidizing solutions (usually 

created by electrolytic processes using sea water as the source of ions), chlorine dioxide, 

and peracetic acid; non-oxidizing chemicals such as menadione/vitamin K (trade name 

SeaKleen©). 

Systems using chemical biocides need to be designed to avoid discharging unwanted 

concentrations of residual biocide. A further issue with systems using chemical biocides 

is the potential for production of disinfection by-products, such as trihalomethanes and 

halo-acetic acids. 

Many of the systems currently available or in development use chemical neutralizing 

agents prior to discharge. According to the Lloyd’s Register Review, most ozone and 
17

chlorine systems neutralize treated ballast water before discharge, but some do not. 

Some treatment system developers rely on minimum hold times to provide an opportunity 

for sufficient degradation of residuals. In at least one case this has proven problematic 

for a type-approved system. The Hamman-SEDNA® ballast water treatment system 

using PERACLEAN® Ocean, which uses the proprietary biocide PERACLEAN® Ocean, 

a peracetic acid-based oxidant, was found to have significantly longer degradation rates 

in cold water than was expected, and the system has subsequently been taken off the 

market (Eason, 2010; Lloyds, 2010). This issue may not be unique to PERACLEAN®

Ocean, as other biocides have also been found to have variable degradation rates 

dependent upon temperature (Landrum et al., 2003). This example provides an indication 

of the current limitations of the international approval process in that the G8 and G9

Guidelines were not subject to validation prior to their use. Furthermore, the challenge 

conditions that are specified in the G8 Guidelines may not provide for an adequate test of 

system performance under the full range of vessel operations for which the systems are 

intended. Temperature and salinity are two important examples, as it is possible under 

the current test procedures for systems to be type approved for all temperatures and 

salinities, while only being subjected to testing under a relatively narrow, and nonextreme, range of both. See Section 4.4 for additional discussion. 

Physical-Chemical Processes

Physical-chemical processes used as means to kill organisms include Ultraviolet (UV) 

and ultrasonic (US) radiation, shear/cavitation; and deoxygenation (through lowered 

pressure via venturi or vacuum, or lowered partial pressure via gas sparging with inert 

gasses).

Most of the systems using UV employ medium pressure amalgam lamps, although some 

low-pressure systems exist. UV effectiveness depends on the applied UV dose/power of 

the lamp, however, the Lloyd’s Register Review states that this information has not been 

given by all suppliers. The transmissivity of the water being treated is another critical 

variable affecting the effectiveness of UV systems. Without accessory filtration, or other 

separation of solids, UV will not likely be as effective as necessary. While all UV-based 

systems to date employ front-end separation processes to improve transmission of UV, 

the challenge conditions required for type approval under the G8 Guidelines (TSS > 50 

mg/L for brackish and fresh water; POC > 5 mg/L for brackish and fresh water) are far 

below the levels that can be encountered in estuarine harbors around the world (by 2 

orders of magnitude for TSS). 

Although most of the systems that currently exist are based on traditional water treatment 

processes, deoxygenation-based technologies have been specifically developed for ballast 

water treatment. Deoxygenation is accomplished through a variety of mechanisms, 

including pressure drops and gas sparging of inert gases. Deoxygenation may take longer 

than other processes (between one and four days seems likely, given current information), 

and thus represents the only type of technology where voyage length is a primary factor 

in process efficacy – although as mentioned above, some of the systems using chemical 

biocides include a minimum treatment time for sufficient action and degradation). 
18

Deoxygenation may not be as broadly effective as other means of disinfection, as some 

organisms, particularly microorganisms, are able to survive for extended periods of time 

under low oxygen conditions. 

3.2. Treatment Systems

Most treatment systems make use of 2 or more treatment processes in a train, for 

example, physical separation followed by some type of biocidal treatment(s). In practice, 

some systems, particularly those using separation and UV, are used on both uptake and 

discharge of ballast water. On uptake the full process train is engaged, with back-flushed 

solids from the filter being discharged overboard at the point of uptake. On discharge of 

the ballast water, the filter is bypassed and the water is exposed to the UV process 

immediately prior to discharge. An apparent assumption by many of the developers of 

these separation+UV systems is that there is no regulatory or environmental concern 

about the discharge of the filter backwash to the environment, since the water and 

sediment is “just being put back where it was taken up...”. However, some jurisdictions 

have regulatory limits on suspended solids, and concentrations of other substances such 

as metals that such backwashing may exceed. 

Several systems use 3 or more processes. At least one system exists for each of the 

following designs: 

• Filter+UV+O3

• Filter+US+O3

• Filter+electrolysis+US

• Filter+deoxygenation+cavitation

• Filter+cavitation+electrolysis+O3

• Shear+cavitation+O3

The expected relative contributions of each process to the system efficacy, under the wide 

range of conditions under which the systems will be expected to work, is not always 

apparent in the information available for many of these systems. 

3.3. Treatment System Requirements 

Size (foot-print, volume, weight) and power requirements are key issues of concern for 

vessel operators considering the pros and cons of alternative treatment systems. For 

operational and logistical reasons, most treatment systems are intended for use in engine 

or pump rooms, where space is quite limited. Until the last year or two, provision of 

sufficient space in these areas for BWT systems have not been requirements in vessel 

designs. Consequently, installation often requires fitting the different modules into 

available spaces on an ad hoc basis. The larger the system, or the more inflexible its 

physical arrangement, the more negatively it is likely to be viewed by ship 

owners/operators. The availability of power is an issue because ships often have 

competing demands on available power during cargo operations when most ballast water 
19

is taken on and discharged; and upgrading generator capacities to provide additional 

power necessary for ballast water treatment is an additional expense, both in capital costs 

and on-going fuel costs. This also results in other increased environmental impacts by 

increasing green house gas and other emissions. Consequently, the systems currently in 

play have a fairly narrow range of space and power requirements (Table I). However, it 

is important to keep in mind that in most cases, these numbers are for individual, or a 

small number of ganged, units. Many of these systems are designed to handle high flow 

rates by using multiple units, each rated for 200 – 300 m3/h. In such situations, both 

space and power requirements would be significantly larger, although the relationship 

between flow and size is not necessarily linear.

Table 2. System Space and Power Characteristics for Ballast Water Treatment Systems 

(From Table 4 in Lloyd’s Register Review). 

Footprint 200 

m3/h (m2) 

Footprint 2000 

m3/h (m2) 

Height (m) Power (kW 

/1000 m3) 

Mean 7 21 3 68

Data Points 37 30 37 33

Min 0.3 1 1 0

Max 30 145 4.6 220

3.4. Treatment System Flow Capacities

While more than half of the vendors polled by Lloyd’s claim to offer systems that can 

handle flow rates of >10,000 m3

/h, in many cases, this would be achieved through 

ganging multiple system units rated individually at 200-300 m3

/hr. However, systems are 

not generally tested for type approval in such ganged configurations and at such high 

flow rates.

3.5. Availability of Treatment Systems 

Since the adoption of the IMO BWM Convention in 2004, and more particularly since 

the initial adoption of the G8 Guidelines for approval of ballast water management 

systems in 2005, a substantial number of treatment systems have been put into 

development globally (Figure 1). The apparent decline in new systems as shown in 

Figure 1 may reflect a real plateau in the number of systems, or may be an artifact of the 

process. Many systems do not come to public light until they apply for G9 Basic 

Approval by the MEPC, and it is at that time that estimates are made for their timelines 

for Final Approval by MEPC and G8 type approval by an Administration. For instance, 

applications for Basic Approval of five systems not identified in the Lloyd’s Register 

Review of February 2010 have been submitted for consideration by MEPC in September 

of 2010; however, we have included these systems in Table 5 of this paper. 
20

Figure 1. Number of systems approved by year. 

BA= MEPC Basic Approval; 

FA= MEPC Final Approval; 

TA= Administration Type Approval. 

All numbers from 2010 onwards are predictions made in February 2010. Data from Lloyd’s Register 

Review (2010).

4. Technical Documents Provided to the Committee

Under the G8 Guidelines for type approval of ballast water management systems, ballast 

water treatment vendors must show that their systems meet the IMO Regulation D-2 

Standards (see Table 1) in three consecutive valid shipboard test cycles and five 

consecutive valid land-based cycles to obtain type approval. Much of the living organism 

effluent data discussed below, particularly that collected in recent years, was gathered

with the intention of seeking type approval from a given flag Administration. Other data 

were assembled in applications for acceptance of vessels in the vessel’s Shipboard 

Technology Evaluation Program (STEP), discussed in greater detail on page 26 of this 

paper. Because this is pre-existing information developed under procedures not subject 

to our control, EPA nor Coast Guard staff cannot provide any quality assurance or quality 

control on any of the data or reports provided to the committee for this review, nor 

confirm the testing results reported actually meet the minimum guideline standard of 

passing three consecutive valid shipboard test cycles and five consecutive valid landbased cycles. 

In order to assist with the committee’s evaluation, EPA has provided numerous 

background documents discussing ballast water treatment systems and reporting results 

from their testing. For purposes of this paper, these documents have been divided into 

three major categories. The first category contains summary reports produced by parties 

evaluating the availability of existing ballast water treatment systems or their potential 
21

efficacy (Section 4.1). These reports will help inform the committee about ballast water 

treatment systems in general, issues that may be present in their testing, and in some 

cases, provide summary data. These reports thus should be useful or provide 

introductory background to help the committee answer all seven charge questions. 

The second category of background documents contains the primary performance data 

reports available to EPA and USCG (Section 4.2). These are land based and/or ship 

based testing reports, provided by either flag Administrations9

30

or the manufacturers, to 

EPA or USCG. Performance reports or summaries of evaluations are available for 8 

systems; many of these reports go into considerably more detail than the summary reports 

above. Many of these documents also give engineering details which may prove useful 

to the committee in answering questions 1c, 2, and 3 of the charge. However, detailed 

results discussing the quality of the effluent produced during the tests are notably absent 

from several of these available sources. Additionally, although we are aware that data 

have been collected on other additional systems, those data are not all available to us to 

provide to this committee: see additional discussion on page . 

The third grouping of background documents are being provided to serve as a reference 

library for the committee (Section 4.3). With one exception, these documents have been 

prepared as reports for, or submissions to, IMO as part of the G9 Procedure review 

process and contain additional background on system design for committee members. An 

additional document written by a class society10 is also included in this section. Because 

this is provided as background information for that purpose, we do not expect each 

committee member to review all the issues addressed in each of these documents. 

Additionally, we discuss the potential availability of other information, which we would 

welcome committee members to introduce at the first committee meeting. Section 4.3

also contains a table (Table 5) which committee members can use as a guide to get a 

sense of all known ballast water treatment systems and where they stand in development 

and testing. For instance, if a treatment has been type approved, clearly data have been 

collected regarding treatment system performance, however, in many cases, those data 

are not currently available to us for supply to the committee.

All of the documents being provided to the committee are being supplied on a 

supplemental CD11

 

9 Flag Administration means the Government of a State whose flag the ship is entitled to fly (from 

. On that CD, an Excel index is provided which includes the system 

discussed, the title of the document, the date, and a hyperlink from that file to the targeted 

file. That index listing all documents supplied to the committee is also provided here as 

Appendix IV. We believe that committee members can use this resource as a tool to 

assist in their evaluation of the information provided, and to identify strengths and 

shortcomings in data availability to assist in answering the charge questions. 

33 CFR 

§ 169.5). 10 The IACS defines class societies as “organizations that establish and apply technical standards in relation 

to the design, construction and survey of marine related facilities including ships and offshore structures.” 11 All documents provided on this CD and listed in Appendix IV are also included in a public docket. That 

docket, number EPA-HQ-OW-2010-0582, can be accessed at www.regulations.gov. 
22

4.1. Third Party Reports or General Evaluations 

There are six documents being provided to the committee which are third party reports or 

general evaluations. We believe that these documents will prove a significant resource 

for the committee by providing additional useful background information and an 

overview of system engineering designs, the complexities associated with evaluating 

these systems, and in the case of Dobroski et al., (2009a), summary data. These 

documents are: 

 

• The February 2010 review prepared by Lloyd’s Register and submitted to 

IMO on the current status of ballast water treatment technologies (Lloyds, 

2010); 

• A June 2010 report produced by American Bureau of Shipping (ABS), 

which examines ballast water treatment systems and discusses 

considerations for shipowners when they select and install these systems; 

(ABS 2010) 

• A January 2009 assessment of the efficacy, availability and environmental 

impacts of ballast water treatment systems for use in California Waters 

prepared for the California State Legislature by staff from the California 

State Lands Commission (Dobroski et al., 2009a); 

• An October 15, 2009, update for that California report (Dobroski et al., 

2009b); 

• A September 24, 2009, Circular prepared by the IMO Secretariat on the 

international approval status for various ballast water treatment systems 

that make use of Active Substances (IMO, 2009); 

• Excerpts from a white paper titled “Density Matters,” produced by Lee et 

al. (2010), which, in part, examined Dobroski’s et al. analyses (2009a, 

2009b) of systems that may be potentially available to meet the California 

Standard. 

Lloyd’s Register Review 

The February 2010 Lloyd’s Register Review discusses the status and availability of 

existing ballast water treatment systems. This review, based upon ballast water treatment 

manufacturer survey responses, addresses issues such as space requirements, system 

costs, system capacities, and systems’ IMO approval status12. 

American Bureau of Shipping Ballast Water Treatment Advisory (ABS, 2010)

In June 2010, the classification society ABS published an Advisory on Ballast Water 

Treatment Technologies. Similar to the Lloyd’s Register Review, the ABS Advisory 

gives an overview of treatment technologies and lists the status of various ballast water 

treatment systems. However, this document also goes into detail for factors vessel 

 

12 Note that we have provided an updated status as to ballast water approval of various systems by the IMO 

that is current as of June, 2010 in Table 4 in Section 4.3 of this document.
23

operators should consider when they purchase and install various systems such as

corrosion and safety concerns, power ratings, total lifecycle costs, and ease of operation. 

In addition to providing information targeted to shipowners, the appendix of that report 

also provides summary information on 14 different ballast water treatment systems, with 

links to each of those manufacturers’ websites. The ballast water treatment systems for 

which it lists summary information are the Alfa Laval Ballast Water Management 

(PureBallast) System, Electro-CleenTM System (ECS), OceanSaver® Ballast Water 

Management System, Venturi Oxygen Stripping (VOS) System, Hyde GuardianTM

Ballast Water Treatment System, NK-O3 BlueBallast, OptiMarin Ballast System (OBS), 

Hitachi Ballast Water Purification (ClearBallast) System, GloEn-PatrolTM System, 

Resource Ballast Technologies System/Unitor BWTS, JFE BWMS, Hyundai Heavy 

Industries (HHI) EcoBallast System, RWO GmbH Marine Water Technology, Veolia 

Water Solutions & Technologies (CleanBallast) System and Greenship Sedinox® Ballast 

Water Management System. Note that the only systems for which we are able to provide 

primary data in Section 4.2 are the NEI Venturi Oxygen Stripping (VOS) system and the 

Hyde Marine (Hyde GuardianTM) System (both underlined above). 

2009 Assessment of the Efficacy, Availability and Environmental Impacts of Ballast 

Water Treatment Systems for Use in California Waters (Dobroski et al., 2009a)

The California State Lands Commission has prepared a report, as directed by the 

California Coastal Ecosystems Protection Act of 2006, as to “the efficacy, availability, 

and environmental impacts, including water quality, of currently available ballast water 

treatment technologies.” (Dobroski et al., 2009a). The authors provide summaries of 

various treatment technologies, explanations of how they used vendor supplied data to 

evaluate those technologies, and conclusions on what they believe those data might mean 

for system availability. Based on their criterion of “at least one replicate in compliance 

with the performance standards” for each size grouping13, irrespective of failure rate, the 

CSLC concluded that: “at least two treatment systems have demonstrated the potential to 

comply with California’s performance standards.”14 However, the authors of the report 

take pains to note that: “the [California State Lands] Commission does not approve 

ballast water treatment systems” and that a “positive compliance assessment for the 

purpose of th[eir] report, however, does not relieve the vessel owner/operator of the 

responsibility of complying with California’s performance standards for the discharge of 

ballast water.” In addition to descriptions of ballast water treatment systems and their 

analyses, the authors provide vendor-supplied summary data in the Appendices, which 

may be useful for the committee in answering question 1 of the study charge.

Lee et al. (2010), discussed below, also describes the California report, which may 

further inform the SAB’s analyses of technology availability. 

 

13 Excluding viruses: there are currently no known viable methods to test for viruses in ballast water 

effluent.

14 California Performance Standards are listed in Table 1. 
24

October 2010 Update: Ballast Water Treatment Technologies for Use in California 

Waters (Dobroski et al., 2009b)

In October, 2009, Dobroski et al. updated the previous version of the report. In this 

update, the authors evaluated additional data and concluded on the basis of the same 

criterion as in the first report that “at least seven ballast water treatment systems: Alfa

Laval, Ecochlor®, SEDNA® ballast water treatment system using PERACLEAN® Ocean, 

Hyde MarineTM, OceanSaver®, OptiMarin, and Techcross have demonstrated the 

capability to comply with California’s performance standards for the discharge of ballast 

water.” Similar to the first report, the authors note that the report does not: “constitute an 

endorsement or approval of any treatment system or system manufacturer by the 

Commission. The Commission does not approve ballast water treatment systems.”

 

Unlike the 2009a full report, the interim report does not contain an appendix with the 

primary vendor-supplied data used in the analysis. According to CSLC staff, an updated 

version of this report, containing such data, may be available in summer of 2010. If 

finalized, that report would be made available at: 

http://www.slc.ca.gov/Spec_Pub/MFD/Ballast_Water/Reports_Presentations.html. 

IMO’s International Convention for the Control and Management of Ships’ Ballast Water 

and Sediments, 2004 - List of ballast water management systems that make use of Active 

Substances which received Basic and Final Approvals (BWM.2/Circ 23)

The September 24, 2009 IMO Secretariat Circular (BWM.2/Circ 23) provides a list of 

systems that have received G9 ”Basic” or “Final” approval for their use of Active 

Substances, reflecting the decisions made up to and including the 59th meeting of the 

MEPC. Note that such approvals only apply to evaluating the potential risk from the 

biocides or by products used by the ballast water treatment system and do not evaluate 

the efficacy of the system in neutralizing living organisms. Hence, these approvals are 

not directly relevant in terms of showing the degree of treatment these systems can 

achieve; rather this document is being provided in this section to serve two purposes. 

First, the document provides a compendium of ballast water treatment systems which use 

Active Substances as of September, 2009. Second, it gives the reviewer a general sense 

of where these treatment systems are in the international approval process.

Additionally, so as to provide the most updated information possible, we have 

summarized subsequent G9 decisions that were made at the 60th meeting of the MEPC in 

the Table 3. This Table should be used as a supplement to the IMO Circular 23 to update 

the Active Substance approval status for the systems it addresses.
25

Table 3. Additional G9 Decisions Made Subsequent to BWM.2/Circ.23 (List of ballast water 

management systems that make use of Active Substances which received Basic and Final Approvals). 

MEPC 60 G9 Decisions (March 26, 2010)15

Basic Approval GRANTED

Siemens SiCURETM Ballast Water Management System Proposed by Germany in document MEPC 

59/2/11

Sunrui Ballast Water Management System Proposed by China in document MEPC 60/2/3

DESMI Ocean Guard Ballast Water Management System Proposed by Denmark in document MEPC 

60/2/4

Blue Ocean Guardian (BOG) Ballast Water Management 

System 

Proposed by the Republic of Korea in 

document MEPC 60/2/5

Hyundai Heavy Industries Co., Ltd. (HHI) Ballast Water 

Management System

(HiBallast)

Proposed by the Republic of Korea in 

document MEPC 60/2/6

Kwang San Co., Ltd. (KS) Ballast Water Management 

System "En-Ballast"

Proposed by the Republic of Korea in 

document MEPC 60/2/7

OceanGuardTM Ballast Water Management System Proposed by Norway in document MEPC 

60/2/8

Severn Trent DeNora (BalPure®) Ballast Water 

Management System

Proposed by Germany in document MEPC 

60/2/9

Basic Approval DENIED

ATLAS-DANMARK Ballast Water Treatment System Proposed by Denmark in document MEPC 

60/2

Final Approval GRANTED

GloEn-PatrolTM Ballast Water Management System Proposed by the Republic of Korea in 

document MEPC 59/2/7

Resource Ballast Technologies System Proposed by South Africa in document MEPC 

59/2/10

JFE Ballast Water Management System (BallastAce) Proposed by Japan in document MEPC 60/2/2

HHI Ballast Water Management System (EcoBallast) Proposed by the Republic of Korea in 

document MEPC 60/2/1

Final Approval DENIED

Ecochlor® Ballast Water Management System Proposed by Germany in document MEPC 59/2/9

Density Matters: Review of Approaches to Setting Organism-Based Ballast Water 

Discharge Standards (Lee et al., 2010).

Density Matters (Lee et al., 2010) was specifically written to supply background 

information to the ongoing NRC study examining approaches to setting environmentally 

protective organism-based ballast water discharge standards16

 

15 Source: Report of the 60th Meeting of the Marine Environment Protection Committee, MEPC 60/22 

(see discussions therein under agenda item 2).

. There are two major 

16 As discussed in the introduction to this paper, EPA and USCG are currently sponsoring a 

contemporaneous study led by the National Academy of Sciences’ National Research Council (NRC) to 

examine that issue (see Appendix II). In that NRC study, EPA and USCG are requesting that the NRC 

broadly assess and make recommendations about various approaches for assessing the risk of establishment 

of new ANS from ballast water discharges. 
26

sections of this paper which are relevant to the charge presented to the SAB. The first 

section discusses California’s zero detectable discharge limit, and includes a discussion 

of the data evaluation in Dobroski et al. (2009a, 2009b). The second relevant section 

examines the statistical considerations in estimating concentrations of organisms larger 

than 50 microns in ballast water discharges. This section discusses statistical

considerations which were not considered in development of the G8 Guidelines, and 

points to limitations in arriving at statistically significant or conclusive results based on 

data collected using methods consistent with the G8 Guidelines.17 Additional extracts 

from this report include regulatory background and another table listing ballast water 

discharge standards to serve as additional references for the committee as needed. 

Additionally, the bibliography from the Lee et al. (2010) paper is included to serve as a 

reference list if needed.

4.2. Available Information for Specific Ballast Water Treatment Systems 

In order to evaluate the efficacy of their ballast water treatment systems, several vendors 

have conducted land-based and/or ship-based evaluations of their systems. The reports 

provided to the committee fall into three categories: (1) those that include data reports 

from the testing of ballast water treatment systems provided to foreign Administrations in 

granting type approval under the BW Treaty and (2) data reports gathered by vendors in 

preparation to apply for type approval by a flag Administration, or (3) application packets 

prepared by the vendor and submitted to the USCG under the Shipboard Technology 

Evaluation Program (STEP). We believe the information in this section should help the 

committee answer questions 1, 2, and 3 of the charge.

As previously discussed, in order to be type-approved in terms consistent with the BW

Treaty (International Maritime Organization, 2004), all ballast water systems (whether or 

not using Active Substances) are subject to a testing and approval process by an 

Administration (typically the Flag state or their authorized representative). These tests 

must demonstrate the ability of the system to kill or remove organisms such that the 

results of the tests conducted on the system indicate it can meet the Treaty’s Regulation 

D-2 discharge standards (see Table 1). This type of testing is commonly referred to as 

“type-approval testing” and it is to be conducted under G8 Guidelines as set forth in 

resolution MEPC.174(58) (October 10, 2008). Many of the reports included below were 

prepared as part of a system manufacturer’s preparations for seeking such G8 typeapproval. 

STEP was established by the US Coast Guard in 2004 as a way to encourage onboard 

ballast water treatment system development and testing. According to the US Coast 

Guard’s: January 2, 2004, Navigation and Vessel Inspection Circular No. 01-04 for the 

STEP program:

 

17 EPA and USCG are working toward finalizing an ETV Ballast Water Protocol, which will include 

updates to discharge testing recommendations to address issues associated with such monitoring 

complexity, including discussing statistical limitations. 
27

“STEP is intended to facilitate the development of effective BWT technologies, thus 

creating more options for vessel owners/operators seeking alternatives to ballast water 

exchange. Technology developers and vessel owners/operators have agreed on the need 

for incentives that will encourage the development of prototype treatment systems and 

shipboard testing. However, vessel owners/operators have expressed a reluctance to 

invest the resources to install and operate an experimental treatment system that might 

not meet discharge standards mandated by future regulations. To address this concern, 

vessels accepted into this program may be granted an equivalency to future ballast water 

discharge standard regulations, for up to the life of the vessel or the system, while the 

prototype system operates satisfactorily.”

Systems entering the STEP program are generally in the advanced prototype stage. 

Hence, the data provided as part of STEP application may not be the most current data, 

and may also not reflect the most current changes to a system. For example, the 

Ecochlor® system, discussed below, has data in its STEP application, and then more 

current data in a land-based report. Between preparation of these two packages, the 

system underwent a modification, whereby a filter was added to increase system 

performance.

Systems for which Data Reports are Provided to the Committee

This section contains reports or papers on eight separate treatment systems, most of 

which contain at least some primary summary data. These reports generally do not 

contain significant raw data. This section is organized by treatment manufacturer, with 

each data report briefly introduced in that section. In many cases, we have not been able 

to obtain primary data reports for this committee’s review. Generally, data on systems 

provided by willing flag Administrations are more thorough and developed than data 

provided under STEP, through peer reviewed papers, or simply flag Administration 

papers submitted to the IMO. The systems for which flag administrations either provided 

reports to the Coast Guard or made those reports publically available were Hamann AG 

(Sedna® BWMS), Hyde Marine, and NEI Treatment Systems LLC (all noted below). 

Echoclor®, NEI Treatment Systems LLC, and Severn Trent De Nora include information 

provided to the Coast Guard as part of the STEP application process. Additionally, 

Echoclor® contains a land based data report provided to EPA for purposes of this 

committee’s review. Other information is from papers submitted to the IMO, peerreviewed journal articles, and other published reports. The final subsection (discussing 

Oceansaver®, OptiMarin, and PureBallast) contains examples of several type approval 

certificates for certain systems for which we do not have data or summary reports from 

the flag Administration or the treatment system developer. 

Table 4 lists each individual system for which we were able to provide the committee 

with additional specific information beyond their G9 summary reports or type approval 

certificates Type Approval Certificates, highlights how that system functions, and where 

that additional information can be found. Note that the names of systems which have 

been type-approved are shaded in green (see section 2.3 for discussion regarding type 

approval and Table 5 for additional treatment system specific information).
28 

Table 4. Ballast Water Treatment Systems for which we have provided additional information.

Supplier

System Technology

Have shipbased or 

land-based 

testing been 

conducted?

Are data available 

to this committee in 

this package (other 

than G9 summary 

reports or Type 

Approval 

Certificates)?

Document where 

Data can be found

Alfa Laval Tumba AB

(Pureballast) Filtration, UV, TiO2 Y2 N Norwegian Maritime 

Directorate (2008)

Ecochlor Inc.

(Ecochlor® BWMS)

Filtration, chlorine 

dioxide Y Y Veldhuis et. al (2009) 

and Ecochlor (2006)

Environmental 

Technologies Inc.

Filtration, ozone, 

ultrasound1 Y Y3 Dobroski et al. 

(2009a) 

Greenship (Sedinox® 

BWMS)

Hydrocyclone, 

electrolysis/ 

electrochlorination

Y Y Siefert and Siers 

(2007)

Hamann AG

(SEDNA® 250 BWMS)

Hydrocyclone, 

filtration, peracetic acid Y Y 

Veldhuis and Fuhr 

(2008) and Eason 

(2010)

Hi Tech Marine Pty Ltd. Heat1 Y Y3 Dobroski et al. 

(2009a)

Hyde Marine; Lamor 

Corporation, LLC

(Hyde Guardian)

Filtration, UV Y Y 

ten Hallers et al 

(2009); Veldhuis et al 

(2009b); Wright (2009)

Marenco Technology 

Group, Inc. Filtration, UV1 Y Y3 Dobroski et al. 

(2009a) 

Mitsui Engineering and 

Shipbuilding Co. Ltd.

(SP-Hybrid BWMS Ozone 

Version)

Hydrodynamic shear, 

cavitation, ozonation1 Y Y3 Dobroski et al. 

(2009a) 

NEI Treatment Systems 

LLC

(Venturi Oxygen Stripping 

(VOS))

Deoxygenation, 

cavitation Y Y NEI (2007)

Oceansaver AS

(OceanSaver® BWMS)

Filtration, 

deoxygenation, 

cavitation

Y2, Y3

Norwegian Maritime 

Directorate (2009b), 

Dobroski et al. 

(2009a)

OptiMarin

(OptiMarin Ballast System) Filtration, UV1 Y2, Y3

Norwegian Maritime 

Directorate (2009a) 

and Dobroski et al. 

(2009a)

Severn Trent De Nora

(BalPure®)

Filtration, electrolysis/ 

electrochlorination, Cl 

neutralization

Y Y3 Dobroski et al. 

(2009a) 

Siemens

(SiCURETM BWMS)

Filtration, 

electrochlorination Y Y Cangelosi, (2010a, 

2010b) 

Techcross

(Electro-Clean System 

(ECS))

Electrolysis/ 

electrochlorination 

Y Y Kim et al (2008)

Vitamar, LLC

(SeakleenTM)

Menadione / Vitamin 

K3 (as SeakleenTM)1 Y Y3 Dobroski et al. 

(2009a) 

1 Information from Lloyd's Register Review (2010).

2 Land-based testing results, which to date, have not been given to US EPA or the US Coast Guard 

3 Information on whether testing had taken place came from Dobroski et al. 2009 discussed in Section 4.1. Summary 

data only 
29 

Ecochlor® Inc. (Ecochlor® BWMS):

Three documents are included which describe the performance of the Ecochlor system. 

The first document is Section 4 of Ecochlor's 2006 STEP application and were provided 

to USCG to enroll a testing vessel into STEP (Echoclor, 2006). These data are from early 

shipboard testing of the full-scale Ecochlor system and do not reflect current system 

design (a filter has subsequently been incorporated in the system) or use the most current 

testing approaches. The second document by Veldhuis et al. (2009a) reports on the landbased testing results from the current design of the Ecochlor system. The authors of that

report tested the Ecochlor system (including the mechanical filter) and noted that no 

regrowth of organisms in treated effluent was observed for more than 15 days. 

Environmental acceptability tests showed that the growth of plankton was not limited by 

the discharge water indicating that the discharged water was not significantly toxic. 

Furthermore, upon discharge, no residual effects of the chemical treatment to the 

receiving environment were observed. The third document is the final Environmental 

Assessment prepared by USCG to accept this system for a particular vessel into the STEP 

program (USCG, 2008).

Note that the Ecochlor® system has not yet been type-approved. Also, as noted in Table 

5, the Ecochlor® system was denied final approval at a recent MEPC meeting, as 

recommended by GESAMP. The manufacturers of the system have submitted 

information to MEPC to seek this final approval and are preparing a package to submit 

for type approval of the system by the German Administration. See, MEPC 61/2/8. 

Electro-Clean Ballast Water Management System:

Kim et al. (2008) discuss constructing a large test barge for land-based testing for Type 

Approval of ballast water management systems in the Republic of Korea. The paper 

describes the Electro-Clean System. This paper provides no data on the efficacy of the 

treatment system. The second document is the MEPC 59/INF.6 paper submitted by the 

Republic of Korea on the G8 type approval of this system. This paper notes that the 

system has ‘passed’ various components of testing, without discussing methods in depth 

or giving any specific results. Also note that this MEPC paper includes the table of 

contents for a more detailed report; however, at this time, we do not have a copy of these 

results.

Greenship’s Sedinox® ballast water treatment system:

A single document for the Greenship (Sedinox® BWMS) is included here (Siefert and 

Siers, 2007). This short 10 page report, published in 2007, described the land based 

testing for discharges from a moored vessel utilizing the Greenship ballast water 

treatment system. 

Note that the Greenship Sedinox® BWMS has received IMO G9 Basic and Final 

approval, but has not yet received type approval. 
30

Hamann AG (Sedna® BWMS)18 (note: recently removed from the market):

Four documents in this section reference the Hamann AG (Sedna®) system. The Hamann 

AG (Sedna®) system uses a hydrocyclone to separate out some solids (potentially 

including living organisms) and then treats the less turbid water with a proprietary

biocide known as Peraclean®. The first document, Siefert and Siers (2007), is a summary 

data report. The second document, the Veldhuis and Fuhr (2008) report, describes the 

land-based tests which were run on the Sedna® system, and provides some summary data 

on the residual discharge. The researchers in this report also found that there were no 

residual biocidal effects and the Active Substance was found to decompose in 24 hours. 

After 5 days in seawater tests, the authors noted a slight but insignificant effect from 

remaining acetic acid.

However, there were several questions regarding the potential toxicity of Peraclean® in 

coldwater and freshwater ecosystems. Further testing revealed that Peraclean® remained 

toxic in these environments, and Hamann subsequently pulled this treatment system from 

the market (Eason, 2010; Lloyds, 2010). Hence, though this treatment system received 

G9 Basic and Final approval, and was type-approved under the G8 Guidelines, it was 

later found to pose an unacceptable ecological risk. 

Even though the Hamann AG system has been removed from the market, we have 

included these data here for two purposes. First, this data report adds another example of 

primary summary data for the committee to consider in what might be possible for 

existing treatment systems. Secondly, it also serves as an example that, even though 

treatment systems undergo significant toxicological testing and G9 review, they may still 

be found to cause unacceptable secondary environmental impacts in receiving waters at a 

later date due to the biocide residual discharge.

Hyde Marine Lamor Corporation, LLC19 (Hyde GuardianTM): 

Five documents are included which exclusively discuss the Hyde Marine System. The 

first document does not discuss the efficacy of the system in neutralizing living 

organisms, instead, ten Hallers et al. (2009) provides a description of how the system 

works and its use of filtration and UV treatment. The report further discusses the risk to 

safety of the ship, ship integrity, if the system can be installed safely in a hazardous area, 

corrosivity, risk for fire and explosion, the absence of risk from chemicals (there are no 

active substances used), risk to the crew, risk to human health, risk to the aquatic 

environment, and noise level. The report’s authors also examine information on potential 

byproducts and end products, their toxicological profile, and the actual presence or 

absence of those products under potential conditions the system might meet. The authors 

note the environmental benefits of the Hyde System not using Active Substances.

 

18 Note that the data for this system were made publicly available by the German Government as a flag 

Administration.

19 Note that the data for this system were made publicly available by the British government as a flag 

Administration.
31

The second document by Veldhuis et al. (2009b) summarizes results from tests run on the 

Hyde GuardianTM system. The authors report that treatment by the system was found not 

to deactivate the entire plankton community, and environmental acceptability tests 

showed that growth of organisms was not limited by the discharge water (and therefore, 

did not have notable toxicity). The third document by Wright (2009) summarizes the 

results of shipboard testing of the Hyde System. 

The final two documents are the MEPC 59/INF.20 report where the United Kingdom 

reports to the IMO that the Hyde System has been type approved by that flag 

Administration and a copy of the type approval certificate.

NEI Treatment Systems LLC (Venturi Oxygen Stripping (VOS)) 20

Six documents are provided to support the analysis of the NEI Treatment Systems LLC, 

representing one of the more complete data packets available to the committee. These 

documents generally discuss results for both the efficacy of the system at neutralizing 

organisms and its potential toxicity, testing methods, and give an overview of the 

engineering of the systems. One document is the USCG STEP Application (NEI, 2006). 

This application contains the study plan for evaluation onboard a test vessel, a description 

of how the system functions, and other information including discussions of vessel and 

crew safety. A second document is the application for type approval certification 

submitted by NEI to the Liberian Flag Administration. Similar to the STEP application, 

this document contains an overview of how the system functions and testing results 

regarding the efficacy of the treatment system, among other things. A third document, 

Tamburri and Ruiz (2005), is a peer reviewed paper which provides summary data of the 

efficacy of the NEI system. The fourth and fifth documents are acute and chronic 

toxicity reports (Burton et al., 2008; Fischer et al., 2009). These short reports summarize 

the results of Whole Effluent Toxicity testing of effluent from lab scale NEI units. The 

final document contains three type approval certificates (Liberia, Malta, and The 

Marshall Islands), which show that this system has received flag Administration approval 

from three separate Administrations. 

Severn Trent De Nora (BalPure®)

Three documents are provided which discuss the Servern Trent De Nora BalPure®

system. The first is an application package the company submitted to the State of 

Washington to obtain approval to use the system in that State’s waters (Severn Trent De 

Nora, 2005). That package contains detailed information about how the company’s 

BalPure® system works, and alludes to work conducted which examined the efficacy of 

that system in land-based testing. The second document (Herwig, 2004), a mesocosmscale study, examines the efficacy of this type of system at eliminating certain organisms, 

and whether the residuals from the system contain significant total residual oxidant 

(TRO). The third document is the Environmental Assessment prepared for the USCG 

discussing the design of the system and its potential impacts on the aquatic environment 

 

20 Note that much of the data for this system were provided by the Liberian Government as a flag 

Administration.
32

(Volpe, 2009). Though these documents do not provide the level of discharge data 

provided by other systems discussed in this section (e.g., NEI, Hyde Marine), these 

documents provide engineering overviews, and some early monitoring results collected 

for this system. Additionally, note that summary data on the BalPure® system are 

presented in Dobroski et al., 2009a. 

Siemens (SiCURETM BWMS)

Two documents are included which summarize treatment efficacy from the Siemens 

(SiCURETM BWMS) ballast water treatment system (Cangelosi, 2010a; Cangelosi 

2010b). In Cangelosi (2010a), the Siemens SiCURETM system was evaluated for its 

ability to remove living organisms from ballast water, meet the BW Treaty Regulation D2 discharge standards after a 5-day holding time, and discharge non-toxic water after a 5-

day retention period. Researchers noted that further testing would be needed to 

characterize residual toxicity after a 5-day retention period, but that no effect was 

detected during these trials. In Cangelosi (2010b), the author discusses ballast water 

management system’s use in the Great Lakes. The researchers discussed what they 

deemed “below the radar” zooplankton, and other issues related to State ballast water 

discharge limits compared to the Regulation D-2 standard. In this report, the authors note 

that this system likely needs a neutralization step for residual chlorine for ballast water 

discharges into the Great Lakes from Great Lakes confined vessels (Lakers) due to short 

voyage times. 

Note that as of the writing of this paper, this system has received G9 Basic Approval, but 

has not yet received such Final Approval, nor has it been type approved under the G8 

Guidelines by a flag Administration.

Oceansaver®, OptiMarin, and PureBallast:

Oceansaver®, OptiMarin, and PureBallast are three separate ballast systems which have 

all received type approval from their respective flag Administrations (see Table 5). As of 

June 15, 2010, Oceansaver® has announced that they have system contracts or signed 

letters of intent for 11 ballast water treatment systems for Very Large Crude Carriers 

(Maritime Executive, 2010). According to the manufacturer, this represents 

approximately 40 million dollars of anticipated ballast water treatment system 

installation. In short, this indicates that this system has obtained some degree of 

commercial desirability.

Two documents are available for Oceansaver®, neither of which contain primary 

summary data. One document is the MEPC 59/INF.17 submitted by the government of 

Norway describing that they type approved the Oceansaver® system. The second 

document is a type approval certificate from the Norwegian flag Administration

(Norwegian Maritime Directorate, 2009b). 

However, neither the government of Norway nor the Norwegian Institute for Water 

Research testing facility (NIOZ) have released sampling methodologies or data from their 
33

sampling to USCG21. As such, EPA and USCG have not been able to independently 

evaluate data on the efficacy of these ballast water treatment systems. 

For both the Alfa Laval PureBallast (Norwegian Maritime Directorate, 2008) and 

OptiMarin (Norwegian Maritime Directorate, 2009a) systems, only the type approval 

certificates are available. The Alfa Laval PureBallast system was granted type approval 

by the flag Administration of Norway in 2008 while the OptiMarin system was granted 

type approval in 2009 (see Table 5).

4.3. G9 Papers and Other Information 

Several papers (including G9 applications and resulting technical reviews) have been 

assembled for the committee collectively labeled “G9 Papers.” These papers are 

included to serve as a reference section for committee members22

2.3

. As discussed above in 

Section , systems using “Active Substances” are subject to approval by the IMO’s 

Marine Environment Protection Committee (MEPC) under BW Treaty Regulation D-3 as 

to the environmental and safety aspects related to the system's use of biocides. The G9 

Procedure for that review is set forth in MEPC resolution MEPC.169(57) (April 4, 2008). 

Under the G9 Procedure, systems using Active Substances are subject to an initial “Basic 

Approval” and then a “Final Approval” by MEPC as to the environmental and safety 

aspects of the active substances as used in that system. 

In addition to discussing the environmental and safety impacts of the biocide’s use23

(which is beyond the direct scope of the committee’s charge), each of the G9 Papers

outlines how a given ballast water treatment system functions, and in some cases, its 

expected mechanism of neutralizing living organisms. Hence, these documents might 

have some utility in providing general information on systems’ designs.

Table 4 below was derived in large part from these MEPC documents and lists 52 

different ballast water treatment systems. Systems for which Primary Data Reports are 

available in Section 4.2 are underlined under the “Supplier System” column. The 

reference library of MEPC documents contains the MEPC documents describing 26 of 

these systems. The reference library also contains several meeting reports which, in 

 

21 Despite several requests to the Flag Administrations, neither Norway nor the Republic of Korea have 

provided test reports for systems granted type approval by those countries 22 We do not expect committee members to review all of these documents, nor do we expect feedback on 

their quality, but we are making them available so committee members could read more about ballast water 

treatment systems with biocides if they need additional general information about a given treatment 

system’s design.

23 Ballast water treatment systems are designed to kill living organisms – if not properly managed, these 

systems may discharge harmful levels of residuals into neighboring waters. We have not asked the 

committee to delve into these issues merely so as not to distract from answering the important question at 

hand – what is the status of technology for effectively and practicably killing or removing living organisms 

before discharge. However, the committee should be cognizant that some of these systems use biocides; 

the use of which must be carefully managed so as not to create one environmental problem while solving 

another.
34

addition to discussing these 26 systems, discuss many of the other systems listed in Table 

5. 

As part of these reference documents, we are also including an additional document 

developed for vessel owners about how to approach purchase and installation of a ballast 

water treatment system which was produced by a vessel classification society (ClassNK, 

2010). Like many of the documents in Section 4.1, the document provides background 

information on the 2004BW Treaty, testing of systems, and generalized information 

about how treatment system works. The document also contains frequently asked 

questions which illustrate some of the complexities with installing these systems onboard 

existing vessels.

As noted above, G8 type approval has been granted for several systems for which neither 

EPA nor USCG have full primary data packs. As shown in Table 5, ten systems 

currently have type approval; however, as discussed in Section 4.2, we only have type 

approval packages for 3 of these systems. Because these systems have been type 

approved, efficacy data on the numbers of living organisms must exist which would have 

been provided to the flag Administrations granting that type approval.24

4.2

 Additionally, 

numerous systems, similar to Ecochlor® as discussed in section , are advanced in their 

development: system designers and developers have likely taken a reasonable level of 

sampling data for these systems before continuing to invest millions of dollars in their 

development. We have not been able to gather and consolidate all existing, available data 

for the committee. Provided that such data are taken by a credible third party within the 

relatively recent past using appropriate test methods, we would encourage introduction 

and use of these data for the committee’s deliberations. We would particularly encourage 

use of these supplemental data for those systems which are type approved by a flag 

Administration. In short, we recognize that there must be relevant additional data 

besides that which we have been able to obtain and provide to the committee. If 

committee members have access to credible additional data, we would encourage their 

use to inform the committee's deliberations.

 

24 Certain system manufacturers and testing facilities are treating the data collected and methods used as 

proprietary or confidential information, which unfortunately impedes additional independent evaluation of 

the availability and efficacy of those systems.
35 

Table 5 Summary Status of Ballast Water Treatment Systems which use Active Substances (Current as of June 16, 2010, through MEPC 61/2/13).

Supplier

System Process

G9 Active 

Substance Approval 

(Basic)1

G9 Active 

Substance 

Approval 

(Final)1

G8 System 

Approval2 Test Site Type Approval Units Installed3

Projected 

Production 

(Units/Year)3

Notes

21st Century 

Shipbuilding Co., 

Ltd.

(ARA Ballast)

Filtration, 

plasma arc 

shockwave, 

and ultraviolet

March 2010

MEPC 60/22 ¶ 2.4.4

MEPC 60/2/12 Annex 

8 [GESAMP]

MEPC 60/2/5

MEPC 61/2/5 - 

TongYeong, 

Korea

- - - 

The name of this system was 

changed from "Blue Ocean 

Guardian BWMS" to "ARA 

Ballast;" see MEPC 61/2/5 ¶ 

5.

Alfa Laval Tumba 

AB

(Pureballast)

Filtration and 

ultravioletTiO2

July 2007

MEPC 56/23 ¶ 2.8

MEPC 55/2/5

July 2007

MEPC 56/23 ¶ 

2.8

MEPC 56/2/2 

Annex 5 

[GESAMP]

MEPC 56/2/1

April 2008 NIVA

27 June 2008

Norway

MEPC 58/2/12 

Annex ¶ 6.3

5 - 

MEPC 53/2/6, MEPC 53/2/14, 

MEPC 53/2/16, MEPC 

55/INF.3, MEPC 57/2/9

AQUA Eng. Co., 

Ltd.

(AquaStar BWMS)

Filtration and 

electrolysiselectrochlorina

tion

MEPC 61/2/1 - - - - - - 

The "Smart Pipe Unit" forms 

part of the AquaStar Ballast 

Water Management System.

Aquaworx ATC 

GmbH

(AquaTriCombTM

BWTS)

Filtration, 

ultraviolet, and 

ultrasound

July 2009

MEPC 59/24 ¶ 2.5.3

MEPC 59/2/19 Annex 

6 [GESAMP]

MEPC 59/2/8

- - - - - - 

ATG Willand Filtration and 

ultraviolet - - - - - 1 - 

ATLAS-DANMARK

(ATLAS-DANMARK 

BWTS)

Filtration and 

"mixed oxidant 

approach" 

(oxidation); 

electrolysis

MEPC 60/22 ¶ 2.6

MEPC 60/2/12 Annex 

4 [GESAMP]

MEPC 60/2

- - - - - 3 This system uses ANOLYTE 

and CATHOLYTE.

Auramarine Filtration and 

ultraviolet - - Land (Jan10) NIVA - 0 Unlimited 

Brillyant Marine 

LLC Electric pulse - - - Maryland - 0 Unlimited 
36

Supplier

System Process

G9 Active 

Substance Approval 

(Basic)1

G9 Active 

Substance 

Approval 

(Final)1

G8 System 

Approval2 Test Site Type Approval Units Installed3

Projected 

Production 

(Units/Year)3

Notes

China Ocean 

Shipping (Group) 

Company 

(COSCO)/Tsinghua 

University

(BlueOcean Shield 

BWMS)

Hydrocyclone, 

filtration, and 

ultraviolet

July 2009

MEPC 59/24 ¶ 2.5.1

MEPC 59/2/16 Annex 

7 [GESAMP]

MEPC 59/2/2

- - - - - - 

Coldharbour Marine

Deoxygenatio

n and 

cavitation

- - - NIOZ - - - 

DESMI Ocean 

Guard A/S

(DESMI Ocean 

Guard BWMS)

Filtration, 

ultraviolet, and 

ozonation

March 2010

MEPC 60/22 ¶ 2.4.3

MEPC 60/2/12 Annex 

7 [GESAMP]

MEPC 60/2/4

- - DHI - - - 

Ecochlor Inc.

(Ecochlor® BWMS)

Filtration and 

ClO2

October 2008

MEPC 58/23 ¶ 2.6.3

MEPC 58/2/8 Annex 5 

[GESAMP]

MEPC 58/2/2

MEPC 61/2/8

MEPC 60/22 ¶ 

2.11

MEPC 60/2/11 

Annex 5 

[GESAMP]

MEPC 59/2/9

Land (Jun08)

Sea 

Ongoing

NIOZ - 2 100

This system uses Purate®.

 

Ecochlor® BWMS is installed 

on board Atlantic Container 

Lines' ATLANTIC COMPASS 

and Matson Shipping's 

MOKU PAHU as a part of the 

USCG STEP (73 FR 72814; 

73 FR 72819). MEPC 

53/2/14, MEPC 53/2/16

Electrichlor 

Hypochlorite 

Generators Inc.

Filtration and 

electrolysiselectrochlorina

tion

- - - - - 3 240 

Environmental 

Technologies Inc.

Filtration, 

ozone, and 

ultrasound

- - - - - 0 - MEPC 53/2/14

Envirotech and 

Consultancy Pte. 

Ltd.

(BlueSeas BWMS)

Filtration and 

electrolysiselectrochlorina

tion

MEPC 61/2/12 - - - - - - 

ERMA FIRST 

E.S.K. Engineering 

Solutions S.A.

(ERMA FIRST 

BWMS)

Filtration, 

hydrocyclone, 

and 

electrolysiselectrochlorina

tion

MEPC 61/2/11 - - - - - >100

ERMA FIRST E.S.K. 

Engineering Solutions S.A. is 

associated with 

Environmental Protection 

Engineering S.A. (MEPC 

61/2/11 Annex, ¶ 1.1).
37

Supplier

System Process

G9 Active 

Substance Approval 

(Basic)1

G9 Active 

Substance 

Approval 

(Final)1

G8 System 

Approval2 Test Site Type Approval Units Installed3

Projected 

Production 

(Units/Year)3

Notes

Gauss Filtration and 

ultraviolet - - - - - 0 - 

MEPC 53/2/11 Annex 2, 

MEPC 53/2/16, MEPC 

56/2/10

Greenship

(Sedinox® BWMS)

Hydrocyclone 

and 

electrolysiselectrochlorina

tion

October 2008MEPC 

58/23 ¶ 2.6.2MEPC 

58/2/7 Annex 6 

[GESAMP]MEPC 

57/2/7

July 

2009MEPC 

59/24 ¶ 

2.8.4MEPC 

59/2/19 Annex 

5 

[GESAMP]ME

PC 59/2/6

Land (Oct07)Sea 

(Jun-08)

Harlingen - 2 Unlimited MEPC 53/2/16

Hamann AG

(SEDNA® 250 

BWMS)

Filtration and 

Peraclean®

March 2006

MEPC 54/21 ¶ 2.8

MEPC 54/2/12 Annex 

5 [GESAMP]

MEPC 53/2/12

April 2008

MEPC 57/21 ¶ 

2.16

MEPC 57/2/10 

Annex 7 

[GESAMP]

MEPC 57/2/5

June 2007 NIOZ

10 June 2008

Germany

MEPC 58/INF.17

2 65

This system uses Peraclean® 

Ocean. MEPC 53/2/11 

Annex 3, MEPC 53/2/14, 

MEPC 53/2/16, MEPC 

55/2/17 Annex 5, MEPC 

56/2/10, MEPC 57/2/9. This 

system has been withdrawn 

from the market (Lloyd's, 

2010).

Hi Tech Marine Pty 

Ltd. Heat - - Land (Feb03) Sydney - 0 - 

Hitachi

(Hitachi Ballast 

Water Purification 

System - 

ClearBallast)

Filtration and 

precoagulation 

(enhanced 

flocculation)

April 2008

MEPC 57/21 ¶ 2.11

MEPC 57/2 Annex 5 

[GESAMP]

MEPC 57/2/2

July 2009

MEPC 59/24 ¶ 

2.8.3

MEPC 59/2/19 

Annex 4 

[GESAMP]

MEPC 59/2/5

Land (Jun08)

Sea (Jul08)

- 5 March 2010

Japan 0 50 MEPC 54/2/9, MEPC 55/2/15

Hyde Marine; 

Lamor Corporation, 

LLC

(Hyde Guardian)

Filtration and 

ultraviolet N/A N/A

Land (Apr09)

Sea (Apr09)

NIOZ

29 April 2009

UK

MEPC 59/INF.20

15 500

This system is installed on 

board Princess Cruise Lines' 

CORAL PRINCESS as a part 

of the USCG STEP (73 FR 

72817). MEPC 53/2/14, 

MEPC 53/2/16

Hyundai Heavy 

Industries (HHI)

(EcoBallast)

Filtration and 

ultraviolet

July 2009

MEPC 59/24 ¶ 2.5.2

MEPC 59/2/16 Annex 

8 [GESAMP]

MEPC 59/2/4

March 2010

MEPC 60/22 ¶ 

2.13

MEPC 60/2/1

MEPC 59/24 ¶ 

2.7

MEPC 59/2/16 

[GESAMP] ¶ 

4.7

Land (2008)

Sea (2009) HHI - 1 98 
38

Supplier

System Process

G9 Active 

Substance Approval 

(Basic)1

G9 Active 

Substance 

Approval 

(Final)1

G8 System 

Approval2 Test Site Type Approval Units Installed3

Projected 

Production 

(Units/Year)3

Notes

Hyundai Heavy 

Industries (HHI)

(HiBallast)

Electrolysiselectrochlorina

tion and 

optional

filtration

March 2010

MEPC 60/22 ¶ 2.4.5

MEPC 60/2/16 Annex 

4 [GESAMP]

MEPC 60/2/6

- Land (2009) HHI - 1 165 

JFE Engineering 

Corporation

(JFE BWMS

(BallastAce)) 

Filtration, 

chlorination, 

and cavitation

October 2008

MEPC 58/23 ¶ 2.6.1

MEPC 58/2/7 Annex 5 

[GESAMP]

MEPC 57/2/8

March 2010

MEPC 60/22 ¶ 

2.7.3

60/2/12 Annex 

5 [GESAMP]

MEPC 60/2/2

Land (Mar09)

Sea (Sep09)

NIVA - 1 300

JFE and Toagosei Group 

were originally categorized 

separately. The suppliers 

were combined because: 1. 

JFE is partnered with TG 

Corporation (Lloyd's, 2008 

and 2010), the manufacturer 

of TG BallastCleaner; and 2. 

Language used in MEPC 

60/2/2 indicates that the 

companies are developing 

one treatment system (the 

JFE BWMS).

MEPC 55/2/15. This system 

uses TG Ballastcleaner and 

TG Environmentalguard.

Kuraray Co., Ltd.

(Kuraray BWMS)

Filtration and 

calcium 

hypochlorite

MEPC 61/2/6 - - - - - - 

Kwang San Co., 

Ltd. (KS)

(En-Ballast)

Filtration and 

electrolysiselectrochlorina

tion

March 2010

MEPC 60/22 ¶ 2.4.6

MEPC 60/2/16 Annex 

5 [GESAMP]

MEPC 60/2/7

- - - - - - 

M H Systems

Deoxygenatio

n with inert 

gas and CO2

- - - SIO - 0 300 

Mahle NFV GmbH Filtration and 

ultraviolet - - Land (2009)Sea (2010) NIOZ - 1 At least 50 

Marenco 

Technology Group, 

Inc.

Filtration and 

ultraviolet - - 20074 MLML - 1 240-360 MEPC 53/2/14
39

Supplier

System Process

G9 Active 

Substance Approval 

(Basic)1

G9 Active 

Substance 

Approval 

(Final)1

G8 System 

Approval2 Test Site Type Approval Units Installed3

Projected 

Production 

(Units/Year)3

Notes

Mexel Industries

Non-oxidizing 

biocide 

treatment

- - - - - 2 Unlimited 

Mitsubishi Heavy 

Industries, 

Ltd.(Hybrid BWTS)

Filtration and 

electrochlorina

tion

MEPC 56/23 ¶ 

2.10MEPC 56/2/2 

Annex 7 

[GESAMP]MEPC 

56/2

- - - - - - 

This system uses the 

"Marine-Growth-Prevention 

System." MEPC 55/2/15

Mitsui Engineering 

and Shipbuilding 

Co. Ltd.

(FineBallast MF)

Filtration (prefiltration and 

membrane 

filtration)

MEPC 61/2/3 - - - - - - 

Mitsui Engineering 

and Shipbuilding

Co. Ltd.

(Special Pipe 

Hybrid BWMS 

Combined with 

PERACLEAN®

Ocean (SPOSYSTEM))

Shear, 

cavitation, and 

PERACLEAN®

Ocean

Applicant states that 

Basic Approval of 

PERACLEAN® was 

granted at MEPC 54 

(see entries for 

Hamann AG's 

SEDNA® system)

MEPC 61/2/10 Land (2008)

Imari 

City, 

Japan

- - - 

It is assumed that Mitsui 

Engineering and Shipbuilding 

Co. Ltd. manufactures this 

system because:

 - The name of the system is 

similar to that of another Mitsui 

product, the "Special Pipe 

Hybrid BWMS" (or "SP-Hybrid 

BWMS Ozone Version; see 

MEPC 59/2/1 ¶ 3

 - MEPC 61/2/10 Section 1.1 

states that the SPO-SYSTEM 

"represents one version of SPHybrid BWMS" (emphasis 

added)

 - MEPC 61/2/10 was 

submitted to IMO by Japan, as 

were the applications for Basic 

and Final approval of Mitsui's 

SP-Hybrid BWMS Ozone 

Version

Mitsui Engineering 

and Shipbuilding 

Co. Ltd.

(SP-Hybrid BWMS 

Ozone Version)

Hydrodynamic 

shear, 

cavitation, and 

ozonation

October 2006

MEPC 55/23 ¶ 2.16

MEPC 55/2/16 Annex 

5 [GESAMP]

MEPC 55/2

MEPC 61/2/2

MEPC 59/24 ¶ 

2.10

MEPC 59/2/16 

Annex 4 

[GESAMP]

MEPC 59/2/1

Land (Feb08)

Sea (Jul09)

JAMS - 1 40-100

The name of this system was 

changed to "Special Pipe 

Hybrid Ballast Water 

Management System 

combined with Ozone 

treatment version (SP-Hybrid 

BWMS Ozone Verision);" see 

MEPC 61/2/2 ¶ 3. MEPC 

53/2/16, MEPC 54/2/9, MEPC 

55/2/15, MEPC 57/2/9
40

Supplier

System Process

G9 Active 

Substance Approval 

(Basic)1

G9 Active 

Substance 

Approval 

(Final)1

G8 System 

Approval2 Test Site Type Approval Units Installed3

Projected 

Production 

(Units/Year)3

Notes

NEI Treatment 

Systems LLC

(Venturi Oxygen 

Stripping (VOS))

Deoxygenatio

n and 

cavitation

N/A N/A - NOAA

11 October 

2007

Liberia

6 200 MEPC 53/2/14, MEPC 

53/2/16

NK-O3

(BlueBallast 

Ozone)

Ozonation

July 2007

MEPC 56/23 ¶ 2.9

MEPC 56/2/2 Annex 6 

[GESAMP]

MEPC 55/2/27

MEPC 55/23 ¶ 2.16

MEPC 55/2/16 Annex 

6 [GESAMP]

MEPC 55/2/3

July 2009

MEPC 59/24 ¶ 

2.8.2

MEPC 59/2/16 

Annex 6 

[GESAMP]

MEPC 59/2/3

MEPC 58/23 ¶ 

2.11

MEPC 58/2/8 

Annex 6 

[GESAMP]

MEPC 58/2/3

Land (2008)

Sea (2008) KOMERI

24 November 

2009

Korea

MEPC 60/INF.14

4 400-700

NK-O3 is affiliated with 

Nutech O3 (as listed in Lloyd's 

Register Reports). MEPC 

53/2/14, MEPC 55/2/21, 

MEPC 57/2/9

Oceansaver AS

(OceanSaver®

BWMS)

Filtration, 

deoxygenation

, and 

cavitation

April 2008

MEPC 57/21 ¶ 2.17

MEPC 57/2/10 Annex 

8 [GESAMP]

MEPC 57/2/6

October 2008

MEPC 58/23 ¶ 

2.10

MEPC 58/2/8 

Annex 4 

[GESAMP]

MEPC 58/2/1

Land (Nov07)

Sea (Sep08)

NIVA

17 April 2009

Norway

MEPC 59/INF.17

6 >200 MEPC 53/2/16, MEPC 

55/INF.3

OptiMarin

(OptiMarin Ballast 

System)

Filtration and 

ultraviolet N/A N/A

Land (May08)

Sea (Jan09)

NIVA

12 November 

2009

Norway

11 1000 MEPC 53/2/14, MEPC 

53/2/16, MEPC 55/INF.3

Panasia Co Ltd 

Korea

(GloEn PatrolTM) 

Filtration and 

ultraviolet

April 2008

MEPC 57/21 ¶ 2.15

MEPC 57/2/10 Annex 

6 [GESAMP]

MEPC 57/2/4

March 2010

MEPC 60/22 ¶ 

2.7.1

MEPC 60/2/11 

Annex 4 

[GESAMP]

MEPC 59/2/7

Land (Dec08)

Sea (Oct09)

KORDI

4 December 

2009

Korea

2 1400 

Pinnacle Ozone 

Solutions

Filtration and 

ozonation - - - GSI - - - 

Qingdao Headway 

Technology Co., 

Ltd.

(OceanGuardTM) 

Filtration, 

electrolysiselectrochlorina

tion, and 

ultrasound

March 2010

MEPC 60/22 ¶ 2.4.7

MEPC 60/2/16 Annex 

6 [GESAMP]

MEPC 60/2/8

MEPC 61/2/7

Land (Oct09)

Sea (Early10)

NIVA - 1 2000

This system uses "Advanced 

Electrocatalysis Enhanced by 

Ultrasonic Technology 

(EUT)."
41

Supplier

System Process

G9 Active 

Substance Approval 

(Basic)1

G9 Active 

Substance 

Approval 

(Final)1

G8 System 

Approval2 Test Site Type Approval Units Installed3

Projected 

Production 

(Units/Year)3

Notes

Qwater Filtration and 

ultrasound - - - - - 0 - MEPC 53/2/16

Resource Ballast 

Technologies (Pty) 

Ltd.(Resource 

Ballast 

Technologies 

System / Unitor 

BWTS)

Cavitation, 

ozonation, 

electrochlorina

tion, and 

filtration

April 2008MEPC 

57/21 ¶ 2.14MEPC 

57/2/10 Annex 5 

[GESAMP]MEPC 

56/2/3

March 

2010MEPC 

60/22 ¶ 

2.7.2MEPC 

60/2/11 Annex 

7 

[GESAMP]ME

PC 59/2/10

Land 

(2010)Sea 

(2010)

Cape 

Town - 4 2000+ MEPC 53/2/16

RWO GmbH 

Marine Water 

Technology, Veolia 

Water Solutions & 

Technologies

(CleanBallast!)

Filtration, 

electrolysiselectrochlorina

tion, and 

advanced 

oxidation

October 2006

MEPC 55/23 ¶ 2.16

MEPC 55/2/16 Annex 

7 [GESAMP]

MEPC 55/2/4

July 2009

MEPC 59/24 ¶ 

2.8.1

MEPC 59/2/16 

Annex 5 

[GESAMP]

MEPC 59/2

MEPC 57/21 ¶ 

2.12

MEPC 57/2/13

MEPC 57/2 

Annex 6 

[GESAMP]

MEPC 57/2/3

Land (Sep07)

Land (Nov08)

Sea (Jan10)

Bremen 

2007

NIVA 

2008

- 16 Unlimited

This system uses EctoSys®

. 

MEPC 53/2/11 Annex 1, 

MEPC 53/2/16, MEPC 

54/INF.6, MEPC 55/2/17 

Annex 1, MEPC 56/2/10, 

MEPC 57/2/9

Sea Knight 

Corporation

Vacuum deoxygenation 

and bioremediation

- - - Virginia - 0 Unlimited 

Severn Trent De 

Nora

(BalPure®

)

Filtration and 

electrolysiselectrochlorina

tion

March 2010

MEPC 60/22 ¶ 2.4.8

MEPC 60/2/16 Annex 

7 [GESAMP]

MEPC 60/2/9

MEPC 61/2/9 Land (Jul09) NIOZ - 2 100

This system is installed on 

board SeaRiver Maritime's 

S/R AMERICAN PROGRESS 

as a part of the USCG STEP 

(74 FR 38666). MEPC 

53/2/16

Siemens

(SiCURETM BWMS)

Filtration and 

electrochlorina

tion

March 2010

MEPC 60/22 ¶ 2.4.1

MEPC 60/2/11 Annex 

6 [GESAMP]

MEPC 59/2/11

- - GSI and 

MERC - - - 

This system uses Siemens' 

Chloropac®

electrochlorination 

technology.
42

Supplier

System Process

G9 Active 

Substance Approval 

(Basic)1

G9 Active 

Substance 

Approval 

(Final)1

G8 System 

Approval2 Test Site Type Approval Units Installed3

Projected 

Production 

(Units/Year)3

Notes

Sunrui Corrosion 

and Fouling Control 

Company

(BalClorTM BWMS)

Filtration and 

electrolysiselectrochlorina

tion

March 2010

MEPC 60/22 ¶ 2.4.2

MEPC 60/2/12 Annex 

6 [GESAMP]

MEPC 60/2/3

MEPC 61/2/4

Land (Late09)

Sea (Late09)

Qingdao, 

China - - - 

The name of this system was 

changed from "Sunrui 

BWMS" to "BalClorTM

BWMS;" see MEPC 61/2/4 ¶ 

3.

Techcross

(Electro-Clean 

System (ECS))

Electrolysiselectrochlorina

tion

March 2006

MEPC 54/21 ¶ 2.8

MEPC 54/2/12 Annex 

6 [GESAMP]

MEPC 54/2/3

October 2008

MEPC 58/23 ¶ 

2.8

MEPC 58/2/7, 

Annex 7 

[GESAMP]

MEPC 58/2

MEPC 57/21 ¶ 

2.9

MEPC 57/2 

Annex 4 

[GESAMP]

MEPC 57/2/1

August 

2007 KORDI

31 December 

2008

Korea

MEPC 59/INF.6

13 1200

Possibly MEPC 53/2/31. 

MEPC 55/2/21, MEPC 57/2/9. 

Explosion-proof type approval 

certificate issued September 

2009 (Lloyd's, 2010).

Techwin Eco Co., 

Ltd. (TWECO)

(PurimarTM)

Filtration and 

electrolysiselectrochlorina

tion

MEPC 61/2 - - - - - - 

Vitamar, LLC

(SeakleenTM) 

Menadione / 

Vitamin K 

(SeakleenTM) 

- - - - - 0 - 

Former supplier: Hyde 

Marine; Lamor Corporation, 

LLC.

Additional Notes: 

Data sources for this spreadsheet include Ballast Water Treatment Technology - Current Status, Lloyd's Register Review (September 2008), Ballast Water Treatment 

Technology - Current Status, Lloyd's Register Review (February 2010), and MEPC Reports. System names in this table and elsewhere in this paper may be subject to 

copyright or trademark protection by their owners.

1 Where applicable. Systems that employ an “Active Substance,” defined by BW Treaty Regulation A-1(7) as ”a substance or organism, including a virus or a fungus that has 

a general or specific action on or against harmful aquatic organisms and pathogens,” are assessed according to the MO G9 Procedure for Approval of Ballast Water 

Management Systems that make use of Active Substances (International Maritime Organization, 2008a). 

2 The ballast water treatment system testing procedure is outlined in the IMO’s G8 Guidelines (International Maritime Organization, 2008b). 

3 Data on units installed and on projected production was provided by vendors to Lloyd's Register Review during Lloyd's research of ballast water treatment systems. The 

numbers listed here are based solely on this vendor-supplied information as reported by Lloyd's (see Ballast Water Treatment Technology - Current Status, Lloyd's Register

Review (February 2010). 

4 Per Lloyd's Register Review (Ballast Water Treatment Technology - Current Status (September 2008)), testing may not strictly meet IMO standards. 

 
43 

Table 6 Acronyms and Abbreviations used in Table 5. 

BWMS Ballast Water Management System

BWTS Ballast Water Treatment System

CBL Chesapeake Biological Laboratory

IMO International Maritime Organization

JAMS Japan Association of Marine Safety

KORDI Korean Oceanic Research and Development Institute

MEPC Marine Environment Protection Committee (IMO)

MLML Moss Landing Marine Laboratories

N/A Not Applicable or Available

NIOZ Royal Netherlands Institute for Sea Research

NIVA Norwegian Institute for Water Research

NOAA National Oceanic and Atmospheric Administration

SIO Scripps Institute of Oceanography

STEP Shipboard Technology Evaluation Program

USNRL United States Naval Research Laboratory

4.4. Implications of Sampling Protocols for Data Quality 

To date, efforts to quantify the efficacy of ballast water treatment systems, either in landbase or shipboard tests have been hampered by a range of methodological and practical 

constraints. The BW Treaty’s G8 Guidelines were developed through a process of best 

professional judgment and policy negotiations. Significant aspects, such as guidance on 

how to analyze samples for the different types of organisms are treated very loosely in 

the G8 Guidelines because it was not possible to come to agreement on such complicated 

issues in the short timeframe allowed. Other sections, such as those on challenge water 

conditions and sample sizes, are quite detailed, but were not formally validated prior to 

their use by different entities. The consequence has been the evolution of a mosaic of 

procedures, developed individually by each of the facilities conducting testing 

internationally, within the general conceptual framework of the G8 Guidelines, but 

differing substantially in specific details. Within the last several months the various test 

facilities have begun to discuss approaches to achieve “harmonization” of test methods. 

In the U.S., efforts to develop standard protocols for testing the efficacy of ballast water 

treatment systems were begun by EPA and the USCG under the auspices of the EPA 

Environmental Technology Verification (ETV) Program in 2002. An early version of the 

draft ETV protocol was used by the U.S. as the basis for a submission to MEPC during 

negotiation of the G8 Guidelines, and much of the ETV conceptual approach was 

incorporated into the G8 Guidelines. However, as the ETV process continued to develop 

the protocols, and then validate their practicability and appropriateness, the ETV 

protocols evolved substantially (Lemieux et al., 2008b, Lemieux et al., 2009), and the 

version now nearing finalization (U.S., EPA, 2010) differs significantly from the version 

under discussion at the time the G8 Guidelines were being developed. Unlike the ETV 

protocols, however, the G8 Guidelines were never subjected to rigorous validation. 
44

Validation of the ETV protocols has revealed that the initial approaches to sampling 

design had substantial limitations. In particular, the early ETV protocols, and the current 

G8 Guidelines, called for collecting three 1m3 samples of water to quantify 

concentrations of living organisms larger than 50 um following treatment. For the BW 

Treaty Regulation D-2 standard of less than 10 organisms in this size group, this means 

that quantification would have to be able to detect the presence of 10 organisms, each as 

small as 50 um in diameter, in one cubic meter of water. In practice, this involves 

concentrating the organisms in the cubic meter samples down to a liter, or in some cases, 

several hundred milliliters. These concentrated samples are then examined, either in their 

entirety, or by sub-sampling, and the number of living organisms is counted. 

Even if the entire concentrated sample is enumerated, counting 10 organisms as small as 

50 um in a liter with adequate precision is a significant challenge. Five to ten cubic 

meters of sample, concentrated to a liter would provide a much better basis for counting. 

Sub-sampling would greatly increase the original sample volume required. 

NRL, in validating the ETV protocols, determined that for the circumstances at Key 

West, FL, where the NRL test facility is located, 20 1 ml subsamples was about the 

maximum that could be processed within the allowable time before sample degradation 

introduced significant artifacts (e.g., increased organism mortality in the concentrated 

sample). 

Enumeration of the organisms from these samples is represented by the Poisson distribution, 

and therefore the cumulative or total count is the key test statistic (Lemieux et al., 2008). 

Further, a chi-square transformation can be utilized to approximate the confidence intervals. 

Assuming, for organisms ≥ 50 μm, that the desired minimum precision is that the upper 

bound of the chi-square statistic should not exceed twice the observed mean (this corresponds 

to a coefficient of variation of 40%), a count of 6 organisms is required. The volume required 

to successfully count 6 organisms is dependent on the whole water sample volume, 

concentration factor, number of sub-samples counted, and the target concentration. For 

enumeration using 20 one ml subsamples, statistical analysis indicated that 30 m3 must be 

sampled to enumerate 10 organisms/m3

, with the desired level of precision. 

The complexities associated with minimum sample volumes raise additional important 

issues. First, counts of less than 10 organisms as small as 50 um in size per cubic meter 

are inherently susceptible to error. To date, none of the test reports available to the Coast 

Guard and EPA have contained QA/QC validation that the counts were made with 

necessary precision and repeatability. In validating the ETV protocols, NRL validated 

their measurement precision using different concentrations of various diameter 

microbeads. Second, samples begin to degrade very quickly, and all enumeration must 

be completed within a narrow window, and this window is to a great degree dependent on 

time and place and holding conditions. As with measurement precision, the test reports 

available to the Coast Guard and EPA do not contain QA/QC documentation of the safe 

period for sample processing and analysis or that this safe period limitation was met.
45 

5. Conclusion – How this Report could be used

In its 2008 Fact Sheet to the VGP (EPA, 2008a), EPA noted that the Agency “will 

evaluate the availability of technologies that are able to meet appropriate living organism 

limitations. Once technologies are commercially available and economically achievable, 

EPA would require that these standards be met as a BAT effluent limit for ballast water 

discharges under subsequent iterations of this permit.” Under § 402(b)(1)(B) of the 

CWA, NPDES permits are issued for fixed terms that may not exceed five years and the 

existing VGP will expire on December 19, 2013. The SAB’s response to the charge will 

better inform EPA as to the status of ballast water treatment systems as the Agency 

develops new technology-based effluent limits and conditions for the next VGP. 

As a co-regulator, the US Coast Guard is supporting EPA in this effort. Additionally, the 

SAB’s findings may also help inform the Coast Guard in their future evaluations of 

technological availability. We are not asking the committee to propose or strongly 

support any specific technology or treatment train, rather, we are asking for advice on the 

state and efficacy of ballast water treatment technology today and where that is likely to 

go in the near term. This information will assist regulatory agencies in moving toward a 

strong US federal ballast water management program which accurately captures the 

current state of ballast water technologies. 
46 

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MEPC (Marine Environment Protection Committee). 2007. Application for Basic Approval of Active 

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MEPC (Marine Environment Protection Committee). 2007. Application for Basic Approval of a ballast water 

management system using Active Substances. Submitted by the Norway. MEPC 57/2/6. 7 September 

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51

MEPC (Marine Environment Protection Committee). 2007. Application for Basic Approval of a combined 

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MEPC (Marine Environment Protection Committee). 2007. Application for Final Approval of a ballast water 

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2007. 

MEPC (Marine Environment Protection Committee). 2007. Application for Final Approval of a ballast water 

management system using Active Substances. Submitted by Germany. MEPC 57/2/5. 7 September 

2007. 

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management system using Active Substances (Electro-Clean Electrolytic Disinfection). Submitted by 

the Republic of Korea. MEPC 57/2/1. 7 September 2007. 

MEPC (Marine Environment Protection Committee). 2007. Basic Approval of Active Substance used by 

GloEn-PatrolTM Ballast Water Management System. Submitted by the Republic of Korea. MEPC 

57/2/4. 7 September 2007. 

MEPC (Marine Environment Protection Committee). 2007. Basic Approval of Active Substances used by 

Resource Ballast Technologies Systems (Cavitation combined with Ozone and Sodium Hypochlorite 

treatment). Submitted by South Africa. MEPC 56/2/3. 6 April 2007. 

MEPC (Marine Environment Protection Committee). 2007. Report of the third meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 56/2/2. 13 April 

2007. 

MEPC (Marine Environment Protection Committee). 2007. Report of the fourth meeting of the GESAMPBallast Water Working Group (GESAMP-BWWG). Note by the Secretariat. MEPC 57/2. 19 

December 2007.

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the 

AquaTriCombTM Ballast Water Treatment System. Submitted by Germany. MEPC 59/2/8. 16 

December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the Blue Ocean 

Shield Ballast Water Management System. Submitted by China. MEPC 59/2/2. 5 December 2008. 

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the Ecochlor® 

Ballast Water Treatment System. Submitted by Germany. MEPC 58/2/2. 20 March 2008. 

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the HHI Ballast 

Water Management System (EcoBallast). Submitted by the Republic of Korea. MEPC 59/2/4. 9 

December 2008. 

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the Siemens 

SiCURETM Ballast Water Management System. Submitted by Germany. MEPC 59/2/11. 19 December 

2008. 
52

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of a ballast water 

management system using Active Substances (Electro-Clean Electrolytic Disinfection). Corrigendum. 

Submitted by the Republic of Korea. MEPC 57/2/1/Corr.1. 12 March 2008. 

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Ecochlor® 

Ballast Water Management System. Submitted by Germany. MEPC 59/2/9. 16 December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the ElectroClean System (ECS). Submitted by the Republic of Korea. MEPC 58/2. 20 March 2008. 

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the GloEnPatrolTM Ballast Water Treatment System. Submitted by the Republic of Korea. MEPC 59/2/7. 16 

December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Greenship 

Sedinox Ballast Water Management System. Submitted by the Netherlands. MEPC 59/2/6. 12 

December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Hitachi 

Ballast Water Purification System (ClearBallast). Submitted by the Japan. MEPC 59/2/5. 11 

December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the NK-O3 

BlueBallast System (Ozone). Submitted by the Republic of Korea. MEPC 58/2/3. 21 March 2008. 

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the NK-O3 

BlueBallast System (Ozone). Submitted by the Republic of Korea. MEPC 59/2/3. 8 December 2008. 

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the 

OceanSaver® Ballast Water Management System (OS BWMS). Submitted by Norway. MEPC 58/2/1. 

19 March 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Resource 

Ballast Technologies System (Cavitation combined with Ozone and Sodium Hypochlorite treatment). 

Submitted by South Africa. MEPC 59/2/10. 19 December 2008. 

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the RWO 

Ballast Water Management System (CleanBallast). Submitted by Germany. MEPC 59/2. 28 

November 2008. 

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Special Pipe 

Hybrid Ballast Water Management System (combined with Ozone treatment). Submitted by Japan. 

MEPC 59/2/1. 4 December 2008.

MEPC (Marine Environment Protection Committee). 2008. Comments on the report of the fourth meeting of 

the GESAMP-BWWG. Submitted by Germany. MEPC 57/2/13. 4 February 2008. 

MEPC (Marine Environment Protection Committee). 2008. Report of the fifth meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 57/2/10. 25 January 

2008. 

MEPC (Marine Environment Protection Committee). 2008. Report of the sixth meeting of the GESAMPBallast Water Working Group. Note by the Secretariat. MEPC 58/2/7. 14 July 2008. 
53

MEPC (Marine Environment Protection Committee). 2008. Report of the seventh meeting of the GESAMPBallast Water Working Group. Note by the Secretariat. MEPC 58/2/8. 28 July 2008. 

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of the 

AquaTriCombTM Ballast Water Treatment System. Corrigendum. Submitted by MEPC

59/2/8/Corr.1. 29 June 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of Blue Ocean 

Guardian (BOG) Ballast Water Management System. Submitted by Republic of Korea. MEPC 60/2/5. 

24 August 2009. 

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of DESMI Ocean 

Guard Ballast Water Management System. Submitted by Denmark. MEPC 60/2/4. 19 August 2009. 

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of Hyundai Heavy 

Industries Co., Ltd. (HHI) Ballast Water Management System (HiBallast). Submitted by the Republic 

of Korea. MEPC 60/2/9. 24 August 2009. 

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of Kwang San 

Co., Ltd. (KS) Ballast Water Management System "En-Ballast". Submitted by the Republic of Korea. 

MEPC 60/2/7. 25 August 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of OceanGuardTM 

Ballast Water Management System. Submitted by Norway. MEPC 60/2/8. 26 August 2009. 

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of the Severn 

Trent DeNora BalPure® Ballast Water Management System. Submitted by Germany. MEPC 60/2/9. 

28 August 2009. 

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of Sunrui ballast 

water management system. Submitted by China. MEPC 60/2/3. 24 August 2009. 

MEPC (Marine Environment Protection Committee). 2009. Application for Final Approval of HHI Ballast 

Water Management System "EcoBallast". Submitted by the Republic of Korea. MEPC 60/2/1. 20 

August 2009. 

MEPC (Marine Environment Protection Committee). 2009. Application for Final Approval of (JFE-BWMS) 

that makes use of "TG Ballastcleaner® and TG Environmentalguard®". Submitted by Japan. MEPC 

60/2/2. 20 August 2009. 

MEPC (Marine Environment Protection Committee). 2009. Information on the Type Approval Certificate of 

the Electro-CleenTM System (ECS). Submitted by the Republic of Korea. MEPC 59/INF.6. 20 

February 2009. 

MEPC (Marine Environment Protection Committee). 2009. Information on the Type Approval Certificate of 

the OceanSaver® Ballast Water Management System. Submitted by Norway. MEPC 59/INF.17. 6 

May 2009. 

MEPC (Marine Environment Protection Committee). 2009. Report of the eighth meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 59/2/16. 8 April 

2009. 
54

MEPC (Marine Environment Protection Committee). 2009. Report of the ninth meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 59/2/19. 5 May 

2009. 

MEPC (Marine Environment Protection Committee). 2009. Report of the tenth meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 60/2/11. 30 October 

2009. 

MEPC (Marine Environment Protection Committee). 2009. Report of the eleventh meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 60/2/12. 1 

December 2009.

MEPC (Marine Environment Protection Committee). 2009. Type Approval of the Hyde GUARDIANTM 

Ballast Water Management System. Submitted by the United Kingdom. MEPC 59/INF.20. 7 May 

2009. 

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of Techwin Eco 

Co., Ltd. (TWECO) Ballast Water Management System (PurimarTM). Submitted by the Republic of 

Korea. MEPC 61/2. 9 March 2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the Special Pipe 

Hybrid Ballast Water Management System combined with Ozone treatment version (SP-Hybrid 

BWMS Ozone version). Submitted by Japan. MEPC 61/2/2. 17 March 2010. 

MEPC (Marine Environment Protection Committee). 2010. Report of the twelfth meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 60/2/16. 8 February 

2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of AquaStar 

Ballast Water Management System. Submitted by Republic of Korea. MEPC 61/2/1. 18 March 2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of the BlueSeas 

Ballast Water Management System. Submitted by Singapore. MEPC 61/2/12. 31 March 2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of the ERMA 

FIRST Ballast Water Management System. Submitted by Greece. MEPC 61/2/11. 29 March 2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of the Kuraray 

Ballast Water Management System. Submitted by Japan. MEPC 61/2/6. 25 March 2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of the MES 

Ballast Water Management System (Fine Ballast MF). Submitted by Japan. MEPC 61/2/3. 17 March 

2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the Special Pipe 

Hybrid Ballast Water Management System combined with PERACLEAN® Ocean (SPO-SYSTEM). 

Submitted by Japan. MEPC 61/2/10. 29 March 2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of “ARA Ballast” 

Ballast Water Management System. Submitted by Republic of Korea. MEPC 61/2/5. 23 March 2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the Ecochlor® 

Ballast Water Management System. Submitted by Germany. MEPC 61/2/8. 28 March 2010. 
55

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the 

OceanGuardTM Ballast Water Management System. Submitted by Norway. MEPC 61/2/7. 25 March 

2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the Severn Trent 

De Nora BalPure® Ballast Water Management System. Submitted by Germany. MEPC 61/2/9. 28 

March 2010. 

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval BalClorTM ballast 

water management system. Submitted by China. MEPC 61/2/4. 22 March 2010. 

Merchant Shipping Directorate. 2010. Ballast Water Management System Type Approval Compliance 

Certificate. Malta Transport Centre.

Michigan Department of Natural Resources and Environment. 2001-2010. Ballast Water Control. 

(http://www.michigan.gov/deq/0,1607,7-135-3313_3682_3713-153446--,00.html). Accessed June 21, 

2010. 

Minnesota Pollution Control Agency. 2010. Vessel Discharge (Ballast Water) Program. 

(http://www.pca.state.mn.us/index.php/water/water-permits-and-rules/water-permits-andforms/vessel-discharge-ballast-water-program.html?menuid=&missing=0&redirect=1). Accessed 

June 21, 2010.

NEI Treatment Systems, LLC. 2007. Application for Type Approval Certification: NEI Treatment Systems' 

Venturi Oxygen Stripping Ballast Water Management System. International Maritime Organization 

International Convention for the Control and Management of Ships' Ballast Water and Sediments. Los 

Angeles, CA.

Northwest Environmental Advocates v. EPA, 573 F.3d 1006 (9th Cir. 2008). Available at: 

http://archive.ca9.uscourts.gov/ca9/newopinions.nsf/1B1275291668F0348825748F00481607/$file/03

74795.pdf?openelement. Accessed June 18, 2010.

Norwegian Maritime Directorate. 2008. Det Norske Veritas Type Approval Certificate. Certificate No. P12397. 

Norwegian Maritime Directorate. 2009a. Det Norske Veritas Type Approval Certificate. Certificate No. P12601. 

Norwegian Maritime Directorate. 2009b. Det Norske Veritas Type Approval Certificate. Certificate No. P13117. 

Perrins, J.C., Cordell, J.R., Ferm, N.C., Grocock, J.L., & Herwig, R.P. 2006. Mesocosm experiments for 

evaluating the biological efficacy of ozone treatment of marine ballast water. Marine Pollution

Bulletin, 52, 1756-1767. 

Quilez-Badia, G., McCollin, T., Josefsen, K.D., Vourdachas, A., Gill, M.E., Mesbahi, E., & Frid, C.L.J. 2008. 

On board short-time high temperature heat treatment of ballast water: A field trial under operational 

conditions. Marine Pollution Bulletin, 56, 127-135. 

Raikow, D.F., Reid, D.F., Blatchley, E.R.I., Jacobs, G., & Landrum, P.F. 2007. Effects of proposed physical 

ballast tank treatments on aquatic invertebrate resting eggs. Environmental Toxicology and Chemistry, 

26, 717-725. 
56

Republic of Korea. 2009. Type Approval Certificate of Ballast Water Management System. Cert. No. 3-2009. 

Republic of Liberia Bureau of Maritime Affairs. 2007. Type Approval Certificate of Ballast Water 

Management System. No. 02NEI070809. 

Republic of the Marshall Islands Office of the Maritime Administrator. 2009. Type Approval Certificate of 

Ballast Water Management System. MI-252. 

Reynolds, K., Knight, I., Wells, C., Pepper, I., & Gerba, C. 1999. Detection of human pathogenic protozoa and 

viruses in ballast water using conventional and molecular methods. In General Meeting of the 

American Society for Microbiology, pp. 594, Chicago, IL, Abstract Q318. 

Roman, J. 2006. Diluting the founder effect: cryptic invasions expand a marine invader's range. Proceedings 

of the Royal Society of London, Series B: Biological Sciences, 273, 2453-2459. 

Ruiz, G.M., Fofonoff, P.W., Carlton, J.T., Wonham, M.J., & Hines, A.H. 2000a. Invasion of coastal marine 

communities in North America: Apparent patterns, processes, and biases. Annual Review of Ecology 

and Systematics, 31, 481-531. 

Ruiz, G.M., Rawlings, T.K., Dobbs, F.C., Drake, L.A., Mullady, T., Huq, A., & Colwell, R.R. 2000b. Global 

spread of microorganisms by ships. Nature, 408, 49-50. 

Ruiz, G.M. & Reid, D.F. 2007. Current state of understanding about the effectiveness of ballast water 

exchange (BWE) in reducing aquatic Nonindigenous species (ANS) introductions to the Great Lakes 

Basin and Chesapeake Bay, USA: synthesis and analysis of existing information. 

Rützler, K. & Sterrer, W. 1970. Oil pollution. Damage observed in tropical communities along the Atlantic 

seaboard of Panama. BioScience, 20, 222-224. 

Severn Trent DeNora. 2005. Washington State Dept. of Fish and Wildlife Application Package: Ballast Water 

Treatment System. 

Siefert, E. and K. Siers. 2007. Landbased test report - Test cycle summary. Institut fur Umwelttechnik 

EUTEC.

Silva, Peter S., & Salerno, Brian (RADM). 2009. EPA and US Coast Guard joint letter to Senators Brown, 

Collins, Durbin, Feingold, Kohl, Levin, Schumer, Stabenow, and Voinovich, December, 31, 2009. 

Smayda, T.J. 2007. Reflections on the ballast water dispersal--harmful algal bloom paradigm. Ballast Water, 6, 

601-622. 

Tamburri, M.N., Wasson, K., & Matsuda, M. 2002. Ballast water deoxygenation can prevent aquatic 

introductions while reducing ship corrosion. Invasion Biology, 103, 331-341. 

Tamburri, M.N. & Ruiz, G.M. 2005. Evaluations of a Ballast Water Treatment to Stop Invasive Species and 

Tank Corrosion. Paper No. 2005-D09. 

Tang Z, Butkus MA, & Xie YF. 2006. Crumb rubber filtration: a potential technology for ballast water 

treatment. Mar Environ Res. 2006 May;61(4):410-23. 

Tang Z, Butkus MA, & Xie YF. 2009. Enhanced performance of crumb rubber filtration for ballast water 

treatment. Chemosphere.;74(10):1396-9. 
57

ten Hallers, C., Leppakoski, E., Sassi, J., Granitto, M., Mackey T., & Bjorkendahl, M. 2009. Environmental 

acceptability evaluation of the Hyde GUARDIAN ballast water treatment system as part of the Type 

Approval process, version 3. 

U.S. Coast Guard. 2004. Navigation and Vessel Inspection Circular No. 01-04 for the STEP program. 

January 2, 2004. 

U.S. Coast Guard. 2008. Final evaluation assessment review of the application by Atlantic Container Lines for 

acceptance of the vessel M/V Atlantic Compass and the EcochlorTM Inc. Technology into the USCG 

Shipboard Technology Evaluation (STEP) Program. 

U.S. EPA. 1996. U.S. EPA NPDES Permit Writers’ Manual. Chapter 5: Technology-Based Effluent Limits.

EPA-833-B-96-003. U.S. Environmental Protection Agency. Washington D.C. Available at: 

http://www.epa.gov/npdes/pubs/chapt_05.pdf. Accessed June 18, 2010.

U.S. EPA. 1996. U.S. EPA NPDES Permit Writers’ Manual. Chapter 6: Water Quality-Based Effluent Limits.

EPA-833-B-96-003. U.S. Environmental Protection Agency. Washington D.C. Available at: 

http://www.epa.gov/npdes/pubs/chapt_06.pdf. Accessed June 18, 2010.

U.S. EPA. 2001. Aquatic nuisance species in ballast water discharges: issues and opinions.

http://epa.gov/owow/invasive_species/ballast_report_attch5.pdf. 

U.S. EPA. 2008a. 2008 Final issuance of National Pollutant Discharge Elimination System (NPDES) Vessel 

General Permit (VGP) for Discharges Incidental to the Normal Operation of Vessels Fact Sheet. 

(www.epa.gov/npdes/vessels) 

U.S. EPA. 2008b. Vessel General Permit. Finalized December 19, 2008. (www.epa.gov/npdes/vessels) 

U.S. EPA. 2010. Environmental Technology Verification Program Generic Protocol for the Verification of 

Ballast Water Treatment Technologies, Ver. 4.2. NSF, International, Ann Arbor, MI. 

Veldhuis, M.J.W. & Fuhr, F., 2008. Final report of the land-based testing of the SEDNA® -System, for Type 

Approval according to the Regulation D-2 and the relevant IMO Guideline (April - July 2007). Royal 

Netherlands Institute for Sea Research.

Veldhuis, M.J.W., Fuhr, F., & Stehouwer, P., 2009a. Final report of the land-based testing of the Ecochlor®-

system, for Type Approval according to regulation-D2 and the relevant IMO guideline (April – July 

2008). Royal Netherlands Institute for Sea Research.

Veldhuis, M.J.W., Fuhr, F., & Stehouwer, P., 2009b. Final report of the land-based testing of the HydeGuardianTM -System, for Type Approval according to the Regulation D-2 and the relevant IMO 

Guideline (April - July 2008). Royal Netherlands Institute for Sea Research. 

 

Volpe Transportation Research Center. 2009. Environmental assessment review of the application for 

acceptance of the SeaRiver Maritime Inc. S/R American Progress and Severn Trent de Nora 

BalPureTM System into the Shipboard Technology Evaluation Program (STEP). U.S. Coast Guard. 

Wisconsin Department of Natural Resources. 2010. Ballast Water Discharge General Permit. 

(http://dnr.wi.gov/news/mediakits/mk_ballast.asp). Accessed June 21, 2010. 

Wright, D.A. 2009. Shipboard Trials of Hyde "Guardian" System in Caribbean Sea and Western Pacific 

Ocean, April 5th - October 7th, 2008. University of Maryland Center for Environmental Science, 

Chesapeake Biological Laboratory.
58

Appendix I – Science Advisory Board Charge

OFFICE OF 

WATER 

July 1, 2010 

MEMORANDUM

SUBJECT: Science Advisory Board Review of the Availability and Efficacy of Ballast Water 

Treatment Technology for EPA’s Office of Water and the United States Coast 

Guard 

FROM: Linda Boornazian, Director 

 Water Permits Division

Office of Water

TO: Vanessa Vu, Director

Science Advisory Board Staff Office 

This memorandum provides an introduction, background information, and specific 

charge questions to the Science Advisory Board (SAB) for their review of the status of ballast 

water treatment technology. To assist the SAB in their efforts, a member of my staff, in 

collaboration with other EPA and Coast Guard colleagues, has prepared a white paper titled 

“Availability and Efficacy of Ballast Water Treatment Technology: Background and Issue 

Paper” (hereinafter the “White Paper”). This paper provides additional background information 

and introduces the numerous documents we have provided to the SAB to assist in your analyses. 

Background 

 Ballast water is typically drawn in from surrounding ambient water and used to assist 

with vessel draft, buoyancy, and stability. Almost all large vessels have ballast tanks dedicated 

to this purpose; some vessels may also ballast empty cargo holds. The ballast water discharge 

rate and constituent concentrations of ballast water from vessels will vary by vessel type, ballast 
59

tank capacity, and type of deballasting equipment. Under current U.S. regulation and permitting 

requirements (discussed in greater detail in the White Paper), there are existing best management 

practices to reduce the potential impacts of ballast water discharges. These include ballast water 

exchange and salt water flushing (collectively referred to as BWE). 

While useful in reducing the presence of potentially invasive organisms in ballast water, 

BWE can have variable effectiveness and may not always be feasible due to vessel safety 

concerns. In order to make progress beyond use of BWE, establishing a standard for the 

concentration of living organisms in ballast water that can be discharged is necessary. The 

United States Environmental Protection Agency (EPA) and the United States Coast Guard 

(USCG) both desire a stronger federal ballast water management program. 

To help develop the next Clean Water Act Vessel General Permit (VGP), EPA needs an 

objective evaluation of the status and efficacy of ballast water treatment technologies and 

systems that are in existence or in the development process. A second major scientific question 

for regulatory agencies is to better understand and relate the concentration of living organisms in 

ballast water discharges to the probability of introduced organisms successfully establishing 

populations in U.S. waters. Given the complexity of the issues, EPA’s Office of Water is 

seeking advice from the Science Advisory Board (SAB) on the first issue and the National 

Academy of Sciences’ National Research Council (NRC) on the second issue. In Particular, EPA 

is seeking advice from the SAB regarding the availability and efficacy of ballast water treatment 

systems in neutralizing (killing) living organisms that might be discharged from ballast water 

tanks. For the other NRC study, EPA has requested that the NRC broadly assess and make 

recommendations about various approaches for assessing the risk of establishment of new 

aquatic non-indigenous species from ballast water discharges (see attachment 2 of the White 

Paper for the NRC charge). 

 

Specific Charge in Evaluating the Efficacy of Ballast Water Treatment Technology 

OW is seeking SAB advice in the following four general categories:

1. Performance of shipboard systems with available effluent testing data25

1a. For the shipboard systems with available test data, which have been evaluated 

with sufficient rigor to permit a credible assessment of performance capabilities in 

terms of effluent concentrations achieved (living organisms/unit of ballast water 

discharged or other metric)?

1b. For those systems identified in (1a), what are the discharge standards that the 

available data credibly demonstrate can be reliably achieved (e.g., any or all of the 

standards shown in Table 1 of the White Paper? Furthermore, do data indicate that 

certain systems (as tested) will not be able to reliably reach any or all of the 

discharge standards shown in that table?

 

25 EPA and the US Coast Guard have provided data they currently have to the panel on the attached CD. Where 

feasible, the panel is encouraged to find additional data if they have appropriate avenues to obtain those data.
60

1c. For those systems identified in (1a), if any of the system tests detected “no 

living organisms” in any or all of their replicates, is it reasonable to assume the 

systems are able to reliably meet or closely approach a “no living organism” 

standard or other standards identified in Table 1 of the White Paper, based on 

their engineering design and treatment processes?

2. Potential performance of shipboard systems without reliable testing data 

2. Based on engineering design and treatment processes used, and shipboard 

conditions/constraints, what types of ballast water treatment systems (which may 

include any or all of the systems listed in Table 4 of the White Paper) can 

reasonably be expected to reliably achieve any of the standards shown in Table 1

of the White Paper, and if so, by what dates? Based on engineering design and 

treatment processes used, are there systems which conceptually would have 

difficulty meeting any or all of the discharge standards in Table 1 of the White 

Paper? 

3. System Development

3a. For those systems identified in questions 1a and 2, are there reasonable 

changes or additions to their treatment processes which can be made to the 

systems to improve performance? 

3b. What are the principal technological constraints or other impediments to the 

development of ballast water treatment technologies for use onboard vessels to 

reliably meet any or all of the discharge standards presented in Table 1 of the 

White Paper and what recommendations does the SAB have for addressing these 

impediments/constraints? Are these impediments more significant for certain size 

classes or types of organisms (e.g., zooplankton versus viruses)? Can currently 

available treatment processes reliably achieve sterilization (no living organisms or 

viable viruses) of ballast water onboard vessels or, at a minimum, achieve zero or 

near zero discharge for certain organism size classes or types?

4. Development of Reliable Information 

4. What are the principal limitations of the available studies and reports on the 

status of ballast water treatment technologies and system performance and how 

can these limitations be overcome or corrected in future assessments of the 

availability of technology for treating ballast water onboard vessels?
61

Background Reading Materials 

A more in depth introduction to these issues can be found in the attached White Paper, 

for which we have included both a hard copy and an electronic copy on the attached CD. The 

documents on the CD are divided into three groups. The first set of documents on that CD are 

summary reports produced by parties evaluating the availability of existing ballast water 

treatment systems or reports evaluating their potential efficacy. The second set of documents 

contains additional available test data and engineering information for specific ballast water 

treatment systems. The third set of documents primarily consist of International Maritime 

Organization papers and submissions, and were provided to serve as a reference library for the 

committee should the committee therein useful. Most of those documents have been prepared as 

reports for IMO as part of the “G9” review process (discussed in greater detail in White Paper). 

There is also an index file on the CD, which lists all of the document names and contains 

hyperlinks to the location of each file on the CD. Additionally, we have created an on-line 

docket which will contain all of the documents found on this CD: it is docket number EPA-HQOW-2010-0582 and can be accessed at www.regulations.gov. 

Thank you for considering these important issues in your review. Your work will prove valuable 

as we move forward with federal ballast water regulation.

Attachments:

 1. June, 2010 White Paper: Albert, R., Everett, R., Lishman, J., and Smith, D. (2010) 

Availability and Efficacy of Ballast Water Treatment Technology: Background and Issue Paper. 

Paper prepared to assist the Science Advisory Board Review of the availability and efficacy of 

ballast water treatment technology. 

 2. Compact Disc containing all documents referenced in Appendix IV of the above 

White Paper.
62 

Appendix II. National Academy of Sciences Charge 
63 

Appendix III. List of Acronyms Used in this Paper

ABS American Bureau of Shipping 

ANS Aquatic nuisance species

BA Basic Approval

BAT Best available technology economically achievable

BMP Best management practice

BOG Blue Ocean Guardian 

BW Ballast water

BWE Ballast Water Exchange

BWM Ballast Water Management

BWT Ballast Water Treatment

BWTS Ballast Water Treatment System

CFR Code of Federal Regulations 

COSCO China Ocean Shipping (Group) Company 

CSLC California State Lands Commission

CWA Clean Water Act

ECS Elector-CleenTM (Electro-Clean) System

EEZ Exclusive Economic Zone 

EPA Environmental Protection Agency

ETV Environmental Technology Verification Program 

EUT Advanced Electrocatalysis Enhanced by Ultrasonic Technology 

FA Final Approval 

GESAMP Joint Group of Experts on the Scientific Aspects of Marine 

Environmental Protection 

GSI Great Ships Initiative 

HHI Hyundai Heavy Industries 

IMO International Maritime Organization 

JAMS Japan Association of Marine Safety

KOMERI Korean Marine Equipment Research Institute

KORDI Korean Oceanic Research and Development Institute

KS Kwang San

LLC Limited Liability Company 

MEPC Marine Environment Protection Committee

MERC Maritime Environmental Resource Center

MLML Moss Landing Marine Laboratories

N/A Not applicable or available

NANPCA Non-indigenous Aquatic Nuisance Prevention and Control Act 

NIOZ Royal Netherlands Institute for Sea Research

NIS Non-indigenous species 

NISA National Invasive Species Act

NIVA Norwegian Institute for Water Research

NOAA National Oceanic and Atmospheric Administration

NOBOB No Ballast On Board

NPDES National Pollutant Discharge Elimination System

NPRM Notice of Proposed Rulemaking 

NRC National Research Council

NRL Naval Research Laboratory

OBS OptiMarin Ballast System
64

POC Particulate organic carbon

QA/QC Quality assurance/quality control

SAB Science Advisory Board

SIO Scripps Institute of Oceanography

SP Special pipe

STEP Ship Technology Evaluation Program 

TA Type Approval 

TG Toagosei Group 

TRO Total residual oxidant 

TSS Total suspended solids

TWECO Techwin Eco Company 

ULCC Ultra large crue carrier

UN United Nations 

US Ultrasonic

USC United States Code

USCG United States Coast Guard

UV Ultraviolet

VGP Vessel General Permit

VOS Venture Oxygen Stripping 

WI DNR Wisconsin Department of Natural Resources
65 

Appendix IV. Table of Contents for all documents provided to the Committee.

Note that hyperlinks in this table to documents link to other files contained on a CD provided to the 

SAB committee. If this white paper is viewed from that CD, hyperlinks will open the documents. 

These documents have also been added to the docket number EPA-HQ-OW-2010-0582 and can be 

accessed at www.regulations.gov. 

System Title Date File name

Group 1: 3rd Party Reports

General Ballast Water Treatment Technology: 

Current Status Feb-10 0210LloydsReport

General

2009 Assessment of the Efficacy, 

Availability and Environmental Impacts of 

Ballast Water Treatment Systems for Use in 

California Waters

Jan-09 2009CSLCTechReportFinal

General

October 2010 Update: Ballast Water 

Treatment Technologies for Use in 

California Waters

10/15/2009 CSLCTechUpdate2009_final

General

Density Matters: Review of Approaches to 

Setting Organism-Based Ballast Water 

Discharge Standards

2010 Lee_Density Matters- Excerpts for SAB

General

International Convention for the Control 

and Management of Ships’ Ballast Water 

and Sediments, 2004 - List of ballast water 

management systems that make use of 

Active Substances which received Basic and 

Final Approvals

9/24/2009 BWM.2-Circ.23.pdf

General Ballast Water Treatment Advisory 6/8/2010 ABS_BWMAdvisoryNotice.pdf

Group 2: Direct Data Reports on Separate BWMS

Ecochlor® Ballast 

Water Treatment 

System

STEP 2006 Application Form - Section 4.0: 

Proof of Ballast Water Treatment 

Performance

2006 Final - STEP Section 4

Ecochlor® Ballast 

Water Treatment 

System

Final report of the land-based testing of the 

Ecochlor®-system, for Type Approval 

according to regulation-D2 and the relevant 

IMO guideline (April – July 2008)

Feb-09 G8-Eco-_report_BSH-v8-final

Ecochlor® Ballast 

Water Treatment 

System

Final Environmental Assessment Review of 

the Application by Atlantic Container Lines 

for Acceptance of the Vessel M/V Atlantic 

Compass and the EcochlorTM Inc. 

Technology into the USCG Shipboard 

Technology Evaluation (STEP) Program

Aug-08 USCG-2007-0042-0010.1

Electro-Clean Ballast 

Water Management 

System

Development of technologies on test 

facility and procedures for the land-based 

test as a type approval test at ballast water 

treatment system

2008 Electroclean barge
66

System Title Date File name

Electro-CleenTM 

System

Information on the Type Approval 

Certificate of the Electro-CleenTM System 

(ECS)

2/20/09 59-INF.6_Electroclean-TypeApp-ROK

GloEn-PatrolTM Ballast 

Water Management 

System

Type Approval Certificate of Ballast Water 

Management System 12/4/09 GloEn-Patrol Type Approval Certificate

Greenship's Ballast 

Water Management 

System

Landbased Test Report - Test Cycle 

Summary 2007 Landb_Test_Rep_Summ_07_07

Hyde GUARDIAN 

Ballast Water 

Treatment System

Environmental Acceptability Evaluation of 

the Hyde GUARDIAN Ballast Water 

Treatment System as Part of the Type 

Approval Process

4/20/2009 environmental_acceptability_evaluation

Hyde GUARDIAN 

Ballast Water 

Treatment System

Final report of the land-based testing of the 

Hyde-GuardianTM -System, for Type 

Approval according to the Regulation D-2 

and the relevant IMO Guideline (April - July 

2008) 

Jan-09 G8-HM-final report MCA

Hyde GUARDIAN 

Ballast Water 

Treatment System

Type Approval Certificate of Ballast 

Management System 4/29/2009 hyde_mca_cert

Hyde GUARDIAN 

Ballast Water 

Treatment System

Shipboard Trials of Hyde "Guardian" System 

in Caribbean Sea and Western Pacific 

Ocean, April 5th - October 7th, 2008

Apr-09 hyde_shipboard_tests

Hyde GUARDIAN 

Ballast Water 

Treatment System

Type Approval of the Hyde GUARDIANTM 

Ballast Water Management System 5/7/2009 59-INF20_TypeApp-UK

OceanSaver® Ballast 

Water Management 

System

Det Norske Veritas Type Approval 

Certificate 4/8/2009 Oceansaver type approval certificate

OceanSaver® Ballast 

Water Management 

System 

Type Approval Certificate of the 

OceanSaver ® BWMS 4/17/2009 Nor-OceanSaver

OceanSaver® Ballast 

Water Management 

System

Information on the Type Approval 

Certificate of the OceanSaver® Ballast 

Water Management System

5/6/2009 59-INF17_OceanSaver-TypeApp-Nor

OptiMarin Ballast 

System

Det Norske Veritas Type Approval 

Certificate 11/12/2009 Optmarin type approval certificate 

Z3_600_8349_20091112_133619

Peraclean Toxic Shock as New Ballast Water 

Treatment Fails Test 2/9/2010 lloyds 2010 peraclean article

SEDNA® ballast water 

treatment system 

using PERACLEAN® 

Ocean

Effective Protection Against “Stowaways”: 

Ballast Water Management System of 

Hamann and Evonik Receives Final 

Approval

6/11/2008 PeraClean-TypeApproval_PR
67

System Title Date File name

SEDNA®-System

Final report of the land-based and 

shipboard testing of the SEDNA®-system 

Mar-08 SEDNA Type Appr Test_results.nioz

SEDNA®-System

Summary of Additional Provisions of the 

Type Approval Certificate of Ballast Water 

Management System SEDNA 250 of 

Hamann AG

Aug-08 Type Approval Additional Provisions_HAMANN

SEDNA ® 250 Type Approval Certificate of Ballast Water 

Management System 8/16/2008 Ger_Sedna

PureBallast 250-2500 Det Norske Veritas Type Approval 

Certificate 6/27/2008 PureBallast Type Approval Certificate

Siemens SICURE 

Ballast Water 

Management System

A Great Lake Relevancy Preamble to the GSI 

Report on Land-Based Testing Outcomes 

for the Siemens SICURE Ballast Water 

Management System

4/28/2010 GLPreamble

Siemens SICURE 

Ballast Water 

Management System

Report of the Land-Based Freshwater 

Testing of the Siemens SiCURE Ballast 

Water Management System

5/15/2010 GSI-LB-F-A-1

NEI Venturi Oxygen 

Stripping (VOS)

Application for Type Approval Certification: 

NEI Treatment Systems' Venturi Oxygen 

Stripping Ballast Water Management 

System.

Mar-07 VOS Application for Type Approval Certification

NEI Venturi Oxygen 

Stripping (VOS)

Short-term Toxicity Testing of a Deoxygenation Ballast Water Treatment to 

Receiving Water Organisms. Final Report. 

8/29/2008 Short-term Acute Toxicity Testing

NEI Venturi Oxygen 

Stripping (VOS)

Short-term Chronic Toxicity Testing of a Deoxygenation Ballast Water Treatment to 

Receiving Water Organisms. Final Report. 

3/27/2009 Short-term Chronic Toxicity Testing

NEI Venturi Oxygen 

Stripping (VOS) STEP 2006 Application Form. Mar-06 STEP Final Version 6-23-09

NEI Venturi Oxygen 

Stripping (VOS)

Evaluations of a Ballast Water Treatment to 

Stop Invasive Species and Tank Corrosion. 2005 Tamburri SNAME_2005_D09

NEI Venturi Oxygen 

Stripping (VOS)

Type Approval Certificate of Ballast Water 

Management System; Ballast Water 

Management System Type Approval 

Compliance Certificate

7/6/2009; 

7/8/2007; 

1/19/2010 

NEI_IMO_BWM_TYPE_APPROVAL_CERTIFICATE

Severn Trent De Nora 

(BalPure)

Washington State Dept. of Fish and Wildlife 

Application Package Ballast Water 

Treatment System

8/8/2005 BWT System Application Package 8-8-05

Severn Trent De Nora 

(BalPure)

Marrowstone Sodium Hypochlorite 

Mesocosm September 2004 Sep-04 Marrowstone Sodium Hypochlorite Mesocosm 

September 2004

Severn Trent De Nora 

(BalPure)

Environmental Assessment Review of the 

Application for Acceptance of the SeaRiver 

Maritime Inc. S/R American Progress and 

Severn Trent de Nora BalPureTM System into 

the Shipboard Technology Evaluation 

Program (STEP)

Feb-09 USCG-2008-0126-0007.1
68

System Title Date File name

Group 3: G9 Files

Alfa Laval Ballast 

Water Management 

System (PureBallast)

Basic Approval of Active Substances used 

by PureBallast management system 4/21/2006 55-2-5_PureBal-Swe-Basic

Alfa Laval Ballast 

Water Management 

System (PureBallast)

Application for Final Approval of a ballast 

water management

system using Active Substances

12/15/2006 56-2-1_PureBal-Nor-Final

AquaStar Ballast 

Water Management 

System

Application for Basic Approval of AquaStar 

Ballast Water Management System 3/18/2010 61-2-1_AquaStar-Jap-Baasic

AquaTriComb 

BallastTM Water 

Treatment System

Application for Basic Approval of the 

AquaTriComb Ballast Water Treatment 

System

12/16/2008 59-2-8_AquaTriComb-Ger-Basic

AquaTriComb 

BallastTM Water 

Treatment System

Application for Basic Approval of the 

AquaTriCombTM Ballast Water Treatment 

System Corrigendum

6/29/2009 MEPC 59-2-8-Corr.1

"ARA Ballast" Ballast 

Water Management 

System (formerly 

Blue Ocean Guardian 

BWMS)

Application for Final Approval of "ARA 

Ballast" Ballast Water Management System 3/23/2010 61-2-5_ARA-ROK-Final

BalPure®

Application for Basic Approval of the Severn 

Trent DeNora BalPure® Ballast Water 

Management System

8/28/2009 60-2-9_BalPure-Ger-Basic

BalPure®

Application for Final Approval of the Severn 

Trent DeNora BalPure® Ballast Water 

Management System

3/28/2010 61-2-9_BalPure-Ger-Final

Blue Ocean Guardian 

(BOG) Ballast Water 

Management System

Application for Basic Approval of Blue 

Ocean Guardian (BOG) Ballast Water 

Management System

8/24/2009 60-2-5_BlueOceanGuardian-ROK-Basic

Blue Ocean Shield 

Ballast Water 

Management System

Application for Basic Approval of the Blue 

Ocean Shield Ballast Water Management 

System

12/5/2008 59-2-2_BlueOceanShield-China_basic

BlueSeas Ballast 

Water Management 

System

Application for Basic Approval of the 

BlueSeas Ballast Water Management 

System

3/31/2010 61-2-12_BlueSeas-Sing-Basic

DESMI Ocean Guard 

Ballast Water 

Management System

Application for Basic Approval of the DESMI 

Ocean Guard Ballast Water Management 

System

8/19/2009 60-2-4_OceanGuard-Den-Basic

EcoBallast

Application for Basic Approval of the HHI 

Ballast Water Management System 

(EcoBallast)

12/9/2008 59-2-4_HHI-EcoBallast-ROK-Basic

EcoBallast Application for Final Approval of HHI Ballast 

Water Management System "EcoBallast" 8/20/2009 60-2-1_EcoBallast-ROK-Final
69

System Title Date File name

Ecochlor® Ballast 

Water Treatment 

System

Application for Basic Approval of the 

Ecochlor® Ballast Water Treatment System 3/20/2008 58-2-2_Ecochlor-Ger-Basic

Ecochlor® Ballast 

Water Treatment 

System

Application for Final Approval of the 

Ecochlor® Ballast Water Management 

System

12/16/2008 59-2-9_EcoChlor-Ger-Final

Ecochlor® Ballast 

Water Treatment 

System

Application for Final Approval of the 

Ecochlor® Ballast Water Management 

System

3/28/2010 61-2-8_EcoChlor-Ger-Final2

EctoSysTM A Swedish Disinfection System 1/13/2006 54-INF-6_EctoSys-Swe-Basic

EctoSysTM Basic Approval of Active Substances used 

by EctoSysTM electrochemical system 4/21/2006 55-2-4_EctoSys-Swe-Basic

ERMA FIRST Application for Basic Approval of the ERMA 

FIRST Ballast Water Management System 3/29/2010 61-2-11_ERMA FIRST-GR-Basic

CleanBallast! Comments on the report of the fourth 

meeting of the GESAMP-BWWG 2/4/2008 57-2-13_CleanBallast-Ger-Rebut

CleanBallast!

Application for Final Approval of a ballast 

water management system using Active 

Substances

9/7/2007 57-2-3_CleanBallast-Ger-Final-1

CleanBallast!

Application for Final Approval of the RWO 

Ballast Water Management System 

(CleanBallast)

11/28/2008 59-2_CleanBallast-Ger-Final-2

Electro-Clean Ballast 

Water Management 

System

Application for Basic Approval of Active 

Substances used by Electro-Clean 

(Electrolytic Disinfection) Ballast Water 

Management System 

12/16/2005 54-2-3_ElectroClean-ROK-Basic

Electro-Clean Ballast 

Water Management 

System

Application for Final Approval of a ballast 

water management system using Active 

Substances (Electro-Clean Electrolytic 

Disinfection)

9/7/2007 57-2-1_ElectroClean-ROK-Final

Electro-Clean Ballast 

Water Management 

System

Application for Final Approval of a ballast 

water management system using Active 

Substances (Electro-Clean Electrolytic 

Disinfection). Corrigendum

3/12/2008 57-2-1-Corr.1

Electro-Clean Ballast 

Water Management 

System

Application for Final Approval of the 

Electro-Clean System (ECS) 3/20/2008 58-2_ElectroClean-ROK-Final

En-Ballast

Application for Basic Approval of Kwang 

San Co., Ltd. (KS) Ballast Water 

Management System "En-Ballast"

8/25/2009 60-2-7_EnBallast-ROK-Basic

GloEn-PatrolTM Ballast 

Water Management 

System

Basic Approval of Active Substance used by 

GloEn-PatrolTM 9/7/2007 57-2-4_GloEnPatrol-ROK-Basic

GloEn-PatrolTM Ballast 

Water Management 

System

Application for Final Approval of the GloEnPatrolTM Ballast Water Treatment System 12/16/2008 59-2-7_GloEnpatrol-ROK-Final
70

System Title Date File name

Greenship's Ballast 

Water Management 

System

Application for Basic Approval of a 

combined ballast water management 

system consisting of sediment removal and 

an electrolytic process using seawater to 

produce Active Substances (Greenship Ltd)

12/20/2007 57-2-7_Greenship-Neth-Basic

Greenship Sedinox 

Ballast Water 

Management System

Application for Final Approval of the 

Greenship Sedinox Ballast Water 

Management System

12/12/2008 MEPC 59-2-6_Greenship-Neth-Final

HiBallast

Application for Basic Approval of Hyundai 

Heavy Industries Co., Ltd. (HHI) Ballast 

Water Management System (HiBallast)

8/24/2009 60-2-6_HiBallast-ROK-Basic

Hitachi Ballast Water 

Purification System 

(ClearBallast)

Application for Basic Approval of Active 

Substances used by Hitachi Ballast Water 

Purification System (ClearBallast)

9/7/2007 57-2-2_ClearBallast-Jap_Basic

Hitachi Ballast Water 

Purification System 

(ClearBallast)

Application for Final Approval of the Hitachi 

Ballast Water Purification System 

(ClearBallast)

12/11/2008 59-2-5_ClearBallast-Jap-Final

Hybrid Ballast Water 

Treatment System 

using Seawater 

Electrolytic Process

Basic Approval of Active Substances used 

by the Hybrid Ballast Water Treatment 

System using Seawater Electrolytic Process

12/14/2006 56-2_Hybrid-Jap-Basic

Kuraray Ballast 

Water Management 

System

Application for Basic Approval of Kuraray 

Ballast Water Management System 3/25/2010 61-2-6_Kuraray-Jap-Basic

MES Ballast Water 

Management System 

(FineBallast MF)

Application for Basic Approval of the MES 

Ballast Water Management System 

(FineBallast MF)

3/17/2010 61-2-3_FineBallast-Jap-Basic

NK Ballast Water 

Treatment System

Request for re-evaluation of the proposal 

for the approval of Active Substances 8/18/2006 55-2-27_NK-ROK-ReSubmit

NK Ballast Water 

Treatment System

Basic Approval of Active Substances used 

by NK Ballast Water Treatment System 4/20/2006 55-2-3_NK-ROK-Basic

NK-O3 BlueBallast 

System

Application for Final Approval of the NK-O3 

BlueBallast System (Ozone) 3/21/2008 58-2-3_NK-ROK-Final-1

NK-O3 BlueBallast 

System

Application for Final Approval of the NK-O3 

BlueBallast System (Ozone) 12/8/2008 MEPC 59-2-3_NK-ROK-Final-2

OceanGuardTM Ballast 

Water Management 

System

Application for Basic Approval of the 

OceanGuardTM Ballast Water 

ManagementSystem

8/26/2009 60-2-8_OceanGuard-Nor-Basic

OceanGuardTM Ballast 

Water Management 

System

Application for Final Approval of the 

OceanGuardTM Ballast Water 

ManagementSystem

3/25/2010 61-2-7_OceanGuard-Nor-Final

OceanSaver® Ballast 

Water Management 

System

Application for Basic Approval of a ballast 

water management system using Active 

Substances

9/7/2007 57-2-6_OceanSaver-Nor-Basic
71

System Title Date File name

OceanSaver® Ballast 

Water Management 

System

Application for Final Approval of the 

OceanSaver® Ballast Water Management 

System (OS BWMS)

3/19/2008 58-2-1_OceanSaver-Nor-Final

Peraclean® Ocean Application for approval of an Active 

Substance for Ballast Water Management 4/15/2005 53-2-12_PeraClean_Ger-Basic

Peraclean® Ocean

Application for approval of an Active 

Substance for Ballast Water Management. 

Corrigendum

5/27/2005 53-2-12-corr.1

Peraclean® Ocean & 

Sedna system

Application for Final Approval of a ballast 

water management system using Active 

Substances

9/7/2007 57-2-5_PeraClean(Sedna)-Ger-Final

PurimarTM Ballast 

Water Management 

System

Application for Basic Approval of Techwin 

Eco Co., Ltd. (TWECO) Ballast Water 

Management System (PurimarTM)

3/9/2010 61-2_Purimar-ROK-Basic

Resource Ballast 

Technologies System 

(cavitation combined 

with Ozone and 

Sodium Hypochlorite 

treatment)

Basic Approval of Active Substances used 

by Resource Ballast Technologies System 

(Cavitation combined with Ozone and 

Sodium Hypochlorite treatment)

4/6/2007 56-2-3_Resource-SAfr-Basic

Resource Ballast 

Technologies System 

(cavitation combined 

with Ozone and 

Sodium Hypochlorite 

treatment)

Application for Final Approval of the 

Resource Ballast Technologies System 

(Cavitation combined with Ozone and 

Sodium Hypochlorite treatment)

12/19/2008 59-2-10_Resource-SAfr-Final

Siemens SiCURE

Application for Basic Approval of the 

Siemens SiCURE Ballast Water 

Management System

12/19/2008 MEPC 59-2-11_SiCure-Ger-Basic

Special Pipe Hybrid 

Ballast Water 

Management System 

combined with 

Ozone treatment 

version

Basic Approval of Active Substances used 

by Special Pipe Ballast Water Management 

System (combined with Ozone treatment)

4/12/2006 55-2_SpecialPipe-Jap-Basic

Special Pipe Hybrid 

Ballast Water 

Management System 

combined with 

Ozone treatment 

version

Application for Final Approval of the Special 

Pipe Hybrid Ballast Water Management 

System (combined with Ozone treatment)

12/4/2008 59-2-1_SpecialPipe-Jap-Final-1

Special Pipe Hybrid 

Ballast Water 

Management System 

combined with 

Ozone treatment 

version

Application for Final Approval of the Special 

Pipe Hybrid Ballast Water Management 

System combined with Ozone treatment 

version (SP-Hybrid BWMS Ozone version)

3/17/2010 61-2-2_SpecialPipe-Jap-Final-2
72

System Title Date File name

Special Pipe Hybrid 

Ballast Water 

Management System 

combined with 

PERACLEAN ® Ocean 

(SPO-SYSTEM)

Application for Final Approval of the Special 

Pipe Hybrid Ballast Water Management 

System combined with PERACLEAN ® Ocean 

(SPO-SYSTEM)

3/29/2010 61-2-10_SpecialPipeSPO-Jap-Final

Sunrui ballast water 

management system

Application for Basic Approval of Sunrui 

ballast water management system 8/24/2009 60-2-3_Sunrui-China-Basic

BalClor TM ballast 

water management 

system (formerly 

Sunrui BWMS)

Application for Final Approval of BalClor TM

ballast water management system 3/22/2010 61-2-4_Sunrui-China-Final

TG Ballastcleaner and 

TG 

Environmentalguard

Application for Basic Approval of the ballast 

water management system using “TG 

Ballastcleaner and TG Environmentalguard” 

as Active Substances (Toagosei Group)

12/26/2007 57-2-8-TG-Jap-Basic

TG Ballastcleaner and 

TG 

Environmentalguard

Application for Final Approval of the JFE 

Ballast Water Management System (JFEBWMS) that makes use of "TG 

Ballastcleaner® and TG 

Environmentalguard®"

8/20/2009 60-2-2-TG-Jap-Final

Peraclean Ocean, 

ElectroClean

Report of the first meeting of the GESAMPBallast Water Working Group (GESMPBWWG)

2/28/2006 54-2-12_GESAMP-Rpt_1

Special Pipe Ballast 

Water Management 

System (combined 

with Ozone 

treatment), NK 

Ballast Water 

Treatment System, 

EctoSys

Report of the second meeting of the 

GESAMP-Ballast Water Working Group 

(GESMP-BWWG)

7/7/2006 55-2-16_GESAMP-Rept_2

Hybrid Ballast Water 

Treatment System 

using Seawater 

Electrolytic Process, 

NKO3 BWTS, 

PureBallast, 

PureBallast

Report of the third meeting of the 

GESAMP-Ballast Water Working Group 

(GESMP-BWWG)

4/13/2007 56-2-2_GESAMP-Rpt_3

Electo Clean System, 

Clear ballast System, 

CleanBallast! System

Report of the fourth meeting of the 

GESAMP-Ballast Water Working Group 

(GESAMP-BWWG)

12/19/2007 57-2_GESAMP-Rpt-4

Resource Ballast 

Technologies System, 

GloEn Patrol, SEDNA 

using Percaclean 

Ocean, OceanSaver

Report of the fifth meeting of the GESAMPBallast Water Working Group (GESMPBWWG)

1/25/2008 57-2-10_GESAMP-Rpt_5
73

System Title Date File name

TG Ballastcleaner and 

TG 

Environmentalguard, 

Greenship's Ballast 

Water Management 

System, ElectroClean System (ECS)

Report of the sixth meeting of the GESAMPBallast Water Working Group 7/14/2008 58-2-7_GESAMP-Rpt-6

OceanSaver, 

Ecochlor,

NK-O3 BlueBallast 

System

Report of the seventh meeting of the 

GESAMP-Ballast Water Working Group 7/28/2008 58-2-8_GESAMP-Rpt-7

Special Pipe Hybrid 

Ballast Water 

Management System 

(with Ozone), 

CleanBallast, 

NK-O3 BlueBallast 

System, Blue Ocean 

Shield, EcoBallast

Report of the eighth meeting of the 

GESAMP-Ballast Water Working Group 

(GESMP-BWWG)

4/8/2009 59-2-16_GESAMP-Rpt_8

ClearBallast, 

Greenship Sedinox, 

AquaTriComb

Report of the ninth meeting of the 

GESAMP-Ballast Water Working Group 

(GESMP-BWWG)

5/5/2009 59-2-19_GESAMP-Rpt_9

GloEn-Patrol, 

Ecochlor, 

SiCURE, Resource 

Ballast Technologies 

System

Report of the tenth meeting of the 

GESAMP-Ballast Water Working Group 

(GESMP-BWWG)

10/30/2009 60-2-11_GESAMP-Rpt_10

ATLAS-DANMARK, TG 

Ballastcleaner and TG 

Environmentalguard, 

Sunrui Ballast Water 

Management 

System, 

DESMI Ocean Guard, 

Blue Ocean Guard 

(BOG)

Report of the eleventh meeting of the 

GESAMP-Ballast Water Working Group 

(GESMP-BWWG)

12/1/2009 60-2-12_GESAMP-Rpt_11

HiBallast, En-Ballast, 

OceanGuard, Severn 

Trent DeNora

Report of the twelfth meeting of the 

GESAMP-Ballast Water Working Group 

(GESMP-BWWG)

2/8/2010 60-2-16_GESAMP-Rpt_12

General Guidelines on the Installation of Ballast 

Water Treatment Systems Mar-10 0310_ClassNK-BWMS-Intsallation