1

Report from the 

Great Lakes Ballast Water Collaborative Meeting: DULUTH

July 20 - 21, 2010

EPA Mid-Continent Ecology Division

Duluth, Minnesota

Prepared for: Wisconsin Department of Natural Resources (WDNR), Bureau of Watershed 

Management

Prepared by: Sharon Moen* 

Date: August 13, 2010

*

Sharon Moen, Science Writer; Duluth, Minnesota

smoen@umn.edu

218-726-6195 (office)

218-591-2568 (cell)

The goals of this two-day meeting were for participants to: 

1. Gain a better understanding of the testing process/technology-verification procedures by 

touring the only freshwater testing facility in the world - the Great Ships Initiative (GSI);

2. Continue detailed discussions about Ballast Water Treatment System (BWTS) 

technology, verification strategies and policies; and

3. Contribute to one of three working groups convening formally for the first time, to 

support the specific information needs of the pending internal WDNR Ballast Water 

Treatment Technology Report. 
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INTRODUCTION

The Great Lakes Ballast Water Collaborative, as explained by Craig Middlebrook, Deputy 

Administrator of the Saint Lawrence Seaway Development Corporation (SLSDC), addresses real 

ballast water management needs with a degree of informallity. It brings key people together at 

key moments in a practical way with an approach that is thoughtful and inclusive.

The meeting began on July 20 at 8:30 a.m. with Middlebrook introducing Dr. Carl Richards, 

director of the EPA Mid-Continent Ecology Division. Richards welcomed a roomful of about 45 

people and three phone-in participants. He explained that the research laboratory is best known 

for its ecology-focused investigations on midcontinent waters (including Great Lakes and 

Mississippi River) and toxicology work.

Paul Eger, Commissioner of the Minnesota Pollution Control Agency (MPCA) was impressed 

with the way the Collaborative has grown and progressed since the Detroit meeting, saying it 

"shows interest and momentum." He commented that SLSDC has exhibited outstanding 

leadership and commitment and that the MPCA's commitment remains strong.

Mark Burrows, scientist and secretary for the Council of Great Lakes Research Managers from 

the International Joint Commission (IJC) said the IJC was happy to provide support for the 

Duluth forum allowing the Collaborative to continue building a common knowledge base. He 

gave Joe Comuzzi, Commissioner to the Canadian Section of the IJC, credit in putting the 

meeting together both with leadership and financial support. Speaking of leadership, he said 

Lana Pollack recently became the Commissioner to the U.S. Section of the IJC. 

Middlebrook praised Minnesota's leadership within the Collaborative, especially Jeff 

Stollenwerk of the MPCA and Dale Bergeron of Minnesota Sea Grant. He reminded participants 

that "we're not here to debate; we're here to talk about what is practical; what is doable." 

Verification and testing (focuses of the Montreal meeting) precipitated the Duluth meeting where 

participants would tour the Great Ships Initiative (GSI), the only freshwater ballast water 

treatment testing facility operating in the world. 

The Collaborative agreed to focus on the needs of Wisconsin but understood that the information 

would go beyond the immediate questions posed by the State of Wisconsin. The future of ballast 

water treatment within the Great Lakes involves scientists from all over North America, federal 

governments of Canada and the United States, Great Lakes state and provincial governments, 

vendors, vessel owners, non-governmental groups, and regulators. The Ballast Water 

Collaborative includes a cross-section of all of these stakeholder groups. 

TYPE-APPROVAL

Federal “type-approval” for ballast water treatment systems dominated the first informational 

segment. Putting ballast water treatment standards aside, Commander Gary Croot, Chief of the 

Environmental Standards Division of the U.S. Coast Guard (USCG), spoke about steps and 

requirements for type-approval.
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He explained that all critical equipment onboard vessels is type-approved by the Flag 

Administration (for example, in the U.S., the USCG, or an accepted three-party authority is 

required to type-approve equipment). Some international challenges are rooted in the fact that 

some Flag Administrations rely on entities acting on their behalf making quality assurance and 

quality control questionable.

Requiring that important components of a ship be type-approved saves costs and time in the long 

run. Cmdr. Croot used life jackets as an example. “It makes much more sense to type-approve a 

design and then spot-check the manufacturing plants, rather than test every item made,” he said. 

To gain type-approval for ballast water treatment systems (BWTS), manufacturers must balance 

three criteria:

1. Is this system effective in meeting the standard?

2. Is the system safe for the crew and the vessel?

3. Is the effluent safe for the environment?

Cmdr. Croot referenced a linear flow chart out of Lloyd's MIU Handbook of Maritime Security

for type-approving a BWTS. Explaining that the type-approval process was not quite that 

simplistic, he discussed a more complex process flow as diagrammed in an American Bureau of 

Shipping (ABS) guide released in March 2010 (Fig. 2).
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This discussion led into a review of the USCG approval process (see “US Type Approval 

Process” figure below). After joking that vendor applications should be sent to Dr. Richard 

Everett, Environmental Protection Specialist, Environment Standards Division of the USCG, for 

a “yes or no” answer, Cmdr. Croot explained that type-approval was not just a USCG process but 

includes the Environmental Protection Agency (EPA) (Office of Water, Office of Chemical 

Safety and Pollution Prevention), the National Oceanic and Atmospheric Administration, and the 

National Marine Fisheries Service. The BWTS must also pass scrutiny under the:

• National Environmental Policy Act (NEPA)

• Coastal Zone Management Act (CZMA)

• Endangered Species Act (ESA)

• Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)

The type-approval process in the U.S. is time consuming. Cmdr. Croot said that if a vendor 

started the process in July 2010, it would be early 2013 before the BWTS could be typeapproved (assuming an aggressive schedule). In other countries, type-approval also takes about 

18-24 months.

Cmdr. Croot talked about the USCG’s Shipboard Technology Evaluation Program (STEP).

STEP is a voluntary, no-fee program that facilitates the development of ballast water 

management system technologies by granting participating vessels a waiver from future ballast 

water discharge standard regulations while their BWTS operates satisfactorily. By providing this 

opportunity for BWTS vendors to partner with vessel owners, STEP encourages early 

installation of BWTS and expedites the onboard testing needed for final BWTS type-approval. 
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The STEP workshop to be held on July 22, 2010, in Duluth, Minn., will encourage vessel owners 

to install experimental BWTS onboard and encourage early installation. The USCG hopes to 

streamline this process through the Collaborative, especially since the ships must receive 

approval from every state affected. In California, if the system and ship are in the STEP 

program, the state cooperates. The USCG wants the same cooperation from the Great Lakes 

states and provinces.

To conclude his presentation, Cmdr. Croot reiterated that:

• In the U.S., type-approving a BWTS will take at least 18-24 months AFTER

independent laboratories for testing are established;

• Fully marine saltwater test facilities do not exist in the U.S.;

• Much of the type-approval process is outside the purview of the USCG; and

• The USCG is evaluating procedures to accept foreign type approved systems for 

operation in U.S. waters.

VERIFICATION AND VALIDATION

The discussion following Cmdr. Croot’s presentation included a reminder that quality assurance 

and quality control are “hugely important and need to be handled with rigor.” QA/QC could be 

assessed onboard vessels like the California Maritime Academy’s training ship Golden Bear, 

which was recently outfitted to test ballast water treatment prototypes. Golden Bear and the 

Maritime Environmental Research Center (MERC) barge (being developed by Dr. Mario 

Tamburri, research associate professor at the University of Maryland and director of MERC) are 

moving toward full marine testing. The USCG wants BWTS to be installed and fully tested on 

ships (hence STEP) and works closely with all three BWTS testing facilities in the U.S. (MERC, 

GSI and Golden Bear).

Dialog among meeting attendees revealed that independent testing laboratories must wait for 

final regulations that set requirements for treatment efficacy, just as do BWTS vendors and 

shippers, before they can finalize their testing schemes and protocols. Laboratories need to be 

independent of vendors. However, on a global scale that independence is not always present and 

might create challenges when vendors and shippers plan to operate in North American waters. 

Independent laboratories don’t approve BWTS, Flag Administrations do based-on outcomes 

from BWTS tests conducted at independent labs. The USCG is looking into a process for 

accepting foreign approvals BUT they are having difficulty with “reporting-transparency” and 

therefore Quality Assurance/Quality Control. Manufacturers of BWTS should develop 

shipboard testing protocols so that users can easily check to verify that systems are working 

properly. The USCG might hire a contractor to conduct tests because they don’t have the 

personnel or expertise to do the testing.

Environmental Technology Verification (ETV) Protocols for independent lab testing are drafted 

and available for public comment (http://www.epa.gov/etv/etvoice0310.html). Sometime 

following EPA’s review of the ETV Protocols, the USCG plans to release the ballast water 

management regulations for both Phase I and Phase II simultaneously.
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It was suggested that within the FIFRA process, the “go-to” person in the multiple agencies 

involved should be made accessible in a list. At this time, this information is not readily 

available, making the process cumbersome and time consuming. 

Chris Wiley of Fisheries and Oceans Canada said that Transport Canada, like the USCG, will not 

“be out there looking at ships.” He explained that Canada is developing a process for type 

approving BWTS based on G8 and G9 IMO guidelines. Transport Canada is encountering issues 

that are similar to those challenging the USCG, i.e., verifying the performance of systems that 

have been type-approved by other Flag Administrations. Another issue is ensuring that systems 

have been tested under conditions representative of what vessels will encounter, such as the fresh 

cold water of the Great Lakes. These conditions can have a significant impact on the efficacy of 

a system that has been tested for type approval in warm, saline water.

SHIP CLASSIFIATION

Bill Lind, Marine Technology and Business Development Director for ABS Americas, reviewed 

the type-approval process from ABS’s perspective. He said that ship classification grew out of 

the need for insurance and dates back to the sixteenth century. Lloyd's Register printed the first 

Register of Ships to give both underwriters and merchants an idea of the condition of the vessels 

they insured and chartered. ABS is like Lloyd’s Register. Founded in 1862, the not-for-profit 

ABS has 3,000 employees and 183 offices in 72 countries. It helps insure 11,000 commercial 

ships, boats, and barges; military vessels; offshore rigging; and yachts. ABS’s mission is to 

protect lives, property, and the environment. 

Lind said that ship classification is third-party certification and that classification is a life-cycle 

process, which certifies adherence to a recognized state of technical standards. Generally, 

certification covers a ship or marine structure as a whole, but it may cover a single piece of 

equipment. 

In addition to addressing pollution, Lind said vessel owners have to work toward energy 

efficiency. An Energy Efficiency Design Index (EEDI) chart is currently being hashed out at an 

international level, he said. What all classification systems try to do is to keep pace with 

regulatory updates. 

In June 2010, ABS published a Ballast Water Treatment Advisory to assist the industry in better 

understanding the evolving ballast water management (BWM) and treatment regulations, with an 

emphasis on providing practical guidance for shipbuilders, owners, and operators on how to 

prepare for the selection, installation, and operation of an appropriate treatment system for 

different ship types. The Ballast Water Treatment Advisory is divided into five sections: 

1. Regulatory developments;

2. Treatment technologies;

3. Considerations for system selection;

4. Evaluation checklists; and 

5. A technical summary of the principal systems currently available on the market.
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Lind provided an overview of the Advisory, which included insights such as: the type of BWTS 

a shipper picks will depend on the ship (consider space to install and maintain, storage of 

chemicals, installation ease, flow rates and pressure drops, supply of spare parts and chemicals, 

training and documentation, life cycle costs). Additional considerations are necessary if the 

BWTS uses active substances or chemicals. For existing vessels, an increased gross tonnage tax 

may be levied. Another problem is that vessels may experience power failures once a BWTS is 

installed. Lind said that there are an increasing number of “dead ships” because of overall 

increasing demands on power. 

Lind concluded by reiterating that “type-approval” means different things to different people. 

He said, “We second what the Coast Guard is saying; be careful about what information you are 

using...does it really fully comply?”

NOTE: The ABS Advisory is a substantive resource for information about the current state of 

ballast water management technologies. Copies of the Advisory are available from ABS offices 

or are available for download from the ABS Web site within Resources, Booklets & Bulletins 

(see: www.eagle.org).

VENDOR PERSPECTIVE (Ecochlor®)

Charles (Charlie) Miller, CEO from Ecochlor®, Inc., stepped to the microphone to report that the 

company has installed full-scale systems onboard working vessels and that Ecochlor’s BWTS 

have been tested by Lloyd’s Register and ABS for type approval on behalf of Flag 

Administrations. Also, the first commercial cargo vessels accepted into USCG’s STEP program 

carry large-scale Ecochlor systems. (It took three years, National Environmental Policy Act 

(NEPA) review included, but Ecochlor was the first BWTS through the process.) 

Ecochlor manages ballast in two steps: pre-filtration and treatment with ClO2 (chlorine dioxide). 

Only the pre-filtration components need to be installed in close proximity to the ballast pumps. 

According to Miller, the scalable system has a small footprint and consumes minimal power. 

Hundreds of these types of filtration systems are in use within marine environments around the 

world (although not specific to BWTS). Miller reported that the test results exceeded the U.S. 

proposed standard (based on values being below the detection limit of the testing method).

Recently, shipboard testing of Ecochlor by German scientists found no viable organisms after 24 

hours. Purate (a precursor in the formation of ClO2) supplies, and service ports are available 

worldwide.

All systems need a pre-filtration component (the Royal Netherland Institute for Sea Research 

testing facility found that a 40-micron filter was successful). The ClO2 treatment can be installed 

where it is convenient. Miller reported that ClO2 is highly effective at killing all organisms and 

biofilm in ballast water. “It is a proven and well-understood technology that does NOT produce 

chlorine,” he said. Dosage is not affected by organics or salinity. ClO2 is a highly soluble gas in 

water and readily disperses. 
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At the end of the presentation, a member of the audience asked if there might be concerns about 

corrosion on the uncoated ballast tanks of Great Lakes ships. Miller said the chlorine was gone 

within about six hours so exposure would be limited. Another audience member reminded the 

group that ballasting may occur many times within a day or two on a laker, whereas ocean-going 

vessels might ballast once a month. This brought up the unanswerable (at this time) question of 

how much purate and acid (to create ClO2) might be needed.

REGULATORY PERSPECTIVE (Minnesota Pollution Control Agency)

Jeff Stollenwerk, Acting Manager of the Industrial Land and Water Quality Permits for the 

Minnesota Pollution Control Agency, talked about the regulatory aspects of ballast water 

management in the Great Lakes. He began with a chart (shown below) illustrating how the 

standards for ballast water are "all over the board for states, and the U.S. and Canadian 

governments." 

Due to regulatory inconsistencies, the state of technology, and timeframe, Stollenwerk felt that 

some vessels currently transiting the Great Lakes will likely not be able to achieve compliance. 

He said that, especially given the difference between marine and freshwater environments, 

ballast water discharge standards will likely need to be more stringent than the IMO D-2 

Convention to meet state water quality standards under the Clean Water Act. The EPA and 

USCG are working with the National Academies 

(http://www8.nationalacademies.org/cp/projectview.aspx?key=49224) to develop an approach to 

establish environmentally protective standards. Stollenwerk thought they might recommend a 

different standard than that proposed by the IMO. He said, "What we understand about 

introduction risks and propagule pressure will force scientists to make pretty conservative 

conclusions. I wouldn't be surprised to see standards close to California standards."

Stollenwerk suggested that states may need to develop enforcement strategies to address noncompliance. He could envision that some vessel owners might refuse to operate in violation of 
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ballast water regulations. Ship owners are concerned about having to make decisions now in 

order to meet some of the proposed deadlines for compliance.

The traditional tools for resolving this type of sticky situation (rulemaking/permitting; 

legislative; litigation) may take 3-5 years within the EPA's framework. To expedite better 

practices for ballast water management in the Great Lakes, Stollenwerk pitched the idea of 

developing compliance agreements between governments and shippers, possibly through the 

Great Lakes Ballast Water Collaborative. He thought that crafting a negotiated enforceable 

document to achieve compliance with respect to challenging regulations could make progress 

toward reducing the spread of aquatic invasive species while complying with discharge 

standards. As a first-step, he thought that a negotiated agreement could be developed to ensure 

the next vessels within the USCG's STEP program are in compliance with all applicable 

regulations.

The group recognized the advantages of putting BWTS onboard vessels sooner rather than later 

(BWTS research and development, environmental health). Scott Smith, Chief of the Ecology 

Section of the U.S. Geological Survey Western Fisheries Research Center, suggested an 

approach similar to that adopted by the State of Washington: if the USCG approved a BWTS, 

the state will accept it also. A BWTS vendor didn't think a negotiated agreement was an efficient 

approach; this thought was challenged by Bruce Bowie, President of the Canadian Shipowners 

Association. Jon Stewart, representing International Maritime Technology Consulting, added 

that while a negotiated agreement could serve as an interim step, it would not be a blanket 

solution. 

Others agreed.

A STUDY OF BALLAST WATER MOVEMENT IN THE GREAT LAKES

Canadian Shipowners Association representatives Bruce Bowie and Azin Moradhassel presented

research results prepared by Canadian Steamship Line's (CSL) Kirk Jones, Caroline Denis, and 

Joe Lewis. The topic concerned the potential risk of transferring invasive species within Great 

Lakes ballast water and workable solutions for existing lakers.

Referencing a handout, Moradhassel explained the three goals of the CSL study:

1. To determine how much ballast water is being moved between domestic ports;

2. To determine what aquatic invasive species (AIS) are moving; and

3. To define the potential risk moving of AIS. 

The researchers drew from the Vessel Transit Study1

 1 Rup, M. P.; Bailey, S. A.; Wiley, C. J.; Minton, M. S.; Miller, A. W.; Ruiz, G. M.; MacIsaac, H. J., 2010. 

Domestic ballast operations on the Great Lakes: potential importance of Lakers as a vector for 

introduction and spread of nonindigenous species. Canadian Journal of Fisheries and Aquatic Sciences 

67(2): 256-268.

to create a database of ballast water 

movement between ports, and to identify potential AIS-donor and AIS-receiver ports. They 
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found that the CSL fleet of 18 vessels moved approximatly 8.5 million metric tons of water 

between Great Lake ports in the 2009 shipping season. A majority of this volume went to seven 

ports (CSL Ballast Receiver Ports chart) from seven donor ports (CSL Ballast Donor Ports 

chart).

Moradhassel then talked about the second goal of compiling a database of AIS in Great Lakes 

and how the AIS database would be used to cross-reference the presence of AIS in ports with the 
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ballast water movement database to model the probablity of further AIS introductions (goal 3). 

The model can be broken down into: per voyage, per load port, per light port, per species, and 

per vessel. The researchers found that the three invasive species most likely to be spread in 

ballast water are: fishhook waterflea, rudd, and bloody red shrimp.

Moradhassel mentioned Lake Superior in particular. She said that preliminary results suggest 

that CSL vessel transits have the potential to move six species (3 percent of existing AIS) into 

Lake Superior through the Hamilton-Superior trade route. However, despite having moved large

volumes of ballast water into Lake Superior ports over a long period of time, there is no evidence 

of AIS transfers from load ports. She reasoned that maybe this is because Lake Superior is a 

“cold spot (Note: see Grigorovich et al, 20032)?” 

CSL intends to improve the model, use it as a tool to examine risk of transfer questions, and to 

potentially develop a “Made in the Great Lakes” solution for addressing AIS transfer risk for 

existing vessels.

CSL was congratulated for the courage to engage in this study. Dr. Sarah Bailey, Research 

Scientist with Fisheries and Oceans Canada, said the CSL model was a useful tool and that in 

addition to shipping companies reporting transfer data, scientists need to identify what is in each 

port to begin with. Bowie asked that Collaborative members provide comments to Middlebrook. 

He said that the CSL identified its potential for moving AIS, but information about propagule 

pressure and infestation risk is limited. They would like to determine workable technologies that 

address the greatest risks. Middlebrook said that while everyone is looking for a BWTS that 

works in cold fresh water, the interim measures being pursued, like the information generated 

through the CSL study, are laudable. 

From 11:30 a.m. onward, many Collaborative participants toured the Superior Midwest Energy 

Terminal to better understand the volume of cargo being moved by Great Lake vessels and the 

importance of cargo velocity (hence the demand for high ballast flow rates). They also toured 

the GSI facility (the only fresh water BWTS testing facility in the world, located in the Superior 

Harbor), and some viewed the layout and ballast tanks of a working vessel at the Duluth Seaway 

Port Authority. 

DAY TWO

Adolph Ojard, Executive Director of the Duluth Seaway Port Authority, interjected as the 

meeting opened on July 21, that he felt it important to give some perspective concerning the 

activity levels in the Port of Duluth/Superior and the general activity of maritime commerce in 

the Great Lakes. Ojard reported that the Port of Duluth-Superior experienced activity involving 

eight different ships in the previous 24 hours: the McCarthy left, the St. Claire, American 

Century, and the White arrived and departed, the Presque Isle was loading grain, a ship destined 

for Montreal was loading wheat, a ship with a byproduct of ethanol used for animal feed was 

 2 Grigorovich, I.A., A.V. Korniushin, D.K. Gray, I.C. Duggan, R.I. Colautti, and H.J. MacIsaac. 2003. Lake 

Superior: an invasion coldspot? Hydrobiologia 499: 191–210.
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going to Turkey, and a ship destined for Spain was loading beet pulp; plus, 1,000 cars of coal 

and grain had been through. 

MORE ON SHIP CLASSIFICATION AND BWTS

Graham Greensmith, Lead Specialist of External Affairs from Lloyd’s Register, spoke to the 

Collaborative via teleconference. He addressed BWTS from an insurer’s perspective. The first 

point he made was that the vendor, Flag Administration, a recognized organization (RO) acting 

for the administration, a land-based testing facility, and a ship need to be involved in ensuring 

that a treatment system is safe and effective. While the Flag Administration is responsible for 

certifying a system, often they pass the process to an RO. The manufacturer must apply for 

approval, which requires land-based and shipboard testing.

Greensmith discussed using the International Maritime Organization’s (IMO) G8 guidelines 

from a practical point of view. He said that the guidelines are complex and open to 

interpretation. IMO type-approval takes about 18-24 months to complete. He suggested that in 

light of experience, it may be time to update the guidelines, but in the meantime, using them 

requires coordination, good relationships, and all parties to fully understand the process and their 

responsibilities.

Responding to audience questions, Greensmith said that ideally, vetting and verification 

procedures would be conducted through a quality assurance program within the IMO. As BWTS 

technologies are developing, so should the type-approval process. Greensmith said he 

understands that some of the BWTSs won’t work in fresh water but didn’t have information to 

comment on what might work in the Great Lakes.

Allegra Cangelosi, Senior Policy Analyst with the Northeast Midwest Institute, said the U.S. 

testing facilities are conducting IMO-consistent tests and developing an information base to 

determine differences between BWTS performance in fresh, brackish, marine waters. She said 

that GSI would like to have a relationship with Lloyd’s Register. 

Dr. Richard Everett commented on the distinction between independent labs and test facilities. 

By the Coast Guard’s definition, he said that an “independent lab” is more of an oversight 

organization responsible for providing oversight to test facilities. He said that GSI is not 

necessarily an independent lab, but that it could be. ABS could be, and maybe it is for some 

things. Engineering issues and efficacy tests may take place at a totally different facility. He 

recommended that Collaborative participants keep in mind that independent laboratory 

representatives may not even be in the room and that some of the components involved in BWTS 

are not at the table (engineering labs, for example). He said that there needs to be some selforganization for independent labs to line up different testing facilities and that most of this 

organization is outside the USCG purview.
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MORE ON VERIFICATION AND VALIDATION

For the next hour, Dr. David Reid, a consulting scientist to the SLSDC, facilitated a panel 

discussion involving the BWTS testing capabilities in the U.S. Panelists consisted of Allegra 

Cangelosi, Dr. Mario Tamburri (by telephone), and Dr. Lisa Drake. Cangelosi is director of the 

GSI test facility located in Superior, Wis.; Dr. Tamburri is Director of the MERC test facility 

located near Baltimore, Md., and Dr. Drake is lead scientist for ETV (Environmental Technology 

Verification) test protocol development at the Naval Research Laboratory, Key West, Fla. GSI 

and MERC are BWTS type-approval test facilities and also conduct test protocol development 

and evaluation; the NRL facility does not conduct BWTS type-testing, but is under contract with 

the U.S. Coast Guard to develop the ETV test protocols, which are designed to verify 

manufacturer claims of system performance. The session was designed to continue discussing, 

not rehash, the information and progress made during the Montreal Ballast Water Collaborative 

meeting (see the Montreal Report for details). Dr. Reid listed four themes for the discussion: 

• Status of protocol development (domestically and internationally);

• Challenges and opportunities for achieving statistical confidence in results at a given landbased test site;

• Opportunities to optimize the predictive accuracy of the overall type-approval process 

outcomes of BWTS performance in the real world; and 

• Database development and management to support review and revision (adaptive 

management).

Major outcomes of the Montreal meeting with respect to this panel include: 

• A review and assessment of verification facilities for BWTS;

• Recognition that there are currently no uniform standards for BWTS test protocols;

• An agreement that quality assurance and quality control references and standards are 

necessary; and

• An understanding that validation is enormously challenging because of sample volumes

and statistics (challenges associated with statistical confidence).

Dr. Drake gave an update on developing the Environmental Technology Verification (ETV) 

protocols to be adopted by federal agencies saying that they have cleared the National Science 

Foundation and are pending clearance by the EPA (Research and Development Laboratory), 

hopefully in August 2010. She acknowledged the persistent challenges associated with sample 

volume and statistics, and the difficulties associated with going from land-based testing to 

shipboard testing. Extrapolating land tests to ship performance is not necessarily a 

straightforward calculation. She suggested a data repository and some associated database 

management could help resolve issues regarding predictiveness. A central database of BWTS 

test performance data measured in a systematic way might include: salinity, type of ecosystem, 

and temperature.

The big change from earlier drafts of the ETV protocols relates to sample volumes; very large 

volumes appear to be necessary to verify that IMO standards are being met (Dr. Drake noted that 

to achieve statistically acceptable confidence that the Wisconsin standards are being met, 
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phenomenal volumes of water would have to be sampled). In earlier drafts of the ETV protocols, 

3-cubic-meter samples were considered sufficient. Now 5-, 10-, and 30-cubic-meter samples are 

called for. It might be possible to use smaller volumes if samples can be concentrated. 

Determining viability was also revisited since it is difficult to determine if protists are living; the 

drafted ETV protocol calls for the coupling of two vital-fluorescence stains. An EPA Science 

Advisory Board (SAB) committee is reviewing the technology to determine if it is possible to 

verify that a BWTS working onboard a ship is meeting IMO standards. This verification is a 

critical challenge for regulators.

Shipping industry representatives wondered how going beyond validation to verification would 

happen. Dr. Drake said that she is discussing this issue with Fisheries and Oceans Canada 

scientists (Sarah Bailey et al.) but that if any parcel of water exceeds the standard, it won’t pass 

verification if regulators are onboard. She thought that maybe ports could take a first cut and if 

the BWTS passed, then it would be approved; if it didn’t, then further testing would be required. 

Dr. Tamburri said that with such large volumes involved, it would be most effective to look for 

gross violators rather than vessels that are barely under or barely over the standard.

Cangelosi said that the forthcoming ETV protocol is likely to be an organizing force for ballast 

water management in the U.S. She said, “It is a first ‘ante’ of how type-approval and compliance

testing could take place.” How well the type-approval testing predicts how well a BWTS will 

perform on a ship in operation will remain enigmatic for several more years. Cangelosi 

continued, “The first ante can barely be informed by the stuff that happens after it. I suggest that 

this group produce a database so that this challenge can be easily addressed. I don’t know if 

there is going to be a gap, but we would be wise to keep the potential disconnect in mind. We 

might review past lessons about performance in the real world verses lab results.” She said 

regulators must be prepared to make changes in the protocol to tighten the gaps as time goes on.

In the myriad conditions in which BWTS will need to operate, it was suggested that a prudent 

ship-owner or environmental advocate would look for the system that had been tested in as many 

conditions as possible. (Presently, a BWTS that has been vetted under controlled conditions is 

probably the best that is possible; hedge your bets.) Cangelosi commented that certain BWTS 

vendors are going beyond bare minimum (inspired by shipper’s requests) by having multiple 

tests done then aggressively marketing their double or triple land-based tests. Dr. Tamburri 

questioned ways to compare complete sets of data. Cangelosi said, “Yeah, that’s why the 

database doesn’t exist already.” Dr. Drake suggested holding a workshop to harmonize methods, 

but reminded the group that the statistics would be tough to get around. “Sample size will have 

to be a factor in the database,” she said.

Dr. Reid asked Cmdr. Croot if the STEP program was gathering data that could contribute to this 

database and if compliance would be monitored under different conditions. Cmdr. Croot 

answered with an emphatic, “Yes!” Ships currently in the STEP program travel from Hawaii to 

the West Coast, and one travels to Asia. They experience significant operating ranges but one of 

the challenges is finding examples of ships that don’t comply; for example, in a test conducted in 

the United Kingdom, the uptake water was already in compliance before any treatment 
15

happened. The panelists agreed that validation and type-approval testing protocol should include 

language stating the uptake water must exceed the IMO standard.

Cangelosi responded to a question about how to encourage regulators to collect information for 

adaptive management by saying, “despite the vagaries of biology, we need a solid information 

base and we have to hope that regulators access it. Those of us here need to help develop this 

information source and put it in the right hands.”

Stewart (International Maritime Technology Consulting) said that vendors would participate on 

an industrial level but that the group should remember that BWTS manufacturers are not nonprofits. He said, “Vendors take tremendous financial risks to develop BWTS. They don’t get 

much in the way of kudos, but they definitely get punished for failure. I don’t know of any 

business that doesn’t want to exceed IMO standards; they want to go beyond compliance 

testing.” He suggested that technology developers could contribute beyond-compliance testing 

information to support the BWTS database being discussed. 

Wiley was asked to comment on Canadian ships with BWTS onboard that are arriving with noncompliant numbers of living organisms in their ballast water. He said he couldn’t find a 

correlation between failure and the conditions. “Manufacturers are working to ensure that their 

systems perform under all conditions,” he said. “Manufacturers are working hard to make 

BWTS work.”

Dr. Bailey said, “Simply, those systems were not tested in freshwater.” Vendors are required to 

test in two of three conditions: saltwater, brackish, or freshwater. Most are tested in brackish 

and saltwater. “Ships are a terrible place to do science,” continued Dr. Bailey suggesting that 

maybe there is a need for more laboratory testing in different conditions even before ship-board 

testing starts. Important variables that are possibly skimmed over during testing include: 

temperature, turbidity, and salinity. Cangelosi agreed saying, “...leaving these variables to 

shipboard testing is very, very risky.” 

Land-based testing facilities in the U.S. are improving. The GSI works to make BWTS testing 

easy and cost-effective. They cooperate with MERC where systems can be tested using brackish 

water and are subsidized by federal funds. Dr. Drake said that the purpose of land-based testing 

is to get information in a controlled condition and that the purpose of shipboard tests is to see if 

the system rattles apart. Ships can experience tremendous physical motion with waves bashing 

and engines churning in hot, humid environments. She said that it is not ETV’s responsibility to 

test at multiple temperatures and salinities. ETV protocols use salinities that are different than 

IMO standards to encourage testing in different conditions.

“Don’t forget the vendors and what they have to go through!” said a Collaborative participant. 

Many salinity and temperature questions can be addressed in lab and some of the questions don’t 

have to be answered everywhere. Water temperature influences decay rate. Salinity is more 

than a chemical issue; it is biological also. BWTS with a filtration component (i.e. most of them) 

will likely function differently in fresh and saltwater. 
16

Dr. Everett (USCG) explained that ETV testing is undertaken and designed to verify a 

manufacturer’s claims. He said that ETV protocols were developed through a Memorandum of 

Understanding between the USCG and the EPA. EPA’s stakeholder process identified the need 

for protocols, which gave the USCG an opportunity to tap a skill set not typically available to 

them. “However, there is a difference between ETV protocols and the type-approval process,” 

he said. ETV protocols might have nothing to do with type-approval. If a manufacturer makes a 

claim, ETV protocols lay out a plan for how the claim should be checked. Dr. Everett said that it 

is easy to confuse the two, especially since the USCG wants to make use of the early spadework 

(ETV) to facilitate the type-approval process.

Dr. Reid summarized the panel discussion about the type-approval process. He recalled the 

concern that land-based testing may not translate well to shipboard performance due to the 

movement and motion of a ship. He also said that it was important not to confuse ETV protocols 

with type-approval protocols. “Verification and validation testing are more complex than we 

might have outlined for simplicity,” he concluded.

Dr. Tamburri wrapped up with the comment that although U.S. land-based testing facilities are 

coordinating their efforts, the diversity of testing around the world means that information is not 

necessarily going to be collected and reported consistently. Communication among scientists is 

crucial in ensuring that the information is comparable. Recent comparisons between GSI and 

MERC indicate that different species are responding to the same system in similar ways. North 

Sea researchers are coordinating to create harmonization of projects, which is being extended to 

the U.S. 

The Ecochlor CEO asked, “What is the incentive for manufacturers to go through the ETV 

program when USCG will require much more? You could bankrupt yourself just going through 

one set of tests?” Dr. Everett responded saying that the USCG intends to reference ETV 

protocols in type-approval. The whole point was to, at a minimum, develop protocols to evaluate 

BWTS to IMO. “If it plays out how I think it will, part of the type-approval application would 

require that a vendor test their BWTS with ETV protocols to IMO standards,” he said. The 

difference between ETV protocols and type-approval is illuminated in a situation where a vendor 

might want to make claims beyond what the USCG cares about (i.e., ease of use, repairs). Shipowners use ETV to verify vendor claims, sort of like Consumer Reports.

A Collaborative participant recalled hearing that the USCG might not require a vendor to get 

type-approval for short runs (as short as 10 hours before reballasting) and at unusual pumping 

rates. Dr. Everett said that if a ship needed special considerations, that information would be 

specified in the type-approval document. 

Cmdr. Croot answered a question about the USCG’s ability to force a ship owner to install an 

approved system. He said, “Cost is not a factor in type-approval; footprint is not a factor. Those 

questions are of practicability.” Type-approval has NOTHING to do with “practicability,” but 

the USCG is required to do this, and is in the process of reviewing BWTS “practicability” this 

week. 
17

Bill Lind suggested that since the USCG has done regulations for a long time (i.e. fire protection 

information) that maybe they could implement ballast water regulations in the same way.

Susan Sylvester, Chief of the Permits Section of the Bureau of Watershed Management with the 

Wisconsin Department of Natural Resources, discussed the practicability review in Wisconsin. 

She expects the working groups to solve some basic questions about feasibility and if BWTS 

technology is practical at this time. Dave Adams (New York DEC) said the practicability review 

in New York is limited by 401 certification requirements and that all the states he has been 

working with have some form of a practicability review.

WORK GROUP BREAKOUT SESSIONS

At 10:30 a.m., Sylvester described the process and expectations for the breakout sessions. (See 

Description of process/expectations for work group breakout sessions handout.) The groups were 

tasked with working together to turn out specific products. Sylvester explained that the sessions 

were designed to help address Wisconsin’s Ballast Water General Permit and the challenges 

associated with it. She appreciated that the EPA is in the process of determining feasible 

national discharge standards and regrets that those numbers won’t be available before 

Wisconsin’s December 2010 deadline for making a decision. Like most, she thinks a proposed 

rule by Coast Guard would be ideal.

Dale Bergeron, Maritime Transportation Specialist for Minnesota Sea Grant, said that since 

uncertainty percolates the issues, the workgroups should “not look for perfect, but instead look 

for available.” He reminded the group that the discussions should reflect positions, not personal 

opinions, he asked the groups to focus at a “high level,” and reminded participants that the 

dialogs were going to be turned into general notes, not testimony.

The Breakout Sessions were as follows:

Work Group 1: Identification of “Available” Ballast Water Treatment Systems “Rated” to 

Meet or Exceed 100x IMO. (Facilitator: Dr. Marvourneen Dolor)

Work Group 2: Evaluating Factors Affecting the Installation of Specific Ballast Water 

Treatment Systems on the Applicable Fleets and Vessels within the Designated 

Timeframes. (Facilitator: Dale Bergeron)

Work Group 3: Review and Assess Current Verification Capability for Treatment Systems 

to Comply with a Discharge Standard of 100x IMO. (Facilitator: Dr. David Reid). 

Full reports from these sessions are available in Appendix I. Each group developed a 15-minute 

summary to close out the Great Lakes Ballast Water Collaborative meeting.

Group 1 reported the that “commercially available” has a muddy definition. They discussed a 

table of BWTS options and spent time talking about IMO final approval and type-approval, Flag 

Administrations, U.S. final rule, timing, and what the Canadian government is going to require 
18

since they ratified the IMO Ballast Water Convention. One point of discussion focused on 

whether carriers can put a system onboard today or if they need to wait for USCG approval. 

What is commercially available can be classified by:

• Regulatory approval;

• Production components;

• Operation acceptability for particular vessels (freshwater, dwell time for active 

ingredients).

The group reiterated a common theme that having USCG proposed protocols would be very 

helpful. They discussed standards for saltwater verses freshwater, and U.S. verses Canada. 

Encouraged by the CSL presentation regarding the potential risk of transfering invasive species 

in Great Lakes ballast water and workable solutions for existing lakers, they pondered risk 

assesment for lakers thinking that maybe the Collaborative could come up with a compliance 

schedule beyond any due dates based on risk. 

Group 2 worked under the assumption that a treatment system 100x IMO is commercially 

available and that their objective would be to get it onto a ship. Their discussion, spanning ideato-complete installation, will feed a flow chart illustrating the process. Specific factors and steps

that come into play were identified, as were sticking points (i.e. regulatory uncertainty was 

considered paralyzing) and opportunties (states could normalize their regulations; regulatory 

consistency would simplify the problem). A time-line conversation suggested that the process of 

selecting and installing a BWTS would take 3-5 years once a decision to install a system has 

been made. 

Group 3 addressed the major question of: “Can scientists currently verify that BWTS can 

comply with 100x IMO standards?”, and they also considered three specific work objectives, and 

several associated action items. To address compliance monitoring and future testing they 

referenced 11 articles published in the last 2 years (since 2008). They expect the number of 

available articles to continue to grow dramatically in the next several years. U.S. and Canadian

scientists participating in the work group explained the IMO (G2, G8, G9) protocols, California 

testing guidelines, etc. Two certification reports were also listed on a handout document for the 

Group 3 discussion. Their dialog covered current available testing protocols and facilities, and 

the necessity of collecting data in a transparent way. Limitations with physical sampling 

continue to hamper verification testing, making ship-based compliance monitoring considerably 

more challenging than land-based verification testing.

NOTE: The summaries from the three “Working Groups” reflect the discussions that were an 

actual part of the break-out sessions of the day (participants of each work group are listed). 

Dialog on various elements of “work group” discussions naturally continued after the official 

meetings. Individual work group participants were encouraged to submit personal comments 

(those not discussed by the entire work group) directly to the WDNR to further inform its permit 

deliberations.
19

CONCLUDING REMARKS

Middlebrook concluded the meeting by posing the question of “Where do we go from here?” He 

summarized the two-day meeting by noting three paths forward, all with the ultimate goal of 

trying to get to effective and workable effective ballast water management solutions and 

regulatory certainty “sooner rather than later.” He noted that each of these paths for reaching 

desirable outcomes are concurrent rather than sequential:

1) Addressing the immediate ballast water regulatory landscape covers the next 6 months to 2 

years and is focused at the moment on assisting the WI Department of Natural Resources in its 

efforts to produce a feasibility report by the end of the year. Other stakeholders are paying close 

attention to Wisconsin and how it will choose to proceed, and the year-end WI DNR feasibility 

report will attract a lot of attention.

2) The longer-term regulatory and technological landscape covers the next 2 to 5 years. It will 

likely take that long before there is a comprehensive legislative, and/or regulatory ballast water 

framework in the U.S. Such a framework would cover such primary issues as applicable 

standards and verification/testing protocols. It is only with such a framework that the 

technological solutions offered by emerging ballast water treatment technologies can be fully 

realized as well.

3) Finally, there is the medium term, which falls somewhere between the first two paths and 

seeks an “interim” solution through more immediate risk-mitigation measures until the longerterm comprehensive framework described above can be put in place and effective BWTS are 

developed. Middlebrook stated that a lot of the discussion at this meeting focused on this path. 

For example, there was Jeff Stollenwerk’s idea of developing some form of “administrative 

agreement” between the states and industry stakeholders, as well as the CSA/LCA proposal to 

explore immediate risk-mitigation measures, and finally, there is the USCG’s STEP program and 

facilitating the better use of this program.

Middlebrook noted that the BWC can – and is – making a tangible contribution to each of these 

efforts. He remarked that by bringing together key stakeholder representatives and experts, the 

Collaborative is trying to help key decision makers make better-informed decisions, and to allow 

them to make these decisions sooner, rather than later.

Regarding possible next steps for the BWC, Middlebrook stated that the primary focus right now 

is on assisting the Wisconsin DNR in preparing its feasibility report. This includes concluding 

the information-gathering work of the three work groups that met during the meeting. Second, 

would be to focus on the proposals for immediate, interim risk-mitigation measures that were 

brought up during the meeting by Jeff Stollenwerk, Bruce Bowie, Dr. Richard Everett and Cmdr. 

Gary Croot. Finally, and more generally, Middlebrook asked the members of the Collaborative 

to be attentive to opportunities where the forum provided by the BWC could be used to educate 

and inform as part of the effort to achieve greater regulatory stability and meaningful 

environmental protection until the regulatory framework, scientific knowledge, and 

technological capabilities arrive at the level where everyone would like 

them to be.
20

Middlebrook thanked the Collaborative's EPA hosts and asked for last thoughts from the floor. A 

Great Lakes fleet representative asked if commercially available included costs or if 

commercially available really meant available to military vessels with much bigger budgets. 

Sylvester said that costs would fall under operational function.

The group agreed with the suggestion that regulatory stability and the availability of BWTS that 

could effectively protect freshwater environments would significantly advance ballast water 

management in the Great Lakes. Three paths forward (each with different timelines) include:

1. Coordinating the immediate regulatory landscape (States and Canada align rulings); this 

could take 6-12 months.

2. Improving the regulatory and technology landscapes (USCG, EPA, vendors, shippers); this 

could take 3-5 years.

3. Work to mitigate environmental risks in a regulatory environment that has enough stability 

not to put the industry out of buisness (or thereby exacerbate other harmful environmental 

impacts through a modal shift); this is an intermediate strategy and need.

When a participant asked if state regulatory bodies in the Great Lakes could agree to accept 

USCG STEP applicants, Stollenwerk answered that the benefits of getting treatment systems 

onboard ships sooner rather than later are clear. He said, "While we can't know for sure if ships 

in the STEP program will meet state standards, we hope states will see this as a necessary effort 

toward the goals of minimizing AIS movement."

Cmdr. Croot said that through STEP the USCG would "like to move the puck down the ice." He 

reminded participants that there would be a STEP training program at the EPA laboratory the 

next day. Having a robust STEP program in the Great Lakes will help ship owners make better 

BWTS selections when facing significant factors and constraints. He said, "We would like a 

variety of vessels enrolled in STEP. I'm not going to tell you that the application is an easy 

process that you can do over a few beers." And then he joked that a few beers probably wouldn't 

hurt. He suggested that maybe states could enter into regulatory aggreements with carriers such 

as Consent Agreements.

It was suggested that testing facility personnel and the USCG meet in the near future to discuss 

BWTS approval processes. Dr. Everett (USCG) agreed that it was a good idea for people 

involved in testing to have a free and open discussion about what works and what doesn't, but 

said the USCG can't get involved in this discussion before the final ruling is put in place (but 

they can talk about testing procedures). Cangelosi said this discussion is happening on an 

international level and Dr. Drake reiterated that facilities in the U.S. are poised to test to IMO 

standards, not beyond.

With the cascade of new information, participants thought it was important to keep incorporating 

the new information into regulations, expectations, testing, installation, etc. The next step for the 

Collaborative was proposed: focus on the ideas put forward at this meeting to help provide 

regulatory stability and environmental protection while the USCG prepares the final ruling; and 

assist Great Lakes Carriers with their immediate efforts to better understand and mitigate specific 

AIS risk.
21

APPENDIX I

Ballast Water Collaborative Duluth Working Group Reports

APPENDIX II

Meeting Handouts
22
23

APPENDIX I

BALLAST WATER COLLABORATIVE DULUTH WORKING GROUP REPORTS

WORK GROUP 1

Identification of “Available” Ballast Water Treatment Systems “Rated” to Meet or Exceed 

100x IMO.

Work Group Chair: Susan Sylvester

Facilitator: Dr. Marvourneen Dolor

Note Taker: Amy Schmidt

Participants: Dr. Ryan Albert (U.S. Environmental Protection Agency)

Robert Dorn (Interlake Steamship)

Dr. Richard Everett (United States Coast Guard)

Capt. Ivan Lantz (Shipping Federation of Canada)

Alicia Lenis (Seaway Marine Transport)

Paul Reader (Transport Canada)

Jon Stewart (Maritime Advisor)

Scott Smith (U.S. Geological Survey)

Chris Wiley (Fisheries and Oceans Canada) (phone).

BACKGROUND:

Following the Ballast Water Collaborative meeting on May 18, 2010 in Montreal, WI 

DNR generated a table which combined information from nine sources, in an effort to identify 

potential available Ballast Water Treatment Systems. Nine systems have received Type 

Approval Certification based on the IMO standards: Alfa Laval Pure Ballast, GLO En Patrol, 

Hyde Guardian, NEI Treatment, NK-03 Blue Ballast, Ocean Saver, Opti Marine, SEDNA –

PeraClean, and Techcross. An additional 45 treatment systems are currently at in the process of 

being evaluated for Type Approval. 

Some systems have received Type Approval based on testing performed in brackish and 

salt water. This approval may not be valid when the vessel is operating in the Great Lakes if the 

treatment mechanism requires salt water or if the active substances do not degrade rapidly 

enough after discharge into the colder waters of the Great Lakes. The US Coast Guard is 

considering these scenarios and will address this issue when their final rule is published. 
24

There were two fundamental questions that the work group needed to answer:

1. What does commercially available mean?

A working definition of “Commercially Available” was offered which consisted of subdefinitions:

Regulatory Availability

• What regulatory regime is being considered? National Invasive Species Act (NISA) 

or the Clean Water Act (CWA)? 

• Does the system meet the specific regulatory requirements under the regime being 

considered?

• Under CWA: Does the discharge meet State discharge limits? Note that there is no 

requirement for Type Approval.

• Under NISA: Is it Type Approved for the conditions it will operate under (e.g. 

salinity and temperature characteristics?

• Does the system meet class society requirements? This may overlap with regulatory 

requirements but may exceed them as well. Class requirements involve insurability.

Commercial Availability

• Is there a company that produces the system and is able to deliver and install it?

• Is there more than one vendor to purchase systems from (i.e is there enough 

competition to make it a viable market-place?)

• Are enough units manufactured per year sufficient to meet the demand?

• Is the cost of the system and/or operation and maintenance a factor?

• Does the system need to be available at more than one location world-wide?

Operational Availability

• It is appropriate for the specific vessel and its trade routes?

• Is there land-side technical support for maintenance and/or repair?
25

2. Do these treatment systems achieve the Wisconsin Standards?

• What are the appropriate criteria for determining whether a system can achieve 

compliance with the WI discharge standard?

o Criteria

o Thresholds

There are no testing protocols for evaluating whether or not a system can achieve 

Wisconsin’s discharge standard (i.e. 100x IMO). This means that although treatment 

manufacturers are claiming that their systems are capable of achieving WI discharge standards 

there is high degree of uncertainty regarding these claims. Note that Wisconsin has a discharge 

standard and does not require that a system must be installed on a vessel. This led Scott Smith of 

USGS to propose another approach: Best Available Technology. Scott explained that this 

approach would provide a little more “wiggle room” for a given treatment to achieve the 

discharge standard. A technical standard as well, would supply a dose of chemical to kill all 

organisms.

• Since USCG protocol for approval has not been adopted, and may not be 

available for years, what else can be used? What other approval is acceptable?

There are no Flag administrations providing type Approvals for standards stricter than 

those outlined in the IMO convention. For Wisconsin’s permit, if the 100x IMO discharge 

standard cannot be met, the permit defaults to the IMO standard or the 100x IMO date is 

extended. 

As mentioned above, States cannot require a treatment system be installed; they can only 

regulate what is discharged from a vessel. Another point reiterated throughout the discussion 

was the fact that only the US. Coast Guard can provide Type Approvals for systems installed on 

U.S. flagged vessels. 
26
27

WORK GROUP 2

Evaluating Factors Affecting the Installation of Specific Ballast Water Treatment Systems 

on the Applicable Fleets and Vessels within the Designated Timeframes.

Work Group Chair: Jeff Stollenwerk

Facilitator: Dale Bergeron

Note Taker: Sharon Moen

Participants: Noel Bassett (American Steamship Co.)

Bruce Bowie (Canadian Shipowners Association)

Cmdr. Gary Croot (United States Coast Guard)

Steve Fisher (Great Lakes Ports Association)

Phyllis Green (NPS - Isle Royale Nat. Park)

Dr. Carolyn Junemann (U.S. Maritime Administration)

Eric McKenzie (Seaway Marine Transport)

Bill Lind (American Bureau of Shipping)

Jen Nalbone (Great Lakes United)

Eric Nygaard (Ohio Environmental Protection Agency)

Julie O’Leary (Minnesota Environmental Partnership)

Georges Robichon (FedNav, Ltd.)

Mark Rohn (Grand River Navigation)

Gregg Ruhl (Great Lakes Fleet)

Jim Sharrow (Port of Duluth)

Goal: Working from a vessel-owner’s perspective, identify and evaluate factors affecting 

the installation of specific ballast water treatment systems on the applicable fleets and 

vessels within the designated timeframes.

[The group understood this was a hypothetical exercise only. For this “case study,” the group 

operated under the premise that ballast water treatment systems meeting a discharge standard 

100 times more stringent than IMO were commercially available.]

Key Components of the Installation Process (the Ship Owner perspective)

1) When can/will a Ship Owner install a BWTS. There must be sufficient certainty of the 

regulatory environment at both state and federal levels. No Ship Owner would consider 

installing a system on a vessel that has not received approval from USCG for use in U.S. 

waters, as well as being evaluated for crew and vessel safety by the appropriate 

Classification Society (necessity for insurance).

2) Vessel Specific Evaluations.

a. The engineering and mechanical requirements to install BWTS during new 

construction is likely to be less complex than the retrofit of existing vessels 

(because the new-build vessel is being designed to accept a specific BWTS).
28

b. A “Life Cycle Analysis” and “Business Case” is required to determine the 

viability of each vessel in relationship to the cost of BWTS installation, whether 

new-build or retrofit (the “Business Case” for a new-build BWTS installation will 

be less complex than understanding the potential continued viability issues of 

vessels undergoing retrofit for BWTS).

3) Requirements for selection of BWTS. In addition to the certification requirements 

noted above, any system must have “PROVEN” ability to meet or exceed, mandated 

treatment standards for the specific vessel and route on which it is to be used. 

a. The system must meet the specific physical and logistical constraints of each 

vessel. In addition, ballasting flexibility must be assured, and the requirements for 

pump rate and volumes for each vessel must be considered (see pgs 29-33 of 

Ballast Water Treatment Advisory; ABS).

b. The system must be readily commercially available.

c. The Vendor must understand the marine environment and be a trusted supplier 

with the capacity to deliver and support BWTS in a timely fashion.

d. The “Life Cycle” of the BWTS must be taken into account, as well as operating 

costs and crew training. Ideally, systems will be simple to install, operate, and 

maintain.

e. The “technology choice” must be compatible with vessel footprint, physical 

structure, cargo compatibility, hazardous space requirements and electrical system 

demands.

f. Onboard compliance monitoring for the system must be simple and effective to 

meet regulatory requirements.

g. The system must be safe in terms of both vessel viability as well as potential crew 

exposures to hazardous chemicals, byproducts and/or operations.

4) Each vessel will require “Design & Installation Drawings.”

5) Each system purchase will need to receive internal capital expenditure approvals 

and will then need to be accepted for financing by a fiduciary agent or institution 

(Bank). 

6) Contractor selection for system installation will be required (if not part of a package 

provided by the system vendor).
29

7) Scheduling of actual system installation for each vessel.

a. Delivery availability (concentrated demand) – The largest BWTS manufacturers 

such as Alfa-Laval will be capable of producing approximately 500 systems per 

year. With only 7 BWTS which have been type approved world-wide, and a 

world-wide demand of well over 50,000 systems, it will take several years to 

satisfy the demand. BWTS manufacturers will not over-prepare for this demand, 

as it will be satisfied within a relatively short time (5 to 7 years, or so) after which 

the only demand will come from new vessel construction, which is a "trickle" in 

comparison.

b. Will “Dry-Docking” be required, and what is the current schedule? For BWTS 

which do not require drydocking for installation, shoreside engineering design 

and installation capability will also be required to meet the 50,000 unit demand.

NOTE: This is not an exhaustive list, only key elements or steps in the required process for 

BWTS selection and installation. Four handouts were used as reference material to drive 

discussion by the group, and are included as addendums to this report:

1) ABS: Ballast Water Treatment Advisory;

2) Shippers Perspective: Installing an Onboard Ballast Water Treatment System;

3) Categorizing Vessel Types and Uses for work on Critical Parameters; and

4) Factors Affecting the Timing or Feasibility of Installation of BWTS.

Estimated timeline for fleet-wide completion of ballast water treatment system (BWTS) 

installation (36 to 60 months or 3-5 years)

Regulatory 

certainty 

established; 

Technology 

available.

BEGIN

Vessel 

Specific 

Evaluations

3-6 months

BWTS 

Selection 

3-6 months

Design & 

Installation 

Drawings

12 months

System 

Purchase

3-6 months

Installation 

Contractor 

Selection

3-6 months

BWTS 

Delivery and 

Installation

12-24 months

Meeting Discussion Summary

Working Group Introduction

Jeff Stollenwerk (discussion leader) and Dale Bergeron (facilitator) opened the meeting. After 

introductions, Jeff Stollenwerk reiterated that the primary objective of the workgroup was to 

provide information for the State of Wisconsin on the specifics of vessel function and structure 

that might impact the timing of installation of ballast water treatment systems. The Wisconsin 

Department of Natural Resources is attempting to determine if there are commercially available 

Ballast Water Treatment Systems (BWTS) which are capable of meeting a standard 100 times 
30

more stringent than the International Maritime Organization (IMO) standard and if technology is 

available to verify compliance with the more stringent standard. New-built ships would be 

required to have BWTS by 2012. If the determination passes, Wisconsin would require older 

ships to retrofit BWTS onboard by 2014. At this time, Great Lakes-bound ships (Lakers) are not 

part of that determination. However, the State of New York is conducting a similar internal 

assessment regarding BWTS for ocean AND Great Lakes vessels. They have to make a similar 

determination with regard to extension requests addressing their Clean Water Act 401 

Certification requirements.

Three handouts (attached) were distributed to the group:

• Shippers Perspective: Installing an Onboard Ballast Water Treatment System

• Categorizing Vessel Types and Uses for work on Critical Parameters

• Factors affecting the timing or feasibility of installation

Jeff explained that the group would be developing two work products:

1. A high-level flow chart which addresses considerations and constraints for installation of 

a BWTS onboard a ship.

2. Specific factors that come into play affecting feasibility and installation, and timing.

The group understood that they were talking about installing something that doesn’t necessarily 

exist for treating freshwater in the Great Lakes. However, they gamely accepted the following 

underpinning, hypothetical assumptions, in the interest of the ensuing discussion. 

1. Commercially available technologies exist.

2. The U.S. Coast Guard has type-approved the BWTS.

3. The BWTS can fit on a ship.

4. A BWTS standard exists, whether it is IMO’s or some other standard.

The discussion opened with Eric McKenzie and Noel Bassett talking about their contributions to 

the “components of the flow chart” handout. 

The shippers said that their initial, typical, response to whether they could install a particular 

BWTS would be, “Well, what type of ship are you taking about?” They and the United States 

Coast Guard representative, Cmdr. Gary Croot, said vessel type is critical to what may or may 

not be installed. (See modified handout, Categorizing Vessel Types and Uses for work on 

Critical Parameters). The age of the vessel is also a consideration.

Carolyn Juneman asked, “At what point does the ship owner say, ‘It’s time?’” 

“We’re in the world of now,” answered Phyllis Green. “It’s now.”

FedNav evidently thinks the time is now, too; Georges Robichon said FedNav’s newest saltwater 

fleet is being built with room for BWTS. Noel Bassett said American Steamship Co. accepts the 

idea that there will be some form of BWT required in the near future. Gregg Ruhl commented 
31

with respect to the Great Lakes Fleet, “To be honest, we wouldn’t want to waste money and do 

more than is necessary until it is necessary.”

Eric McKenzie brought up a string of questions about specification requirements like: How big 

is the BWTS? What treatment method(s) does it use? When and where could it be installed? He 

said, “We tie up for 3 months in winter but where are the contractors to install it? We’re having 

problems just finding contractors to do our winter maintenance.” He suggested that maybe they 

could put half a system on at first so the companies can make sure it works. 

Jim Sharrow commented that it will be important when shopping for a BWTS to specify where 

the systems are being operated. What is the temperature range? What is the range of conditions? 

“If you’re shopping, you need to ask if this meets your needs,” he said. Ruhl expressed a hope 

that the Coast Guard and other regulators would type-approve the system(s) in advance for the 

operational conditions and the types of ships seen on the Great Lakes.

Ruhl’s comment prompted a conversation about the collision of two different regulatory 

approaches: EPA’s and the Coast Guard’s. The EPA (and states)don’t type-approve treatment 

systems but have achieved success in water pollution control by setting achievable standards and 

allowing industry to determine how best to make the control happen within their own unique 

situation. On the other hand, the Coast Guard conducts detailed analyses of treatment systems 

and if appropriate issues a type approval. This provides the industry an assurance regarding 

compliance if the system is operated properly. Stollenwerk said there were pros and cons for the 

EPA approach and for the USCG type-approval approach and suggested keeping the EPA model 

as an option.

The discussion touched on possibly building ballast-less ships or dockside ballast management 

systems. At this time, ballast-less ship technology isn’t perfected to a point where it is useful. 

An option for shore-based ballast treatment is being tested in Milwaukee but Robichon, for one, 

doesn’t think it will work. Sharrow said he stopped calculating how much a shoreline treatment 

system for the Duluth Superior Harbor would cost when he reached $1 billion. There is a 

shoreside ballast water treatment facility in Valdez, Alaska, however, it’s purpose was to accept 

ballast water from tankers which carry ballast water in their cargo tanks. The treatment facility 

is an oily water separator designed to remove oil from the ballast water. It is not designed to 

treat ballast water to remove organisms.

Steve Fisher asked if a vessel operator would be able to install a BWTS on a ship before the 

Coast Guard approved it. The answer seemed to be: they could, but it would be inadvisable 

(referenced red boxes on the Shippers Perspective handout). Under design drawings on the 

Shippers Perspective, a step “send to ABS and USCG” should be added.

The workgroup was asked to look at the ABS report (page 20), as a starting point for asking, 

“What’s different for the Great Lakes?” This fed into the discussion about the handout Factors 

affecting the timing or feasibility.
32

The group considered the biggest factor affecting installment to be Coast Guard type-approval. 

Shippers felt it would be financially foolish, and possibly a safety risk, for them to put a BWTS 

on a ship before the BWTS was type-approved by the Coast Guard. 

Jen Nalbone asked, “If a system were put on, could it be traded out?”

Robichon replied, “Not in a practical sense.” He went on to say that a 5-year grandfathering plan 

for retrofitted older vessels “is simply an insufficient amount of time” if the shippers were 

compelled to put unapproved system on ships. Given the current state of technology, Robichon 

felt that shippers on the Great Lakes would be unable to comply with state rulings.

Nalbone asked, “Should we look at modular/component systems?”

Cmdr. Croot explained that the Coast Guard will not type-approve to a standard other than a 

federal standard. For example, if Wisconsin wants a 100x IMO standard and that is not the 

federal standard, the Coast Guard will not be type approving to the 100x IMO standard. 

However, if vendors successfully put their BWTS through a rigorous testing procedure such as 

the ETV protocols promulgated by the EPA office of Research and Development, they might be 

able to legitimately claim “100x IMO standards”. However, no such protocols presently exist to 

test to the more stringent standard.

Cmdr. Croot could not release when either the Discharge Standard of the ETV Protocols will be 

finalized and released to the public. However, once the Final Rule is published, Independent 

Labs and Test Facilities will begin the process of becoming certified to conduct tests in 

accordance with the ETV protocols. This process will likely take up to one year for most of the 

IL’s and test facilities to complete, after which, they will be certified to begin the shoreside 

testing in accordance with the ETV protocols. 

The Coast Guard has not yet established an enforcement and compliance regime for the Ballast 

Water Discharge Standard. It will likely consist of a records check to ensure the vessel has 

submitted the required documentation to the National Ballast Information Clearinghouse 

(NBIC); an inspection to ensure the vessel crew operated the system in accordance with the 

manufacturer’s specifications; and an inspection of the equipment to ensure it is installed and 

being maintained adequately. Protocols for discharge sampling have not yet been finalized. 

In Oregon and possibly California, regulators do go onboard to examine discharge when they 

think it is necessary.

Fisher urged states to make enforceable rules, NOT ones that violate Coast Guard rulings. Gary 

Croot said again that the BWTS needs to be effective, safe, and that the effluent needs to be 

environmentally acceptable. Stollenwerk reiterated that the Collaborative understands that 

inconsistent state regulatory standards are a big issue and that ship owners can’t make decisions 

based on one state’s standards. He said reason needs to be self-imposed by states and that 

different state standards are almost impossible to address on an ocean-going vessel. Then he 

asked, “As a lake carrier, however, isn’t this more of a pain than an impossibility?”
33

Bassett replied, “No, a ship owner is going to design the vessel for the (most stringent) state 

requirement, which is New York at this moment.”

The group agreed that ABS Americas did a “stellar job” of laying out questions for vessel 

owners to evaluate feasibility of installation. Their scope includes new and retrofitted ships. Bill 

Lind, from ABS Americas, offered three points for installation that an insurer is interested in: 

• Can the BWTS physically be packed on the vessel? 

• How many do you need?

• Will it affect economics?

“How about the tank we use on the Ranger III?” asked Green. “Nobody type-approves a tank, 

but how about the chemicals?”

Trade laws were considered relevant to the overall issue but beyond the scope of Work

Group 2’s discussion.

The lack of convenient testing facilities was felt to add a degree of uncertainty as does the 

conundrum of what testing needs to be done.

The conversation got back on track when the group was asked to examine the “Factors affecting 

the timing or feasibility” handout. They were asked, “How long does it take to get from 

standards, to implementation strategies? Say what is possible. Say what is not.”

Review of Feasibility Sheet

A. Science and technology: shippers can provide a platform for testing on ships (participate in 

STEP); there are reliable guidelines for sampling ports (IMO protocol—G2).

B. Regulatory compliance: The Collaborative can encourage the Coast Guard to issue BWTS 

standards. The requirement for deep sea ballast exchange and the salt water flushing of NOBOB 

tanks to assure a minimum salinity level of 30 ppt is in force and effect and authoritatively 

verified for all ballast tanks in all salties seeking to enter the Great Lakes through the Seaway at 

Montreal. When Fednav and the Shipping Federation of Canada (representing salties trading in 

the Great Lakes) approached the USCG in the fall of 2007 requesting that it make mandatory its 

recommendation for the salt water flushing of NOBOB ballast tanks (to ensure consistency with 

Transport Canada's mandatory requirements) they came face to face with the prospect of a long 

federal regulatory process which, with the USCG's not objecting, was avoided through the 

willingness of the US and Canadian Seaway authorities to jointly enact and enforce enhanced 

ballast water rules/regulations for the start of the 2008 navigation season making the salt water 

flushing of all tanks in all NOBOBs mandatory. Therefore, since the start of the 2008 navigation 

season every ballast tank in every salty seeking to enter the Great Lakes, be it in ballast or not, 

has had its salinity level checked and if not authoritatively verified to be 30 ppt is either not 

permitted to enter the Seaway or its offending tank is sealed.
34

Green suggested that using a technology standard rather than biological standard for ballast 

management might expedite the Coast Guard’s ruling.

(Julie O’Leary commented that working through this list will just yield another list of why 

nothing can be done. She was hoping for a more positive discussion. Stollenwerk replied that, 

while a positive perspective was appreciated, the point was to address Wisconsin’s Yes-or-No 

question. If the answer is “No, BWTS technology cannot be installed on vessels in the Great 

Lakes at this time,” there better be a good explanation and justification of why not.)

C. Vendor information: Vendors should be able to offer the information listed except maybe 

details about life-cycle costs (the technology is too new and untried). Mark Burrows suggested 

including a tonnage and stability check. “You have space requirements but nothing about weight 

and stability,” he said.

Pumping volumes within the system’s capacity are an issue related to space; keep this in mind. 

Even if it is a linear progression, as the numbers of BWTS add up, they might end up creating a 

giant footprint.

Nalbone asked if there is a quality assurance output device indicating that a system is operating 

in compliance. Answer: It is possible to tell if the system is running as it is designed but NOT if 

it is meeting a particular standard. However, for some systems, there may be secondary 

indicators which could indicate if the system is effective in killing organisms. The situation was 

likened to meeting sewage treatment standards where a simple test for residual chlorine was 

developed, a process control mechanism. (Mark Burrows remembered that there was a time 

when ships were putting port-a-potties onboard vessels.)

Lind suggested that the group write in Joe Fisher under “C” for engineering support.

Sharrow spoke of crew safety concerns; “crew support will be necessary, mistakes will be 

made.” Before installation, crews need training manuals, vendors will need to be vetted. 

The installation will require some flexibility since some systems are on a skid and others are 

modular. If a system breaks, there will need to be a backup plan. Cmdr. Croot explained, 

“Unlike any other Convention, the Ballast Water Convention makes no allowance for break 

downs. Maybe this is where shore side treatment becomes an option.” NOTE: “Emergency 

Dosing Strategies” may be an option to address BWTS failure, as noted earlier in the day’s 

discussions but that is not presently permitted by the Convention. Reliability and redundancy 

need to be considered as does the possibility that if ballast tanks need to be coated to minimize 

corrosion due to chemical use, the process would add more time and expense to dry-docking and 

BWTS installation. 

D. Physical characteristics of vessels: Vessel type and capacity are a big deal, especially when 

the issue becomes Lakers. It is not clear when and where the BWTS installation can happen; 

where is the shipyard space and BWTS installation expertise? Salties usually go to dry-dock in 

China. It was suggested that a retrofit BWTS installation might be doable while the vessel was 

afloat (however Robichon advised that as concerns the OceanSaver BWT system, of which he 

was quite familiar, each system sold to date was to be installed in new-builds undergoing 
35

construction in a shipyard and for retro-fits that system would require installation during drydocking) but Cmdr. Croot said he would be surprised if this was the case for any Lakers due to 

size differences and complexity of pumping systems. However, due to the significant 

differences between the Laker fleet and ocean-going fleet in terms of ballast water capacities, 

pumping volumes and ballast system arrangements, thought many Lakers would require 

drydocking for installation of BWTS.

There was interest in the CSA/LCA route data and characteristics presented the day before to the 

entire group (see meeting notes) and what it might mean for the spread of organisms and ballast 

water treatment.

E. Time and method for installation: Some systems are installed by the vendor, other systems 

are installed by an agent (typically the shipyard). For example, the OceanSaver system is 

installed by the yard, not the vendor.

F. Business considerations: For FedNav, a ship’s life is 20 years (consider amortization). 

BWTS are not resalable, mainly because they would be very costly to remove. However, a 

vendor should be able to estimate a life-cycle cost and offer a warranty. Vessel owners should 

expect the system to last the life of the vessel.

G. Classification society requirements/ impacts: & H. Liability considerations:

Lind said that ABS has drafted Class Society Requirements for installing BWTS that is coming 

out in a month. “We want to look at drawings of how systems are going to be installed,” he said. 

Wisconsin has the drafted ABS list, which is written from a classification standpoint. Usually it 

takes about a month from submitting a drawing to approval; but this is a new component and 

ABS isn’t sure how long engineering approval will take. Shippers stand to lose their insurance if 

operating without compliance to regulations. In order to expedite the insurance process, e-mail 

these three people at ABS with BWTS installment designs: Bill Lind, Charlie Dorchak, Yoshi 

Osaki.

After a short break, the workgroup reconvened to compile the report-out. They responded to the 

question, “When it’s time to put treatment systems on vessels, what are the key issues, and how 

do they affect the timeline? Can it be done by 2014?” 

Regulatory Uncertainty is the Largest Handicap.

The current regulatory environment is having an adverse affect on progress toward BWTS 

installation. A complex regulatory framework has been created through federal and state 

permits, legislation, and rulemaking. The Canadian government has ratified the IMO D-2 

standards. Several US states have adopted ballast water discharge standards ranging from IMO 

D-2 to 1000 times more stringent than the IMO standard with implementation dates ranging from 

2012 to 2016. The final requirements under the federal regulations issued by the US Coast 

Guard or the permit requirements issued by the US Environmental Protection Agency remain 

uncertain. The USCG is developing responses to the 3000+ comments received during the 

NPRM public comment period, and the USEPA is reviewing its technology-based effluent limit 
36

and water quality-based effluent limit determinations under its Vessel General Permit. This 

regulatory uncertainty is a major obstacle to achieving compliance with numeric ballast water 

discharge standards. 

The group identified a number of promising opportunities that could provide incremental risk 

reduction without requiring significant capitol or operating expenses. However, until regulatory 

quiescence is achieved, it is unreasonable to expect ship owners to begin work to achieve a 

particular discharge standard that requires significant investment. Ship owners are unable to 

obtain financing and make capital expenditures without reasonable assurance that regulatory 

compliance will be achieved in all waters that they transit.

Two important steps in achieving regulatory certainty are:

1) The US Coast Guard should finalize at least Phase 1 of its proposed regulation. This will get 

us moving toward the IMO D-2 standard which represents substantial improvement over current 

conditions; and

2) The US EPA should complete its technology-based determination and water quality-based 

procedure analysis to establish numeric discharge standards in the Vessel General Permit.

Maybe the Collaborative could encourage Wisconsin to pursue agreements for high-risk 

situations, rather than regulate ballast at this time. Maybe they could recommend an interim 

technology standard or shoreline implementation while working on biological standard 

verification. Although there are biocide concerns, some standard of success needs to be viewed 

as acceptable. What standard and model is appropriate? It comes down to risk. What risk are 

you willing to live with?

Stollenwerk said that the EPA is very interested in having states normalize their discharge 

standards. National Academies of Science (NAS) and advisory group will likely have their 

recommendations on the method for calculating numeric water quality discharge standards 

prepared by June 2011.

The group calculated that from the time of a National standard and certified/approved 

technology being deemed available, the timeline for the installation of BWTS will still 

be 3 to 5 years. The exact timeline is hard to define since the regulatory and interim solution 

plans are nebulous. Green offered to put together a timeline for this component based on the 

Ranger 3’s experimental system permit experience. Roughly, this included 6 months to review 

treatment options and scoping (pick one and send out for peer review); 6-12 months for 

contracting; and 18-24 months until installation (if the system required dry-docking, installation 

could have taken 7 years). Green said, “We’re treating now because we’re not using a shipinstalled treatment.” See attached report “Bridging ballast water treatment technology gaps: 

Moving from proof of concept to full implementation of Great Lakes Ballast Water treatment 

within 24 to 36 months.”

Ruhl estimates that for the Great Lakes Fleet, it could take 18-24 months to select system(s) for a 

variety of vessels; 6-12 months to raise the capital necessary to install and operate the systems; 
37

12 months to design the system’s installation; 3-6 months for review (depending on application 

numbers) by ABS, the Coast Guard, and everybody else who needs to review it (some of the 

states might want to review compliance/certification). He said, “We use about two or three 

engineering firms in the Great Lakes. There are not a lot of them and only one dry-dock that is 

available to us, and only two that are physically possible for our ships. Oh yeah, and only one 

person in the Coast Guard has the authority to review BWTS at this time.”

For ocean going ships, regular dry-dockings happen in China, by appointment, about every 2 1⁄2 

years.

Components/Systems Selection is a step, not necessarily one that lengthens the process. 

However, depending on what is selected, a ship owner may need to install a second sea chest to 

accommodate back flushing.

Construction and installation time could be a sticking point. A participant said, “It’s not like you 

can go to Wal-Mart and pick one off the shelf. They are custom made. Where are all the 

systems going to come from?” This led to a discussion about the lead-time needed to book 

installation crews and for the orders to be filled. For example, an engine from a catalog took a 

shipper two years to get. It took another shipper 18 months to get a single bearing. These were 

catalog items, not custom-made BWTS.

The group estimated that it could take 1-2 years of lead-time for fabrication, delivery and 

installation for ONE system. Then, should more than one system be needed, the other systems 

will likely follow in another few months. It was said that most vendors are still in research and 

development; even those that are IMO certified, can only produce 2 or 3 a year, save for maybe 

AlphaLaval, the most successful vendor that has sold 100 systems operating on saltwater vessels. 

This brought up an interesting point. Cmdr. Croot suggested that from a vendor’s perspective, 

“If I can produce BWTS for the worldwide market (40,000-50,000) or the narrower standard and 

fewer ships (i.e. 250 Great Lakes ships), would I even build a BWTS for use in freshwater?

Probably not.”

The group wondered how long it took to install other ancillary vessel components such as the 

sewage treatment systems and the self-unloaders? Evidently it takes a minimum of 6 months to 

physically get an AlphaLaval BWTS on a ship. Also, trade routes and ship types have huge 

impact on timing.

The group thought that incentives to speed up the installation process could include:

• Find technology to bypass dry-docking.

• Find simpler processes.

• Uniform and achievable standards.

• Develop interim measures.

• Create appropriate subsidies 
38

Attachments –

Meeting Handouts

• Shippers Perspective: Installing an Onboard Ballast Water Treatment System

• Categorizing Vessel Types and Uses for work on Critical Parameters

• Factors affecting the timing or feasibility of installation 
39

• Shippers Perspective: Installing an Onboard Ballast Water Treatment System

(McKenzie and Bassett table) 

List 1 List 2

 Determine final regulatory 

requirements

 Physical Space: determine if/how 

can the BWTS fit on the ship

 Create specification requirements 

o Capacity needs  Electrical Power: determine how 

to power the BWTS based on 

ship’s capacity

o Footprint limitations

o Treatment method 

 Identification of systems that meet 

requirements

 Piping: determine what 

infrastructure will be required to 

operate the BWTS and if the ship 

can accommodate the new 

infrastructure

 BWTS review 

o Type

o Required approvals

o Cap ex  Evaluate how the BWTS could 

o Op ex impact cargo and discharge rates

 Business case analysis

 Selection of system or systems to 

shipboard test

 Evaluate use and risks associated 

with active ingredients with 

respect to crew, ship, USCG, and 

ABS.

 Develop test protocols

 Develop design and installation 

drawings for shipboard test

 RFQ – installation (shipboard test)  Are unit components USCG/ABS 

 Schedule installation (shipboard test) “type-approved?”

 Install test system or systems

 Monitor and test system  Can the BWTS be efficiently and 

accurately monitored?

 Develop specification requirements 

for each individual class of vessel

 Installation Timing: Lead time? 

Where? How long does installation 

take? New underwater hull 

penetrations require drydocking.

 Receive Capital approvals

 Complete design and installation 

drawings for each class of vessels

 Regulatory approvals for installation 

and drawings

 Is the BWTS simple to operate? 

Will crew need special training?

 Procure BWTS systems  Can the BWTS be produced fast 

 Develop installation schedule for fleet enough to meet the demand? 

 Evaluate life expectancy of vessels  What are the service needs of the 

components of the BWTS? Costs? 

Can vessel personnel perform 

them?

 Installation of BWTS system

 Develop testing protocol

 Demudding of vessels

Special thanks to Eric McKenzie and Noel Bassett.
40

Categorizing Vessel Types and Uses for Work on Critical Parameters

There are a number of different categories that must be considered in determining the suitability 

of a ballast treatment system for a given vessel on the Great Lakes, including:

Ballast system arrangement and specifications: Ballast pumping rates and volumes vary greatly 

among different types of ships. It is useful to categorize vessels into certain groups:

• Foreign salt water ships

• Great Lakes wide beam ships with centralized ballast pumping and distribution systems-

(typically 1000-footers)

• Great Lakes mid to handy size ships with centralized ballast pumping and distribution 

systems

• Any ship with a decentralized ballast pumping and distribution system

• Other- includes work boats, barges, research vessels, etc.

The particular trade route of the ship may affect the need to perform ballast water treatment. 

Ballast water retention time associated with the trade routes of the ship will directly affect the 

suitability of certain treatments for a particular ship.

Trade route specific ships:

At what point during the ship’s life cycle is the investment to be made? Can the marketplace 

afford the ballast water treatment?, or will the ship be laid up and scrapped?

Ship’s life cycle and economic considerations:

Special thanks to Jim Sharrow.
41

Factors affecting the Timing or Feasibility of Installation 

The following areas and issues of concern are proposed to jumpstart the discussion:

A) Science & Technology

a. Testing/Sampling Equipment and Access

B) Regulatory Compliance

a. Sampling set-up for new builds

b. Time and Local for System Installation

c. Other physical parameters...

C) Vendor Information

a. Treatment Methodology/ Applicability

b. System Capacity

c. Impact on “Normal Operation”

d. Space Requirements

e. Equipment Durability/Limitations

f. Power Requirements

g. Corrosion Impacts

h. Handling & Operations (control & monitoring)

i. Certification/Indemnification

j. Ability to Deliver and Support Products

k. Maintenance and Life Cycle Costs

D) Physical Characteristics of Vessels

a. Vessel Type and Capacity

b. BWMPs

c. Ballasting Characteristics

d. Vessel Service/Route Characteristics

e. Ballast System Design (configuration/space and tank/piping characteristics) 

E) Time and Method for Installation

a. In-service VS at Dry Dock

b. Plug-in VS Redesign/Rebuild

c. Vendor or Agent Install

d. Electrical and Mechanical Issues

e. Controls & Monitoring

F) Business Considerations

a. Access to Capital

b. Impacts on O&M

c. Ability to Amortize 

d. Life Cycle of Vessel and Long-Term Strategic Plan

e. Degree of Liability (vendor indemnification/port state certification)

G) Classification Society Requirements/Impacts

a. Maintaining “Insurability”

b. Impact of “ignoring” regulatory mandates

H) Liability Considerations (opportunity for mitigation through HACCP: Hazard Analysis and 

Critical Control Points)

a. Who will design, train, and monitor?
42
43

WORK GROUP 3

Review and Assess Current Verification Capability for Treatment Systems to Comply with 

a Discharge Standard of 100x IMO.

Work Group Chair: Dave Adams

Facilitator: Dr. David F. Reid

Note Taker: Paul Luebke

Participants: Dr. Sarah Bailey (Fisheries and Oceans Canada)

Barry Burns (Michigan Department of Natural Resources)

Allegra Cangelosi (Great Ships Initiative)

Nicole Dobroski (California Lands Commission) (phone)

Dr. Lisa Drake (U.S. Naval Research Laboratory)

Marney Hoefer (Wisconsin Department of Natural Resources)

Joel Mandelman (Nutech)

Craig Middlebrook (U.S. Saint Lawrence Seaway Development Corporation)

Charlie Miller (EcoChlor®)

Azin Moadhassel (Canadian Shipowners Association)

Capt. William Peterson (Great Lakes Fleet/Key Lakes)

Dr. Mario Tamburri (Maritime Environmental Resource Center) (phone)

Goal: Review and Assess Current Verification Capability for Treatment Systems to 

Comply with a Discharge Standard of 100x IMO.

As part of the July 2010 Great Lakes Ballast Water Collaborative meeting, staff from the three 

U.S. land-based ballast water testing facilities, representatives from the states of WI, NY, CA, 

and MI, two treatment developers, several shipping interests, and interested stakeholders met in 

an effort to gather documentation and present and discuss professional opinions relevant to the 

goals and objects noted herein. 

Objectives:

1. Assess current testing protocols and facilities considered necessary to type test

to 100x IMO.

Meeting Discussion Summary: Type approval testing of ballast water treatment systems is 

critical to showing that a system can meet an established discharge standard. At this time, the 

most current protocols available for land-based and shipboard verification are the IMO 

documents commonly known as guidelines G2, G8, and G9, which provide guidance for landbased and shipboard testing of ballast water treatment systems and for compliance monitoring. 

However, these (IMO) guidelines were developed to verify system performance only to the level 

of the IMO D-2 discharge standard, and the methods and procedures to test to the D-2 standard 

are still being refined at the U.S. facilities. These methods and procedures may be relevant for 

testing ballast water treatment systems capable of meeting a discharge standard of up to one 

order of magnitude different from the IMO D-2 standard, if sampling approaches and volumes 
44

are adjusted to provide acceptable statistical confidence. Efforts are underway to harmonize 

methodologies for test facilities globally. The U.S. Environmental Technology Verification 

protocol is being finalized for verification of ballast water treatment systems' performance at 

land-based test facilities in conjunction with U.S. regulatory agencies. The ETV protocol is 

much more detailed than the IMO G2, G8, and G9 guidelines, but it is currently confined to landbased testing. There are currently no established protocols for verification of ballast water 

treatment systems performance to the more stringent Wisconsin discharge standards (100x more 

stringent than the IMO D-2 discharge standard), and ballast water treatment systems performing 

to the 100x IMO standard have not yet been conclusively demonstrated. Shipboard type 

approval testing poses a separate set of challenges, and the feasibility of designing type approval 

tests on ships to detect treatment performance to higher treatment standards with acceptable 

statistical certainty has yet to be determined. Thus, there are significant issues that will need to 

be resolved if testing or compliance monitoring to the more stringent Wisconsin Standard (100x 

more stringent than the IMO D-2 discharge standard) is to become possible and practical. 

Conclusion(s): While progress has been made in the development of detailed testing 

protocols and harmonization among test facilities globally, there are currently no 

established protocols for, nor facilities capable of verifying ballast water treatment systems 

performance to the more stringent Wisconsin (100x IMO) discharge standard. 

2. Identify approaches to meeting intensified verification needs associated with 100x IMO.

Meeting Discussion Summary: Existing land-based facilities have been designed to test the 

ability of ballast water management systems to achieve the IMO D-2 discharge standard using

the guidelines of the IMO G8, G9, and ETV documents. It has been postulated that use of larger 

sample volumes and additional replicate trials will make it possible for facilities to test systems 

to more stringent standards, such as the Wisconsin 100x IMO discharge standard; however, these 

approaches are still being studied and have not been statistically verified, and their practicability, 

feasibility, and associated costs have not been evaluated. Test facility experts in Working Group 

3 were unanimous in stating there are no accepted testing protocols presently available to deliver 

acceptable statistical confidence at the level of a 100x IMO standard. In addition, the test facility 

experts stated that because accumulated testing errors would be larger, resolving the problem 

through sampling and analyzing larger volumes of water may not prove to be a valid approach to 

achieve the necessary statistical confidence. For example, representativeness will decline due to 

increased organism mortality as time to conduct the biological analyses increases, resulting in 

greater uncertainty and less statistical confidence. The scientific experts stated that testing to a 

more stringent standard would be very difficult and is not presently possible, as no appropriate 

and experimentally verified protocols for this presently exist. One technology developer 

presented multiple test results for their treatment system (tested using IMO D-2 guidelines) and 

stated their opinion that these results are indicative of meeting 100x IMO Standards. However, 

the scientific experts expressed their opinion that no ballast water management systems have 

been verified to meet a discharge standard 100x more stringent than the IMO D2 standard with 

the necessary level of statistical confidence, by either land-based or shipboard testing.
45

Conclusion(s): Approaches to meet WI 100x IMO verification and compliance monitoring 

are theoretically possible, but not presently practicable, nor verified, due to existing facility 

and analytical limitations and incomplete R&D on this issue.

3. Assess current compliance monitoring protocols and facilities considered necessary to 

spot check to 100x IMO.

Meeting Discussion Summary: The group agreed that compliance monitoring under a 100x IMO 

discharge standard might be accomplished using indicative metrics to identify gross failures of a 

ballast water treatment system, but only in very rare instances would it be possible to 

conclusively determine via compliance monitoring if a vessel met a 100x IMO standard. The 

scientific experts noted that no formal protocols are currently in place for compliance monitoring 

of ballast water treatment systems to any standard, including the IMO D-2 standard. Several 

concepts have been proposed by regulatory agencies as a result of ongoing monitoring projects, 

and efforts are underway to develop detailed guidelines for establishing formal compliance 

monitoring programs relevant to IMO D-2 standards. Thus, while no protocols are currently in 

place for compliance monitoring of ballast water treatment systems, monitoring for gross failure 

against Wisconsin’s discharge standard could be possible. Development of ship discharge 

sampling apparatuses and sample port design required for compliance monitoring are underway 

at various test facilities, but have not been completed. Sample port design and testing

specifically for Great Lakes ships is being conducted at GSI and will be trialed next year on 12 

vessels. Mobile laboratories have been proposed as a means of standardizing and stabilizing 

implementation of analytical methods once regulatory agencies establish compliance programs.

Conclusion(s): Equipment, sampling, and analyses required for compliance testing to the 

D-2 standard are under development. There are no existing protocols for compliance 

monitoring against the WI 100x IMO discharge standard. Once appropriate protocols and 

facilities are developed, it is possible that compliance monitoring will be able to detect gross 

violations of the WI standard with acceptable statistical certainty.

4. Identify approaches to meeting compliance monitoring needs.

Meeting Discussion Summary: Shipboard verification testing of a ballast water treatment system 

is different from shipboard compliance testing. Compliance testing is likely to be indicative, but 

not conclusive, of compliance to a standard, although it could be conclusive in cases of noncompliance. Verification testing needs to be conclusive of compliance to the standard. The 

greatest limitations to compliance monitoring, with acceptable precision and statistical certainty, 

are the logistical challenges associated with handling very large-volume or extremely large 

numbers of small- volume water samples, and separating line contamination from procedural or 

analytical error at extremely low organism densities. Therefore, the ideal indicative compliance 

monitoring regime may be a combination of 1) administrative review, 2) continuous monitoring 

and data logging of appropriate treatment system indicators during system operation, and 

3) targeted biological sampling to detect gross system failures.
46

Conclusions: Compliance monitoring should be viewed as a tool to detect gross failure. 

Compliance monitoring to determine conclusively if ballast water meets a discharge 

standard 100x more stringent than IMO is not currently practicable. The recommended 

approach is to combine administrative review, application of sensor technology to verify 

system functionality to specifications, and targeted biological sampling to detect gross 

system failure. The details of such an approach are yet to be developed.

References & Supporting Information:

Many of the documents listed in the References section at the end of this report were briefly 

described by the various group members familiar with them. Each member volunteered his or her 

interpretations of the basic concepts contained within each document. 

Albert et al (2010), California State Land Commission (2010), and Dobroski et al. (2008) each 

provided reviews and/or assessments of the availability of ballast water treatment technologies. 

Gollasch (2010) provided a summary of the results of an expert workshop on harmonization of 

methodologies for ballast water test facilities. 

IMO MEPC G2 "Guidelines for Ballast Water Sampling", G8 "Guidelines for Approval of 

Ballast Water Management Systems", and G9 "Procedure For Approval of Ballast Water 

Management Systems That Make Use Of Active Substances", along with the draft "US EPA 

ETV Program Generic Protocol for the Verification of Ballast Water Treatment Technologies", 

are currently the most relevant protocols available for land-based and shipboard verification of 

Ballast Water Treatment Systems (BWTS). Additional guidelines are provided via the IMO 

"Guidance for Administrations on the Type Approval Process for Ballast Water Management 

Systems in Accordance with Guidelines (G8)". 

Lee et al. (2010) assessed the strengths and weaknesses of six existing and one new (proposed) 

approach to generating national organism-based discharge standards and applied a Poisson 

probability distribution model to sampling issues, especially volume requirements. 

While not directly pertinent to the verification issue, two recent industry reviews of the status of 

BWTS were made available for review, ABS (2010) and Lloyd's Register (2010).

Lastly, it was mentioned that New York staff are preparing a paper for possible publication, 

which builds upon the concepts in Lee et al. (2010) to provide a basis for establishment of more 

formal guidelines for testing ballast water treatment systems to the Wisconsin discharge standard 

(100x IMO).

Goal Discussions & Supporting Information: 

Review and Assess Current Verification Capability for Treatment Systems to Comply with 

a Discharge Standard of 100x IMO. 

While the WI and NY regulatory programs do not plan to approve individual systems, neither are 

they dependant on the existence of a federal BWTS approval program. Individual states have the 

ability, through state legislation and regulation, or by the use of conditions within letters of 
47

certification to the EPA VGP under the Clean Water Act, to require the installation of 

appropriate technology to meet specific ballast water discharge standards, with verification being 

a separate issue. (Dave Adams)

Third party certification, such as from the American Bureau of Shipping (ABS) and Lloyd's 

Register of London (Lloyd's), have the role of assisting ships owners to insure that installed 

technologies are built and/ or installed according to specifications. These certifications may be 

completed prior to approval by the US Coast Guard. ABS and Lloyd's approve how something is 

installed, the US Coast Guard approves for safety. A ballast water treatment system could 

possibly be installed without US Coast Guard type approval, but with third party certification. 

(Bill Lind & William Peterson)

There is precedence for imposing standards beyond the capability of current monitoring 

methods. The limits for mercury discharges 10 years ago were below the analytical test methods 

level of detection and actual compliance couldn’t be confirmed. Today, now the test methods 

are available to quantify mercury below water quality standards so that true compliance can be 

verified. (Barry Burns)

Higher treatment standards have influenced technology development, now they may help in 

driving the test methods to verify treatment performance. (Allegra Cangelosi)

All treatment system vendors aim to kill everything, not just meet the IMO standard. They’re 

striving to achieve the "zero discharge" standard. (Mario Tamburri) 

Ecochlor does not want to simply meet IMO standards of "10 organisms per cubic meter"; we 

want "zero viable organisms". (Charlie Miller)

Objectives Discussion & Supporting Information:

1. Assess current testing protocols and facilities considered necessary to type test to 100x 

IMO.

Type approval testing of ballast water treatment systems is critical to showing that a system can 

meet an established standard. Verification testing for the IMO D-2 biological performance 

standard is difficult. There are significant issues for testing to the more stringent Wisconsin 

Standard of 100x IMO. Non-detection of live organisms across the board would be a first 

indicator of possible performance beyond the IMO standard, but this outcome has not yet been 

demonstrated or achieved. That is, no ballast water treatment system for which type testing data 

are available has performed so well as to indicate possible compliance with the 100x IMO 

standard. (Allegra Cangelosi)

National land-based BWTS testing facilities include the Great Ship Initiative (GSI), the Maritime 

Environmental Resource Center (MERC), and the Golden Bear. The Navy Research Lab (NRL) 

facility in Key West currently focuses on protocol development; no routine testing of BWTS is 

currently conducted. Other international facilities include the Norwegian Institute for Water 

Research (NIVA), the Royal Netherlands Institute for Sea Research (NIOZ), and facilities in 

Japan and Korea, although they are all not necessarily independent like the US domestic 

facilities strive to be. More ballast water test facilities may come into being in the future, 

including third-party units. The need for additional test facilities is questionable, but will be 

market (profit) driven by vendors. (Lisa Drake & Allegra Cangelosi)
48

All facilities are currently testing to the IMO discharge standards only. Current testing protocols 

can identify gross failures, but can't verify compliance to 100x IMO discharge standards.

Changes to protocols, such as many more replicates or use of alternative indicators, and facility 

infrastructure, or both, could allow facilities to accommodate that objective. The questions are,

at what cost, to what level of precision, and is it worth it? (Allegra Cangelosi)

The IMO G2, G8, and G9 guidelines, along with the draft ETV Protocol, are the most current 

protocols available for land-based and shipboard verification of BWTS. IMO guidelines are 

interpreted by Administrations; they are guidelines, not regulations. (Mario Tamburri)

The current IMO guidelines recommend 3 consecutive successful shipboard tests, over at least a 

six-month period, with replicate 1 m3 samples collected and entirely analyzed. The knowledge 

gained from land based testing can be applied to shipboard testing, i.e. sample port design. 

(Mario Tamburri)

The State of California (Dobroski et al., 2008; CA State Lands Commission, 2010) has 

interpreted existing land-based and shipboard treatment system test data to suggest that some 

presently available ballast water treatment systems have the potential to meet the CA discharge 

standard of "zero detectable organisms". (Nicole Dobrowski).

The World Shipping Council conducted a survey and concluded that no ballast water treatment 

systems have demonstrated the ability to meet discharge standards of 100x IMO or 1000x IMO. 

(Joel Mandelman)

There are no statistically significant data showing that any ballast water treatment system by 

itself can exceed the IMO performance standard. (Mario Tamburri)

Land-based tests of the Ecochlor System found zero living organisms in 28 of 30 post-treatment 

test samples, with two additional tests having only 1 organism each. That is an average of 0.07 

organisms/m3. Ecochlor considers these results to be significant and to be indicative of meeting 

100x IMO Standards. Our first shipboard test in July on the Moku Pahu in California, conducted 

under IMO protocols, showed that there were zero organisms at discharge after 24 hours. 

(Charlie Miller)

Ballast water treatment systems may be able to exceed protectiveness of IMO standards if the 

treatment system is used in combination with existing ballast water exchange practices. (Allegra 

Cangelosi) 

This is a hypothesis that Canada plans to test with shipboard trials. It must be clarified that BWE 

+ treatment will not result in a lower number of organisms discharged, rather, it is expected that 

invasion risk will be lower. Discharge standards reduce invasion risk by lowering propagule 

pressure. Other means to reduce invasion risk include altering the physio-chemical conditions of 

the environment to reduce survival. BWE + treatment is not expected to reduce the number of 

organisms surviving any treatment system, but may reduce the number of individuals expected to 

survive freshwater conditions in Great Lakes’ ports after discharge. (Sarah Bailey)

2. Identify approaches to meeting intensified verification needs associated with 100x IMO.

Verification monitoring needs to be more comprehensive, with continuous sampling, as opposed 

to "grab" samples (discrete sub-samples) which may be used in compliance monitoring. (Sarah 

Bailey)
49

To test that ballast water management systems meet the IMO D-2 discharge standard at MERC 

and GSI, a sample of at least 5 m3 of treated water is concentrated (to ~5 liters) and tested for the 

presence of living organisms. Therefore, the entire 5 m3 sample is evaluated. If a linear 

relationship is used for testing to standards 100x more stringent than the IMO D-2 standard, 

using the same approach, 500 m3 of water would need to be concentrated (to ~500 liters) and 

evaluated. There are no facilities, or accepted protocols, for handling such sample volumes. 

Also, the time to conduct the biological laboratory analyses would cause significant delays 

resulting in unintended mortality. (Lisa Drake) 

More errors in testing are to be expected when using larger sample volumes. (Mario Tamburri & 

Allegra Cangelosi)

The draft ETV protocol provides more detailed methods and guidance than the IMO G8 

guidelines. It’s impracticable, or possibly impossible, to test to 100x IMO with the same rigor 

contained within the ETV protocol using similar analytical approaches. (Lisa Drake)

The science is very young for ballast water biological compliance monitoring to the IMO 

standard. We don’t yet know what can be done with measuring to the 100x IMO standard. (Sarah 

Bailey)

Combining of multiple tests may be a means of transcending this problem in some cases. 

Existing facilities may be able to provide indicative testing for 100x IMO, but not conclusive 

testing. (Lisa Drake & Allegra Cangelosi)

To sum, it is fair to say that type verifying to a strict standard at land-based facilities can indeed 

be done, if we choose to invest the necessary extensive resources to do so, or are willing to 

accept surrogate measurements to counting individual live organisms, but we cannot do so today 

in any reliable way. The methods have not been developed or verified. (Allegra Cangelosi)

A shipboard ETV verification protocol may need to be developed. It would likely be different 

from, but may share some aspects with, the US Coast Guard Shipboard Technology Evaluation 

Program (STEP), which promotes active shipboard ballast water technology use and 

development. (Lisa Drake)

3. Assess current compliance monitoring protocols and facilities considered necessary to 

spot check to 100x IMO.

Because of the unknowns with monitoring, the Wisconsin general permit doesn’t contain any 

specific requirements for the biological monitoring for determining compliance with the 

Wisconsin standard. The permit requires the submission of a monitoring plan, which would be 

specific to the vessel and its onboard treatment system. We may accept the type approval test of 

a ballast water treatment system as sufficient verification with no additional shipboard 

compliance monitoring. (Paul Luebke)

There are significant differences in the handling of ballast water between oceangoing vessels and 

Great Lakes vessels. Oceangoing vessels may discharge over a period of 12 hours, and some 

may discharge ballast in route. (William Peterson)

The U.S. negotiating policy at IMO has been that if any portion of a vessel’s ballast water 

discharge is found not in compliance, all the vessel's ballast water is considered not in 

compliance. This view is not shared by other administrations. (Lisa Drake)
50

California’s vessel inspection consists of an administrative inspection to confirm ballast water 

exchange occurred. About 20% to 25% of the vessels are inspected to check for their ballast 

water management plan and ballast log. A salinity sample is taken, but that can be of limited 

value since all the vessels are oceangoing, but it will detect if a vessel was at a brackish port and 

didn’t conduct mid-ocean exchange. We look for gross violations, emphasizing compliance and 

won’t take enforcement action unless nothing is done. California may need to push its 

compliance dates back, but likely won’t change the discharge standards. (Nicole Dobroski)

A multi-agency group (Transport Canada, USCG, St. Lawrence Seaway Corporations) currently 

conducts joint inspections of all oceangoing vessels headed for the Great Lakes. Vessels must 

inform Transport Canada officials 96 hours in advance of arriving at port by submitting their 

ballast water exchange report. Canada can instruct vessels to conduct another ballast water 

exchange if procedures weren’t followed correctly. A visit to the ship is made on arrival to 

review ballast water management plans, ballast logs and to interview the crew for knowledge and 

reliability. The salinity of each tank is also measured. Biological testing of each vessel is not 

feasible, but sampling may be done if there are red flags with the administrative review or other 

issues. In the future, when BWMS are used, indicator tests for gross non-compliance may be 

conducted with a 1 m3 sub-samples according to IMO procedures. Canada is not as concerned 

about the level of statistical rigor for compliance sampling, or if results will hold up in a 

subsequent legal battle – Canada’s main concern is having the ability to stop ballast water 

discharges that pose an environmental risk. The assumption is that if there’s a failure, the system 

will fail big. Monitoring for a gross failure of Wisconsin’s discharge standard would be possible, 

although there is concern that setting the discharge standard at 100x IMO may result in a higher 

failure rate of treatment systems (e.g. higher rate of filter clogging or tears). (Sarah Bailey)

4. Identify approaches to meeting compliance monitoring needs.

The question is open as to what we should design for in-line sampling protocols. California does 

not have a volume requirement for determining compliance with our zero discharge limit (no 

detection). It could be one liter. The sample needs to be representative of what is in the ballast 

tank that’s discharged, though. (Nicole Dobroski) 

Biological testing of ballast water (counting living organisms) must be conducted within a 

couple hours. Compliance testing facilities will need to be located near the port of inspection, or 

there may be a need for mobile facilities. As with the current joint-inspection program, 

inspections should be done strategically at a ‘choke-point’ in the St. Lawrence River prior to 

Great Lakes’ entry. (Sarah Bailey)

Ideally, protocols for compliance should be in place prior to implementation of a specific 

standard. For conclusive sampling, sample volume is dependent on the discharge standard used. 

Compliance monitoring may first start with an indicative sampling step (to test for gross 

exceedance) that will not determine conclusive achievability of any standard and then follow 

with a conclusive sampling step, if needed, to address the D-2 standard. (Lisa Drake)
51

Shipboard verification monitoring for a ballast water treatment system is different from 

compliance monitoring. Conducting scientifically valid procedures on board ship is very 

difficult since conditions cannot be controlled very well. Current compliance testing protocols 

can find gross failures with 100x IMO, but not verification of compliance. Compliance testing is 

likely to be indicative, whereas verification testing needs to be conclusive. (Sarah Bailey)

Indicative measures can be employed as an initial level of compliance monitoring. Sensor 

measurements of treatment system operational parameters, such as total residual oxidant levels 

for oxidizing chemical treatments and dissolved oxygen levels for deoxygenation treatments, 

biological measures such as chlorophyll levels using in situ fluorometers and perhaps estimates 

of ATP levels, could serve as rough indicators of the treatment system performance and a step 

that triggers more intensive biological sampling. (Mario Tamburri)

Use of ballast water treatment system operation indicators that show the system is functioning 

according to specifications could be the best approach to onboard monitoring. This type of 

monitoring would be more practical and reliable than biological monitoring of effluent for 

compliance with the discharge standard. Biological work-ups should still be undertaken 

however, in some percentage of monitoring events and for high-risk vessels. (Allegra Cangelosi) 

Some onboard biological testing will be needed, but it should be used to demonstrate 

conclusively non-compliance. It will be next to impossible to demonstrate compliance 

conclusively with shipboard monitoring. (Mario Tamburri & Allegra Cangelosi)

The following matrix was developed in an attempt to show the various compliance monitoring 

scenarios.

Compliance Monitoring Scenarios

Indicative (gross) Detailed (conclusive failure)

"Grab" (Discrete Sub-sample) Not Possible Only if # of all organisms 

allowable in ship discharge are 

found in sample

**Time Integrated: Partial 

Discharge

(e.g., 1 m3/ 15 minutes)

May be used as a first 

approximation

Can show conclusive failure and 

will be more sensitive than the 

grab sample above, but false 

positive possible

**Time Integrated 

Entire Discharge

Applicable if some partial 

analysis is used, such as 

analysis for a subset of 

organisms in the 

discharge.

Can show conclusive failure and 

will be more sensitive than the 

grab or partial time-integrated 

sample, but false positives still 

possible. 

Water Chemistry

Operational Parameters

May be used as first 

approximation

Not Applicable

** Greater statistical rigor can be achieved assuming high quality sample and analysis requirements are met. 
52

Resources

1. ABS. 2010. Ballast Water Treatment Advisory. ABS Advisory Notice, 08 June 2010, 

available via http://www.eagle.org/

2. Albert, R., R. Everett, J. Lishman and D. Smith. 2010. Availability and Efficacy of Ballast 

Water Treatment Technology: Background and Issues Paper. U.S. Environmental Protection 

Agency, Washington D.C.

3. California State Lands Commission. 2010. 2010 Assessment of the Efficacy, Availability and 

Environmental Impacts of Ballast Water Treatment Systems for Use in California Waters (Draft) 

Technical Rept., June 2010. (Note: updated final version became available August 2010). 

Available at http://www.slc.ca.gov/Spec_Pub/MFD/Ballast_Water/Ballast_Water_Default.html

4. Dobroski, N., C. Scianni, D. Gehringer and M. Falkner. 2008. Ballast Water Treatment 

Technology Testing Guidelines. CA State Lands Commission, Technical Report, October 2008. 

Available at 

http://www.slc.ca.gov/Spec_Pub/MFD/Ballast_Water/Documents/TestingGuidelinesFinal_1010

08.pdf

5. Gollasch, S. 2010. Global Expert Workshop on Harmonization of Methodologies for Test 

Facilities of Ballast Water Management Systems. Workshop Report. January 2010. Available at: 

http://globallast.imo.org/1st_Test_Facility_Forum_Report_2010.pdf

6. International Maritime Organization. 2004. Convention BWM/CONF/36 ‘International 

Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004’

7. International Maritime Organization. 2005. Resolution MEPC.126(53). ‘Procedure for 

Approval of Ballast Water Management Systems That Make Use of Active Substances (G9)’.

8. International Maritime Organization. 2005. Resolution MEPC.126(53). ‘Procedure for 

Approval of Ballast Water Management Systems That Make Use of Active Substances (G9)’.

9. International Maritime Organization. 2008. Resolution MEPC.1763(58) ‘Guidelines for 

Ballast Water Sampling (G2)’.

10. Lee II, H., Reusser, D.A., Frazier, M., and Ruiz, G. 2010. Density Matters: Review of 

Approaches to Setting Organism-Based Ballast Water Discharge Standards. U.S. EPA, Office of 

Research and Development, National Health and Environmental Effects Research Laboratory, 

Western Ecology Division. EPA/600/R-10/031. 

11. Lloyd's Register. 2010. Ballast Water Treatment Technology: Current Status. Technical 

report, Lloyd's Register. 71 Fenchurch Street, London EC3M 4BS. Available at: 

http://www.lr.org/Images/BWT0210_tcm155-175072.pdf

12. US EPA. 2010. Generic Protocol for the Verification of Ballast Water Treatment 

Technologies, Version 4.2 (Draft). March 2010. Available at: 

http://standards.nsf.org/apps/group_public/download.php/7597/Draft%20ETV%20Ballast%20W

ater%20Prot-v4%202.pdf
53

Acknowledgements

This document was prepared based on notes made during the meeting by:

Paul W. Luebke

Wisconsin Department of Natural Resources

Bureau of Watershed Management

and

Dr. David F. Reid (Facilitator)

Professor Emeritus

SLSDC Consultant and BWC Advisor

and

David J. Adams (Moderator)

New York State Department of Environmental Conservation

Office of Invasive Species Coordination
54
55

APPENDIX II

MEETING HANDOUTS

Duluth Meeting agenda

Report from the Great Lakes Ballast Water Collaborative Meeting (Montreal, 18 May 2010)

Ballast Water Collaborative Duluth Working Groups

Description of process/expectations for work group breakout sessions

STEP Workshop, July 22, 2010

Ballast Water Collaborative Working Group Proposal: Exploring Measures to Further Mitigate 

the Risk of Spreading AIS with Existing Lakers