2010 ASSESSMENT OF THE EFFICACY, AVAILABILITY

AND ENVIRONMENTAL IMPACTS OF BALLAST WATER 

TREATMENT SYSTEMS FOR USE IN CALIFORNIA WATERS

PRODUCED FOR THE 

CALIFORNIA STATE LEGISLATURE

By

California State Lands Commission

August 2010
ii

EXECUTIVE SUMMARY

The Coastal Ecosystems Protection Act (Act) of 2006 expanded the Marine Invasive 

Species Act of 2003 to more effectively address the threat of nonindigenous species 

introduction through ballast water discharge. The Act charged the California State 

Lands Commission (Commission) to implement performance standards for the 

discharge of ballast water and to prepare a report assessing the efficacy, availability 

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

treatment technologies. The performance standards regulations were adopted in 

October 2007, and subsequent ballast water treatment technology assessment reports

was approved by the Commission in December 2007 (see Dobroski et al. 2007) and 

December 2008 (see Dobroski et al. 2009a). This report summarizes the Commission‟s 

conclusions on the advancement of ballast water treatment technology development 

and evaluation during 2009 and the first half of 2010 and discusses ongoing activities of 

the Commission‟s Marine Invasive Species Program regarding the implementation of 

California‟s performance standards for the discharge of ballast water.

Vessels have several options for complying with the performance standards regulations. 

Over 80% of vessel voyages to California waters do not involve the discharge of ballast 

water. In these cases, the standards are met because all ballast water is retained on 

board the vessel. Retention is the most protective management strategy available 

because no organisms are released from the vessel via ballast water. Alternatively,

vessels may discharge to a shoreside or barge-based ballast water reception facility. 

Although no such facilities currently exist in California, there has been recent interest by 

several companies in developing this option for vessels in California and along the West 

Coast. Finally, for vessels that cannot retain all ballast on board or discharge to a 

reception facility, shipboard ballast water treatment will likely be necessary to meet 

California‟s performance standards.

Progress continues to be made in the development and assessment of treatment 

systems (see Dobroski et al. 2007, Dobroski et al. 2009a). Both the quantity and the 

quality of the recently received data on system performance attest to this fact. The fields 
iii

of treatment technology assessment and compliance verification, however, are still 

evolving. Scientific methods to assess the concentration of certain types of viable 

organisms present in ballast water discharge still must be developed or refined so that 

Commission staff may rapidly assess vessel compliance with the ballast water 

performance standards. The Commission is currently funding research to address some 

of these knowledge gaps, however additional work is necessary to develop compliance 

verification protocols for use in California. 

California‟s standards for bacteria and viruses pose a significant challenge. While 

methods exist to quantify total counts of bacteria and viruses (or virus-like particles) in a 

sample of ballast water, no techniques are available to assess the viability of all bacteria 

and viruses, as is required by the California performance standards. The best available 

technique for bacterial assessment involves the use of a subset or proxy group of 

organisms to represent treatment of bacteria as a whole. While this technique is not 

without some debate, it is scientifically supported by many experts in microbiology and 

technology assessment (see Dobroski et al. 2009a, Appendix A). The viruses pose a 

greater challenge. Without strong evidence for the selection of proxy organisms in this 

size class, Commission staff believes that there are no acceptable methods for 

verification of compliance with the total viral standard at this time, and that the 

Commission should proceed with assessment of technologies for the remaining 

organism size classes in the standards. 

Commission staff reviewed 46 ballast water treatment systems for this report. Based on 

currently available information and using best assessment techniques, at least eight 

treatment systems have demonstrated the potential to comply with the Commission‟s 

performance standards (see Tables VI-1 and VII-1). Efficacy data for these systems 

indicate that at least one test met or exceeded California‟s performance standard for 

every testable organism/size category during either land-based or shipboard testing. 

Three of the eight systems show the potential to meet California‟s performance 

standards under more rigorous evaluation criteria. These three passed more than 50% 

of the time over multiple tests (3 or more) at either the land or shipboard scale (Tables 
iv

VI-3 and VII-1). Additional systems are close to demonstrating the potential for meeting 

California‟s standards, and Commission staff are awaiting data from these tests of 

system performance. Commission staff have consulted with the vendors of systems that 

have demonstrated the potential to comply with California‟s standards, and at this time, 

two vendors (Ecochlor and Qingdao Headway Tech.), are willing to self-certify that their 

systems will meet California‟s standards. Evaluations in this report do not constitute 

endorsement, approval, or guarantee that a ballast water treatment system will meet 

California‟s standards for all vessels and all scenarios.

It is important to note that, as a whole, treatment systems have undergone a relatively 

small number of tests, under a limited range of environmental conditions. This leads to 

inherent uncertainty regarding treatment system performance across the spectrum of

potential variables, including ship type and source water properties (e.g. temperature, 

turbidity, salinity). This uncertainty is likely to persist over the next several years. In the 

absence of a significant worldwide effort to install and test treatment systems on 

multiple vessels and under all possible environmental scenarios, it is unreasonable to 

expect that sample sizes and available data will increase adequately in the near future 

to demonstrate, with a high level of confidence, that treatment systems will consistently 

meet California‟s performance standards under every potential situation and under all 

circumstances. However, continuing to wait for such information will only serve to delay 

progress. Due to the inherent uncertainty regarding treatment system performance and 

evaluation, the utilization of an adaptive management approach will be essential at all 

stages of implementation in order to move forward and protect California‟s aquatic 

resources from the impacts of species introductions.

Commission staff believe that, given the data currently available, multiple treatment 

systems have demonstrated the potential to meet California‟s performance standards 

for vessels with construction initiated on or after January 1, 2012, and a ballast water 

capacity greater than 5000MT. Practically speaking, vessels with this construction date 

will not be expected to meet the standards until construction is complete and they are 

operational, sometime in 2014 at the earliest. The lead time available for further 
v

technology development and refinement is sufficient to indicate that technologies will be 

available by the time these vessels are operational. At least three to four years will 

pass before any vessels in this size class will need to install treatment systems to meet

California‟s standards. 

All eight of the systems that have demonstrated the potential to meet California‟s 

standards are currently commercially available. Seven of these systems are marketed 

as having the capability to treat ballast water at pump rates over 2000 m3/hr, which 

would accommodate over 80% of the vessels that operate in California with ballast 

water capacity over 5000 MT. The manufacturers of six systems attest that their 

products will operate at much higher pump rates. The three systems that show 

potential for meeting the standards under more rigorous consistency criteria can 

accommodate much higher pump rates of 4500 m3/hr or more.

Treatment vendors and vessel operators will also need to assess the potential water 

quality impacts from treatment systems prior to operation in California waters. All ballast 

water discharges from vessels must comply with the U.S. Environmental Protection 

Agency‟s (EPA) National Pollution Discharge Elimination System (NPDES) Vessel 

General Permit for Discharges Incidental to the Normal Operation of Vessels, and the 

California-specific provisions added to the Vessel General Permit through the Clean 

Water Act Section 401 certification process. Commission staff recommends that 

treatment vendors also consult the Marine Invasive Species Program‟s “Ballast Water 

Treatment Technology Testing Guidelines,” which were developed in conjunction with 

the State Water Resources Control Board (Water Board) and provide additional 

guidance on relevant California water quality control plans and objectives for vessels 

intending to discharge treated effluent in State waters. Based on the available data it is 

clear that not all treatment systems will meet the EPA water quality objectives, 

particularly for chlorine residuals. Currently, California defers to the EPA Vessel General 

Permit for regulation of chlorine residuals in discharged ballast water. The eight systems 

that show the potential to meet California‟s standards have undergone some toxicity 

testing, and have received environmental approvals from the International Maritime 
vi

Organization and/or the State of Washington. Vessel owners and operators will need to 

consult with the EPA and the Water Board to better assess the potential for water 

quality impacts from treatment system usage in California waters.

The Commission will continue to gather information on treatment system efficacy, 

availability and environmental impacts as California‟s standards are implemented and 

additional vessels install treatment systems for both experimental purposes and to meet 

state, federal and international ballast water management requirements. Commission 

staff is working closely with the shipping industry and treatment vendors to ensure a 

smooth transition to the new standards. Commission staff believe that sufficient 

evidence exists to demonstrate that systems will be available to implement the 

performance standards for new vessels with a ballast water capacity greater than 5000 

MT in 2012. However, in recognition of the rapidly changing fields of technology 

development and performance assessment, Commission staff will prepare an update of 

this report by September 1, 2011. In preparation of the update, Commission staff will 

convene a scientific advisory panel to review the latest data on treatment systems and 

testing protocols and provide input regarding the availability of treatment systems in an 

effort to ameliorate concerns regarding the implementation of California‟s performance 

standards. While not required by statute, this update will verify that technology 

development is progressing on schedule to allow for the implementation of the 

standards beginning January 1, 2012. 

At this time, Commission staff recommends that the Legislature allow the 

implementation of standards for new vessels with a ballast water capacity over 5000 MT 

to proceed on January 1, 2012. In addition, and in order to ensure full implementation 

and compliance verification as performance standards move forward, Commission staff 

also recommend that the Legislature: 1) Support staff involvement with the 

development of performance standards and evaluation of treatment technologies at the 

federal and international levels; and 2) Maintain the accessibility and funding levels of 

the Marine Invasive Species Control Fund, so research can be supported and methods 
vii

developed for compliance verification as vessels with treatment systems begin to arrive 

to California. 
viii

TABLE OF CONTENTS

EXECUTIVE SUMMARY..................................................................................................ii

TABLE OF CONTENTS ................................................................................................viii

ABBREVIATIONS AND TERMS .....................................................................................ix

DISCLAIMER .................................................................................................................. 1

I. PURPOSE.................................................................................................................... 1

II. INTRODUCTION......................................................................................................... 2

III. REGULATORY AND PROGRAMMATIC OVERVIEW ............................................... 6

IV. TREATMENT TECHNOLOGY ASSESSMENT PROCESS..................................... 24

V. TREATMENT TECHNOLOGIES............................................................................... 26

VI. ASSESSMENT OF TREATMENT SYSTEMS ......................................................... 40

VII. DISCUSSION AND CONCLUSIONS...................................................................... 73

VIII. RECOMMENDATIONS.......................................................................................... 80

IX. LOOKING FORWARD............................................................................................. 83

X. LITERATURE CITED................................................................................................ 85

XI. APPENDICES........................................................................................................ 104

APPENDIX A: BALLAST WATER TREATMENT SYSTEM

EFFICACY MATRIX................................................................ 105

APPENDIX B: ADVISORY PANEL MEMBERS AND MEETING 

NOTES................................................................................ 130
ix

ABBREVIATIONS AND TERMS

Act Coastal Ecosystems Protection Act

CCR California Code of Regulations

CFR Code of Federal Regulations

CFU Colony-Forming Unit

CSLC/Commission California State Lands Commission

Convention International Convention for the Control and Management of 

Ships‟ Ballast Water and Sediments

CWA Clean Water Act

EEZ Exclusive Economic Zone

EPA United States Environmental Protection Agency

ETV Environmental Technology Verification Program

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

GESAMP-BWWG Joint Group of Experts on the Scientific Aspects of Marine 

Environmental Protection – Ballast Water Working Group

IMO International Maritime Organization

MEPC Marine Environment Protection Committee

Michigan DEQ Michigan Department of Environmental Quality

ml Milliliter

MPCA Minnesota Pollution Control Agency

MT Metric Ton

NIS Nonindigenous Species

nm Nautical Mile

NPDES National Pollution Discharge Elimination System

NRL Naval Research Laboratory

PRC Public Resources Code

Staff Commission staff

STEP Shipboard Technology Evaluation Program

TRC Total Residual Chlorine

μm Micrometer (one millionth of a meter)

USCG United States Coast Guard

UV Ultraviolet Irradiation

VGP Vessel General Permit for Discharges Incidental to the 

Normal Operation of Commercial Vessels and Large 

Recreational Vessels

Water Board California State Water Resources Control Board

WDFW Washington Department of Fish and Wildlife

WDNR Wisconsin Department of Natural Resources
1

DISCLAIMER

This report provides information regarding the ability and availability of ballast water 

treatment systems to meet California‟s performance standards for the discharge of 

ballast water. This report does not constitute an endorsement or approval by the 

California State Lands Commission (Commission) of any treatment system or system 

manufacturer. It is the responsibility of the vessel owner/operator to select treatment 

systems that will ensure that ballast water discharges are in compliance with California‟s 

performance standards for preventing species introductions and all other applicable 

laws, regulations and permits. 

I. PURPOSE

This report was prepared for the California Legislature pursuant to Public Resources 

Code (PRC) Section 71205.3. Among its provisions, PRC Section 71205.3 requires the 

Commission to adopt performance standards for the discharge of ballast water and to 

prepare and submit to the Legislature, “a review of the efficacy, availability, and 

environmental impacts, including the effect on water quality, of currently available 

technologies for ballast water treatment systems.” California‟s performance standards 

for the discharge of ballast water were approved in 2007 (see California Code of 

Regulations (CCR), Title 2, Division 3, Chapter 1, Article 4.7). The Commission 

completed an initial ballast water treatment technology assessment report in 2007 (see 

Dobroski et al. 2007) and a revised report in 2009 (see Dobroski et al. 2009a). 

Additional reports are due to the California Legislature 18 months prior to each of the 

implementation dates for California‟s performance standards (see Tables III-1 and III-2). 

This report fulfills the legislative mandate to assess the availability of ballast water 

treatment technologies prior to the January 1, 2012 implementation of performance 

standards for newly built vessels with a ballast water capacity greater than 5000 metric 

tons (MT). The report summarizes Commission conclusions on the advancement of 

ballast water treatment technology development and discusses progress by 

Commission staff in implementing California‟s performance standards for the discharge 

of ballast water. 
2

II. INTRODUCTION

Nonindigenous Species and their Impacts

Also known as “introduced,” “invasive,” “exotic,” “alien,” or “aquatic nuisance species,” 

nonindigenous species (NIS) are organisms that have been transported by human 

activities to a region where they did not occur historically, and have established 

reproducing populations in the wild (Carlton 2001). Once established, NIS can have 

serious human health, economic and environmental impacts in their new environment. 

One of the most infamous examples is the zebra mussel (Dreissena polymorpha), which 

was introduced from the Black Sea to the Great Lakes in the mid-1980s (Carlton 2008) 

and was discovered in California in 2008 (California Department of Fish and Game 

2008). This tiny striped mussel attaches to hard surfaces in dense populations that clog 

municipal water systems and electric generating plants, costing approximately $1 billion 

a year in damage and control for the Great Lakes alone (Pimentel et al. 2005). In San 

Francisco Bay, the overbite clam (Corbula amurensis) is believed to be a major 

contributor to the decline of several pelagic fish species in the Sacramento-San Joaquin 

River Delta by reducing the plankton food base of the ecosystem (Feyrer et al. 2003, 

Sommer et al. 2007). In addition, many human pathogens and contaminant indicator 

microorganisms have been found in ballast tanks. These include human cholera (Vibrio 

cholerae O1 and O139) (Ruiz et al. 2000), the microorganisms that cause paralytic 

shellfish poisoning (Hallegraeff 1998), human intestinal parasites (Giardia lamblia, 

Cryptosporidium parvum, Enterocytozoon bieneusi) and microbial indicators for fecal 

contamination (Escherichia coli and intestinal enterococci) (Reid et al. 2007). 

In marine, estuarine and freshwater environments, NIS may be transported to new 

regions through various human activities including aquaculture, the aquarium and pet 

trade, and bait shipments (Cohen and Carlton 1995, Weigle et al. 2005). In coastal 

habitats commercial shipping is an important transport mechanism, or “vector,” for 

invasion. In one study, shipping was responsible for, or contributed to, approximately 

80% of invertebrate and algae introductions to North America (Fofonoff et al. 2003, see 

also Cohen and Carlton 1995 for San Francisco Bay). Ballast water was a possible 
3

vector for 69% of those shipping introductions, making it a significant ship-based 

introduction vector (Fofonoff et al. 2003).

Ballast water is necessary for many functions related to the trim, stability, 

maneuverability, and propulsion of large oceangoing vessels (National Research 

Council 1996). Vessels take on, discharge, or redistribute water during cargo loading 

and unloading, as they take on and burn fuel, encounter rough seas, or transit through 

shallow coastal waterways. Typically, a vessel takes on ballast water after its cargo is 

unloaded in one port to compensate for the weight imbalance, and will later discharge 

that water when cargo is loaded in another port. This transfer of ballast water from 

“source” to “destination” ports results in the movement of many organisms from one 

region to the next. In this fashion, it is estimated that more than 7000 species are 

moved around the world on a daily basis (Carlton 1999). 

Ballast Water Management

Attempts to eradicate NIS after they have become widely distributed are often costly 

and unsuccessful (Carlton 2001). Between 2000 and 2006, over $7 million was spent to 

eradicate the Mediterranean green seaweed (Caulerpa taxifolia) from two small 

embayments in southern California (Woodfield 2006). Unsuccessful eradication 

attempts for nuisance NIS generally evolve into control efforts that typically represent an 

expensive and continual economic commitment. Approximately $10 million is spent 

annually to control the sea lamprey (Petromyzon marinus) in the Great Lakes (Lovell 

and Stone 2005). Over $10 million has been spent to control the zebra mussel and 

quagga mussel in California waters since the species were first found in 2007 (Ellis, S., 

pers. comm. 2010). By the end of 2010, over $12 million will have been spent in San 

Francisco Bay to control the Atlantic cordgrass (Spartina alterniflora) (Spellman, M., 

pers. comm. 2008). These costs reflect only a fraction of the cumulative expense over 

time, as species control is an unending process. Prevention is therefore considered the 

most desirable way to address the NIS issue.
4

For the vast majority of commercial vessels, ballast water exchange is the primary 

management technique to prevent or minimize the transfer of coastal (including 

bay/estuarine) organisms. During exchange, the biologically rich water that is loaded 

while a vessel is in port or near the coast is exchanged with the comparatively speciesand nutrient-poor waters of the mid-ocean (Zhang and Dickman 1999). Coastal 

organisms adapted to the conditions of bays, estuaries and shallow coasts are not 

expected to survive and/or be able to reproduce in the mid-ocean due to the differences 

in biology (competition, predation, food availability) and oceanography (temperature, 

salinity, turbidity, nutrient levels) between the two regions (Cohen 1998). Mid-ocean 

organisms are likewise not expected to survive in coastal waters (Cohen 1998).

Performance Standards for the Discharge of Ballast Water

Ballast water exchange is generally considered an interim tool because of its variable 

efficacy and operational limitations. Studies indicate that the effectiveness of ballast 

water exchange at eliminating organisms in tanks ranges widely from 50-99% (Cohen 

1998, Parsons 1998, Zhang and Dickman 1999, USCG 2001, Wonham et al. 2001, 

MacIsaac et al. 2002). When performed properly, exchange has been considered an 

effective tool to reduce the risk of coastal species invasions (Ruiz and Reid 2007). 

However, new research demonstrates that the percentage of ballast water exchanged 

does not necessarily correlate with a proportional decrease in organism abundance 

(Choi et al. 2005, Ruiz and Reid 2007). Some vessels are regularly routed on short 

voyages or voyages that remain within 50 nautical miles (nm) of shore, and in such 

cases, the exchange process may create a delay or require a vessel to deviate from the 

most direct route. Such deviations can extend travel distances, increasing vessel costs 

for personnel time and fuel consumption.

In some circumstances, ballast water exchange may not be possible without 

compromising vessel or crew safety. For example, vessels that encounter adverse 

weather or experience equipment failure may be unable to conduct ballast water 

exchange safely. Unmanned barges are incapable of conducting exchange without 

transferring personnel onboard, a procedure that can present unacceptable danger if 
5

attempted in the exposed conditions of the open ocean. In recognition of these 

challenges, state and federal ballast water regulations allow vessels to forego exchange 

should the master or person in charge determines that it would place the vessel, its 

crew, or its passengers at risk. Though the provision is rarely invoked in California, the 

handful of vessels that use it may subsequently discharge unexchanged ballast into 

state waters, presenting a risk of NIS introduction.

Regulatory agencies and the commercial shipping industry have therefore looked 

toward the development of effective ballast water treatment technologies as a promising 

management option. For regulators, such systems would provide NIS prevention,

including in situations where exchange may be unsafe or impossible. Technologies that 

eliminate organisms more effectively than mid-ocean exchange could provide a 

consistently higher level of protection to coastal ecosystems from NIS. For the 

shipping industry, the use of effective ballast water treatment systems might allow 

voyages to proceed along the shortest routes, in all operational scenarios, thereby 

saving time and money.

Until very recently, financial investment in the research and development of ballast 

water treatment systems had been limited, and the advancement of ballast water 

treatment technologies had been slow. Many barriers have hindered the development 

of technologies, including equipment design limitations, the cost of technology 

development, and the lack of guidelines for testing and evaluating performance. 

Perhaps most importantly, some shipping industry representatives, technology 

developers and investors considered the absence of a specific set of ballast water 

performance standards as a primary deterrent to progress. Performance standards 

would set benchmark levels for organism discharge that a technology would be required 

to achieve for it to be deemed acceptable for use in eliminating the threat of species 

introductions. Such targets were needed so developers could design technologies to 

meet the standards (MEPC 2003). Without standards, investors were reluctant to 

devote financial resources towards conceptual or prototype systems because they had 

no indication that their investments might ultimately meet future regulations. For the 
6

same reason, vessel owners were hesitant to allow installation and testing of prototype 

systems onboard operational vessels. It was argued that the adoption of performance 

standards would address these fears, and accelerate the advancement of ballast 

treatment technologies. Thus in response to the slow progress of ballast water 

treatment technology development and the need for effective ballast water treatment 

options, many state, federal and international regulatory agencies have adopted or are 

in the process of developing performance standards for ballast water discharges. 

III. REGULATORY AND PROGRAMMATIC OVERVIEW

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

an understanding of the regulatory framework associated with the development and 

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

knowledge of mechanisms for the testing and evaluation of treatment systems to meet 

those standards. Currently, there are no formally adopted international, federal or state 

programs that include performance standards, guidelines or protocols to verify the 

performance of treatment technologies, and methods to sample and analyze discharged 

ballast water for compliance purposes. California, other U.S. states, the federal 

government, and the international community have recently made great strides towards

the development of a standardized approach for the management of discharged ballast 

water. However, existing legislation, standards and guidelines still vary by jurisdiction. 

The following is a summary of current performance standards-related laws, regulations 

and permits, and a review of current and proposed processes for treatment system 

evaluation and compliance verification. 

International Maritime Organization 

In February 2004, after several years of development and negotiation, International 

Maritime Organization (IMO) Member States adopted the International Convention for 

the Control and Management of Ships‟ Ballast Water and Sediments (Convention) (see 

IMO 2005). Among its provisions, the Convention imposes performance standards for 

the discharge of ballast water (Regulation D-2) with an associated implementation 
7

schedule based on vessel ballast water capacity and date of construction (Tables III-1 

and III-2). 

The Convention will enter into force 12 months after ratification by 30 countries 

representing 35% of the world‟s commercial shipping tonnage (IMO 2005). As of May 

31, 2010, twenty-five countries representing 24.28% of the world‟s shipping tonnage 

have signed the convention (IMO 2010). The Convention cannot be enforced upon any 

ship until it is ratified and enters into force (IMO 2007). Because the Convention was not 

ratified in time to enter into force before the first performance standards implementation 

date in 2009, the IMO General Assembly adopted Resolution A.1005(25) (IMO 2007). 

The resolution delays the date by which new vessels built in 2009 with a ballast water 

capacity of less than 5000 MT must comply with Regulation D-2 from 2009 until the 

vessel‟s second annual survey, but no later than December 31, 2011 (IMO 2007). The 

resolution also calls for the IMO Marine Environment Protection Committee (MEPC) to 

address the impending implementation date for vessels constructed in 2010 (IMO 

2007). In September 2009, another draft resolution was put forth to encourage the 

installation of ballast water treatment systems on new build ships based on the existing 

implementation dates even though the Convention has not yet been ratified (MEPC 

2009j). That resolution was adopted at the 60th meeting of the MEPC in March, 2010. 

However, since the conditions of the resolution are not mandatory, the implementation 

dates for all other vessel size classes and construction dates remain the same as 

originally proposed (Table III-2). 
8

Table III-1. Ballast Water Treatment Performance Standards

Organism Size Class IMO Regulation D-2

[1] California[1,2]

Organisms greater 

than 50 μm[3] in 

minimum dimension

< 10 viable organisms 

per cubic meter

No detectable living 

organisms

Organisms 10 – 50 μm 

in minimum 

dimension

< 10 viable organisms 

per ml[4]

< 0.01 living organisms 

per ml

Living organisms less 

than 10 μm in 

minimum dimension

Escherichia coli

Intestinal enterococci

Toxicogenic Vibrio 

cholerae

(O1 & O139)

< 250 cfu[5]/100 ml

< 100 cfu/100 ml

< 1 cfu/100 ml or 

< 1 cfu/gram wet weight 

zooplankton samples

< 103bacteria/100 ml

< 104 viruses/100 ml 

< 126 cfu/100 ml

< 33 cfu/100 ml

< 1 cfu/100 ml or 

< 1 cfu/gram wet weight 

zoological samples 

[1]

See Table III-2 below for dates by which vessels must meet California and IMO Ballast Water 

Performance Standards.

[2]

Final discharge standard for California, beginning January 1, 2020, is zero detectable living organisms 

for all organism size classes. 

[3] Micrometer – one-millionth of a meter

[4] Milliliter – one-thousandth of a liter

[5] Colony-forming unit – a measure of viable bacterial numbers

Table III-2. Implementation Schedule for Performance Standards

Ballast Water Capacity 

of Vessel

Standards apply to new 

vessels in this size class 

constructed on or after

Standards apply to all 

other vessels in this size 

class beginning in1

< 1500 metric tons 2009 (IMO)2 /2010 (CA) 2016

1500 – 5000 metric tons 2009 (IMO)2 /2010 (CA) 2014

> 5000 metric tons 2012 2016

1 In California, the standards apply to vessels in this size class as of January 1 of the year of compliance. 

The IMO Convention applies to vessels in this size class no later than the first intermediate or renewal 

survey, whichever occurs first, after the anniversary date of delivery of the ship in the year of compliance 

(IMO 2005).

2

IMO has pushed back the initial implementation of the performance standards for vessels constructed in 

2009 in this size class until the vessel‟s second annual survey, but no later than December 31, 2011 (IMO 

2007).
9

In order to ensure globally uniform application of the requirements of the 

Convention, the IMO MEPC has adopted 14 implementation guidelines (Everett, R., 

pers. comm. 2010). Most relevant to this report, Guideline G8, “Guidelines for Approval 

of Ballast Water Management Systems” (MEPC 2008i), and Guideline G9, “Procedure 

for Approval of Ballast Water Management Systems That Make Use of Active 

Substances” (MEPC 2008f), work together to create a framework for the evaluation of 

treatment systems by the MEPC and Flag State Administration (the country or flag 

under which a vessel operates) (Figure III-1). Flag States (not the IMO) may grant 

approval (also known as “Type Approval”) to treatment systems that are in compliance 

with the Convention‟s Regulation D-2 performance standards based upon 

recommended procedures detailed in Guideline G8 for full-scale land-based and 

shipboard testing. A treatment system may not be used by a vessel party to the 

Convention to meet the D-2 standards unless that system is Type Approved.

In addition to receiving Type Approval from the Flag State Administration, ballast water 

treatment systems using “active substances” must first be approved by the IMO MEPC 

based upon procedures developed by the organization (IMO 2005). An active substance 

is defined by IMO as, “...a substance or organism, including a virus or a fungus, that 

has a general or specific action on or against Harmful Aquatic Organisms and 

Pathogens” (IMO 2005). For all intents and purposes, an active substance is a chemical 

or reagent (e.g. chlorine, ozone) that kills organisms in ballast water. The IMO approval 

pathway for treatment systems that use active substances is more rigorous than the 

evaluation process for technologies that do not. As required by Guideline G9, 

technologies utilizing active substances must go through a two-step “Basic” and “Final” 

approval process. Active substance systems that apply for Basic and Final Approval are 

reviewed for environmental, ship, and personnel safety by the IMO Joint Group of 

Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) –

Ballast Water Working Group (BWWG) in accordance with the procedures detailed in 

Guideline G9. The MEPC may grant Basic or Final Approval based upon the 

recommendation of the GESAMP-BWWG. 
10

Figure III-1. Summary of IMO approval pathway for ballast water treatment systems. 

(Modified from Lloyd‟s Register (2007))

The entire IMO evaluation process, including approval for systems using active 

substances has been estimated to take between six months and two years to complete 

(Everett, R., pers. comm. 2007, Lloyd‟s Register 2007). Once a ballast water treatment 

system has acquired Type Approval (and the Convention is ratified and in force), the 

system is deemed acceptable by parties to the Convention for use in international 

waters in compliance with Regulation D-2.

Because the U.S. has not signed on to the Convention, the U.S. has neither reviewed 

nor submitted applications to IMO on behalf of any U.S. treatment technology vendors. 

Until the Convention is both signed by the U.S. and enters into force through 

international ratification, no U.S. federal agency has the authority (unless authorized by 

Congress) to manage a program to review treatment technologies and submit 

applications on their behalf to IMO. United States treatment vendors may approach IMO 

through association with other IMO Member States, and several have or are in the 

process of doing so. However, until the U.S. signs on to the Convention, and the 

Convention is ratified and enters into force, the U.S. is not party to the Convention 

requirements. Hence, vessels calling on U.S. ports have no authority to use systems 
11

approved through the IMO Type Approval process to meet U.S. ballast water 

management requirements. 

One additional guideline related to the implementation of the IMO Convention is 

relevant to California‟s ballast water management program. Guideline G2, the 

“Guidelines for Ballast Water Sampling,” provides valuable information, in the absence 

of U.S. federal guidance, on the location of shipboard sampling points and equipment 

necessary to collect ballast water samples to assess compliance with the IMO 

Regulation D-2 performance standards. Guideline G2 defines the preferred sampling 

point (i.e. the place in the ballast water piping where the sample is taken) and sampling 

facilities (i.e. the equipment installed to take the sample) for sample collection (BLG 

2008). In order to maintain international uniformity, Commission staff based California‟s 

regulations governing the collection of ballast water samples on IMO Guideline G2 (see 

pg. 18, California Legislation and Implementation of Performance Standards, for 

details).

U.S. Federal Legislation and Programs 

Ballast water discharges in the United States are regulated by both the United States 

Coast Guard (USCG) and the United States Environmental Protection Agency (EPA). 

Prior to February 6, 2009, ballast water was regulated solely by the USCG through 

regulations found in Title 33 of the Code of Federal Regulation (CFR) Part 151. The 

USCG regulations, developed under authority of the Nonindigenous Aquatic Nuisance 

Prevention and Control Act of 1990, which was revised and reauthorized as the National 

Invasive Species Act of 1996, require ballast water management (i.e. ballast water 

exchange) for vessels entering U.S. waters from outside of the 200 nm Exclusive 

Economic Zone (EEZ) of the U.S. Vessels may use onboard treatment systems to meet 

the current ballast water management requirements if that system is at least as effective 

as exchange and is approved by the Commandant of the USCG. However, a target has 

not been developed to define the efficiency of exchange, preventing any evaluation of 

treatment systems against the efficacy of ballast water exchange. Without a specific 
12

target (or performance standard), the USCG has been unable to move forward on the

approval of any treatment systems. 

On August 28, 2009, the USCG proposed regulations that would establish federal 

performance standards for living organisms in ships‟ ballast water discharged in U.S. 

waters. The proposed regulations would amend 33 CFR Part 151 to include a twophase ballast water discharge standard and associated implementation schedule. 

Phase one would require vessels to meet the IMO D-2 standard – a standard roughly

1000 times weaker than California‟s standards - by 2012, and phase two would require 

that discharged ballast comply with a standard 1000 times more stringent than IMO –

roughly equivalent to California‟s standards - by 2016. The implementation of the phase 

two standard is contingent upon a review of the availability of technologies to meet that 

standard. The proposed regulations would also establish a program to approve ballast 

water management systems for use in U.S. waters. The public comment period closed 

on December 4, 2009. The USCG received thousands of comments on the contents of 

the proposed regulations, and it is possible that the proposed regulation could undergo 

substantial change before the final rule is issued. At this time, no date has been set for 

the release of the final regulation. 

On February 6, 2009, the EPA joined USCG in the regulation of ballast water in U.S.

waters. The EPA regulates ballast water, and other discharges incidental to normal 

vessel operations, through the Clean Water Act (CWA). This requirement stems from a 

2003 lawsuit filed by Northwest Environmental Advocates et al. against the EPA in U.S. 

District Court, Northern District of California, challenging a regulation originally 

promulgated under the CWA (Nw. Envtl. Advocates v. U.S. EPA, No. C 03-05760 SI, 

2006 U.S. Dist. LEXIS 69476 (N.D. Cal. Sept. 18, 2006)). The regulation at issue, 40

CFR Section 122.3(a), exempted effluent discharges “incidental to the normal 

operations of a vessel,” including ballast water, from regulation under the National 

Pollution Discharge Elimination System (NPDES). The plaintiffs sought to have the 

regulation declared ultra vires, or beyond the authority of the EPA, under the CWA. On 

March 31, 2005, the District Court granted judgment in favor of Northwest 
13

Environmental Advocates et al., and on September 18, 2006 the Court issued an order

revoking the exemptive regulation (40 CFR Section 122.3(a)) as of September 30, 

2008. EPA filed an appeal with the Ninth Circuit U.S. Court of Appeals but was denied 

in July 2008 (Nw. Envtl. Advocates v. U.S. EPA, No. 03-74795, 2008 U.S. App. LEXIS 

15576 (9th Cir. Cal. July 23, 2008)). 

In June 2008, EPA released for public comment the draft NPDES “Vessel General 

Permit for Discharges Incidental to the Normal Operation of Commercial Vessels and 

Large Recreation Vessels” (VGP). In September 2008, the District Court granted a 

motion to delay the vacature of the 122.3(a) regulation from September 30 to December 

19, 2008. The implementation of the permit was later delayed to February 6, 2009 to 

provide the regulated community with additional time to comply. 

Under the VGP, all vessels greater than 300 gross registered tons, or with a ballast 

water capacity greater than 8 cubic meters, must submit a Notice of Intent with EPA in 

order to receive permit coverage. Vessels greater than 79 feet but less than 300 tons 

receive automatic permit coverage. In large part, the VGP maintains the current 

regulation of ballast water discharges by the USCG through 33 CFR Part 151. The VGP 

does not currently include performance standards for the discharge of ballast water. 

Performance standards may be included in the next iteration of the permit in 2013 

based on the outcome of the USCG rulemaking on ballast water performance 

standards, or if they are proposed independently by EPA. In either case, EPA would 

have to determine if treatment technologies are commercially available and 

economically achievable to meet standards in order to include them in the 2013 VGP. 

The EPA VGP and the USCG regulations do not relieve vessel owners/operators 

(permittees) of the responsibility of complying with applicable state laws and/or 

regulations. Many states with authority to implement the CWA have added specific 

provisions, including performance standards, for vessel discharges in state waters to 

the EPA‟s general permit through the CWA Section 401 certification process. Thus we 

do not expect to see any impact from the implementation of the NPDES permit on 
14

individual states‟ ability to implement performance standards for the discharge of ballast 

water in state waters, including California. Vessels will, however, have to comply with 

both state and federal regulations for ballast water management under the VGP and the 

USCG regulations. This may result in vessels having to exchange ballast water to 

comply with federal management requirements under the VGP and USCG regulations 

and also treat ballast water to comply with state regulations. Federal legislation may be 

required to clarify this potentially confusing situation.

While the federal implementation of performance standards for the discharge of ballast 

water remains uncertain, two federal programs have been working to support the 

development of treatment technologies and facilitate the testing and evaluation of those 

systems: 1) The USCG Shipboard Technology Evaluation Program (STEP), and 2) The 

EPA‟s Environmental Technology Verification (ETV) program.

The USCG STEP is intended to facilitate the development of ballast water treatment 

technologies. Vessel owners and operators accepted into STEP may install and 

operate specific experimental ballast water treatment systems on their vessels for use in 

U.S. waters. In order to be accepted, treatment technology developers must assess the 

efficacy of systems for removing biological organisms, residual concentrations of 

treatment chemicals, and water quality parameters of the discharged ballast water 

(USCG 2004). STEP provides incentives for vessel operators and treatment developers 

to test promising new technologies. Vessels accepted into the program are authorized 

to operate the system to comply with existing USCG ballast water management 

requirements and will be grandfathered for operation under future ballast water 

discharge standards for the life of the vessel or the treatment system, whichever is 

shorter. As of June 2010, six vessels have been accepted into STEP (USCG 2010). The 

lengthy STEP review process and recent uncertainties regarding testing protocols have 

delayed significant testing on STEP vessels thus far, however, the USCG has plans to 

streamline the review process for future applicants (USCG 2008). USCG plans to 

continue STEP even after the implementation of performance standards, as the STEP 

will serve to facilitate system shipboard testing for USCG approval, and will continue to 
15

promote vessel access for the research and development of promising experimental 

technologies (Moore, B., pers. comm. 2010; Everett, R., pers. comm. 2010). 

The EPA ETV program is an effort to accelerate the development and marketing of 

environmental technologies. The USCG and the EPA established a formal agreement to 

implement an ETV program focused on ballast water management. Under this 

agreement, the ETV program developed a draft protocol in 2004 for verification of the 

performance of ballast water treatment technologies. Subsequently, the USCG 

established an agreement with the Naval Research Laboratory (NRL) to evaluate, 

refine, and validate this protocol and the test facility design required for its use. This 

validation project resulted in the construction of a model ETV Ballast Water Treatment 

System Test Facility at the NRL Corrosion Science and Engineering facility in Key West, 

Florida. The innovative research conducted at the NRL facility is intended to result in 

technical procedures for testing ballast water treatment systems for the purpose of 

approval and certification. Based on the information collected during the evaluation of 

the 2004 draft protocol, ETV staff, in consultation with an advisory panel (of which 

Commission staff is a member), is currently developing a revised final treatment 

technology verification protocol, which was released in draft form for public comment in 

March 2010. 

U.S. State Legislation and Programs 

States have taken two approaches to the implementation of ballast water management 

and specifically performance standards for the discharge of ballast water. Some states 

have specific authority granted by state legislation to establish performance standards 

either by regulation or permit. Other states have added specific provisions establishing 

performance standards to the VGP through the Section 401 certification process. The 

following is a summary of ballast water performance standards by state and how each 

has approached implementation. 
16

CWA Section 401 Certifications Under the Vessel General Permit (VGP)

Section 401 of the Clean Water Act requires states to approve federal permits and 

allows states to add requirements, if necessary, above and beyond those present in the 

federal permit. A number of states established ballast water management programs in 

2009 through the VGP. States that specifically included the establishment of 

performance standards in their 401 certification include: Illinois, Indiana, New York, 

Ohio, and Pennsylvania. Illinois, Indiana and Ohio require vessels to comply with the

IMO D-2 standard (see Table III-1) by 2012 for newly built vessels or 2016 for existing 

vessels. Pennsylvania established a two-phase standard that requires vessels built prior 

to 2012 to install treatment systems that meet the IMO D-2 standard by 2012, and 

vessels built on or after 2012 to meet California‟s performance standards (roughly 

equivalent to1000 times the IMO D-2 standard). Finally, New York will require all 

vessels to install treatment systems that meet a standard roughly equivalent to 100

times the IMO D-2 standard by 2012. Vessels constructed on or after 2013 must install 

systems that meet California‟s performance standards. 

Non-VGP State Ballast Water Programs that Include Performance Standards

Michigan

Michigan passed legislation in June 2005 (Act 33, Public Acts of 2005) requiring a 

permit for the discharge of any ballast water from oceangoing vessels into the waters of 

the state beginning January 2007. Through the general permit (Permit No. MIG140000) 

developed by Michigan Department of Environmental Quality (DEQ), any ballast water 

discharged must first be treated by one of four methods (hypochlorite, chlorine dioxide, 

ultraviolet radiation preceded by suspended solids removal, or deoxygenation) that have 

been deemed environmentally sound and effective in preventing the discharge of NIS. 

In state waters, vessels must use treatment technologies in compliance with applicable 

requirements and conditions of use as specified by Michigan DEQ. Vessels using 

technologies not listed under the Michigan general permit may apply for individual 

permits if the treatment technology used is deemed, “environmentally sound and its 

treatment effectiveness is equal to or better at preventing the discharge of aquatic 
17

nuisance species as the ballast water treatment methods contained in [the general] 

permit,” (Michigan DEQ 2006). 

Minnesota

Effective July 1, 2008, Minnesota state law (S.F. 3056) requires vessels operating in 

state waters to have both a ballast water record book and a ballast water management 

plan onboard that has been approved by the Minnesota Pollution Control Agency 

(MPCA) (MPCA 2008). Additionally, based on the authority in Minn. Stat. 115.07, Minn. 

R. 7001.0020, subp. D, and Minn. R. 7001.0210, and to implement the recently enacted 

legislation, the MPCA approved a State Disposal System general permit for ballast 

water discharges into Lake Superior and associated waterways in September 2008 

(MPCA 2008). Under the permit, all vessels (oceangoing and lakes-only) transiting 

Minnesota waters must comply immediately with approved best management practices. 

No later than January 1, 2012, new vessels will be required to comply with the IMO D-2 

performance standards for the discharge of ballast water (see Table III-1), and existing 

vessels will be required to comply with those standards no later than January 1, 2016 

(MPCA 2008). 

Washington

The Washington Department of Fish and Wildlife (WDFW), in consultation with their 

stakeholder Ballast Water Work Group, completed a comprehensive rewrite of the 

state‟s ballast water management regulations, which became effective on July 26, 2009. 

The new rules and information on the state program can be found at: 

http://wdfw.wa.gov/fish/ballast/ballast.htm. WDFW has initiated new rulemaking to adopt 

permanent concentration-based standards. A priority for WDFW is to adopt standards 

that help bring the national and/or U.S. Pacific coast states into greater management 

consistency. The WDFW no longer independently approves treatment systems for use 

in state waters and now relies on regional, national or international approvals. Systems 

previously approved under the interim regulations will remain approved for their original 

period of use. WDFW staff expects the new standards to be adopted in early 2011 

(Pleus, A., pers. comm. 2010).
18

Wisconsin

As of February 1, 2010, vessels that discharge ballast in Wisconsin waters must comply 

with the General Permit to Discharge under the Wisconsin Pollutant Discharge 

Elimination System. The permit was established by the Wisconsin Department of 

Natural Resources (WDNR) under authority provided by Chapter 283, Wisconsin 

Statutes. Among its provisions, the permit sets ballast water performance standards 

roughly equivalent to 100 times the IMO D-2 standard. All vessels constructed on or 

after 2012 must meet the Wisconsin Standard set forth in the permit. Existing vessels 

have until 2014 to comply. Prior to the implementation of the standards, WDNR will 

conduct an assessment of the availability of treatment systems to meet the Wisconsin 

standards. If the WDNR determines that treatment technologies are commercially 

unavailable, the permit requires vessels to comply with the IMO D-2 standard in place of 

the Wisconsin Standard. The existing implementation schedule remains the same. 

California Legislation and the Implementation of Performance Standards

Review of Legislation

California‟s Marine Invasive Species Act of 2003 directed the Commission to 

recommend performance standards for the discharge of ballast water to the State 

Legislature in consultation with the State Water Resources Control Board (Water 

Board), the USCG and a technical advisory panel (see PRC Section 71204.9). The 

legislation directed that standards should be selected based on the best available 

technology economically achievable, and should be designed to protect the beneficial 

uses of the waters of the State. 

In 2005, Commission staff convened a cross-interest, multi-disciplinary panel consisting 

of regulators, research scientists, industry representatives and environmental 

organizations and facilitated discussions over the selection of performance standards. 

Many sources of information were used to guide the performance standards selection 

including: biological data on organism concentrations in exchanged and un-exchanged 

ballast water, theories on coastal invasion rates, standards considered or adopted by 

other regulatory bodies, and available information on the efficacy and costs of 
19

experimental treatment technologies. Though all sources and panel members provided 

some level of insight, none could provide solid guidance for the selection of a specific 

set of standards that would reduce or eliminate the introduction and establishment of 

NIS. At a minimum, it was determined that reductions achieved by the selected 

performance standards should improve upon the status quo and decrease the 

discharge of viable ballast organisms to a level below quantities observed following 

legal ballast water exchange. Additionally, the technologies used to achieve these 

standards should function without introducing chemical or physical constituents to the 

treated ballast water that may result in adverse impacts to receiving waters. Beyond 

these general criteria, however, there was no concrete support for the selection of a 

specific set of standards. This stems from the key knowledge gap that invasion risk 

cannot be predicted for a particular quantity of organisms discharged in ballast water 

(MEPC 2003), with the exception that zero organism discharge equates to zero risk.

The Commission ultimately put forward performance standards recommended by the 

majority of the Panel because they encompassed several desirable characteristics: 1) 

A significant improvement upon ballast water exchange; 2) In-line with the best 

professional judgment of scientific experts that participated in the development of the 

IMO Convention; and 3) Approached a protective zero discharge standard. The 

proposed interim standards were based on organism size classes (Table III-1). The 

standards for the two largest size classes of organisms (greater than 50 micrometers 

(μm = one-millionth of a meter) in minimum dimension and 10 – 50 μm in minimum 

dimension) were significantly more protective than those proposed by the IMO 

Convention. The majority of the Panel also recommended standards for organisms less 

than 10 μm including human health indicator species and total counts of living bacteria 

and viruses. The recommended bacterial standards for human health indicator species,

Escherichia coli and intestinal enterococci, are identical to those adopted by the EPA in 

1986 for recreational use and human health safety (EPA 1986). The implementation 

schedule proposed for the interim standards was similar to the IMO Convention (Table

III-2). A final discharge standard of zero detectable organisms was recommended by 
20

the majority of the Panel. The Commission included an implementation deadline of 2020 

for this final discharge standard. 

The Commission submitted the recommended standards and information on the 

rationale behind its selection in a report to the State Legislature in January of 2006 (see 

Falkner et al. 2006). By the fall of that same year, the Legislature passed the Coastal 

Ecosystems Protection Act (Chapter 292, Statutes of 2006) directing the Commission to 

adopt the recommended standards and implementation schedule through the California 

rulemaking process by January 1, 2008. The Commission completed that rulemaking in 

October, 2007 (see 2 CCR § 2291 et seq.). 

In anticipation of the implementation of the interim performance standards, the Coastal 

Ecosystems Protection Act also directed the Commission to review the efficacy, 

availability and environmental impacts of currently available ballast water treatment 

systems by January 1, 2008. The review and resultant report was approved by the 

Commission in December, 2007 (see Dobroski et al. 2007). Additional reviews must be 

completed 18 months prior to the implementation dates for all other vessel classes and 

18 months before the implementation of the final discharge standard on January 1, 

2020 (see Table III-2 for full implementation schedule). During any of these reviews, if it 

is determined that existing technologies are unable to meet the discharge standards, 

the report must describe why they are not available. 

The first technology assessment report (Dobroski et al. 2007) determined that 

technologies would not be available to meet California‟s discharge standards for new 

vessels with a ballast water capacity under 5000 MT by the original 2009 

implementation date. In response, the Legislature passed Senate Bill 1781 in 2008 

(Chapter 696, Statutes of 2008). Senate Bill 1781 amended PRC Section 71205.3(a)(2) 

and delayed the implementation of the interim performance standards for new vessels 

with a ballast water capacity of less than 5000 MT from January 1, 2009 to January 1, 

2010. Senate Bill 1781 also required an additional assessment of available ballast water 

treatment technologies by January 1, 2009 (see Dobroski et al. 2009a) prior to the new 
21

2010 implementation date. Dobroski et al. (2009a) determined that technologies that 

demonstrated the potential to meet California‟s performance standards were available. 

The report recommended that the Commission proceed with the initial implementation 

of the performance standards in 2010. 

Implementing California’s Performance Standards

As of January 1, 2010, newly built vessels (vessels for which construction began on or 

after January 1, 2010) with a ballast water capacity of less than 5000 MT that discharge 

ballast in California waters must comply with California‟s performance standards. Vessel 

construction often takes a year or more, and it is anticipated that the first vessels that 

must meet the performance standards will not begin to arrive in California until 

sometime during 2011. Commission staff have consulted with vendors to determine if

treatment systems have been or will be purchased in order to meet this first 

implementation date. At this time, staff are not aware of any specific purchases. Many 

vessels in the midst of construction are leaving dedicated space for a ballast water 

treatment system so it may be installed at the last possible moment to ensure that the 

system purchased is the most up-to-date available. Commission staff are in the process 

of preparing protocols to assess compliance with the performance standards and will be 

ready to begin inspection of vessels once new build vessels that fall under the 2010 

implementation date arrive in California waters. 

Commission staff do not have the practical ability to test and approve ballast water 

treatment systems for use in California waters. Staff encourages the shipping industry to 

collaborate with treatment vendors and third party testing organizations to conduct 

performance verification testing and determine the best treatment solution for each 

vessel. Commission staff will focus on dockside inspection of vessels for verification of 

compliance with the performance standards (in accordance with PRC Section 71206). 

Vessel inspections will consist of both an administrative review of applicable ballast 

water management plans and reporting documents as well as the collection of ballast 

water samples for analysis. Vessels must currently keep an up-to-date ballast water 

management plan on board as well as copies of all ballast water reporting forms 
22

submitted to the Commission within the past two years. Dobroski et al. (2009a) 

recommended that additional authority be granted to the Commission in order to allow 

for the collection of specific information about the installation and use of ballast water 

treatment systems on vessels operating in California waters. This information is 

necessary to monitor the effective implementation of California‟s performance 

standards. In response to the recommendation in Dobroski et al. (2009a), Assembly Bill 

248 (Chapter 317, Statutes of 2009) was passed in the fall of 2009, which provides the 

Commission with the authority to request the aforementioned information on forms to be 

developed by the Commission. Commission staff is currently in the process of adopting 

those forms through the rulemaking process.

During an inspection, once Commission staff has reviewed applicable vessel 

paperwork, a ballast water sample will be drawn from vessels intending to discharge in 

California waters. California‟s performance standards are a discharge standard, and 

thus samples must be drawn from the vessel‟s ballast water discharge piping. Most 

vessels do not have the equipment to take samples of ballast water from the discharge 

line. Therefore, the Commission developed regulations in the fall of 2009 that require 

vessels to install sampling ports (i.e. sampling facilities) as near to the point of 

discharge as practicable (2 CCR § 2297). In order to maintain international uniformity, 

the regulations are based on the IMO Guideline G2 for ballast water sampling with 

additional input provided by the USCG. The regulations establish design specifications 

for in-line sampling facilities and set requirements for where the sampling facilities 

should be installed on the discharge line (i.e. the sampling point). Vessels must install 

the sampling facilities by the same year that they must comply with California‟s 

performance standards. 

Commission staff is currently in the process of refining procedures for analysis of the 

samples collected from the discharge line. Commission staff is working in consultation 

with technical experts and will make use of the best available scientific techniques to 

assess viable organism concentration for each of the standards. One issue of concern 

has been the development of sampling methods and procedures that will verify vessel 
23

compliance with an acceptable level of legal and scientific confidence (see King and 

Tamburri 2009). The bulk of these arguments are aimed at performance standards for 

the greater than 50 μm organism size class, specifically for standards that are defined 

as a given number of live organisms per cubic meter (e.g. IMO and proposed USCG 

standards). While sampling large volumes of ballast water (i.e. many cubic meters) are 

necessary to attain adequate statistical confidence to verify a given number of viable 

organisms are indeed present in each cubic meter, this argument is not necessarily 

appropriate for California‟s (as well as New York and Pennsylvania‟s) performance 

standards. California‟s performance standard for the greater than 50 μm organism size 

class is defined as “no detectable living organisms” and is technically not bound by any 

volumetric units or the confidence limits associated with those units. Therefore 

Commission staff believes it is appropriate to sample as large a volume as is feasible 

(whether that is 50 liters, 500 liters, 5000 liters, or any volume in-between) in order to 

verify compliance with California‟s unit-less performance standard. Although it is 

important to ensure that a reasonable volume of water is sampled during compliance 

verification, sampling methods must balance the desire for statistical confidence with 

practical, rapid, and relatively easy techniques for shipboard inspection. As the 

precision of sampling equipment and analytical techniques improve, Commission staff 

will regularly discuss sampling methodologies with other states, the federal government 

and the international community to stay up-to-date on advances in the technology to 

conduct compliance verification. 

Finally, Commission staff will continue to gather information about treatment system 

development, installation, and use on board vessels, particularly as the standards are 

implemented for existing vessels and vessels with larger ballast water capacities. This 

information will guide the development of new regulations which take into account 

development within the rapidly advancing ballast water treatment technology industry. 
24

IV. TREATMENT TECHNOLOGY ASSESSMENT PROCESS

Public Resources Code (PRC) Section 71205.3 directs the Commission to prepare, "a 

review of the efficacy, availability, and environmental impacts, including the effect on 

water quality, of currently available technologies for ballast water treatment systems." In 

accordance with the law, the Commission has consulted with, “the State Water 

Resources Control Board, the United States Coast Guard, and the stakeholder advisory 

panel described in subdivision (b) of [PRC] Section 71204.9.” This stakeholder panel 

also provided guidance in the development of the performance standards report to the 

California Legislature (Falkner et al. 2006).

During the preparation of the initial technology assessment report (Dobroski et al. 

2007), Commission staff received input from a small technical workgroup prior to 

consulting with the stakeholder advisory panel. The workgroup met in May 2007 to 

assess the current availability of treatment systems, the efficacy of those systems, and 

any potential environmental and water quality impacts. This group included individuals 

with expertise in ballast water treatment technology development, water quality and 

biological monitoring and evaluation, naval architecture and engineering, and 

technology efficacy analysis (see Dobroski et al. 2007 for workshop participants and 

summary). The conclusions drawn during the workshop in 2007 have continued to 

provide valuable guidance and direction in the preparation of subsequent reports.

As with previous reports (Dobroski et al. 2007, 2009a), Commission staff conducted an 

exhaustive literature search to prepare this report. Staff focused its review on recently 

available scientific articles, performance verification reports, and water quality impact 

analyses from independent testing organizations. Staff also contacted treatment 

technology vendors in order to gather the most up-to-date information about system 

development, testing and approvals. On several occasions, staff held meetings inperson with technology vendors. These face-to-face gatherings have proved to be 

extremely valuable opportunities to inform vendors about California‟s performance 

standards requirements and to engage in dialogue about system performance 

verification testing and the Commission‟s technology assessment reports. 
25

Due to a rapid increase in the availability of new data on treatment system performance 

in mid-2009, and a desire by industry to receive updates on the latest technology 

developments, Commission staff conducted an interim assessment of available 

treatment technologies in October 2009 (see Dobroski et al. 2009b). The technology 

update was not legislatively mandated, and was not reviewed by the technical advisory 

panel. The update was intended as a resource for stakeholders interested in ballast 

water treatment systems for use in California waters. It also provided Commission staff 

with an opportunity to begin identifying and focusing on issues of concern for this 2010 

legislatively mandated report. 

For the preparation of this report, Commission staff compiled available data to develop 

a treatment system matrix (see Tables V-1, VI-1, VI-3, VI-4, VI-5, VI-6, VII-1 and 

Appendix A). The 2010 report addresses the availability of treatment systems for 

vessels with a ballast water capacity greater than 5000 MT. Industry has expressed 

concern about whether or not treatment systems will be able to effectively treat ballast 

water on these high volume/high flow rate vessels. Therefore, Commission staff 

included relevant data on treatment systems‟ maximum capacities and flow rates for this 

report. The data was summarized relative to the ballast water capacities and pump flow 

rates of the vessel fleet operating in California waters in order to determine if systems 

both meet California‟s performance standards and are available for this largest size 

class of vessels. As with previous reports, Commission staff also gathered the latest 

data on environmental impacts, including effects on water quality, and the economics of 

treatment system installation and operation. Upon completion of the data analysis, 

Commission staff drafted a preliminary report for review by the Commission‟s 

stakeholder advisory panel (see Appendix B for list of panel members), the Water Board 

and USCG. The advisory panel met in April 2010 to discuss the current report (see 

Appendix B for meeting notes). Advisory panel discussions were considered by staff to 

help guide the development of this final report. 
26

V. TREATMENT TECHNOLOGIES

The goal of ballast water treatment is to remove or kill organisms entrained in ballast 

water. Given the long history and use of wastewater treatment technologies, the design 

and production of ballast water treatment systems may seem simple. However, 

transferring such technological concepts to mobile, space- and energy-limited vessels 

has proven complex in practice. A system must be effective under a wide range of 

challenging environmental conditions including variable temperature, salinity, nutrients 

and suspended solids. It must also function under difficult operational constraints 

including high flow-rates of ballast water pumps, large water volumes, and variable 

retention times (time ballast water is held in tanks). Treatment systems must be capable 

of eradicating a wide variety of organisms ranging from viruses and microscopic 

bacteria, to free-swimming plankton, and must operate so as to minimize or prevent 

impairment of the water quality conditions of the receiving waters. The development of 

effective treatment systems is further complicated by the variability of vessel types, 

shipping routes and port geography. 

Two general platform types have been explored for the development of ballast water 

treatment technologies. Shoreside ballast water treatment occurs at a barge- or landbased facility following transfer from a vessel. Shipboard treatment occurs onboard 

vessels through the use of technologies that are integrated into the ballasting system. 

Shipboard treatment systems are attractive because they allow flexibility to manage 

ballast water during normal operations, while shoreside treatment may be a good option 

for vessels with small ballast water capacities and/or dedicated port calls. 

Shoreside treatment of ballast water is an appealing option, particularly from a 

regulatory perspective. Permitting and inspection of a fixed shoreside facility is 

significantly easier than the regulation of discharges from mobile sources such as 

vessels. Shoreside treatment also provides an option for treatment technologies and 

methods that are not feasible onboard vessels due to space and/or energy constraints, 

such as reverse osmosis. Shoreside treatment facilities could be staffed by trained 

wastewater engineers instead of ships‟ crew, who may not be specifically trained in the 
27

operation and maintenance of water treatment facilities. Additionally, in the event that a 

shipboard treatment system fails or sea conditions prevent ballast water exchange, 

shoreside or barge-mounted treatment facilities could provide an important facility 

where unmanaged ballast water could be held or treated. 

Shoreside treatment does pose several challenges, however. Vessels must have the 

appropriate piping or attachment mechanism to establish a connection with a shoreside 

facility. An international standard would be necessary to standardize the design of these 

connections in order to ensure that ships could connect to shoreside facilities 

throughout the world. Additionally, vessels must be able to discharge ballast at a rate 

that prevents vessel delays. The cost of these retrofits may be prohibitive (CAPA 2000). 

Additionally, current wastewater treatment plants are not equipped to treat saline water 

(Water Board 2002, Moore, S., pers. comm. 2005). If existing municipal facilities are to 

be used for the purposes of ballast water treatment, they will need to be modified, and a 

new extensive network of piping and associated pumps will be required to distribute 

ballast water from vessels at berth to the treatment plants. The establishment of new 

piping and facilities dedicated to ballast water treatment, while technically feasible, 

would require the acquisition of land for facility construction, and this would be complex 

and costly in California‟s densely populated coastal and port areas. Furthermore, 

shoreside treatment is not feasible for vessels that must take on or discharge ballast 

water while underway, for example, if the vessel must adjust its draft to navigate 

through a shallow channel or under a bridge. 

To date only limited feasibility studies have been conducted on shoreside treatment 

(see references in Falkner et al. 2006). A recent study by McMullin et al. (2008) 

assessed the feasibility of shoreside treatment at the Port of Milwaukee. The authors 

concluded that shoreside treatment is a feasible alternative to shipboard treatment, but 

only under certain conditions. Since vessels must be retrofitted to allow the connection 

of shoreside pumps to the vessel‟s ballasting piping, an international standard would 

likely need to be created. Additionally, procedures would need to be developed for each 

vessel to maintain its stability and ensure safe deballasting rates during cargo loading. 
28

Finally, due to space constraints, the authors determined that the most cost-effective 

and practical approach to shoreside treatment at the Port of Milwaukee would likely 

require vessels to discharge ballast to a barge to store or treat the ballast before 

disposal to land-based facilities. The authors caution against the extrapolation of the 

report‟s conclusions to port areas outside of Milwaukee, as each unique region presents 

its own set of challenges. 

In California, shoreside treatment may be a good option for unique terminals such as 

those with limited but regular vessel calls (e.g. cruise ships). Nonetheless, one study 

specific to cruise ships indicated that due to the operational practices of cruise ships –

many do not deballast in California - and with the current ballast water management and 

environmental regulatory requirements in California and the Port of San Francisco, 

there is little demand for shoreside treatment except in emergency situations (Bluewater 

Network 2006). Additional studies are necessary to determine the feasibility of and 

demand for shoreside treatment for other vessel types and across the State as a whole. 

These may include assessments by those involved in the wastewater treatment sector 

on whether existing technologies could meet California's performance standards. 

Within the last six months, Commission staff have been contacted by companies

interested in developing barge-based and/or shore-based reception facilities for use in 

California and along the West Coast. Commission staff will continue to work with these 

companies to ensure that as many options as possible are available to vessels in order 

to comply with California‟s performance standards. As of the writing of this report 

though, no barge- or land-based facilities are yet available for vessels operating in 

California waters. Because the vast majority of time, money, and effort in the 

development of ballast water treatment technologies during recent years has been 

focused on shipboard treatment systems, we will focus on shipboard systems for the 

remainder of this report. 

Shipboard systems allow for greater flexibility during vessel operations. Vessels may 

treat and discharge ballast while in transit, and thus will not need to coordinate vessel 
29

port arrival time with available space and time at shoreside treatment facilities. As with 

shoreside treatment, however, shipboard treatment systems face their own set of 

challenges. They must be engineered to conform to a vessel‟s structure, ensure crew 

safety, and withstand the vibrations and movements induced by the vessel‟s engine and 

rough seas. Additionally, shipboard systems must be effective under transit times that 

range from less than 24 hours to several weeks, and must treat ballast water in 

compliance with the water quality requirements of recipient regions. 

The timing and location of shipboard ballast water treatment can be varied according to 

the needs of the treatment system and the length of vessel transit. Ballast water may be 

treated in the pipe (in-line) during uptake or discharge or in the ballast tanks during the 

voyage (in tank). While mechanical separation (such as filtration) generally occurs 

during ballast uptake in order to remove large organisms and sediment particles before 

they enter the ballast tanks, other forms of treatment may occur at any point. Some 

treatment systems treat ballast water at multiple points during the voyage, such as 

during uptake and discharge. 

Because of the wide range of variables associated with shipboard ballast water 

treatment, the identification of a single treatment technology for all NIS, ships, and water 

conditions is unlikely. Each technology may meet the objective of killing or inactivating 

NIS in a slightly different manner and each could potentially impact the water quality of 

the receiving environment through the release of chemical residuals or alterations to 

temperature, salinity, and/or turbidity. Thus a suite of treatment technologies will 

undoubtedly need to be developed to treat ballast water industry-wide and across all 

ports and environments.

Treatment Methods

The development of ballast water treatment systems that are effective, environmentally 

friendly and safe for vessels and crew has been a complex, costly and time consuming 

process. At the root of many treatment systems are methods that are already in use to 

some degree by the wastewater treatment industry. A preliminary understanding of 
30

these treatment methods forms the basis for more detailed analysis and discussion of 

ballast water treatment systems. The diverse array of water treatment methods currently 

under development for use in ballast water treatment can be broken down into five 

major categories: mechanical, chemical, physical, biological and combination. 

Mechanical Treatment

Mechanical treatment traps and removes mid- and large-sized particles from ballast 

water. Mechanical treatment typically takes place upon ballast water uptake in order to 

limit the number of organisms and amount of sediment that may enter ballast tanks. 

Common options for mechanical treatment include filtration and hydrocyclonic 

separation. 

Filtration works by capturing organisms and particles as water passes through a porous 

screen or filtration medium, such as sand or gravel. The size of organisms trapped by 

the filter depends on the mesh size in the case of screen or disk filters, or on the size of 

the interstitial space for filtration media. In ballast water treatment, screen and disk 

filtration is more commonly used over filter media, however, there has been some 

interest in the use of crumb rubber as a filtration medium in recent studies (Tang et al. 

2006, 2009). Typical mesh size for ballast water filters ranges from 25 to 100 μm 

(Parsons and Harkins 2002, Parsons 2003). Most filtration-based technologies also 

use a backwash process that removes organisms and sediment that become trapped 

on the filter and clog it. Backwash systems can discharge particles and organisms at 

the port of origin before the vessel gets underway. Filter efficacy is a function not only 

of initial mesh size, but also of water flow rate and backwashing frequency. 

Hydrocyclonic separation, also known as centrifugation, relies on density differences to 

separate organisms and sediment from ballast water. Hydrocyclones create a vortex 

that cause heavier particles to move toward the outer edges of the cyclonic flow where 

they are trapped in a weir-like device and can be discharged before entering the ballast 

tanks (Parsons and Harkins 2002). Hydrocyclones used in ballast water treatment 

generally trap particles in the 50 to 100 μm size range (Parsons and Harkins 2002). One 
31

challenge associated with hydrocylone use, however, is that many small aquatic 

organisms have a density similar to sea water and are thus difficult to separate.

Chemical Treatment

A variety of chemicals (i.e. active substances) are available to kill organisms in ballast 

water. While the vast majority of chemicals are biocides, some chemicals function to 

clump or coagulate organisms in order to assist with their mechanical removal. 

Chemical treatment may take place during ballast uptake, vessel transit, or discharge. 

Chemicals may be stored onboard in liquid or gas form, or they may be generated on 

demand through electrochemical processes. 

Chemicals used in ballast water treatment can generally be classified into two major 

categories: oxidizing and non-oxidizing. Oxidizing agents (e.g. chlorine, chlorine dioxide, 

bromine, hydrogen peroxide, peroxyacetic acid, ozone) are commonly used in the 

wastewater treatment sector and work by destroying cell membranes and other organic 

structures (National Research Council 1996, Faimali et al. 2006). Electrochemical 

oxidation combines electrical currents with naturally occurring reactants in seawater 

and/or air (e.g. salt, oxygen) to produce killing agents. For example, electrochemical 

oxidation can produce products such as hydroxyl radicals, ozone or sodium hypochlorite 

that are capable of damaging cell membranes. Non-oxidizing biocides, including 

Acrolein®, gluteraldehyde, and menadione (Vitamin K3), are reported to work like 

pesticides by interfering with an organism‟s neural, reproductive or metabolic processes 

(National Research Council 1996, Faimali et al. 2006).

The ultimate goal of chemicals is to maximize organism mortality while minimizing 

environmental impact. Environmental concerns surrounding chemical use in ballast 

water focus on the impacts of residuals or byproducts in treated discharge on receiving 

waters. The effective use of chemicals in ballast water treatment requires a balance 

between the amount of time required to achieve inactivation of organisms, with the time 

needed for those chemicals and residuals to degrade or be neutralized to 

environmentally acceptable levels. Both of these times vary as a function of ballast 
32

water temperature, salinity, organic content and sediment load. As a result, certain 

chemicals may be more effective than others depending on ballast volume, voyage 

length, and water quality conditions. Additional concerns about chemical use specific to 

shipboard operation include corrosion of metals, personnel and ship safety, and vessel 

design limitations that impact the availability of space onboard for both chemical storage 

and equipment for dosing. 

Physical Treatment

Physical treatment methods include a wide range of non-chemical means to kill 

organisms present in ballast water. Like chemical treatment, physical treatment may 

occur on ballast uptake, during vessel transit or during discharge. 

Rigby et al. (1999, 2004) discuss the use of waste heat from the ship‟s main engine as 

a mechanism to heat ballast water and kill unwanted organisms during vessel transit. 

However, it would be difficult to heat ballast water to a sufficient temperature to kill all 

species of bacteria due to lack of sufficient energy/heat available on a vessel (Rigby et 

al. 1999, Rigby et al. 2004). An alternative approach to heat treatment involves the use 

of microwaves (Balasubramanian et al. 2008). Currently such a treatment technology 

would be prohibitively expensive (up to $2.55/m3), but additional research and 

development may reduce costs to acceptable levels (Boldor et al. 2008). 

Ultraviolet (UV) irradiation is another physical method of sterilization that is commonly 

used in waste water treatment. UV damages genetic material and proteins, disrupting 

reproductive and physiological processes and can be highly effective against pathogens 

(Wright et al. 2006). Both low-pressure and medium-pressure UV systems have been 

used to treat ballast water on vessels. The pairing of UV light and a catalyst (e.g. 

titanium dioxide) results in an advanced oxidative process that generates hydroxyl 

radicals - an effective killing agent. 

Additional methods of physical treatment include ultrasound, cavitation and 

deoxygenation. Ultrasound (ultrasonic treatment) kills through high frequency vibration 
33

that creates microscopic bubbles that rupture cell membranes (Viitasalo et al. 2005). 

The efficacy of ultrasound varies based on the intensity of vibration and length of 

exposure. Cavitation is another physical treatment method that uses mechanical forces 

to generate and collapse microscopic bubbles that crush or implode organisms in 

ballast water. Deoxygenation involves the displacement or “stripping” of oxygen with 

another inert gas such as nitrogen or carbon dioxide. This process is primarily physical 

in nature, although the addition of carbon dioxide may trigger a chemical response and 

result in a reduction in ballast water pH (Tamburri et al. 2006). 

Biological Treatment

By far, the least common method of ballast water treatment involves the use of 

biological organisms to directly kill or produce conditions that will kill organisms present 

in ballast water. These treatment organisms are considered an “active substance” 

according to the IMO definition (IMO 2005). One example of biological treatment is the 

use of yeast to produce low-oxygen (hypoxic) conditions in ballast tanks. In this 

instance, yeast cells extract the available oxygen in the ballast water tank during cell 

replication (Bilkovski, R., pers. comm. 2008). The resultant hypoxic environment is toxic 

to the remaining organisms in the ballast tank. Vendors of biological treatment systems 

will likely need to address how systems will meet the performance standards, as the 

organisms responsible for producing the desired killing effect on NIS may trigger noncompliance if detected at sufficient levels in the discharged ballast. 

Combination Treatment

The vast majority of ballast water treatment technologies kill organisms by combining 

mechanical, chemical, physical and/or biological treatment processes, and are 

categorized as “combination treatment” in this report. In combination treatment, any 

single treatment method may not be sufficient to treat the ballast water to required 

standards, but in combination the methods produce the desired result. For example, 

while filtration is rarely sufficient to remove organisms of all size classes from ballast 

water, and UV irradiation may be insufficient to deactivate dense clusters of organisms, 

paired together they may be an effective method of ballast water treatment. The most 
34

common combined treatment methods pair mechanical removal with physical or 

chemical process(es). 

Treatment Systems 

Twenty-eight treatment technologies were reviewed in the first technology assessment 

report to the California Legislature (see Dobroski et al. 2007), and 30 treatment systems 

were reviewed in 2009 (see Dobroski et al. 2009a). For this report, Commission staff 

compiled and reviewed information on 46 shipboard ballast water treatment systems 

from developers and vendors located in 16 countries (Table V-1). 

Thirty-four of the treatment systems reviewed here utilize a combination of treatment 

methods, and 32 of those combine mechanical treatment with another treatment 

method(s). Aside from mechanical separation, the most common method used in ballast 

water treatment systems is chemical. Of the 46 systems reviewed, 28 use an active 

substance in the treatment process (Table V-1). Specifically:

13 systems use chlorine or the electrochemical generation of sodium 

hypochlorite 

7 systems use ozone 

3 use advanced oxidation or electrochemical processes that generate an array of 

oxidants including bromine, chlorine, and/or hydroxyl radicals 

1 system uses chlorine dioxide 

1 uses ferrate 

3 systems use other chemicals including a coagulant or biocides not identified at 

this time 

All of the systems that use active substances require IMO Basic and Final Approval 

prior to operating in compliance with the IMO Convention. These systems will also 

require additional scrutiny to ensure compliance with all applicable requirements of the 

EPA Vessel General Permit.
35

The next most commonly used method of ballast water treatment amongst the 48 

systems reviewed is UV irradiation. Fifteen treatment systems use UV as a means to 

kill or deactivate organisms found in ballast water. All of these systems combine UV 

treatment with filtration and/or hydrocyclonic mechanical separation methods. Four of 

these systems have an additional treatment step involving another physical or chemical 

process.

Only five systems use deoxygenation as a treatment method. Other approaches to 

ballast water treatment include a heat treatment technology and one that uses electrical 

pulses to kill organisms (Table V-1). 
36

Table V-1. Ballast Water Treatment Systems Reviewed by Commission Staff 

Manufacturer Country System 

Name

Technology 

Type Technology Description Approvals

21st Century Shipbuilding 

Co. Ltd. Korea Blue Ocean Guardian combination filtration + plasma + UV IMO Basic

Alfa Laval Sweden PureBallast combination filtration + advanced oxidation 

technology (hydroxyl radicals)

IMO Basic and Final,

Type Approval 

(Norway)

Aquaworx ATC GmbH Germany AquaTriComb combination filtration + ultrasound + UV IMO Basic

atg UV Technology United 

Kingdom combination hydrocyclone + UV

ATLAS-DANMARK Denmark ABTS combination filtration + biocide (ANOLYTE + 

CATHOLYTE)

Auramarine Ltd. Finland Crystal Ballast physical UV-C irradiation

Brillyant Marine LLC USA physical electric pulse

Coldharbour Marine United 

Kingdom physical deoxygenation

COSCO/Tsinghua 

University China Blue Ocean Shield combination hydrocyclone + filtration + UV IMO Basic

DESMI Ocean Guard A/S Denmark DESMI Ocean 

Guard BWMS combination filtration + ozone + UV (advanced oxidation process) IMO Basic

Ecochlor USA EcochlorTM

BWTS combination filtration + biocide (chlorine dioxide) IMO Basic, STEP1

EcologiQ USA/Canada BallaClean biological deoxygenation

Electrichlor USA Model EL 1-3 B chemical electrolytic generation of sodium 

hypochlorite

Environmental 

Technologies Inc. (ETI) USA BWDTS combination ozone + sonic energy

Ferrate Treatment 

Technologies LLC USA Ferrator chemical biocide (ferrate)

1

STEP Approval is an experimental use approval that applies to the combination of one vessel and one treatment system. While STEP enrollment 

includes a rigorous technical and environmental screening it is not a type approval process.
37

Table V-1 (Continued). Ballast Water Treatment Systems Reviewed by Commission Staff 

Manufacturer Country System Name Technology 

Type

Technology 

Description Approvals

Hamann Evonik 

Degussa2 Germany SEDNA combination hydrocyclone + filtration + biocide (Peraclean Ocean)

IMO Basic and 

Final, Type 

Approval (Ger.)

Hamworthy Greenship

Ltd. U.K./Netherlands SEDINOX combination hydrocyclone + electrolyticchlorination

IMO Basic and 

Final

Hi Tech Marine Australia SeaSafe-3 physical heat treatment New South Wales 

EPA

Hitachi/Mitsubishi Heavy 

Industries Japan ClearBallast combination coagulation + magnetic separation + filtration

IMO Basic and 

Final

Hyde Marine USA Hyde Guardian combination filtration + UV

WA Conditional, 

Type Approval 

(U.K.), STEP1

Hyundai Heavy 

Industries Co. Ltd. (1) Korea EcoBallast combination filtration + UV IMO Basic and Final

Hyundai Heavy 

Industries Co. Ltd. (2) Korea HiBallast combination filtration + electrochlorination + neutralizing agent IMO Basic

JFE Engineering Corp./ 

Toagosei Group Japan JFE-BWMS combination

filtration + biocides (sodium 

hypochlorite) and neutralizing 

agent (sodium sulfite)

IMO Basic and 

Final

Kwang San Co. Ltd. Korea En-Ballast combination

filtration + electrochlorination + 

neutralizing agent (sodium 

thiosulfate)

IMO Basic

MAHLE Industriefiltration 

GmbH Germany Ocean Protection System (OPS) combination filtration + UV

MARENCO USA combination filtration + UV WA General 

Approval

Maritime Solutions Inc. USA combination filtration + UV

Mexel Industries France Mexel® chemical biocide

1 STEP Approval is an experimental use approval that applies to the combination of one vessel and one treatment system. While STEP enrollment 

includes a rigorous technical and environmental screening it is not a type approval process.

2

The Hamann system was temporarily removed from the market due to toxicity concerns (effective 1/31/10).
38

Table V-1 (Continued). Ballast Water Treatment Systems Reviewed by Commission Staff 

Manufacturer Country System Name Technology 

Type Technology Description Approvals

MH Systems USA BW treatment 

system combination deoxygenation + carbonation

Mitsui Engineering Japan SP-Hybrid BWMS

Ozone combination

filtration + mechanical 

treatment + ozone + 

neutralization

IMO Basic

NEI USA Venturi Oxygen 

Stripping (VOS) combination deoxygenation + cavitation Type Approval (Liberia), STEP1

NK Co. Ltd. Korea NK-03 BlueBallast 

System chemical ozone + neutralization (thiosulfate)

IMO Basic and 

Final, Type 

Approval (Korea)

ntorreiro Spain Ballastmar combination

filtration + electrochlorination + 

neutralization (sodium 

metabisulphite)

Nutech 03 Inc. USA SCX 2000, Mark III chemical ozone

OceanSaver Norway OceanSaver

BWMS combination

filtration + cavitation + nitrogen 

supersaturation + 

electrodialysis

IMO Basic and 

Final, Type 

Approval (Nor.)

OptiMarin Norway OptiMarin Ballast 

System combination filtration + UV Type Approval (Norway)

Panasia Co. Ltd Korea GloEn-Patrol combination filtration + UV

IMO Basic and 

Final, Type 

Approval (Korea)

Pinnacle Ozone 

Solutions USA

Aquatic 

enhancement 

system

combination filtration + ozone + UV

Qingdao Headway Tech 

Co. Ltd. China OceanGuard BWMS combination filtration + electrocatalysis + ultrasound IMO Basic

Resource Ballast 

Technologies South Africa Unitor BWTS combination cavitation + ozone + sodium hypochlorite + filtration

IMO Basic and 

Final

RWO Marine Water 

Technology Germany CleanBallast combination filtration + advanced electrolysis 

IMO Basic and 

Final

1 STEP Approval is an experimental use approval that applies to the combination of one vessel and one treatment system. While STEP enrollment 

includes a rigorous technical and environmental screening it is not a type approval process.
39

Table V-1 (Continued). Ballast Water Treatment Systems Reviewed by Commission Staff 

Manufacturer Country System Name Technology 

Type Technology Description Approvals

Severn Trent DeNora USA BalPure chemical

filtration + electrolytic 

generation of sodium 

hypochlorite + neutralizing 

agent (sodium bisulfite)

WA Conditional, 

IMO Basic, STEP1

Siemens UK/USA/Ger. SiCure combination filtration + electrochlorination IMO Basic

Sunrui CFCC China BalClor combination

filtration + electrochlorination + 

neutralizing agent (sodium 

thiosulfate)

IMO Basic 

Techcross Inc. Korea Electro-Cleen chemical

electrochemical oxidation + 

neutralizing agent (sodium 

thiosulfate)

IMO Basic and 

Final, Type 

Approval (Korea)

Wartsila Finland combination filtration + UV

1 STEP Approval is an experimental use approval that applies to the combination of one vessel and one treatment system. While STEP enrollment 

includes a rigorous technical and environmental screening it is not a type approval process.
40

VI. ASSESSMENT OF TREATMENT SYSTEMS

The Coastal Ecosystems Protection Act required the adoption of regulations to 

implement performance standards for the discharge of ballast water. Over 80% of 

voyages to California ports report that they do not discharge ballast into California 

waters (Falkner et al. 2007). These vessels can comply with the performance standards 

simply by retaining all ballast onboard while in California waters. Vessels that do 

discharge but use nontraditional sources for ballast water (such as freshwater from a 

municipal source) will likely meet the discharge standards without needing to use ballast 

water treatment systems. Alternatively, vessels may discharge to barge- or land-based 

reception and treatment facilities. Vessels that utilize riverine, estuarine, coastal or 

ocean water as ballast, however, will require ballast treatment prior to discharge. For 

these vessels, this assessment of treatment system efficacy, availability, and 

environmental impacts (as required by PRC Section 71205.3(b)) is necessary to 

understand if systems will be available prior to the implementation of performance 

standards for newly built vessels with a ballast water capacity greater than 5000 MT in 

2012. 

Efficacy 

Treatment system performance (i.e. efficacy) can be defined as the extent to which a 

system removes or kills organisms in ballast water. For this report, Commission staff‟s 

specific focus is on ability of available treatment systems to meet or exceed California‟s 

performance standards for the discharge of ballast water (see Table III-1 for 

performance standards) for newly built vessels with a ballast water capacity greater 

than 5000 MT. 

Previous reviews of treatment system efficacy (Dobroski et al. 2007, 2009a) faced 

several challenges. First and foremost, for many systems the lack of available data 

precluded any form of efficacy assessment. For systems with data available, 

inconsistent testing methodologies among systems, and occasionally between tests of a 

single system, made comparison of data nearly impossible. Results varied in scale 
41

(bench-top (i.e. laboratory) vs. pilot vs. full-scale) and location (dockside vs. shipboard), 

and until recently, were often presented in metrics incomparable with California‟s 

standards (e.g. as percent reduction instead of concentration of organisms). 

An additional challenge when evaluating the available data has been the wide range of 

data sources. For some systems, data have been provided by vendors in brochures, on 

the web, or in vendor-authored reports, that have not been evaluated by independent 

third-parties. Recently, staff has seen a surge in the availability of performance 

verification data gathered by independent, scientific testing organizations. These 

independent reports generally provide the most robust, comprehensive review of 

system performance and environmental acceptability. However, variability remains 

among scientific testing organizations in terms of the types of analytical and statistical 

tests in use and methods of data presentation. Commission staff are working with 

vendors and testing organizations to encourage the standardization of data analysis and 

presentation.

For this assessment, Commission staff are providing the California Legislature and 

interested stakeholders with all available sources of information on treatment 

technology development and operation, including both vendor-supplied and third-party 

data from all testing scales and locations (lab-based, land-based and shipboard). In all 

instances, citations are provided for the original source of the data (Table VI-1 and

Appendix A). This information is presented so that interested parties can review and 

evaluate all of the available data and data sources in order to make an informed 

decision about whether a treatment system may or may not be sufficient for their needs. 

Commission staff were able to collect efficacy data on 27 of the 46 treatment systems 

reviewed in this report (Tables VI-1 and VI-3, Appendix A). As a reference for 

stakeholders, laboratory data on system performance is summarized in Appendix A. 

With the exception of the evaluation of system performance for inactivating Vibrio 

cholerae, laboratory data is not used for evaluation purposes in this report because of 

the large difference in scale between the laboratory and land-based and shipboard 
42

investigations. Six systems have only laboratory data available for review. The 

remaining twenty-one systems have been assessed for potential compliance with 

California‟s standards using large scale land-based and/or shipboard data.

No available dataset on treatment system performance can represent the efficacy of 

that system on all vessel types or under all possible voyage conditions. Many systems 

have not yet undergone full-scale shipboard testing (see Appendix A for breakdown of

data by type of testing facility), the number of tests performed varies from system to 

system, and those that have been tested on vessels may have only been assessed on 

one ship or one type of ship under limited testing scenarios. Water condition variables, 

such as salinity level, turbidity, and temperature can affect the ability of a system to kill 

organisms. Some systems require minimum ballast water “holding times” for optimal 

performance, while others appear to perform poorly on extended voyages. The density 

or diversity (types) of organisms found at the ballast uptake location can also affect 

system performance. In essence, a system that fails to meet California‟s standards 

under one scenario (e.g. short voyage duration) may meet the standards perfectly well 

under a different one (e.g. longer voyage duration). The reverse situation may also be 

true.

Because of the limitations of testing data and the variable conditions present in the “real 

world,” this report examines treatment system performance data to determine whether 

or not systems have demonstrated the potential to comply with California‟s 

performance standards. Commission staff do not have the practical ability to test and 

approve treatment systems for operation in California waters. Positive assessment for 

the purpose of this report does not guarantee system compliance when operated in 

California waters, nor does the report suggest or imply system approval. Vessel owners 

and operators should consult extensively with treatment system vendors to ensure that 

thorough system verification work has been conducted, and that the system is 

appropriate for the type and behavior of the vessel in question under normal ballasting 

conditions. Ultimately vessel owners/operators are responsible for complying with 

California‟s performance standards for the discharge of ballast water. 
43

Staff considered the best available data and methods for assessing organism 

concentration and viability for each of the organism size classes in California‟s 

standards (see Table III-1). The latest data have generally been presented according to 

organism size class, however, some older data, not updated since previous reports, 

have been presented by organism type (i.e. zooplankton, phytoplankton). In an effort to 

standardize results among reports, staff evaluated data on zooplankton abundance as 

representative of the largest size class of organisms (greater than 50 μm in size), and 

phytoplankton abundance was evaluated on par with organisms in the 10 – 50 μm size 

class. While these substitutions are not accurate in all instances (e.g. zooplankton 

species may be less than 50 μm in size), they were used solely for the purpose of this 

report and are not applicable to vessel compliance verifications. 

Recent discussions over the implementation of the IMO and proposed federal standards 

have focused on whether or not methods and/or protocols exist to assess compliance 

with more stringent standards – such as California‟s standards. Specific concerns have 

focused on the volume of water necessary to assess compliance with the standards for 

organisms greater than 50 μm in size. California‟s standards for organisms greater 50 

μm is defined as “nondetectable,” and does not define a specific volumetric 

concentration. Many outside parties have reasoned that the volumes of ballast water 

required to determine compliance with this standard are not verifiable and too large to 

be practical for shipboard compliance verification. However, it is important to note that, 

unlike the IMO standard for the same size class, the standard for California is unitless. 

Whereas IMO defines its standard for organisms greater than 50 microns as less than 

10 per cubic meter, California‟s standard does not set forth a volume requirement. 

Therefore compliance and performance testing for this size class could occur with any

volume of water, especially volumes that are realistic under shipboard operation. For 

the other organism classes, volumes specified in California‟s standards are not at issue. 

Commission staff are currently developing protocols to assess vessel compliance with 

California‟s standards (see Section IX Looking Forward). These protocols will address 

ballast water sample volumes and take into account both scientific rigor and practicality 

for shipboard inspection.
44

One challenge associated with the assessment of the bacteria and virus standards is 

that methods exist to quantify bacteria and viruses (or virus-like particles) in a sample of 

ballast water, however, no techniques are available to assess the viability of all bacteria 

and viruses, as is required by the California performance standards (see Dobroski et al. 

2009a, Appendix A1 for discussions on this topic). To assess compliance with the 

bacterial standard, Commission staff used a representative group of organisms 

(culturable, aerobic, heterotrophic bacteria – hereafter culturable heterotrophic bacteria) 

to quantify potential compliance with the bacterial standard. Culturable heterotrophic 

bacteria were selected as a representative for the total bacterial concentration because, 

unlike total bacteria, there are reliable, widely-accepted standard methods to both 

enumerate and assess viability of these organisms. 

Culturable heterotrophic bacteria are a well-studied group of bacteria, and research is 

being conducted to examine the relationship between their populations and the larger 

pool of bacterial species (Dobbs, F., pers. comm. 2008). Staff examined the ability of 

treatment system to reduce culturable heterotrophic bacteria to levels within the 

California standard of 1000 bacteria (in this case expressed as colony-forming units 

(CFU)) per 100 ml of ballast water. At an advisory panel meeting in 2008, panel 

members debated whether the culturable heterotrophic bacteria – a subset of all 

bacteria species - should be held to a different standard than that written in the law (see 

Dobroski et al. 2009a, Appendix C for discussion). Because culturable heterotrophic 

bacteria represent only a portion of the total population of bacteria (Giovannoni et al. 

2007), it was argued that they should be held to a standard in proportion to their relative 

abundance in nature (for example if heterotrophic bacteria represent 10% of the total 

population of bacteria, the standard for assessment using this proxy group might be 

more appropriate if set at 10% of 1000/100 ml or 100 CFU/100 ml). However, this 

approach to setting a standard requires the selection of a uniform method to culture and 

quantify bacteria in order to assess the percent of culturable bacteria relative to the total 

population of all bacteria. Based on techniques available in 1990, culturable bacteria 

represented 1/10,000th of the total bacterial community present in seawater (Giovannoni 

et al. 2007). Newer techniques have allowed scientist to culture anywhere from two to 
45

sixty percent of bacterial cells in a given water body (Giovannoni et al. 2007). Until such 

time that a scientific authority clearly establishes the percent composition of culturable 

heterotrophic bacteria in marine or freshwater, Commission staff will continue to analyze 

all data using best available techniques and the numerical standard found in the law. 

Analysis of viruses remains challenging at this time. While several representative 

organisms exists for viruses, their relationship to the greater population of all viral 

species is more tenuous than for bacteria (confer Culley and Suttle 2007). For the 

purposes of this analysis, Commission staff believes that no widely accepted technique 

is available to quantify or reliably estimate virus concentrations, and thus systems were 

not evaluated for compliance with the viral standard. Staff will continue to monitor the 

development of new assessment techniques for all organism size classes and 

incorporate them into future technology assessment reports. 

Taking into account the limitations of the available data, staff determined the potential 

for treatment systems to comply with California‟s performance standards using two 

approaches. The first assessment approach, presented in Table VI-1, provides a broad 

review of the data on system performance from both land-based and shipboard testing. 

The second assessment approach, presented in Table VI-3, takes a closer look at the 

performance, specifically the success rate of those systems at demonstrating potential 

to meet California‟s standards.

In the first broad-scale assessment (presented in Table VI-1), staff accepted one test 

(averaged across replicates) with data less than the standard as indicative of a system‟s 

potential to comply with that standard. While this criterion is optimistic, it does highlight 

the rapid and encouraging development of treatment technologies. This approach is 

slightly more stringent than that taken in previous reports (Dobroski et al. 2007, 2009a) 

when systems were only required to meet the standard in one test replicate in order to 

demonstrate potential compliance. Because of this change in approach, and because 

laboratory data is no longer included in this analysis, readers should be cautioned 
46

against comparing the results in Table VI-1 in this report with table(s) in previous 

reports. 

Systems with at least one test (averaged across replicates) at either land-based or 

shipboard scale in compliance with the performance standard are scored with a “Y” for 

having demonstrated the potential to comply with California‟s standards (Table VI-1). 

Efficacy data with no tests demonstrating potential compliance with the standards are 

scored with a “N.” Systems that presented data for a given size class in metrics not 

comparable to the standards (e.g. as percent reduction instead of organism 

concentration) are classified as “Unknown.” Cells with hashing indicate lack of available 

data. The source(s) of the data for each system can be found in the Literature Cited 

section. See Appendix A for all laboratory data and for specifics about land-based and 

shipboard testing including number of tests and replicates for each system. 
47

Table VI-1. Summary of systems with available results for assessment of efficacy

Systems with at least one land-based or shipboard test (averaged across replicates) in compliance with the performance standards are denoted by a “Y.”Noncompliance is denoted by a “N,” and those systems with data in metrics not directly comparable to the performance standards were designated as “Unknown.” A 

cell with hashing indicates that no data was available. Information about systems having only lab-scale data is provided in Appendix A.

21st Century Shipbuilding Lab data only

Alfa Laval Y Y Y Y Y Y

4 137,138,141

Aquaworx ATC GmbH

atg UV Technology

ATLAS-DANMARK

Auramarine Ltd. Y N N Y

4 Y Y4 4,165

Brillyant Marine LLC

Coldharbour Marine

COSCO/Tsinghua Univ.

DESMI Ocean Guard A/S

Ecochlor Y Y Y Y Y Y

6 76,133,148

EcologiQ

Electrichlor

ETI N N 73,74,75

Ferrate Treatment Tech. Lab data only

Hamann Evonik Degussa5Y Y Y Y

4 Y4 Y4 132,166

Hamworthy Greenship Y Y Y Y

4 Y4 Y6 48,167

Hi Tech Marine Y Y 32,51

Hitachi/Mitsubishi

Hyde Marine Y Y Y Y

4 Y4 Y4 134,192

Hyundai Heavy Ind. (1) Lab data only

Hyundai Heavy Ind. (2) Lab data only

JFE Eng.Corp./TG Corp.

Kwang San Co. Ltd. Lab data only

1 Bacteria were assessed through examination of aerobic culturable heterotrophic bacteria (expressed as colony-forming units). 

2 No methods exist to quantify and assess the viability of viruses at this time.

3 Numbered references can be found in Literature Cited section.

4 Concentration at intake was zero, non-detectable or unknown.

5

 Hamann system has been temporarily removed from the market due to toxicity concerns (effective 1/31/10).

6 Vibrio testing conducted on live cultures in a lab.

References3

N Unknow n

Manufacturer E. coli Enterococci V. cholerae < 10 μm 

(bacteria)

> 50 μm 10 - 50 μm 1,2
48

Table VI-1 (contined). Summary of systems with available results for assessment of efficacy 

Systems with at least one land-based or shipboard test (averaged across replicates) in compliance with the performance standards are denoted by a “Y.”Noncompliance is denoted by a “N,” and those systems with data in metrics not directly comparable to the performance standards were designated as “Unknown.” A 

cell with hashing indicates that no data was available. Information about systems having only lab-scale data is provided in Appendix A.

MAHLE

MARENCO Y N Y 64,65,189

Maritime Solutions Inc. N N Y Y Y Y

4 79

Mexel Industries

MH Systems Lab data only

Mitsui Engineering N Unknow n Unknow n 56,58,59

NEI Y Unknow n N Y

4 Y4 170,171,172

NK Co. Ltd.

ntorreiro

Nutech 03 Inc. Y N Y Y

4 Y4 Y4 50,195

OceanSaver Y Y Y Y

4 Y4 Y4 139,176

OptiMarin Y Y Y Y

4 Y4 Y4 136,140

Panasia Co. Ltd.

Pinnacle Ozone Solutions

Qingdao Headway Tech. Y Y Y Y

4 Y4 Y4 142,147

Resource Ballast Tech. Y N Y Y Y

4 2,3

RWO Marine Water Tech. Y Y Y Y Y

4 30,31

Severn Trent DeNora5Y Y Y 49

Siemens N N N Y Y Y

4 78

Sunrui CFCC

Techcross Inc. Y Y Y Y

4 Y4 Y4 62,63

Wartsila

1 Bacteria were assessed through examination of aerobic culturable heterotrophic bacteria (expressed as colony-forming units). 

2 No methods exist to quantify and assess the viability of viruses at this time.

3 Numbered references can be found in Literature Cited section

4 Concentration at intake was zero, non-detectable or unknown.

5 System has added a filter since this data was collected. 

Unknow n

V. cholerae References Manufacturer 3 Enterococci

Unknow n Unknow n Unknow n

> 50 μm 10 - 50 μm E. coli < 10 μm 

(bacteria)1,2
49

Twenty-one treatment systems were reviewed for potential compliance with California‟s 

performance standards (Table VI-1). One system, produced by Hamann Evonick 

Degussa, was pulled from the market in January of 2010 due to toxicity concerns (see 

de Lafontaine et al. 2008, 2009 for toxicity data). The system‟s performance data and 

references are included in Tables VI-1, VI-3, VI-5 and VI-6 of this report for readers to 

examine. However, because it is currently not a practical option for installation on 

vessels, it is excluded from narratives and other tables that summarize the potential

(efficacy) and availability of systems to meet California‟s standards.

In the largest organism size class (organisms greater than 50 μm in size), land-based or 

shipboard data was available for 20 systems, and 15 demonstrated the potential, in at

least one test (averaged across replicates), to meet the required standard of no 

detectable living organisms in discharged ballast water (Table VI-2, Appendix A1). In 

the 10 – 50 μm size class, 21 systems were reviewed and 10 systems had at least one 

test that indicated compliance with the standard of less than 0.01 living organisms per 

ml (Appendix A2).

Table VI-2. Summary of potential treatment system performance (land-based and/or 

shipboard) with respect to California performance standards 

Organisms 

Greater 

than 50

Organisms 

10 – 50

Organisms 

less than 

10 

(bacteria)1

Escherichia 

coli

Intestinal 

enterococci

Vibrio 

cholerae

Total # 

Systems with 

Data 

Available 2

20 21 19 18 17 17

Number 

Systems with 

Potential to 

Meet 

Standard3

15 10 13 16 14 15

1

Bacteria examined using culturable heterotrophic bacteria.

2 Of out of the 46 total systems assessed in this report, only 27 had testing results available for review, 

and 21 of those provided results of land-based and/or shipboard testing. Not all 21 covered testing under 

each of the organism size classes. The total number of systems with results in a given size class is 

indicated in this category.

3 This category reflects the number of systems with at least one test (averaged across replicates)

demonstrating the potential to comply with the California performance standard (see Table III-1 for 

standards). 
50

The results of analyses for human health indicator species (Escherichia coli, intestinal 

enterococci and Vibrio cholerae) and organisms less than 10 μm (bacteria) are 

encouraging (see Table VI-2, Appendices A3-A6). Most treatment systems are 

succeeding in killing human health indicator species. Eighteen systems provided results 

of E. coli concentration in treated ballast water (Appendix A3), and 16 demonstrated 

potential compliance. Seventeen systems tested for the presence of intestinal 

enterococci, and fourteen systems demonstrated potential compliance. (Appendix A4). 

The low, and sometimes non-detectable, natural concentration of Vibrio cholerae in 

coastal waters makes it difficult to adequately assess system performance at eliminating 

this species. In land-based and shipboard data examined for this evaluation, the 

ambient pre-treatment concentrations of Vibrio cholerae were frequently so low they 

could not be detected, or were not reported (see footnote 4 in Table VI-1). In such 

cases, post-treatment data did not necessarily demonstrate a system‟s ability or inability

to kill the microbe. Those systems that conducted laboratory analysis for Vibrio cholerae

examined the efficacy of systems at treating live cultures (spiked concentrations) of 

Vibrio that would otherwise not be naturally present in waters used for land-based or 

shipboard testing. Such laboratory data provides as much, if not more insight into 

systems‟ ability to kill Vibrio as does data from land-based or shipboard tests. Thus, the 

evaluation of Vibrio data here included results from two laboratory studies (as noted in 

Table VI-1 and Appendix A5). Seventeen systems examined treated ballast water for 

toxicogenic Vibrio cholerae, and fifteen systems demonstrated potential compliance with 

the California performance standard (Appendix A5). 

Lastly, available data was analyzed for compliance with the bacterial standard of 1000 

bacteria or CFU per 100 ml (Table VI-1, Appendix A6). Nineteen systems analyzed 

system performance at treating culturable heterotrophic bacteria, and 13 demonstrated 

potential compliance with the standard. As described earlier in this section, methods are 

not available to assess compliance with the viral standard at this time. 
51

Based on this first assessment approach, eight ballast water treatment systems have 

demonstrated the potential to comply with California‟s performance standards. These 

systems are Alfa Laval, Ecochlor, Hamworthy Greenship, Hyde Marine, OceanSaver, 

OptiMarin, Quingdao Headway Tech., and Techcross Inc. These eight systems have at 

least one test (averaged across replicates) that can meet each of California‟s 

performance standards, excluding the viral standard. Though data for the Hamann 

Evonik Degussa system also demonstrate the potential to meet California‟s 

performance standards using this first assessment approach, the system was pulled 

from the market in early 2010 and is currently not a viable option for use on ships. 

Passage of a single land-based or shipboard test may not be sufficient as a sole

indicator for which systems will or will not comply with California‟s standards when 

operated under the variable conditions present on vessels. This analysis does, 

however, provide a good summary of the development status of treatment systems, and 

this information should be used by stakeholders to further investigate treatment systems 

that may comply with California‟s performance standards. A positive assessment for 

the purpose of this report, however, does not constitute Commission approval or 

endorsement, nor does it relieve the vessel owner/operator of the responsibility for 

complying with California‟s performance standards for the discharge of ballast water. 

Potential treatment system customers should consult extensively with vendors to ensure 

that thorough system verification work has been conducted, and that the system is 

appropriate for the type of vessel of interest, under normal ballasting conditions.

A second, more rigorous assessment approach takes a closer look at the performance 

rates of those systems with available land-based and shipboard data (Table VI-3). The 

assessment presents the available data in fraction form, with the number of tests that 

demonstrated potential compliance with California‟s standards in the numerator, and the 

total number of tests in the denominator. This more detailed presentation provides the 

opportunity to discriminate between systems that have demonstrated higher rates of 

potential compliance versus those that may need to undergo additional testing or 

development to consistently meet California‟s performance standards.
52

Table VI-3. Detailed analysis of system performance at land-based (Land) and shipboard (Ship) testing scales. Data presented as number of tests 

that have demonstrated potential to meet standard/total number tests conducted. References for each system are listed in Table VI-1.

>50 10 - 50 <10 (bacteria) E. coli Enterococci Vibrio

Land Ship Land Ship Land Ship Land Ship Land Ship Land Ship

Alfa Laval 8/10 1/4 3/10 1/4 0/8 2/2 10/10 4*/4 10/10 4*/4 10*/10 4*/4

Auramarine 4/6 -- 0/7 -- 0/2 -- 1*/1 -- 1/1 -- 1*/1

Ecochlor 8/15 1/119/11 1/118/11 1/1110/10 1/1111/11 -- (1/1 lab) Unk

ETI 0/3 -- 0/3 -- -- -- -- -- -- --

Hamann216/19 4/5 17/18 0/5 1/13 3/4 12/12 4*/4 12/12 4*/4 1*/1 --

Hamworthy 5/5 -- 3/5 -- 2/5 -- 5*/5 -- 5*/5 -- (2/3 lab)

Hi Tech -- 0/2 -- Unk 5/6 -- 6/6 -- -- -- -- --

Hyde 1/10 3/3 0/10 1/3 5/10 3/3 10*/10 3*/3 10*/10 3*/3 -- 3*/3

MARENCO 3/4 -- 0/1 -- 2/3 -- -- -- -- -- -- --

MSI 0/5 -- 0/5 -- 3/5 -- 5/5 -- 5/5 -- 5*/5 --

Mitsui 0/4 0/1 Unk Unk Unk Unk Unk -- Unk -- Unk --

NEI 1/5 1/2 0/1 Unk 0/2 0/2 0/1 2*/2 0/1 Unk -- 2*/2

Nutech 0/3 2/3 0/2 0/3 3/3 2/2 -- 3*/3 -- 3*/3 -- 3*/3

OceanSaver 2/14 1/3 5/14 0/2,Unk 5/5 -- 14*/14 3*/3 9*/14 3*/3 14*/14 3*/3

OptiMarin 8/12 0/8 6/12 2/8 2/12 -- 12*/12 8*/8 12*/12 8*/8 12*/12 8*/8

Qingdao 4/13 3/3 8/13 3/3 9/13 3/3 13*/13 3*/3 13*/13 3*/3 13*/13 3*/3

RBT 3/3 0/2 0/3 0/2 -- -- 3/3 2*/2 -- 2/2 3*/3 2*/2

RWO 2/2 -- 1/2 -- -- -- 2/2 -- 2/2 -- 2/2 --

Severn Trent 3/5

1

-- 2/5

1

-- 4/4

1

-- -- -- -- -- -- --

Siemens 0/3 -- 0/3 -- 0/3 -- 3/3 -- 3/3 -- 3*/3 --

Techcross 8/11 3/3 9/11 3/3 4/4 Unk 10*/10 3*/3 11*/11 2*/2 11*/11 3*/3

* Concentration at intake was zero, non-detectable or unknown.

1

Vendor has added a filter since system testing was conducted.

2 The Hamann system was removed from the market (effective 1/31/10).
53

The data presented in Table VI-3 are highly variable. Some systems reliably meet the 

standards during land-based testing, but fail to do so during shipboard testing. The 

reverse is also true. Others have demonstrated the potential to meet the standards in 

100% of tests, but have only undergone one or two tests. As described earlier, much of 

the performance data for human health indicator species was collected when the initial 

pre-treatment concentration of microbes, particularly Vibrio cholerae, was zero, nondetectable or unknown. The IMO G8 Guidelines do not require testing organizations to 

“spike” testing water with microbes due to safety concerns. Testing can proceed in the 

absence of natural populations of these species. However, the conclusions drawn from 

these tests may be of questionable value because they do not demonstrate how 

effectively a system may eliminate such microbes under detectable concentration 

conditions. Conversely, data from laboratory tests that spike water with microbes 

before treatment provide valuable insight to the efficacy of systems to kill bacteria, E. 

coli, intestinal enterococci, and/or Vibrio cholerae. 

In order to determine if systems are available to meet California standards on a 

consistent basis, Commission staff reviewed the data (Table VI-3) for systems that have 

conducted three or more tests per standard (land-based or shipboard) and have 

demonstrated the potential to meet each of the CA standards at least 50% of the time.

Two treatment systems – Qingdao Headway Tech. and Techcross - meet these more 

rigorous criteria. Qingdao demonstrated the potential to meet California‟s standards in 

all shipboard tests (see Table VI-3), and Techcross demonstrated the potential to meet 

California‟s standards more than 70% of the time for all land-based tests. One additional 

system – Ecochlor – met the standard over 50% of the time for all organism classes

during land-based testing, but was only tested once for Vibrio cholerae in the laboratory. 

Though this does not meet the more rigorous criteria of three tests or more, the 

laboratory test did involve evaluating system efficacy under spiked concentrations of 

Vibrio above levels present in the pre-treatment tests of other systems. As noted 

earlier, such laboratory testing provides as much, if not more insight into a system‟s 

ability to kill Vibrio as does data from land-based or shipboard tests. Thus, the 
54

Commission believes Ecochlor system also shows potential to meet California‟s 

standards under this more rigorous assessment. 

 

Overall, this review of system performance indicates that progress is being made in the 

development of treatment systems to meet California‟s performance standards for the 

discharge of ballast water. Eight systems have demonstrated the potential (in at least 

one test) to meet California‟s performance standards (Table VI-1). A more stringent 

review indicates that two systems have demonstrated the potential to meet California‟s 

standards greater than 70% of the time over multiple tests. A third system meets all but 

the Vibrio standard greater than 50% of the time over multiple tests. However, that

system did met the Vibrio standard in a single laboratory test using spiked 

concentrations of the bacteria above the pre-treatment levels present in land-based or 

shipboard tests of nearly all other systems. Thus, this third system also shows potential 

to meet California‟s standard using the more stringent assessment approach. No 

system has yet met California‟s standards 100% of the time for both land-based and 

shipboard testing. As noted repeatedly throughout this document, evaluations in this 

report do not constitute endorsement, approval, or guarantee that a ballast water 

treatment system will meet California‟s standards for all vessels and all scenarios.

Commission staff have consulted with the vendors of systems that have demonstrated 

the potential to comply with California‟s standards, and at this time, two vendors

(Ecochlor and Qingdao Headway Tech.), are willing to self-certify that their systems will 

meet California‟s standards. California does not require this certification for operation in 

California waters, but this certification may help assuage some concerns by vessel 

owners/operators about the availability of systems for use. Ultimately, however, vessel 

owners/operators must closely scrutinize the available data to ensure that systems will 

meet California‟s standards on a regular basis given the configuration of the vessel, 

piping/water flow requirements, normal transit routes and water quality conditions.
55

Availability 

Many factors play into system availability including industry demand (i.e. how many 

ships need to buy systems) and commercial availability (i.e. are there enough systems 

being sold to meet industry demand). Of the eight systems that demonstrated the 

potential to meet California‟s standards, all eight are commercially available at this time 

(see Lloyd‟s Register 2010). As noted in the efficacy section, the Hamann Evonik 

Degussa system was pulled from the market in 2010 due to toxicity concerns. It is more 

difficult to gauge how many vessels with a ballast water capacity greater than 5000 

metric tons will be built that will need to purchase systems for the implementation of the 

standards in 2012. As shown in Figure VI-1, the majority the vessels calling on 

California ports have a total ballast water capacity of greater than 5000 MT.

Figure VI-1. Number of unique vessels that arrived to California ports between January, 

2000 and March, 2010 as a function of ballast water capacity (MT). 

Between January 2000 and March 2010, 6353 unique vessels with a ballast water 

capacity greater than 5000 MT arrived at California ports (Figure VI-1). Presuming a 

319

655

6353

0

1000

2000

3000

4000

5000

6000

7000

<1500 1500 - 5000 >5000 Number of Unique Vessel Arrivals to CA Ports (January 2000 - March 2010)

Ballast Water Capacity (MT)
56

20-year vessel replacement cycle (Reynolds, K., pers. comm. 2010), approximately 5% 

(=318) of these 6353 vessels may be replaced by new vessels and be required to meet 

the performance standards in 2012. As only 20% of vessels, on average, discharge 

ballast in California waters (Falkner et al. 2007), an even smaller number of vessels (~ 

64) will likely require treatment system usage. Distributed among the eight treatment 

systems that have demonstrated the potential to comply with California‟s performance 

standards and are commercially available, that equates to about eight systems per 

treatment vendor. That number would certainly fall within treatment system 

manufacturing capabilities. For example, Alfa Laval sold over thirty treatment systems in 

the last year (Marinelink 2010). However, caution should be made in interpreting these 

statistics, as the number of vessels in production and visiting California waters may vary 

based on economic conditions, and not all treatment systems are equally appropriate 

for all vessels. 

System support is as important as commercial availability. Following installation, system 

developers will need to have personnel and infrastructure in place to troubleshoot and 

fix problems that arise during system operation. Maritime trade is a global industry, and 

vessel operators will need to have global support for onboard machinery. The Lloyd‟s 

Register (2010) report does not address the issue of after-purchase support of systems. 

The initial influx of systems into the marketplace will no doubt challenge developers to 

provide adequate service. Larger companies entrenched in the maritime logistics or 

equipment industries may already be prepared to respond to technological challenges 

and emergencies as they arise, but smaller ballast water treatment vendors may face 

an initial period to ramp-up service and access to replacement parts. Vendors claim that 

service will be available worldwide. Only time will tell, however, how well existing 

support networks can deal with this influx of new machinery, and if system support 

services will be adequate as California‟s performance standards are implemented for 

vessels with a ballast water capacity greater than 5000 MT in 2012. 

While commercial availability and industry demand are two important components of 

this assessment of availability, the specific purpose of this report is to assess the 
57

availability of ballast water treatment systems for newly built vessels with a ballast water 

capacity greater than 5000 metric tons. The 2009 technology assessment report (see 

Dobroski et al. 2009a) did not specifically address the capacity of systems to treat large 

volumes of water – as will be necessary for this upcoming largest size class of vessels. 

Systems must be able to treat all ballast on a vessel prior to discharge. For systems that 

treat on uptake and/or discharge - which includes all of the systems that have 

demonstrated the potential to meet California‟s standards (Table VI-4) – the total 

volumetric capacity of the vessel is not the determining factor. Instead, the treatment 

system must be able to keep pace with the flow rate of the vessel‟s ballast water 

pumps. Commission staff analyzed data on the number of ballast water pumps and the 

maximum pump rates for the fleet of vessels that call on California ports. It is difficult to 

pinpoint an average system treatment rate necessary for these vessels because, 

depending on a vessel‟s piping configuration, a vessel may need one system per pump 

or one system to treat water coming in or out from all pumps. Figures VI-2 and VI-3 

illustrate the range of ballast water pump rates on vessels with a ballast water capacity 

of greater than 5000 MT that operate in California waters. The figures include both 

vessels that have discharged and have not discharged ballast in California waters, 

because all vessels have the potential to discharge ballast at some point either due to 

cargo operations or safety concerns. Figure VI-2 shows the maximum single pump rate 

per vessel, and Figure VI-3 shows the maximum combined pump rate per vessel.
58

Table VI-4. System Capacity and Timing of Treatment for Systems that Have 

Demonstrated Potential to Meet California‟s Performance Standards

System Manufacturer Timing of Treatment Maximum System Capacity

Alfa Laval Uptake and Discharge 2500 m3/h

Ecochlor** Uptake Unlimited (>13000 m3/h)

Hamworthy Greenship Uptake 1000 m3/h per pump

Hyde Marine Uptake and Discharge 6000 m

3

/h

OceanSaver Uptake Unlimited (>6000 m3/h)

OptiMarin Uptake and Discharge 3000 m3/h

Qingdao Headway 

Tech.**

Uptake and Discharge 4500 m3/h

Techcross** Uptake and Discharge Unlimited (>5000 m3/h)

**Demonstrated potential to meet California‟s standards under more rigorous evaluation 

criteria: Showed potential more than 50% of the time in 3 or more tests.

Figure VI-2. Histogram of number of vessels with a total ballast water capacity greater 

than 5000 MT that have visited California ports and their maximum ballast water pump 

rate for any single pump (m3/h).

0

200

400

600

800

1000

1200

1400

1600

1800

500 1000 1500 2000 2500 3000 3500 4000 4500 5000 >5500 Number of Vessels (Ballast Water Capacity >5000 MT)

Maximum Ballast Water Pump Rate for Any Single Pump (m3/h)
59

Figure VI-3. Histogram of number of vessels with a total ballast water capacity greater 

than 5000 MT that have visited California ports and their maximum combined ballast 

water pump rates (m3/h).

Taking into account both single and combined pump rates, the majority of vessels 

operating in California waters will need treatment systems that operate at rates between 

250 and 3000 m

3

/h. A closer look at vessel pump rates reveals that treatment systems 

with a maximum rate of 2000 m

3

/h will accommodate over 80% of those vessels with a 

ballast water capacity of greater than 5000 MT that operate in California waters. Based 

on vendor supplied data (Table VI-4), seven of the treatment systems that have 

demonstrated the potential to meet California‟s performance standards are 

commercially available and are able to treat ballast water at a rate of 2000 m

3

/h. All 

three of the systems that show potential for meeting the standards under the more 

rigorous consistency criteria can accommodate much higher pump rates of 4500 m3/h 

or more. Many systems are modular, and vendors note that systems can be combined 

to accommodate a wide variety of flow rates. Therefore vessel owners and operators 

0

200

400

600

800

1000

1200

1400

500 1000 1500 2000 2500 3000 3500 4000 4500 5000 5500 6000 >6500 Number of Vessels (Ballast Water Capacity >5000 MT)

Maximum Combined Ballast Water Pump Rate (m3/h)
60

should consult with treatment vendors to determine if systems are available to treat the 

appropriate flow rates given the piping and tank configurations of each vessel. 

For systems that do not treat on uptake and/or discharge, total ballast water capacity, 

and not ballast pump flow rate, is the determining factor for system size. Of the 46

systems reviewed in this report, only six treat ballast in-tank during the voyage (see 

Lloyd‟s Register (2010) for additional information on timing of treatment), and none of 

these systems have demonstrated the potential to meet California standards. At this 

time there is insufficient information available to evaluate whether or not these systems 

will be able to accommodate the range of ballast water capacities of vessels operating 

in California waters. As these systems undergo additional testing, Commission staff will 

gather information in order to assess the ability of these systems to treat the largest size 

class of vessels operating in California waters.

Environmental Regulation and Impact Assessment 

An effective ballast water treatment system must consistently comply with both 

performance standards for the discharge of ballast water and applicable environmental 

safety and water quality laws, regulations and permits. The discharge of treated ballast 

should not impair water quality so it impacts the beneficial uses of the State‟s receiving 

waters (e.g. recreation, fisheries, fish/wildlife habitat). The IMO, federal government and 

individual states have developed specific limits for discharge constituents and/or whole 

effluent toxicity evaluation procedures in order to protect the beneficial uses of 

waterways from harmful contaminants. Commission staff has drawn on the 

environmental review of ballast water treatment systems and active substance 

constituents from all levels of government (international, federal, state) in the 

assessment of environmental risk from the 46 treatment systems reviewed here.

International 

As discussed in Section III (Regulatory Overview), the IMO has established an approval 

process through Guideline G9 for treatment technologies using active substances (i.e. 

chemicals) to ensure systems are safe for the environment, ship, and personnel. The 
61

two-step process is comprised of an initial “Basic Approval” utilizing laboratory test 

results to demonstrate basic environmental safety, followed by “Final Approval” based 

upon evaluation of the environmental integrity of the full-scale system. 

Guideline G9 of the Convention requires applicants to provide information identifying: 1) 

Chemical structure and description of the active substance and relevant chemical 

byproducts; 2) Results of testing for persistence (environmental half-life), 

bioaccumulation, and acute and chronic aquatic toxicity effects of the active substance 

on aquatic plants, invertebrates, fish, and mammals; and 3) An assessment report that 

addresses the quality of the tests results and a characterization of risk (MEPC 2008f). 

Systems that apply for Basic and Final Approval are reviewed by the IMO Joint Group of

Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) –

Ballast Water Working Group (BWWG) in accordance with the procedures detailed in 

Guideline G9. The Guideline does not address system efficacy, only environmental 

safety (MEPC 2008f). 

Federal 

Outside of the USCG‟s Shipboard Technology Evaluation Program (STEP), ballast 

water treatment systems are not currently approved for use in compliance with federal 

ballast water management requirements. Consequently, there is no formal 

environmental impacts assessment process (like that of IMO) for ballast water treatment 

systems at the federal level. EPA, however, recognizes that ballast water treatment 

systems will be used both experimentally at the federal level and in compliance with 

state ballast water management requirements, and has therefore included provisions in 

the VGP for discharges from vessels employing ballast water treatment systems. 

The effluent limits and best management practices described in the VGP are specific to 

those treatment systems that make use of biocides. Under the permit, all biocides that 

meet the definition of a “pesticide” under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA; 7 U.S. Code § 136 et seq.) must be registered for use with the 

EPA. Biocides generated onboard a vessel solely through the use of a “device” (as 

defined under FIFRA) do not require registration. Additionally, the permit sets a limit for 
62

Total Residual Chlorine (TRC; instantaneous maximum = 100 μg/l) in ballast water 

discharge, and states that discharges of other biocides or residuals must not “exceed 

acute water quality criteria as listed in EPA‟s 1986 Quality Criteria for Water [the Gold 

Book], or any subsequent revisions” (EPA 2008). Systems that use biocides or produce 

derivatives which lack applicable EPA Water Quality Criteria must conduct Whole 

Effluent Toxicity testing to determine chronic toxicity levels. Systems that do not meet 

the Water Quality Criteria or chronic toxicity limits may be required to cease discharging 

and must apply for coverage under an individual NPDES permit.

Vessels participating in the STEP must comply with the VGP and additionally conform 

to the environmental compliance requirements associated with STEP participation 

including: 1) Compliance with the National Environmental Policy Act process; 2) Due 

diligence by the applicant in providing requested biological and ecological information 

and obtaining necessary permits from regulatory agencies; and 3) A provision that 

systems found to have an adverse impact on the environment or present a risk to the 

vessel or human health will be withdrawn from the program (USCG 2006). 

States

As discussed in Section III, several states established ballast water management 

programs and performance standards requirements through the Section 401 

certification of the Vessel General Permit. This certification also provided states a 

mechanism to set water quality criteria for ballast water discharges. Chlorine was a 

toxicant of concern for many states, particularly those located on the Great Lakes. 

Several states chose to establish limits for Total Residual Chlorine (TRC) in ballast 

discharges that were substantially more stringent than the limit established by the VGP 

(= 100 μg/l). Massachusetts, for example, set a TRC limit of 10 μg/l in discharges from 

experimental treatment systems. Several states also established conditions requiring 

evaluation of acute and chronic impacts from treated discharges.
63

State of Washington

The State of Washington‟s evaluation of environmental impacts from the discharge of 

treated ballast water has proved an invaluable resource to Commission staff. The 

Washington State Department of Ecology developed a framework for “Establishing the 

Environmental Safety of Ballast Water Biocides” in 2003, and revised it in 2008 to be 

included as Appendix H in the Laboratory Guidance and Whole Effluent Toxicity Test 

Review Criteria manual (Washington State Department of Ecology 2008, available at 

http://www.ecy.wa.gov/pubs/9580.pdf). Thus far, three systems have completed toxicity 

testing in accordance with Washington requirements (Table VI-5).

The tests used in the Washington State framework for evaluating ballast water biocides 

include EPA-approved acute and sensitive life stage toxicity tests on invertebrate, fish 

and algal species. One ISO test on growth inhibition of a marine diatom is also required 

in order to be consistent with international testing requirements. If treated ballast water 

might be discharged more than once in the same location during a week or in sensitive 

marine areas in the state, then EPA chronic tests or Washington State tests using 

Pacific herring may also be required to determine the biocide environmental safety. 

The results of the toxicity testing are used to set system discharge conditions such as 

maximum concentration or minimum degradation time (Washington State Department of 

Ecology 2008). 

California

California does not have a formal environmental impact evaluation process for the 

discharge of ballast water that has undergone treatment. Vessels that discharge in 

California waters must comply with the applicable provisions of the EPA‟s VGP 

including any California-specific conditions added by the State Water Resources Control 

Board through the Section 401 certification process. California‟s Section 401 

certification requires that vessel discharges contain no hazardous wastes as defined in 

California law or hazardous substances as listed in the certification letter (see Water 

Board 2009). Discharges may not contain an oily sheen, noxious liquid substance 

residues, and detergents may not be used to disperse hydrocarbon sheens. For more 
64

information go to http://www.swrcb.ca.gov/water_issues/programs/index.shtml and 

review the section on vessel discharges under the clean beaches/ocean programs. 

Environmental Assessment of Treatment Systems

Staff has compiled environmental assessment reports and water quality data reported to 

the IMO, as well as information made available to the State of Washington and 

Commission staff, to assess available treatment systems for potential environmental 

impacts to California waters. The IMO active substance approval documents, in 

particular, have proved to be a valuable resource to assess a treatment system‟s broadscale environmental safety prior to comparison of specific system effluent constituents 

to the VGP and California water quality objectives. 

Of the 46 treatment systems reviewed for this report, 28 use a biocide or chemical 

additive in the treatment process (Table VI-5), and will therefore require monitoring of 

discharges for chemical residuals. An assessment of the potential impacts from all 

possible chemicals and residuals associated with the use of these treatment 

technologies cannot be adequately addressed in this report and is the purview of the 

California Water Board and the EPA. Instead, Commission staff has focused this 

environmental assessment on total residual chlorine (TRC) concentrations in 

discharged ballast water because both the VGP and the Water Board (through the 

California Ocean Plan; see Water Board (2005)) have identified TRC as a particular 

concern due to its widespread toxicity to all organisms. Currently, California defers 

regulation of TRC in discharged ballast water to the EPA through the VGP. All vessels 

that discharge ballast in California waters must comply with the EPA VGP limit for TRC 

(= instantaneous maximum of 100 μg/l in discharged waters). Vendors and vessel 

owners/operators must consult with the Water Board and EPA to ensure that vessel 

discharges comply with all other applicable effluent requirements. 

Table VI-5 lists the active substances and summarizes the status of environmental 

approvals/assessments for each of the technologies reviewed in this report. Where 

applicable, the available data has been analyzed to determine whether or not treated 
65

ballast would comply with the EPA water quality objective for TRC in ballast water 

discharge (= instantaneous maximum of 100 μg/l in discharged waters). Many systems 

have initiated toxicity testing of treated discharges and have applied to IMO for Basic 

and Final Approval. The IMO Basic Approval application, however, may include data 

from general literature review or laboratory analysis of system toxicity. Until such time 

that a system submits a full dossier of whole effluent toxicity data as required for IMO 

Final Approval, it will be difficult to anticipate the potential environmental impacts to 

California waters from the discharge of treated ballast from a fully functioning treatment 

system. Currently only twelve treatment systems have received Final Approval from 

IMO (Table V-1, VI-5).

The “pesticide” registration requirement under FIFRA is one mechanism to regulate and 

assess the impacts to U.S. federal waters from biocide use in treatment systems. The 

thorough chemical safety analysis and registration process required under FIFRA has 

been completed by two systems - Hamann Evonik Degussa (removed from the market 

in 2010) and Ecochlor (Albert, R., pers. comm. 2010). FIFRA, however, does not apply 

to chemicals that are generated onsite and used in place (e.g. generated and used by a 

vessel). Most treatment systems using biocides generate that chemical through onboard 

electrochemical processes, and thus will not be subject to FIFRA registration. This 

exception provides significant room for systems to operate in U.S. waters without any 

kind of federal biocide regulation except as provided by the VGP, and at this time, it is 

uncertain how EPA will enforce the permit‟s provisions.
66

Table VI-5. Summary of environmental assessment and approval of treatment systems

Note: Table does not address whether or not toxicity testing was performed in accordance with the EPA Vessel General Permit.

21st Century Shipbuilding superoxide, oxygen radical,hydroxyl radical, 

electron, ozone X IMO Basic Y 117

Alfa Laval free radicals X IMO Basic and Final Y 86,135,137

Aquaworx ATC Gmbh n/a (UV, cavitation bubble) X IMO Basic Y 111

atg UV Technology n/a (UV)

ATLAS-DANMARK

hyplochlorous acid, ozone, hydrogen 

peroxide,chlorine dioxide, hydrogen, sodium 

hydroxide

125

Auramarine Ltd. n/a (UV) X 4

Brillyant Marine LLC

Coldharbour Marine n/a (deoxygenation)

COSCO/Tsinghua Univ. n/a (UV) X IMO Basic 105

DESMI Ocean Guard A/S hydroxyl radical, ozone X IMO Basic 115

Ecochlor chlorine dioxide X IMO Basic, Rec WA Cond.1 Y 97,124

EcologiQ yeast X 6

Electrichlor sodium hypochlorite

ETI ozone X 75

Ferrate Treatment Tech. ferrate

Hamworthy Greenship free active chlorine, total residual chlorine X IMO Basic and Final Y 93,100,109

Hi Tech Marine n/a (heat) New South Wales EPA 175

Hyde Marine n/a (UV) X

Hyundai Heavy Ind. (1) 

EcoBallast n/a (UV) X IMO Basic and Final 107,114

Hyundai Heavy Ind. (2) 

HiBallast

chlorine, bromine, sodium hypochlorite, 

sodium hypobromite, hypochlorous acid, 

hypobromous acid, 

X IMO Basic

Detection limit 

of tests above 

EPA standard

119

JFE Eng. Corp./TG Group sodium hypochlorite X IMO Basic and Final Y 100,116

Blank cells indicate that data was not available

88,108 triiron tetraoxide, poly aluminum chloride, 

poly acrylamide sodium acrylate Hitachi/Mitsubishi X IMO Basic and Final

Manufacturer Active Substance

Toxicity 

Testing 

Conducted

Environmental Related 

Approvals

VGP TRC 

Compliant? 

(100 ug/l)

Hamann Evonik Degussa2 Peraclean Ocean (peracetic acid, hydrogen 

peroxide, acetic acid)

Source

X 90,132 IMO Basic & Final, EPA 

Reg., Rec. WA Conditional1

1

 WA Dept. of Ecology Water Quality Program has recommended Conditional Approval of the system to WA Dept. Fish and 

Wildlife. As of the writing of this report, approval has not been granted.

2

 The Hamann Evonik Degussa system was temporarily removed from the market in 2010 due to environmental concerns regarding 

the toxicity of Peraclean Ocean in freshwater and cold water (see de Lafontaine et al. 2008, 2009). 
67

Table VI-5 (Continued). Summary of environmental assessment and approval of treatment systems

Note: Table does not address whether or not toxicity testing was performed in accordance with the Vessel General Permit

Kwang San Co. Ltd. Cl2, hypochlorous acid, hypobromous acid, 

sodium hypochlorite, sodium hypobromite

X IMO Basic

Detection limit 

of tests above 

EPA standard

120

MAHLE Ind. GmbH n/a (UV)

MARENCO n/a (UV)

Maritime Solutions Inc. n/a (UV)

Mexel Industries yes, unknown

MH Systems n/a (deoxygenation)

Mitsui Engineering ozone X IMO Basic N 84,104,114

NEI n/a (deoxygenation) X 11

NK Co. Ltd. ozone, total residual oxidant X IMO Basic and Final Y 98,106,114

ntorreiro yes, unknown

Nutech 03 Inc. ozone X N 195

OceanSaver free and total residual oxidant X IMO Basic and Final Y 95,101,146

OptiMarin n/a (UV) X Y 136

Panasia Co. n/a (UV) X IMO Basic and Final Y 91,94,110

Pinnacle Ozone Solutions ozone

Qingdao Headway Tech hydroxyl radical, hypochlorous acid, 

hypochlorite, hydrogen peroxide X IMO Basic Y 121,126,147

Resource Ballast Tech. ozone, hydroxyl radicals, hypochlorite X IMO Basic and Final N 87,112,124

RWO Marine Water Tech. hydroxyl radicals, free active chlorine X IMO Basic and Final N 89,103,114

Severn Trent DeNora sodium hypochlorite, sodium bisulfite X

IMO Basic, Rec. WA 

Conditional1 Y 49,122

Siemens sodium hypochlorite, sodium hypobromite, 

oxygenated species, oxygen, hydrogen X IMO Basic Y 78,113

Sunrui CFCC hypochlorite, hypobromite, chloramines, 

bromamines X IMO Basic 118

Wartsila n/a (UV)

Blank cells indicate that data was not available

Techcross Inc. hypochlorite, hypobromite, ozone, hydroxyl 

radicals, hydrogen peroxide

1

 WA Dept. of Ecology Water Quality Program has recommended Conditional Approval of the system to WA Dept. Fish and 

Wildlife. As of the writing of this report, approval has not been granted.

X IMO Basic and Final Y 83,96,100

VGP TRC 

Compliant? 

(100 ug/l)

Manufacturer Active Substance Source

Toxicity 

Testing 

Conducted

Environmental Related 

Approvals
68

A system‟s availability for use in California waters is dependent on its ability to meet all 

of the EPA‟s and California‟s environmental laws, regulations and permits for vessel 

discharges - not simply the performance standards. While it is the purview of the EPA 

and the Water Board to review and regulate the effluent from treatment systems used 

on vessels, Commission staff is working to educate technology vendors, particularly 

those from foreign countries, about the EPA‟s water quality objectives. Staff also 

encourages vendors to consult with the Water Board to ensure that systems meet 

California‟s Section 401 provisions in the VGP. 

As a first step towards assessing system environmental impacts, staff has attempted to 

compile data on TRC in treated effluent because of its broad-scale toxicity, and because 

so many systems use chlorine and related byproducts in the treatment process. Of the 

46 systems reviewed, 21 have data available for TRC in the treated effluent. Based on 

the available data, 14 appear to meet the EPA VGP objective (California defers to the 

EPA VGP for regulation of TRC in vessel discharges) of 100 μg/L or less of TRC (Table 

VI-5). Of the eight systems that demonstrated the potential to meet California‟s 

performance standards for the discharge of ballast water and that are commercially 

available, seven have data demonstrating TRC compliance with the EPA VGP 

objective. The only system without TRC data, Hyde, uses a filtration/UV system that 

should not generate any chlorine residuals. Clearly, not all treatment systems will meet 

California‟s and EPA‟s stringent water quality standards. However, it is difficult to 

assess at this time whether systems are simply unable to meet the standards or 

whether additional water quality data must be gathered from operation of full-scale 

systems under real world scenarios. Commission staff will continue to work with the 

Water Board, vessel owners/operators and technology vendors to ensure that systems 

are tested with California and federal water quality objectives in mind and that the 

information is made available to interested parties.

Economic Impacts 

An assessment of the economic impacts associated with the implementation of 

performance standards and the use of treatment technologies requires consideration 
69

not only of costs connected with the purchase, installation and operation of treatment 

systems, but also the costs of NIS introductions if performance standards are not met. 

As discussed in the Introduction (Section II), the U.S. has suffered major economic 

losses as a result of attempts to control and eradicate NIS (aquatic and terrestrial; 

Carlton 2001, Lovell and Stone 2005, Pimentel et al. 2005). NIS can also cause direct 

economic losses by reducing yield (i.e. aquaculture), reducing the value of commodities, 

increasing health care costs, or by reducing tourism-based revenues. For example, 

evidence strongly indicates that a toxogenic strain of Vibrio cholera was transported via 

ships from South America to the U.S. Gulf coast in 1991, resulting in the closure of 

Mobile Bay (Alabama) shellfish beds. Economic damages for the short-term localized 

closure are estimated at over $700,000 (Lovell and Drake 2009). Prince Edward Island 

oyster operations in Canada lose approximately $1.5 million annually due to mortality 

caused by the nonindigenous seaweed Codium fragile (Colautti et al. 2006). The rate of 

new introductions is increasing (Cohen and Carlton 1998, Ruiz and Carlton 2003) which 

suggests that economic impacts will likely increase as well.

California had the largest ocean-based economy in the U.S. in 2004, ranking number 

one for employment, wages and gross state product (NOEP 2010a). California‟s natural 

resources contribute significantly to the coastal economy. For example, in 2007 total 

landings of fish were over 380 million pounds, valued at more than $120 million (NOEP 

2010b). Squid, the top revenue-generating species in 2007, brought in almost $30 

million (NOEP 2010b). Millions of people visit California‟s coasts and estuaries each 

year, spending money on recreational activities that are directly related to the health of 

the ecosystem. Annually, over 150 million visits are made to California‟s beaches: 

approximately 20 million for recreational fishing, over 65 million for wildlife viewing, and 

over 5 million for snorkeling or scuba diving (Pendleton 2009). Direct expenditures for 

recreational beach activities alone likely exceed $3 billion each year (Kildow and 

Pendleton 2006). In total, the tourism and recreation industries accounted for almost 

$12 billion of California‟s gross state product in 2004 (NOEP 2007). NIS pose a threat to 

these and other components of California‟s ocean economy including fish hatcheries 

and aquaculture, recreational boating, and marine transportation.
70

The use of ballast water treatment technologies to combat NIS introductions will involve 

economic investment on the part of ship owners. This investment reflects not only initial 

capital costs for the equipment and installation, but also the continuing operating costs 

for replacement parts, equipment service and shipboard energy usage. Cost estimates 

are strongly linked to vessel-specific characteristics including ballast water capacity, 

ballast pump rates and available space. Additionally, the retrofit of vessels already in 

operation (existing vessels) with ballast water treatment technologies may cost 

significantly more than installation costs for newly built vessels due to: 1) The necessity 

to rework existing installations (plumbing, electric circuitry); 2) Non-optimal arrangement 

of equipment that may require equipment be broken into pieces and mounted 

individually; 3) Relocation of displaced equipment; and 4) Time associated with lay-up 

(Reynolds, K., pers. comm. 2007). Nonetheless, the use of these treatment 

technologies will help minimize or prevent future introductions of NIS and relieve some 

of the future economic impacts associated with new introductions.

Many treatment technology vendors are hesitant to release costs because system 

prices still represent research and development costs and do not reflect the presumably 

lower costs that would apply once systems are in mass production. In the 2010 Lloyd‟s 

Register report, only 22 of 41 technologies profiled provided estimates of system capital 

expenditures (equipment and installation) and half (20) provided estimates of system 

operating expenditures (parts, service, and energy usage; Table VI-6). Commission 

staff has also acquired some data on capital and operating costs. Capital expenditure 

costs are dependent on system size. A 200 cubic meters per hour (m3/h) capacity 

system may require an initial capital expenditure between $20,000 and $630,000 with 

an average cost of $291,000 (Lloyd‟s Register 2007, Lloyd‟s Register 2010, 

Commission data from technology vendors 2007-2008) – down $96,500 from 2009 (see 

Dobroski et al. 2009a). A 2000 m3/h capacity system ranges from $50,000 to 

$2,000,000 with an average cost of $892,500 per system (Lloyd‟s Register 2007, 

Lloyd‟s Register 2010, Commission data from technology vendors 2007-2008). The 

average cost of the large capacity systems has not changed since Dobroski et al. 
71

(2009a). Operating costs range from negligible, assuming waste heat is utilized, to 

$1.50 per m3 with an average of $0.07 per m3(Lloyd‟s Register 2007, Lloyd‟s Register 

2010, Commission data from technology vendors 2007-2008) – down $0.06 per m3 

since 2009 (see Dobroski et al. 2009a).

Treatment systems will likely increase the cost of a new vessel by 1-2%. For example, a 

new 8200 TEU (twenty-foot equivalent unit) container ship built by Hyundai Samho 

Heavy Industries costs approximately $120 million per vessel (Pacific Maritime 2010). 

Installation of the most expensive treatment system currently available at $2.0 million 

(as indicated in Table VI-6) would increase the cost of that vessel by 1.7%. Many 

treatment technology developers claim that their systems will last the life of the vessel, 

so the capital costs for treatment systems should be a one-time investment per vessel. 

While the economic investment by the shipping industry in ballast water treatment 

technologies will be significant, when compared to the major costs to control and/or 

eradicate NIS, the costs to treat ballast water may be negligible. Treating ballast water 

with treatment technologies will help to prevent further introductions and lower future 

costs for control and eradication. Additional studies will be necessary to obtain actual 

economic impacts associated with treating ballast water. 
72

Table VI-6. Summary of capital and operating cost data for select treatment systems. 

Unless otherwise noted, source of data is Lloyd‟s Register (2010). 

Manufacturer

Capital Expenditure

(Equipment & Installation)

Operating 

Expenditure

200 m3/h

($ in thousands)

2000 m3/h

($ in thousands)

Other

($ in thousands)

($ per m3, 

unless otherwise 

noted)

21st Century Shipbuilding

Alfa Laval 0.0151

Aquaworx ATC

atg UV Technology

ATLAS-DANMARK 180 850

Auramarine Ltd. 0.040

Brillyant Marine LLC 300 2000

Coldharbour Marine

COSCO/Tsinghua Univ.

DESMI Ocean Guard

Ecochlor 500 800 0.080

EcologiQ <5011 - 1.501

Electrichlor 350 .019

ETI 500 cost of power

Ferrate Treatment Tech.

Hamann Evonik Degussa 0.2

Hamworthy Greenship

Hi Tech Marine 150 1600

16.5 – 3001

(equipment only) nil2

Hitachi/Mitsubishi 400

Hyde Marine 250 1200 174 – 5031<.020

Hyundai Heavy Industries 

(1) – Ecoballast

Hyundai Heavy Industries 

(2) – HiBallast

JFE Eng. Corp./TG Corp. 0.053

Kwang San Co. Ltd.

MAHLE

MARENCO 145 175 0.0006 - 0.001

Maritime Solutions Inc.

Mexel Industries 20 50

MH Systems 500 1500 0.06

Mitsui Engineering

1001

(installation only) 0.153

NEI 249 670 0.13

NK Co. Ltd. 250 1000 0.007

ntorreiro

Nutech 03 Inc. 250 450 0.32

OceanSaver 288 1600 0.063

1

Source: Communications with technology vendors (2007-2008). 

2 Assumes waste heat utilized

3 Source: Lloyd‟s Register (2007)
73

Table VI-6 (Continued). Summary of capital and operating cost data for select 

treatment systems. Unless otherwise noted, source of data is Lloyd‟s Register (2010). 

Manufacturer

Capital Expenditure

(Equipment & Installation)

Operating 

Expenditure

200 m3/h

($ in thousands)

2000 m3/h

($ in thousands)

Other

($ in thousands)

($ per m3,

unless otherwise 

noted)

OptiMarin 290 1280

Panasia Co. Ltd.

Pinnacle Ozone Solutions 200 500 0.013

Qingdao Headway Tech. 0.0018

Resource Ballast Tech. 275 700

RWO Marine Water Tech.

Severn Trent DeNora 630 975 0.020

Siemens 500 1000 0.0085 - 0.010

Sunrui CFCC

Techcross Inc. 200 600 0.003

Wartsila

1

Source: Communications with technology vendors (2007-2008). 

2 Assumes waste heat utilized

3 Source: Lloyd‟s Register (2007)

VII. DISCUSSION AND CONCLUSIONS

Recognizing the threat to California‟s waters from nonindigenous species, California‟s 

legislature enacted legislation in 2006 requiring the Commission to implement 

performance standards for the discharge of ballast water. Those standards, set forth in 

statute and adopted via regulation, set limits for the concentration of viable organisms in 

discharged ballast water. The standards will be implemented on a graduated time 

schedule based on a vessel‟s ballast water capacity and year of construction. Vessels 

have several options for complying with the performance standards regulations. Over 

80% of vessel voyages to California waters do not involve the discharge of ballast 

water. In these cases, compliance with the regulations is achieved because all ballast 

water is retained on board the vessel. Alternatively vessels may discharge to a 

shoreside or barge-based ballast water reception facility. Although no such facilities 

currently exist in California, there has been recent interest by several entities in

developing this option for vessels operating in California and along the West Coast. 

Finally, for vessels that cannot retain all ballast on board or discharge to a reception 

facility, shipboard ballast water treatment will likely be necessary to meet California‟s 
74

performance standards. Per PRC Section 71205.3, the purpose of this report is to 

assess the efficacy, availability and environmental impacts of ballast water treatment 

systems prior to the implementation of California‟s performance standards for newly 

built vessels with a ballast water capacity greater than 5000 MT beginning on January 

1, 2012. 

Ballast water treatment is an emerging and quickly expanding industry. New 

technologies continue to be developed and existing ones refined in search of the most 

effective methods to reduce and/or eliminate the spread of nonindigenous species via 

ballast water release. While hurdles remain for the full implementation of all of 

California‟s performance standards, significant progress has been made in the 

development of treatment systems since previous technology assessment reports (see 

Dobroski et al. 2007, 2009a). Both the quantity and the quality of the recently received 

data on system performance attest to this fact.

Treatment system performance data has improved in recent years, however it is 

important to note that systems have undergone a relatively small number of tests, under 

a limited range of environmental conditions. This leads to inherent uncertainty 

regarding treatment system performance across the spectrum of potential variables, 

including ship type and source water properties (e.g. temperature, turbidity, salinity). 

This uncertainty is likely to persist over the next several years. In the absence of a 

significant worldwide effort to install and test treatment systems on multiple vessels and 

under all possible environmental scenarios, it is unreasonable to expect that sample 

sizes and available data will increase adequately in the near future to demonstrate, with

a high level of confidence, that treatment systems will consistently meet California‟s 

performance standards under every potential situation and under all circumstances. 

However, continuing to wait for such information will only serve to delay progress. Due 

to the inherent uncertainty regarding treatment system performance and evaluation, the 

utilization of an adaptive management approach will be essential at all stages of 

implementation in order to move forward and protect California‟s aquatic resources from 

the impacts of species introductions.
75

Similar to the ballast water treatment industry, the fields of treatment technology 

assessment and compliance verification are still evolving, and recent discussions have

centered on whether or not methods and/or protocols exist to assess compliance with 

California‟s standards. California‟s standards for organisms greater than 50 μm in size is 

set as “nondetectable.” In discussions related to the International Maritime Organization 

standard, external parties have reasoned that the volumes of ballast water required to 

determine compliance with any standard more stringent than 10 organisms per cubic 

meter are not testable. However, it is important to note that California‟s standard for 

organisms greater than 50 μm is unitless. There are no volume requirements set forth in 

the standard. Therefore, compliance and performance testing can occur with any 

volume of water. The volumes of water sampled for the remaining size classes are

small enough so that they do not pose an issue.

The bacteria and virus standards do pose a challenge. While there are currently widelyaccepted methods for assessing viability for a subgroup of total bacteria, Commission 

staff believes that there are no acceptable methods for verification of compliance with 

the virus standard and that the Commission should proceed with assessment of 

technologies for the remaining six standards. Commission staff have considered all of 

these issues while evaluating treatment systems for compliance with California‟s 

standards. 

Based on currently available information and using best assessment techniques, at 

least eight treatment systems have demonstrated the potential to comply with the 

Commission‟s performance standards (Table VII-1). Efficacy data for these systems 

indicate that at least one test met or exceeded California‟s performance standard for 

every testable organism/size category during either land-based or shipboard testing. 

Systems that met California‟s Vibrio standard in laboratory tests that involved spiked

concentrations of the microbe above levels generally found in land- or ship-based 

testing were considered indicative of a system‟s performance at the land or shipboard

scales. Three of the eight systems show the potential to meet California‟s performance 
76

standards under more rigorous evaluation criteria. These three passed more than 50% 

of the time over multiple tests (3 or more) at either the land or shipboard scale (Table 

VII-1). Additional systems are close to demonstrating the potential for meeting 

California‟s standards, and Commission staff are awaiting data from these tests of 

system performance.

Commission staff believe that, given the data currently available, multiple treatment 

systems have demonstrated the potential to meet California‟s performance standards 

for vessels with construction initiated on or after January 1, 2012, and a ballast water 

capacity greater than 5000MT. Practically speaking, vessels with this construction date 

will not be expected to meet the standards until construction is complete and they are 

operational, sometime in 2014 at the earliest. The lead time available for further 

technology development and refinement is sufficient to indicate that technologies will be 

available by the time these vessels are operational. At least three to four years will 

pass before any vessels in this size class will need to install treatment systems to meet 

California‟s standards. 

Current federal law will continue to require ballast water exchange as the primary 

management method. Thus, in order to comply with both California and federal law, 

many vessels that must discharge in California will need to first exchange ballast water 

according to federal requirements for distance from shore and depth, and utilize a 

ballast water treatment system to reduce organisms to levels at or below California‟s 

standards. Though seemingly duplicative, the execution of exchange along with or 

before treatment will likely serve to improve the efficacy of systems. The concentrations 

of organisms in the open ocean (where exchange will occur) will be lower than 

concentrations in nearshore areas. Since the shipboard and land-based data utilized for 

this report tested treatment systems with comparatively organism-rich water from 

nearshore areas, it is expected that system performance will be improved if open ocean 

exchange is conducted before treatment. Open ocean waters also generally exhibit 

lower levels of turbidity, organic matter, and human pathogens/pathogen indicators, 
77

which should also serve to improve system performance and reduce organism levels at 

discharge. 

All eight of the systems that have demonstrated the potential to comply with California‟ 

standards (see Table VII-1) are currently commercially available. Seven should be able 

to treat at ballast water pump rates over 2000 m3/hr, which would accommodate over 

80% of the vessels that operate in California with ballast water capacity over 5000 MT. 

The manufacturers of six systems attest that their products will operate at much higher 

pump rates. Of the three systems that show potential for meeting the standards under 

more rigorous consistency criteria, all can accommodate much higher pump rates of

4500 m3/hr or more.
78

Table VII-1. Summary of assessment for ballast water treatment systems with potential to meet California‟s performance 

standards. **Denotes systems which demonstrated potential to meet standards more than 50% of the time over 3 or 

more tests. See tables V-1, VI-1, VI-3, VI-4, VI-5, VI-6, and Section VI text for more information. 

System 

Manufacturer

Max System 

Capacity 

(Pump Rate)

General 

Approvals 

(Non-California)

Environmental 

Approvals

VGP Total 

Residual 

Chlorine 

Compliant

Costs

Initial

($ in Thousands) Operating

($ per m3)

200 m3/hr 2000 m3/hr

Alfa Laval 2500 m3/hr Type Approval 

(Norway) IMO Basic & Final Yes 0.015

Ecochlor** >13,000 m3/hr USCG STEP1

, WA 

Conditional1

IMO Basic, USCG 

STEP1, WA 

Conditional1

Yes 500 800 0.080

Hamworthy 

Greenship

1000 m3/hr 

(per pump) IMO Basic & Final Yes

Hyde Marine 6000 m3/hr

WA Conditional1, 

Type Approval 

(UK), USCG STEP1

(UV System)

USCG STEP1, WA

Conditional1

N/A 2502

12002

<0.020

OceanSaver >6000 m3/hr Type Approval 

(Norway) IMO Basic & Final Yes 288 1600 0.06

OptiMarin 3000 m3/hr Type Approval 

(Norway) (UV System) Yes 290 1280

Quingdao 

Headway 

Tech**

4500 m3/hr IMO Basic Yes 0.0018

Techcross** >5000 m3/hr Type Approval 

(Korea) IMO Basic & Final Yes 200 600 0.003

1 USCG STEP and WA Conditional approvals require that systems demonstrate levels of efficacy and environmental acceptability. Acceptance into STEP 

constitutes an experimental use approval that applies to the combination of one vessel and one treatment system. STEP requires compliance with the EPA Vessel 

General Permit, the National Environmental Policy Act, and requires vessels to obtain other applicable permits. STEP is not a Type Approval process. Washington 

State Conditional Approval requires data from specific laboratory and effluent toxicity tests. See text for more detail.

2

Additional initial costs for the Hyde Marine system not noted in table are $174-503 thousand.

NOTE: These systems demonstrate the potential to meet California‟s performance standards, however, this does not constitute an approval or

endorsement of any system. 
79

The IMO approval pathway for systems utilizing active substances has been a resource 

for information about the potential environmental impacts from the discharge of treated 

ballast water. Overall, the number of systems that have received IMO Final Approval 

remains small at this time, however, and thus environmental impact analysis of whole 

effluent toxicity remains hampered by a lack of data. The data available on total residual 

chlorine concentration in treated ballast effluent makes it clear that not all systems will 

meet water quality standards set forth in the EPA Vessel General Permit. However, 

information gaps related to system impacts to receiving waters still exist. Commission 

staff continues to work with the Water Board to track the implementation of the Vessel 

General Permit in California and assess the acceptability of discharges under this new 

regulatory program. Ultimately, treatment vendors and vessel operators will need to 

consult with the EPA and the Water Board to assess the potential for water quality 

impacts and treatment system compliance with water quality requirements in federal

and California waters.

Most of the eight treatment systems that demonstrate the potential to meet California‟s 

standards have received one or more approvals from other regulatory entities, which 

involve the demonstration of specific levels of efficacy and/or minimization of 

environmental impact. Four have received both IMO Basic and Final approval for the 

use of active substances. Two additional systems have received USCG STEP and 

Washington State Conditional approvals, which require certain levels of performance 

efficacy, and/or environmental toxicity testing. Available data indicate that all eight 

systems either meet the EPA VGP total residual chlorine limit or do not produce chlorine 

in the treatment process. Though systems must ultimately meet all requirements of the 

U.S. EPA and the California Water Board, in addition to California‟s performance 

standards, in order to operate in California waters, the available environmental data 

reviewed for this report is promising. While STEP, IMO and/or Washington Conditional 

approvals do not constitute authorization for use in California (California does not 

require these approvals nor will California provide approvals), approvals from other 

regulatory entities may allow operation of such systems on routes outside of California.
80

The Commission will continue to gather information on treatment system efficacy, 

availability and environmental impacts as California‟s standards are implemented and 

additional vessels install treatment systems for both experimental purposes and to meet 

state, federal and international ballast water management requirements. The ballast 

water treatment industry is evolving rapidly. In December 2007, the Commission report 

(see Dobroski et al. 2007) indicated that no technologies had demonstrated the 

potential to meet California‟s standards. Less than four years later, this report indicates 

that eight systems have demonstrated the potential to meet the standards. Given that 

several years remain before the next class of vessels must be prepared to meet 

California‟s standards, Commission staff believe that sufficient evidence exists to 

demonstrate that systems will be available. However, in recognition of the rapidly 

changing fields of technology development and performance assessment, Commission 

staff will prepare an update of this report by September 1, 2011. In preparation of the 

update, Commission staff will convene a scientific advisory panel to review the latest

data on treatment systems and testing protocols and provide input regarding the 

availability of treatment systems in an effort to ameliorate concerns regarding the 

implementation of California‟s performance standards. While not required by statute, 

this update will verify that technology development is progressing on schedule to allow 

for the implementation of the standards beginning January 1, 2012. 

VIII. RECOMMENDATIONS

1. Move forward with January 1, 2012 implementation date of California’s 

performance standards for new vessels with a ballast water capacity 

greater than 5000 MT. 

Based on the available information, the Commission recommends that the 

implementation of performance standards for new vessels with a ballast water 

capacity greater than 5000 MT proceed on January 1, 2012. This review 

indicates that systems will be available to meet California‟s performance 

standards, and those systems are available for use on vessels with a ballast 

water capacity greater than 5000 MT. Commission staff is developing verification 
81

procedures to assess vessel compliance with the performance standards, and is 

working closely with the shipping industry and treatment vendors to ensure a 

smooth transition to the new standards. The Commission intends to proceed with 

the implementation of the standards as set forth in statute and in regulation. 

While not required by statute, Commission staff will conduct an update of this 

technology assessment by September 1, 2011 to ensure that progress in 

technology development is sufficient to allow for the implementation of the 

standards beginning January 1, 2012. The next legislatively mandated report is 

due July 1, 2012 in anticipation of the 2014 implementation date for existing 

vessels (those built before 2010) with a ballast water capacity of between 1500 

MT and 5000 MT. 

2. Support Commission staff involvement with the development and 

implementation of performance standards at the federal and international 

levels.

Commercial shipping is an international industry; any single ship may operate 

throughout several regions of the world. Ideally, performance standards that align 

both at the federal and international levels are preferable to a patchwork of 

standards adopted by individual states. Commission staff have been working with 

the federal government, including the U.S. Congress, USCG and EPA, on the 

development of federal performance standards and treatment technology 

performance verification protocols. Staff participates on both the EPA ETV 

program Ballast Water Technical Panel and Stakeholder Advisory Panel. These 

panels are working with ETV program staff and the USCG to finalize the 

technology verification protocols for ballast water treatment systems. Additionally, 

due to California‟s role as a world leader in the implementation of ballast water 

management regulations, Staff has recently been invited to participate in 

meetings hosted by the European Union to discuss the future implementation of 

the IMO Convention and rules for ballast water management in European waters. 

Staff expects to be asked to provide information and guidance about the 
82

Commission‟s Marine Invasive Species Program during conferences and 

outreach events held throughout California, the U.S. and internationally. 

The development of U.S. Federal and international policies and regulations 

related to performance standards frequently take place in locations outside of 

California (esp. Washington D.C.) and occasionally, at international venues. 

With ongoing prohibitions on out-of-state and out-of-country travel, Commission 

staff can often only participate in such discussions when it is possible to do so via 

teleconference. Often teleconferencing is not an option, and the development of 

federal or international policies simply move forward without input from California. 

When presentations over the telephone are possible, sound quality is poor, 

presentation via power point is problematic, and audience question and answer 

sessions are difficult. Engagement in discussion or dialogue in-person at 

meetings and conference is extremely effective. The Legislature is encouraged to 

support Commission Staff participation in such important meetings and 

conferences, particularly in instances where travel expenses are covered by third 

parties.

3. Maintain accessibility to Marine Invasive Species Program funds to 

address immediate research needs related to the development of methods

to assess compliance with California’s performance standards.

Additional research is needed to develop new techniques and refine existing 

methods to assess treatment system performance and verify vessel compliance 

with California‟s performance standards. Scientific methods do not currently exist 

to assess the viability and quantity of all living bacteria and viruses in ballast 

water samples. The development of these techniques is necessary for the full 

implementation and verification of California‟s performance standards. Sampling 

methods must balance the need for statistical confidence with practical, rapid, 

and relatively easy techniques for shipboard inspection. Research must be 

conducted to determine the most effective way of achieving adequate sampling 
83

confidence that are practicable for regulators and do not unduly burden vessel 

operators. 

As performance standards are implemented, the need for practical and rapid 

onboard methods to assess compliance will quickly become critical. It is 

anticipated that vessels with operating treatment systems will begin arriving to 

the state as early as next year (2011). Though the Marine Invasive Species 

Program is funded through a programmatic fee and does not draw from the 

general fund, it has been subject to the same cuts that have applied to many 

California agencies. The legislature should ensure that MISP funds dedicated to 

priority research needs are not compromised, particularly given the current 

budget climate. 

IX. LOOKING FORWARD

Ballast water treatment remains a burgeoning industry that will undergo significant 

development as the IMO, proposed federal, and California‟s performance standards are 

progressively implemented and as new vessel types are built. Staff is currently 

engaged with numerous activities to ensure the comprehensive implementation and 

enforcement of California‟s performance standards for the discharge of ballast water: 

Staff is developing draft protocols for use by the Commission‟s marine safety personnel 

to verify vessel compliance with the performance standards. Commission staff is 

consulting with scientists and industry experts in order to determine the volumes of 

ballast water that must be sampled and to select the best available methods for 

organism enumeration and viability assessment taking into account practicality, cost 

effectiveness, accuracy and precision, acceptance by the scientific community, and 

ability to withstand legal scrutiny. The draft compliance verification protocols describe 

administrative inspection procedures, including review of relevant reporting forms and 

ballast water logs, and methods for on-site sampling of ballast water discharges. The 

performance standards compliance protocols will be tested on vessels over the next 

several months in conjunction with regular vessel inspections conducted by the 
84

Commission‟s marine safety personnel. This process will be challenging, as few vessels 

that operate in California waters have installed ballast water treatment systems or 

sampling ports for collection of treated discharge samples. Commission staff will seek 

out every possible sampling opportunity in order to refine the draft protocols in 

preparation for the arrival of the first vessels that must meet California‟s performance 

standards. These vessels will likely arrive in California waters in 2011. 

To augment the administrative component of the ballast water inspections, Commission 

staff has developed two ballast water treatment technology reporting forms. These 

forms will require information on ballast water treatment system installation and use in 

California waters. This information will be valuable to the Commission‟s marine safety 

personnel as they inspect ballast water treatment systems onboard vessels. The data 

will also be used by Commission staff to evaluate the implementation of the 

performance standards in California waters. Assembly Bill 248 (Chapter 317, Statutes of 

2009) provided Commission staff with the authority to develop these forms. Staff met 

with an advisory panel to discuss the contents of the forms before implementing the 

forms via the California rulemaking process. The 45-day public comment period for the 

rulemaking closed in March, 2010. Based on comments, staff revised the forms. The 

15-day comment period on the revisions closed in July, 2010. Staff expects the final 

forms to be approved and adopted by the fall of 2010. 

Research Needs

In addition to the aforementioned activities being conducted by Commission staff to 

implement California‟s performance standards, staff is also working with scientists and 

industry experts to identify and address gaps in our understanding of ballast water 

treatment methods and system evaluation, particularly at the shipboard level. Eight 

systems evaluated in this report have demonstrated the potential to meet California‟s 

performance standards, but many systems still require further development and 

evaluation, and many have not yet been tested on vessels. The proposed USCG ballast 

water treatment system approval process will involve shipboard evaluation of treatment 

systems, and therefore vessel owners and operators must continue to make their 
85

vessels available for the shipboard testing of experimental treatment systems. A greater 

understanding of how treatment systems function on vessels will be particularly 

important as existing vessels, those built before 2010, will be retrofitted with treatment 

systems beginning in 2014 to comply with California‟s performance standards. Those 

technologies must be installable under limited space conditions, and must be able to 

integrate with the existing engineering of ships (piping, electrical, computer, etc.). 

Funding from state, federal and international organizations will be necessary to advance 

this important shipboard work.
86

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87. MEPC (Marine Environment Protection Committee). 2007a. Basic Approval of 

Active Substances used by Resource Ballast Technologies Systems (Cavitation 

combined with Ozone and Sodium Hypochlorite treatment). Submitted by South 

Africa. 56/2/3. 6 April 2007.

88. MEPC (Marine Environment Protection Committee). 2007b. Application for Basic 

Approval of Active Substances used by Hitachi Ballast Water Purification System 

(ClearBallast). Submitted by Japan. 57/2/2. 7 September 2007.

89. MEPC (Marine Environment Protection Committee). 2007c. Application for Final 

Approval of a ballast water management system using Active Substances. 

Submitted by Germany. 57/2/3. 7 September 2007.

90. MEPC (Marine Environment Protection Committee). 2007d. Application for Final 

Approval of a ballast water management system using Active Substances. 

Submitted by Germany. 57/2/5. 7 September 2007.
94

91. MEPC (Marine Environment Protection Committee). 2007e. Basic Approval of 

Active Substance used by GloEn-PatrolTM Ballast Water Management System. 

Submitted by the Republic of Korea. 57/2/4. 7 September 2007.

92. MEPC (Marine Environment Protection Committee). 2007f. Report of the fourth 

meeting of the GESAMP-Ballast Water Working Group (GESAMP-BWWG). Note 

by the Secretariat. 57/2. 19 December 2007.

93. MEPC (Marine Environment Protection Committee). 2007g. Application for Basic 

Approval of a combined ballast water management system consisting of 

sediment removal and an electrolytic process using seawater to produce Active 

Substances (Greenship Ltd). Submitted by the Netherlands. 57/2/7. 20 

December 2007.

94. MEPC (Marine Environment Protection Committee). 2008a. Report of the fifth 

meeting of the GESAMP-Ballast Water Working Group (GESMP-BWWG). Note 

by the Secretariat. 57/2/10. 25 January 2008.

95. MEPC (Marine Environment Protection Committee). 2008b. Application for Final 

Approval of the OceanSaver® Ballast Water Management System (OS BWMS). 

Submitted by Norway. 58/2/1. 19 March 2008.

96. MEPC (Marine Environment Protection Committee). 2008c. Application for Final 

Approval of the Electro-Clean System (ECS). Submitted by the Republic of 

Korea. 58/2. 20 March 2008.

97. MEPC (Marine Environment Protection Committee). 2008d. Application for Basic 

Approval of the Ecochlor® Ballast Water Treatment System. Submitted by 

Germany. 58/2/2. 20 March 2008.

98. MEPC (Marine Environment Protection Committee). 2008e. Application for Final 

Approval of the NK-O3 BlueBallast System (Ozone). Submitted by the Republic 

of Korea. 58/2/3. 21 March 2008.

99. MEPC (Marine Environment Protection Committee). 2008f. Procedure for 

approval of ballast water management systems that make use of active 

substances (G9). MEPC 57/21. Annex 1. Resolution MEPC.169(57). Adopted on 

4 April 2008.

100. MEPC (Marine Environment Protection Committee). 2008g. Report of the sixth 

meeting of the GESAMP-Ballast Water Working Group. Note by the Secretariat. 

MEPC 58/2/7. 14 July 2008.

101. MEPC (Marine Environment Protection Committee). 2008h. Report of the 

seventh meeting of the GESAMP-Ballast Water Working Group. Note by the 

Secretariat. 58/2/8. 28 July 2008.
95

102. MEPC (Marine Environment Protection Committee). 2008i. Guidelines for 

approval of ballast water management systems (G8). MEPC 58/23. Annex 4. 

Resolution MEPC.174(58). Adopted on 10 October 2008.

103. MEPC (Marine Environment Protection Committee). 2008j. Application for Final 

Approval of the RWO Ballast Water Management System (CleanBallast). 

Submitted by Germany. 59/2. 28 November 2008.

104. MEPC (Marine Environment Protection Committee). 2008k. Application for Final 

Approval of the Special Pipe Hybrid Ballast Water Management System 

(combined with Ozone treatment). Submitted by Japan. 59/2/1. 4 December 

2008. 

105. MEPC (Marine Environment Protection Committee). 2008l. Application for Basic 

Approval of the Blue Ocean Shield Ballast Water Management System. 

Submitted by China. 59/2/2. 5 December 2008.

106. MEPC (Marine Environment Protection Committee). 2008m. Application for Final 

Approval of the NK-O3 BlueBallast System (Ozone). Submitted by the Republic 

of Korea. 59/2/3. 8 December 2008.

107. MEPC (Marine Environment Protection Committee). 2008n. Application for Basic 

Approval of the HHI Ballast Water Management System (EcoBallast). Submitted 

by the Republic of Korea. 59/2/4. 9 December 2008. 

108. MEPC (Marine Environment Protection Committee). 2008o. Application for Final 

Approval of the Hitachi Ballast Water Purification System (ClearBallast). 

Submitted by Japan. 59/2/5. 11 December 2008.

109. MEPC (Marine Environment Protection Committee). 2008p. Application for Final 

Approval of the Greenship Sedinox Ballast Water Management System. 

Submitted by the Netherlands. 59/2/6. 12 December 2008.

110. MEPC (Marine Environment Protection Committee). 2008q. Application for Final 

Approval of the GloEn-PatrolTM Ballast Water Treatment System. Submitted by 

the Republic of Korea. 59/2/7. 16 December 2008.

111. MEPC (Marine Environment Protection Committee). 2008r. Application for Basic 

Approval of the AquaTriCombTM Ballast Water Treatment System. Submitted by 

Germany. 59/2/8. 16 December 2008.

112. MEPC (Marine Environment Protection Committee). 2008s. Application for Final 

Approval of the Resource Ballast Technologies System (Cavitation combined 

with Ozone and Sodium Hypochlorite treatment). Submitted by South Africa. 

59/2/10. 19 December 2008.
96

113. MEPC (Marine Environment Protection Committee). 2008t. Application for Basic 

Approval of the Siemens SiCURETM Ballast Water Management System. 

Submitted by Germany. 59/2/11. 19 December 2008.

114. MEPC (Marine Environment Protection Committee). 2009a. Report of the eighth 

meeting of the GESAMP-Ballast Water Working Group. Note by the Secretariat. 

59/2/16, Annex 4. 8 April 2009. 

115. MEPC (Marine Environment Protection Committee). 2009b. Application for Basic 

Approval of the DESMI Ocean Guard Ballast Water Management System. 

Submitted by Denmark. 60/2/4. 19 August 2009.

116. MEPC (Marine Environment Protection Committee). 2009c. Application for Final 

Approval of the JFE Ballast Water Management System (JFE-BWMS) that 

makes use of “TG Ballastcleaner® and TG Environmentalguard®.” Submitted by 

Japan. 60/2/2. 20 August 2009. 

117. MEPC (Marine Environment Protection Committee). 2009d. Application for Basic 

Approval of Blue Ocean Guardian (BOG) Ballast Water Management System. 

Submitted by the Republic of Korea. 60/2/5. 24 August 2009. 

118. MEPC (Marine Environment Protection Committee). 2009e. Application for Basic 

Approval of the Sunrui ballast water management system. Submitted by China. 

60/2/3. 24 August 2009.

119. MEPC (Marine Environment Protection Committee). 2009f. Application for Basic 

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Management System (HiBallast). Submitted by the Republic of Korea. 60/2/6. 24 

August 2009.

120. MEPC (Marine Environment Protection Committee). 2009g. Application for Basic 

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121. MEPC (Marine Environment Protection Committee). 2009h. Application for Basic 

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122. MEPC (Marine Environment Protection Committee). 2009i. Application for Basic 

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123. MEPC (Marine Environment Protection Committee). 2009j. Draft MEPC 

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97

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125. MEPC (Marine Environment Protection Committee). 2009l. Report of the 

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XI. APPENDICES
105

APPENDIX A 

Ballast Water Treatment System

Efficacy Matrix

Forty-six ballast water treatment systems were reviewed by Commission staff for 

compliance with the California performance standards. Twenty-seven systems had data 

on system efficacy available for review. Staff included data from shipboard, dockside 

and laboratory studies of system performance. In an effort to standardize results, staff 

evaluated any data on zooplankton abundance as representative of the largest size 

class of organisms (greater than 50 μm in size), and phytoplankton abundance was 

evaluated on par with organisms in the 10 – 50 μm size class. Results presented as 

percent reduction in organism abundance or as concentration of pigments or biological 

compounds associated with organism presence were noted, but these metrics were not 

comparable to the performance standards. 

In the following tables, systems with at least one test (averaged across replicates) in 

compliance with the performance standard are scored as meeting California standards. 

Efficacy data with no tests demonstrating potential compliance with the standards are 

scored as not meeting California standards. Systems that presented data for a given 

organism size class but presented the results in metrics not comparable to the 

standards are classified as “Unknown.” For example, a system that presented results of 

system efficacy as percent reduction of zooplankton abundance could not be compared 

against the California standards, and thus ability of the system to comply with the 

standards is unknown. Open cells indicate lack of data for a given organism size class. 

Compliance with the bacteria standard was assessed using the concentration of 

culturable heterotrophic bacteria in discharged ballast water. Due to the lack of available 

methods to both quantify and assess the viability of all viruses, systems cannot be 

assessed for compliance with the viral standard at this time. The source(s) of the data 

for each system can be found in the Literature Cited section of the main report. 
106

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/cubic meter Methods Reference

Laboratory 2 1 Unk Unk 0 - 10 Unk 117

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory 1 0 - - Unk (% Reduction) Visual Assesment 82

Land-Based 10 8 6 Y 0 - 26 Microscope/mobility 137

Shipboard 4 1 12 Y 0 - 3 Microscope/mobility 138

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 5 3 Y Y 0 - 19.3 Unk 4,165

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory1 2 2 2 Y 0 - 3.5x105 Visual, Neutral Red Stain 148

Land-Based 15 8 - Y 0 - 81 Visual Assess, Neutral Red 133

Shipboard1 1 1 3 Y 0-5 Visual Assessment 76

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, 1 = Filter added to system since testing conducted

21 Century 

Shipbuilding

Aquaworx ATC 

Gmbh

ATLAS-DANMARK

Auramarine Ltd.

Brillyant Marine 

LLC

Coldharbour 

Marine

COSCO/Tsinghua 

Univ.

DESMI Ocean Guard 

A/S

Appendix A1 Organisms > 50 μm

ETI

Ferrate Treatment 

Tech.

Alfa Laval

EcologiQ

Electrichlor

atg UV Technology

Ecochlor
107

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/cubic meter Methods Reference

Laboratory 2 2 Y Y 0 Visual Assesment 44,182

Land-Based 19 16 Y Y 0-0.7 Visual Asses., Neutral Red 132

Shipboard 5 4 3 Y 0-1.1 Visual Asses., Neutral Red 132

Laboratory - - - - - - -

Land-Based 5 5 Y Y 0 Visual Assessment 167

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard 2 0 - - Unk (% mortality) - 51

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 1 0 Y Y - Visual Assessment 70

Land-Based 10 1 Y Y 0 - 7.3 Visual, Neutral Red Stain 134

Shipboard 3 3 9 Y 0 Visual, Neutral Red Stain 192

Laboratory 2 2 9 Y 0 Unk 107

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 2 9 Y 0 Unk 119

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 0 Unk Y 160-180 Unk 120

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 4 3 3 Y 0 - 1.57 Visual Assessment 64,65,189

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 5 0 5 Y 6 - 2170 Microscope/Mobility 79

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n

Kwang San Co. Ltd.

MAHLE

Hyundai Heavy 

Industries (1)

Hyundai Heavy 

Industries (2)

Mexel Industries

Appendix A1 Organisms > 50 μm

MARENCO

JFE Engineering 

Corp

Maritime Solutions 

Inc.

Hamann AG Evonik 

Degussa

Hi Tech Marine

Hitachi

Hyde Marine

Hamworthy 

Greenship
108

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/cubic meter Methods Reference

Laboratory 11 10 Y Y Unk (No Units) Visual Assessment 41,52

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 4 0 3-5 Y BD, 2 x105 - 1.4x106 Visual Assessment 58,59

Shipboard 1 0 - Y 8 Visual Assessment 56

Laboratory - - - - - - -

Land-Based 5 1 Y Y 0, Unk (% Survival) Visual Assessment 170,171

Shipboard 2 1 Y Y 0 - 7 Visual Assessment 172

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 3 0 4 Y 1.2x102 - 1.2x104 Visual Assessment 154

Land-Based 3 0 Y Y Unk (% Live) Visual Assessment 50

Shipboard 3 2 12 Y 0 - 150 Visual Assessment 195

Laboratory - - - - - - -

Land-Based 14 2 3 Y 0-135 Visual Assessment 139

Shipboard 3 1 3 Y 0 - 9720 Visual Assessment 176

Laboratory 1 0 - Y > 0 Visual Assessment 57

Land-Based 12 8 3 Y 0-144 Microscope/Mobility 136

Shipboard 8 0 9 Y 1.4 - ~5500 Visual Assessment 140

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 13 4 3 Y 0 - 15.3 Microscope/Mobility 142

Shipboard 3 3 Y Y 0 Microscope/Mobility 147

Laboratory - - - - - - -

Land-Based 3 3 Unk Y 0 Microscope/Mobility 3

Shipboard 2 0 3 Y 0.6 - 1.1 Microscope/Mobility 3

Laboratory 1 1 - - 0 Visual Assessment 85

Land-Based 2 2 N Y 0 "Standard Operating Proc." 30,31

Shipboard - - - - - - -

Unk = Unknow n, BD = Below Detection Limits

Mitsui Engineering

Nutech O3 Inc.

OceanSaver

OptiMarin

Panasia Co. 

MH Systems

ntorreiro

Appendix A1 Organisms > 50 μm

Resource Ballast 

Tech

RWO Marine Water 

Tech

NEI

NK-O3

Pinnacle Ozone 

Solutions

Qingdau Headway 

Tech
109

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/cubic meter Methods Reference

Laboratory - - - - - - -

Land-Based 5 3 3-4 Y 0 - ~4x105 Visual Assessment 49

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 3 0 5 Y 15-57 Microscope/Mobility 78

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 11 8 3 Y 0-6 Visual Assessment 62

Shipboard 3 3 3 Y 0 Visual Assessment 62

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

1

 System has added a filter since testing w as conducted.

Siemens

Sunrui CFCC

Wartsila

Techcross Inc.

Severn Trent1 

Appendix A1 Organisms > 50 μm
110

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/ml Methods Reference

Laboratory 2 0 Unk Unk 1 Unk 117

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory 1 0 - - Unk (% Reduction) Visual Assesment 82

Land-Based 10 3 6 Y 0-92.5 Microscope/stain (CDFA_AM), MPN 137

Shipboard 4 1 12 Y 0-1.7 Microscope/stain (CDFA_AM), MPN 138

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 7 0 Y Y <0.1 - >240 MPN, plate counts 4,165

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory1 2 0 2 Y <0.1 - >60, Unk ([Chl a]) Visual Assessment, MPN, [Chl a] 148

Land-Based 11 9 N Y 0.0 - 3.7 Visual, Sytox, flow cytometer, PAM fluorometer 133

Shipboard1 1 1 3 Y 0-81 Visual Assessment, [Chl a] 76

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 3 0 2-3 Y 1 - 1.5 Grow out (+, -), Flow cam 73,74,75

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unkow n, MPN = Most Probable Number, 1 = Filter added to system since testing conducted

Aquaworx ATC Gmbh

21 Century 

Shipbuilding

ATLAS-DANMARK

Auramarine Ltd.

Coldharbour Marine

Electrichlor

COSCO/Tsinghua 

Univ.

DESMI Ocean Guard 

A/S

Brillyant Marine LLC

Ferrate Treatment 

Tech.

Appendix A2 Organisms 10 - 50 μm

ETI

atg UV Tech

EcologiQ

Alfa Laval

Ecochlor
111

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/ml Methods Reference

Laboratory 3 3 Y Y 0 (100% Mortality) Visual Assessment, Sytox Green 44,46,182

Land-Based 18 17 3 Y 0 - <0.01 Flow Cytometer, Sytox stain 132

Shipboard 5 0 3 Y <0.1 Flow Cytometer, Sytox stain, PAM fluorometry 132

Laboratory - - - - - - -

Land-Based 5 3 Y Y 0 - 7 Total Counts 167

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard 2 Unk Unk Unk Unk (% Mortality) Unk 51

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 1 0 Y Y 26 - 210 Visual Assessment, Coulter, MPN 70

Land-Based 10 0 Y Y 0.0 - 10.9 SYTOX Green, FCM, [Chl a] 134

Shipboard 3 1 9 Y 0.002 - 0.10 Visual, [Chl a], Grow out, neutral red 192

Laboratory 2 2 9 Y 0 Unk 107

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 2 9 Y 0 Unk MEPC 60/2/6

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 0 Unk Y 1 Unk 120

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 1 0 3 Y 0.05 - 0.186 MPN, [Chl a], 14C, PAM 64,65,189

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 5 0 5 Y 0.6-12 CDFA-AM, Chl a 79

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unkow n, MPN = Most Probable Number

Hamworthy 

Greenship

Hyundai Heavy 

Industries (1)

Hyundai Heavy 

Industries (2)

Hamann Evonik 

Degussa

Maritime Solutions 

Inc.

Hi Tech Marine

Hitachi

Hyde Marine

MARENCO

MAHLE

Kwang San Co. Ltd.

JFE Engineering Corp

Appendix A2 Organisms 10 - 50 μm

Mexel Industries
112

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/ml Methods Reference

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 4 Unk 3-5 Y BD, 206.6 - 387.4, Unk Visual Assessment (20 - 50um) 58,59

Shipboard 1 Unk Unk Y BD Visual Assessment 56

Laboratory - - - - - - -

Land-Based 1 0 Y Y Unk [Chl a] 170,171

Shipboard 4 Unk Y Y 443 - 593 Total Counts (Preserved), [Chl a], Regrow th 172

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 3 0 4 Y Unk [Chl a] 154

Land-Based 2 0 Y Y 22 - 190 Total Counts (Preserved) 50

Shipboard 3 0 5 Y 0.016 - 4 [Chl a], Grow Out, Counts 195

Laboratory - - - - - - -

Land-Based 14 5 3 Y 0-8.7 dilution, microscopy (CFDA stain), plate counts 139

Shipboard 2 0,Unk 3 Y 0-2.8 Microscope (CFDA stain), Photosynethic rates 176

Laboratory 1 0 - Y 26 - 210 MPN, Coulter 57

Land-Based 12 6 3 Y 0-92 Microscope/stain, MPN, agar plates 136

Shipboard 8 2 9 Y 0 - 3.9 Serial Dilution, Counts, Grow out 140

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 13 8 3 Y 0-35 Serial dilution, CFDA-AM 142

Shipboard 3 3 Y Y 0.0007 - 0.003 Microscope/stain (CDFA), MPN 147

Laboratory - - - - - - -

Land-Based 3 0 Unk Y 0.32 - 2.7 FDA stain, Flow CAM 3

Shipboard 2 0 3 Y 0.5 - 1.4 FDA stain, Flow CAM 2,3

Laboratory 1 1 Unk Unk 0 Visual Assessment 85

Land-Based 2 1 N Y 0 - 1 "Standard Operating Proc." 30,31

Shipboard - - - - - - -

Unk = Unknow n, BD = Below Detection Limits, MPN = Most Probably Number

Pinnacle Ozone 

Solutions

Mitsui Engineering

Panasia Co. 

OptiMarin

Appendix A2 Organisms 10 - 50 μm

MH Systems

NEI

NK-O3

Nutech O3 Inc.

OceanSaver

ntorreiro

Resource Ballast 

Tech

RWO Marine Water 

Tech

Qingdau Headway 

Tech
113

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/ml Methods Reference

Laboratory - - - - - - -

Land-Based 5 2 3-4 Y 0.002 - 10, BD ([Chl a]) MPN, [Chl a] 49

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 3 0 5 Y 0.5-6.8 CFDA PAM, Chl a 78

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 11 9 3 Y 0-4 Light micro., epifluor. and fluorometer (FDA stain) 62

Shipboard 3 3 3 Y 0 Light micro., epifluor. and fluorometer (FDA stain) 62

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, BD = Below Detection Limits, MPN = Most Probably Number, 1 = Filter added to system since testing conducted

Wartsila

Techcross Inc.

Severn Trent1 

Siemens

Sunrui CFCC

Appendix A2 Organisms 10 - 50 μm
114

Manufacturer Location # Tests # Tests Met Std Replicates Controls used # CFU/100 ml Methods Reference

Laboratory 2 2 Unk Unk 0 Unk 117

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory 1 0 - - Unk (% Reduction) - 82

Land-Based 12 12 6 Y 0 - 800 Membrane filtration 137

Shipboard 4 4* 9 Y 0* Membrane filtration 138

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 1 1 Y Y <1 Unk 4,165

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 10 10 N Y <0.1 NEN-EN-ISO 9308-1 133

Shipboard1 1 1 3 Y 0 - ~21 Idexx Labs Colilert 76

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 1 0 - - 300 Idexx Labs QuantiTray MPN 22

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unkow n, MPN = Most Probable Number, 1 = Filter added to treatment system since testing conducted, * = Initial concentration at intake w as 0, unk or non-detectable

ETI

Ferrate Treatment 

Tech.

Auramarine Ltd.

Brillyant Marine LLC

Coldharbour Marine

COSCO/Tsinghua Univ.

DESMI Ocean Guard 

A/S

Appendix A3 E. coli

Alfa Laval

Ecochlor

atg UV Technology

EcologiQ

Electrichlor

21 Century 

Shipbuilding

Aquaworx ATC Gmbh

ATLAS-DANMARK
115

Appendix A3 E. coli

Manufacturer Location # Tests # Tests Met Std Replicates Controls used # CFU/100 ml Methods Reference

Laboratory 1 1 Y - 0 Plate Counts 46

Land-Based 12 12 3 Y <0.1/ml Membrane filtration 132

Shipboard 4 4* 3 Y <0.1/ml Membrane filtration 132

Laboratory 1 1 - Y >1000 - 3000 Plate Counts 29

Land-Based 5 5 Y Y 0 - 1 Unk 167

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 6 6 Y Y 0 APHA 9222 32

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 10 10* N Y <10 NEN EN ISO 9308-1 134

Shipboard 3 3* 9 Y 0 Idexx Labs Colisure 192

Laboratory 2 2 9 Y 0 Unk 107

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 2 9 Y 0 Unk 119

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 2 Unk Y 0 Unk 120

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 5 5 5 Y 0 IDEXX kit, Membrane Filtration 79

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, * = Initial concentration at intake w as 0, unk or non-detectable

Hyundai Heavy 

Industries (1)

Hamworthy 

Greenship

JFE Engineering Corp

Mexel Industries

Maritime Solutions 

Inc.

MARENCO

Hamann Evonik 

Degussa

Hi Tech Marine

Hitachi

Hyde Marine

Hyundai Heavy 

Industries (2)

Kwang San Co. Ltd.

MAHLE
116

Manufacturer Location # Tests # Tests Met Std Replicates Controls used # CFU/100 ml Methods Reference

Laboratory 7 0, Unk Unk Y BD-420 IDEXX Colilert 18 41

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 2 0 3 Y BD, Unk Plate Counts 58

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 1 0 Y Y 10 - 160 Idexx Labs MPN Kit 170,171

Shipboard 2 2* Y Y <100 Idexx Labs MPN Kit 172

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard 3 3* 11-12 Y 0* IDEXX Labs MPN Kit 195

Laboratory - - - - - - -

Land-Based 14 14* 3 Y 0-123 Membrane Filtration 139

Shipboard 3 3* 3 Y 0* Membrane Filtration 176

Laboratory - - - - - - -

Land-Based 12 12* 3 Y 0-2 Membrane Filtration 136

Shipboard 8 8* 9 Y 0 Membrane Filtration 140

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 13 13* 3 Y <1 Plate Counts 142

Shipboard 3 3* Y Y 0 Membrane Filtration 147

Laboratory - - - - - - -

Land-Based 3 3 Unk Y 0 Unk 3

Shipboard 2 2* 3 Y 0 "Standard methods" 3

Laboratory - - - - - - -

Land-Based 2 2 N Y <15 - 32 EN ISO 9303-3 30,31

Shipboard - - - - - - -

Unk = Unknow n, MPN = Most Probable Number, BD = Below Detection Limits, * = Initial concentration at intake w as 0, unk or non-detectable

Appendix A3 E. coli

MH Systems

Mitsui Engineering

NEI

ntorreiro

Panasia Co. 

NK-O3

Nutech O3 Inc.

OceanSaver

OptiMarin

Resource Ballast Tech

RWO Marine Water 

Tech

Pinnacle Ozone 

Solutions

Qingdau Headway 

Tech
117

Manufacturer Location # Tests # Tests Met Std Replicates Controls used # CFU/100 ml Methods Reference

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 3 3 5 Y 0.10 - 0.20 Membrane Filtration 78

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 10 10* 3 Y 0 Plate counts 62

Shipboard 3 3* 3 Y 0 Plate Counts 62

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, * = Initial concentration at intake w as 0, unk or non-detectable

Sunrui CFCC

Appendix A3 E. coli

Wartsila

Techcross Inc.

Severn Trent 

Siemens
118

Manufacturer Location # Tests # Tests Met Std Replicates Controls # CFU/100 ml Methods Reference

Laboratory 2 2 Unk Unk 0 Unk 117

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 10 10 6 Y 0 - 4 Membrane filtration 137

Shipboard 4 4* 10 Y 0 Membrane filtration 138

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 1 1 Y Y <1 Unk 4,165

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 11 11 N Y <1 NEN-EN ISO 7899-2 133

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 1 0 Unk Unk 80 Idexx Labs QuantiTray MPN 22

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, * = Initial concentration at intake w as 0, unk or non-detectable.

Electrichlor

Brillyant Marine LLC

Coldharbour Marine

COSCO/Tsinghua 

Univ.

DESMI Ocean Guard 

A/S

21 Century 

Shipbuilding

Aquaworx ATC 

Gmbh

Appendix A4 Intestinal Enterococci

ETI

Ferrate Treatment 

Tech.

atg UV Technology

EcologiQ

Alfa Laval

Ecochlor

ATLAS-DANMARK

Auramarine Ltd.
119

Manufacturer Location # Tests # Tests Met Std Replicates Controls # CFU/100 ml Methods Reference

Laboratory - - - - - - -

Land-Based 12 12 3 Y <0.1/ml Membrane filtration 132

Shipboard 4 4* 3 Y <0.1/ml Membrane filtration 132

Laboratory - - - - - - -

Land-Based 5 5* Y Y 0 Unk 167

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 10 10* N Y <100 NEN EN ISO 7899-2 134

Shipboard 3 3* 9 Y 0-3.4 Idexx Labs Enterolert 192

Laboratory 2 2* 9 Y 0 Unk 107

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 2 9 Y 0 Unk 119

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 2 Unk Y 0 Unk 120

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 5 5 5 Y 0 IDEXX kit, Membrane Filtration 79

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, * = Initial concentration at intake w as 0, unk or non-detectable.

Hyundai Heavy 

Industries (2)

Kwang San Co. Ltd.

MAHLE

Hyundai Heavy 

Industries (1)

Appendix A4 Intestinal Enterococci

Hamworthy 

Greenship

Mexel Industries

Hamann Evonik 

Degussa

JFE Engineering 

Corp

Maritime Solutions 

Inc.

Hi Tech Marine

Hitachi

Hyde Marine

MARENCO
120

Manufacturer Location # Tests # Tests Met Std Replicates Controls # CFU/100 ml Methods Reference

Laboratory 3 0 Unk Y 90-350 IDEXX Enterolert 41

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 2 0 3 Y BD, Unk Plate counts 58

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 1 0 Y Y 36 Idexx Labs MPN Kit 170,171

Shipboard 2 Unk Y Y Unk Idexx Labs MPN Kit 172

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard 3 3* 11-12 Y 0* Idexx Labs Enterolert 195

Laboratory - - - - - - -

Land-Based 14 9* 3 Y 0-133 Membrane Filtration 139

Shipboard 3 3* 3 Y 0*-9 Membrane Filtration 176

Laboratory - - - - - - -

Land-Based 12 12* 3 Y 0 Membrane Filtration 136

Shipboard 8 8* 9 Y 0 Membrane Filtration 140

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 13 13* 3 Y 0.3 - <1 Membrane Filtration 142

Shipboard 3 3* Y Y 0.3 - 1 Membrane Filtration 147

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard 2 2 3 Y 5.0 - 9.3 "Standad methods" 3

Laboratory - - - - - - -

Land-Based 2 2 N Y neg Membrane Filtration 30,31

Shipboard - - - - - - -

Unk = Unknow n, BD = Below Detection Limits, * = Initial concentration at intake w as 0, unk or non-detectable

Appendix A4 Intestinal Enterococci

MH Systems

Mitsui Engineering

NEI

Qingdau Headway 

Tech

NK-O3

Nutech O3 Inc.

OceanSaver

ntorreiro

Panasia Co. 

OptiMarin

Resource Ballast 

Tech

RWO Marine Water 

Tech

Pinnacle Ozone 

Solutions
121

Manufacturer Location # Tests # Tests Met Std Replicates Controls # CFU/100 ml Methods Reference

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 3 3 5 Y 1.00 - 2.22 IDEXX kit 78

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 11 11* 3 Y 0-5 Plate counts 62

Shipboard 2 2* 3 Y 0 Plate counts 62

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, BD = Below Detection Limits, * = Initial concentration at intake w as 0, unk or non-detectable

Siemens

Appendix A4 Intestinal Enterococci

Wartsila

Techcross Inc.

Severn Trent 

Sunrui CFCC
122

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/100 ml Methods Reference

Laboratory 2 2 Unk Unk 0 Unk 117

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 10 10* 3 Y <1* Supplemented Agar Plates 137

Shipboard 4 4* 9 Y <1* Supplemented Agar Plates 138

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 1 1* Y Y <1 Unk 4,165

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory11 1 2 Y 0 (% cover) Plate Counts 148

Land-Based - - - - - - -

Shipboard11 0 3 Y BD - ~1000 Unk 76

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 1 0 Unk Unk 108 Indexx Labs QuantiTray MPN 22

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, * = Initial concentration at intake w as 0, unk or non-detectable, 1 = Filter added to system since testing conducted

Auramarine Ltd.

Brillyant Marine LLC

Coldharbour Marine

COSCO/Tsinghua Univ.

DESMI Ocean Guard 

A/S

Electrichlor

Ferrate Treatment 

Tech.

Aquaworx ATC Gmbh

ATLAS-DANMARK

21 Century 

Shipbuilding

Appendix A5 Vibrio cholerae

ETI

EcologiQ

Alfa Laval

atg UV Technology

Ecochlor
123

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/100 ml Methods Reference

Laboratory - - - - - - -

Land-Based 1 1* N N 0* culture, molecular methods 166

Shipboard - - - - - - -

Laboratory 3 2 Unk N 0-1 TSB broth, incubation 48

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard 3 3* 9 Y 0* PCR 192

Laboratory 2 Unk 9 Y BD Unk 107

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 2* 9 Y 0 Unk 119

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 2* Unk Y 0 Unk 120

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 5 5* 5 Y 0* DFA 79

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, BD = Below Detection, * = Initial concentration at intake w as 0, unk or non-detectable

Hamworthy 

Greenship

Hamann Evonik 

Degussa

JFE Engineering Corp

Appendix A5 Vibrio cholerae

Hyundai Heavy 

Industries (2)

Kwang San Co. Ltd.

MAHLE

Maritime Solutions 

Inc.

Hi Tech Marine

Hitachi

Hyde Marine

MARENCO

Hyundai Heavy 

Industries (1)

Mexel Industries
124

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/100 ml Methods Reference

Laboratory 1 Unk 3 N Unk (% Reduction) Plate Counts 52

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 2 0 3 Y BD, Unk Plate Counts 58

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard 2 2* Y Y 0 DFA 172

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard 3 3* 11-12 Y 0* Unknow n 195

Laboratory - - - - - - -

Land-Based 14 14* 3 Y <1* Plate counts (TCBS agar) 139

Shipboard 3 3* 3 Y 0* Plate counts (TCBS agar) 176

Laboratory - - - - - - -

Land-Based 12 12* 3 Y <1 Supplemented Agar Plates 136

Shipboard 8 8* 9 Y <1 Filtration, Plate count, PCR 140

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 13 13* 3 Y <1 Membrane Filtration 142

Shipboard 3 3* Y Y 0 Membrane Filtration 147

Laboratory - - - - - - -

Land-Based 3 3* Unk Y 0 Unk 3

Shipboard 2 2* 3 Y 0 Unk 3

Laboratory - - - - - - -

Land-Based 2 2 N Y neg APHA Std. Method 31,31

Shipboard - - - - - - -

Unk = Unknow n, BD = Below Detection Limits, DFA = Direction Fluorescent Antibody, * = Initial concentration at intake w as 0, unk or non-detectable

OceanSaver

Appendix A5 Vibrio cholerae

MH Systems

Qingdau Headway 

Tech

Panasia Co. 

Mitsui Engineering

NEI

NK-O3

ntorreiro

Resource Ballast Tech

RWO Marine Water 

Tech

Nutech O3 Inc.

OptiMarin

Pinnacle Ozone 

Solutions
125

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/100 ml Methods Reference

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 3 3* 5 Y 0 DFA 78

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 11 11* 3 Y 0* Plate counts (TCBS agar) 62

Shipboard 3 3* 3 Y 0* Plate counts (TCBS agar) 62

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, BD = Below Detection Limits, DFA = Direction Fluorescent Antibody, * = Initial concentration at intake w as 0, unk or non-detectable

Sunrui CFCC

Siemens

Severn Trent 

Appendix A5 Vibrio cholerae

Wartsila

Techcross Inc.
126

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/100 ml Methods Reference

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory 1 0 - - Unk (% Reduction) Visual Assesment 82

Land-Based 8 0 6 Y 820/ml - 4x108/ml Agar Plate Counts 137

Shipboard 2 2 9 Y 480 - 800 Plate Counts, Difco marine agar 141

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based 1 0 Y Y 80/ml - 1200/ml Unk 4,165

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory1 2 2 2 Y 0,Unk (% of control, % Plate cover) Plate Counts, 3H-leucine 148

Land-Based 11 8 N Y <10 - 1700 plate, NEN-EN-ISO 6222:1999 133

Shipboard1 1 1 3 Y BD Plate Counts, 3H-leucine 76

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 1 0 3 Y - Plate Counts, BacLight 72

Land-Based 3 0 2-3 Y 5x107 - 1x109 Grow out (+, -), FCM/PicoGreen 73,74,75

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, BD = Below Detection Limits, FCM = Flow Cytometer, 1 = Filter added to system since testing conducted

Electrichlor

Brillyant Marine LLC

Coldharbour Marine

COSCO/Tsinghua Univ.

DESMI Ocean Guard 

A/S

21 Century 

Shipbuilding

Aquaworx ATC Gmbh

Appendix A6 Organims < 10 μm (Bacteria)

ETI

Ferrate Treatment 

Tech.

ATG Willand

EcologiQ

Alfa Laval

Ecochlor

ATLAS-DANMARK

Auramarine Ltd.
127

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/100 ml Methods Reference

Laboratory 2 0 Y Y 3.8x107 - 4.6x107 Plate Counts, PicoGreen 182

Land-Based 13 1 3 Y <10/ml - 4.6 x 107 PicoGreen, Agar Plate 132

Shipboard 4 3 3 Y 5-15/ml heterotrophic bacteria, plate 132

Laboratory - - - - - - -

Land-Based 5 2 Y Y 0 - 6000 Unk 167

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 6 5 Y Y 1 - 1.9x106 APHA 9215B, pour plate method 32

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 1 0 Y Y ~5000 - 7000 Plate Counts 70

Land-Based 10 5 Y Y <1000 - >100000 Plate Counts, AODC 134

Shipboard 3 3 9 Y 1 - 148 Plate Counts 192

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 2 2 Unk Y 0 Unk 120

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - -

Land-Based 3 2 3 Y 0 - ~5x108 Plate Counts, Membrane Filtration 64,65,189

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 5 3 5 Y 116.88-7860 Plate Counts 79

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, AODC = Acridine Orange Direct Counts, FCM = Flow Cytometer

Hyundai Heavy 

Industries (2)

Kwang San Co. Ltd.

MAHLE

Hyundai Heavy 

Industries (1)

Appendix A6 Organims < 10 μm (Bacteria)

Hamworthy 

Greenship

Mexel Industries

Hamann Evonik 

Degussa

JFE Engineering Corp

Maritime Solutions 

Inc.

Hi Tech Marine

Hitachi

Hyde Marine

MARENCO
128

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/100 ml Methods Reference

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 2 0 3 Y BD, Unk Plate Counts 58

Shipboard 1 0 - Y BD Plate Counts 56

Laboratory - - - - - - -

Land-Based 2 0 Y Y > 1x108 FCM 170,171

Shipboard 2 0 Y Y 7.3x107 - 7.9x107 FCM 172

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory 3 3 4 Y < 101 - 108 Plate Counts, Membrane Filtration 154

Land-Based 3 3 Y Y 3x10-1 - 3x102 Plate Counts, Membrane Filtration 50

Shipboard 2 2 9-12 Y 0 Plate Counts, Filtration 195

Laboratory - - - - - - -

Land-Based 5 5 3 Y 0 - 8.2x105/ml Plate Counts 139

Shipboard - - - - - - -

Laboratory 2 0 Unk Y ~ 5x103 - ~7x103 Plate Counts 57

Land-Based 12 2 3 Y 9-220/ml Agar Plate Counts 136

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 13 9 3 Y 30 - 19000 Plate Counts 142

Shipboard 3 3 Y Y 243 - 590 Plate Counts 147

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, FCM = Flow Cytometer, BD = Below Detection Limits

Panasia Co. 

OceanSaver

OptiMarin

Resource Ballast Tech

ntorreiro

Pinnacle Ozone 

Solutions

Qingdau Headway 

Tech

RWO Marine Water 

Tech

Appendix A6 Organims < 10 μm (Bacteria)

MH Systems

NEI

NK-O3

Nutech O3 Inc.

Mitsui Engineering
129

Manufacturer Location # Tests # Tests Met Std Replicates Controls # Organisms/100 ml Methods Reference

Laboratory - - - - - - -

Land-Based 4 4 3-4 Y <1 - 1010 Plate Counts, Membrane Filtration 49

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 3 0 5 Y 169100 - 1515200 Plate Counts 78

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Laboratory - - - - - - -

Land-Based 4 4 3 Y 0 - 500 plate counts, DAFI stain 63

Shipboard 3 Unk 3 Y Unk Fluorescent microscopy (DAFI) 62

Laboratory - - - - - - -

Land-Based - - - - - - -

Shipboard - - - - - - -

Unk = Unknow n, 1 = Filter added to system since testing conducted.

Techcross Inc.

Appendix A6 Organims < 10 μm (Bacteria)

Severn Trent1 

Siemens

Sunrui CFCC

Wartsila
130

APPENDIX B

California State Lands Commission

Advisory Panel Members

Ryan Albert U.S. Environmental Protection Agency

Marian Ashe (2007 only) California Department of Fish and Game

John Berge Pacific Merchant Shipping Association

Dave Bolland Association of California Water Agencies

Brad Chapman (2007,2009) Chevron Shipping Company

Sejal Choksi San Francisco Baykeeper

Andrew Cohen San Francisco Estuary Institute

Tim Eichenberg (2007 only) The Ocean Conservancy

Richard Everett United States Coast Guard

Naomi Feger San Francisco Bay Regional Water Quality Control Board

Andrea Fox California Farm Bureau Federation

Dominic Gregorio State Water Resources Control Board

Marc Holmes The Bay Institute

Rian Hooff Oregon Department of Environmental Quality

Bill Jennings The DeltaKeeper

Edward Lemieux Naval Research Laboratory

Karen McDowell San Francisco Estuary Project

Steve Morin Chevron Shipping Company LLC

Allen Pleus Washington Department of Fish & Wildlife

Darrin Polhemus State Water Resources Control Board

Kevin Reynolds The Glosten Associates

Greg Ruiz Smithsonian Environmental Research Center

Spencer Schilling Herbert Engineering Corp.

Sharon Shiba California Department of Fish and Game, OSPR

Jon Stewart International Maritime Technology Consultants Inc.

Lisa Swanson Matson Navigation

Mark Sytsma Portland State University

Drew Talley (2007, 2009) San Francisco Bay National Estuarine Research Reserve

Kim Ward (2007, 2009) State Water Resources Control Board

Nick Welschmeyer Moss Landing Marine Laboratory
131

California State Lands Commission

2010 Treatment Technology Assessment Report

Technical Advisory Panel

April 15, 2010

Meeting Notes

Attendees

Sharon Shiba, California Department of Fish and Game

Steve Morin, Chevron Shipping

Maurya Falkner, California State Lands Commission

Jackie Mackay, California State Lands Commission

Nicole Dobroski, California State Lands Commission

Lynn Takata, California State Lands Commission

Gary Gregory, California State Lands Commission

Kevin Mercier, California State Lands Commission

Cameron Baker, Herbert Engineering

Tom Burke, California State Lands Commission

Rian Hooff, Oregon Department of Environmental Quality

Lisa Swanson, Matson Navigation

Nick Welschmeyer, Moss Landing Marine Laboratories

John Berge, Pacific Merchant Shipping Association

Ryan Albert, U.S. Environmental Protection Agency

Purpose of Meeting 

California Public Resources Code requires that the California State Lands Commission 

produce a report for the state legislature reviewing the efficacy, availability and 

environmental impacts of ballast water treatment systems 18 months before the 

implementation dates for California‟s performance standards for ballast water discharge. 

The purpose of this meeting is to review and discuss a draft report evaluating treatment 

systems for new build vessels with a ballast water capacity over 5000 metric tons (MT), 

before the implementation date on January 1, 2012.
132

Report Timeline

This draft report was provided to this Technical Advisory Panel (Panel) during the week 

of April 5th. Today‟s meeting will focus on discussion of major content issues for that 

draft. To maximize discussion time, the TAG is requested to submit editorial type 

comments via email by April 23, rather than discuss them at this meeting. Following 

this meeting, the goal will be to complete a revised draft in early May that will be 

provided to Commission executive staff for review. A draft final version will be posted 

for public comment on the Commission website two weeks before the Commission 

meeting (currently scheduled for June 28th). Public comments may be submitted in 

writing before the Commission meeting or comments may be submitted in person during 

the public comment portion at the meeting. The final, Commission-approved report is 

due to the California State Legislature by July 1, 2010.

Highlights of the Draft Report

The format of this report is based on the previous 2009 assessment report that 

evaluated treatment systems for new build vessels with ballast water capacity less than 

5000 MT. Revisions/updates for the 2010 draft include: 

New information on related State and Federal programs 

This report covers 46 systems – ranging from chemical to UV filtration systems 

(majority). 

Efficacy: The quality and quantity of testing data from treatment vendors has 

improved, including better 3rd party testing data and more large scale land-based 

facility testing. Though most testing has been done to meet International 

Maritime Organization (IMO) standards and requirements, the data also 

addresses California‟s standards. 

Robust and widely accepted test procedures still do not exist for viral standards, 

so the systems were not evaluated against California‟s viral standard.

Nine systems appear to have the potential to comply with California‟s standards, 

though California will not be approving systems. Commission staff reviewed the 

available data, and if at least one replicate met CA standards, the system was 

considered to have the “potential” to comply. Ultimately, it is up to vessel 
133

owners/operators working with vendors to select systems that are appropriate for 

their vessels‟ routes and water conditions.

Of the 9 systems, 8 are commercially available. The one that is not is the 

Hamann system, which was pulled from production due to potential toxicity

problems. It is not clear if they will continue to pursue the system.

Availability: The ability of systems to handle large ballast water capacities was 

considered a potentially new issue with the current class of vessels, and was 

investigated by staff. However, since most systems treat on uptake and/or 

discharge, the ballast water uptake/discharge rates of ballast pumps were found 

to be a more important factor than total ballast water capacity in determining the 

availability of systems. Systems must be able to keep pace with ballasting rates. 

Data on pump rates of vessels visiting California was reviewed, and in general,

most systems are designed to keep up with observed pump rates.

Environmental Impacts: Current requirements are the purview of the U.S. 

Environmental Protection Agency‟s (EPA) Vessel General Permit and California

additions through the Clean Water Act Section 401 Certification process. These 

issues are the purview of the California State Water Resources Control Board

(Water Board) rather than the Commission, but staff did evaluate systems 

against the chlorine discharge standard, since several systems use it as an 

active substance. Most systems that use chlorine can comply with chlorine 

standard, but not all. Currently the systems that may not comply did not provide

adequate or appropriate data. For example, the detection limits of the tests 

measuring chlorine residuals was not sensitive enough to determine compliance 

with EPA standards. Commission staff is encouraging vendors to consult with 

Water Board to make sure they meet these and other water quality requirements.

Economics: Costs have not changed significantly from the 2009 report. There 

has been a slight drop in price for smaller capacity systems (200 cubic meters 

per hour), and it is likely that research and development costs will decrease as 

vessels begin purchasing and installing them. The average cost of larger 

capacity systems has not changed since the last report.
134

The MISP plans on taking an adaptive management approach for implementing 

performance standards

No specific recommendations to the State Legislature are included in this report.

Update on Related Marine Invasive Species Program (MISP) Activities

In 2010 the performance standards went into effect for new build vessels with a ballast 

water capacity less than 5000 MT. Since these are new vessels, they probably won‟t 

call to California ports until 2011. Commission staff is currently completing a rulemaking

for reporting forms that will be required of vessels using treatment systems in California 

waters. These are expected to be approved by the Office of Administrative Law in early 

August. These forms will be required as systems are used and standards are 

implemented in California.

MISP staff provided comments on U.S. Coast Guard (USCG) proposed rule for 

performance standards, and are working with the EPA on Environmental Technology 

Verification (ETV) protocols for land-based ballast water treatment system testing. Staff 

are also consulting with federal, state, and international entities on the implementation 

of performance standards, and compliance verification.

Major Panel Comments & Discussion (Paraphrased and Edited)

Berge: Since much of the data provided by vendors is based on the IMO G8 testing 

protocols, how can it be used to gauge a system‟s potential to meet California‟s much 

more stringent standard? 

o Dobroski: Vendors are providing data, rather than saying simply “yes” or 

“no” to meeting the IMO standard. Commission staff used this data to see if it 

also meets California‟s standards. While there are issues around volumes 

necessary to test at certain levels of statistical significance, those volumes 

are unwieldy and impractical. No one is providing data on that level, nor is 

testing occurring at that level.
135

Berge: The industry is concerned about this, because it isn‟t clear if these systems can 

meet California‟s standards if testing protocols required are ultimately different from 

IMO‟s.

o Falkner: In discussions with folks from land-based testing facilities, it appears 

that results from systems they have tested are very accurate, you are 

probably getting good numbers with their data. The bigger issue is how to 

translate shore-based testing to the efficacy of a system on a ship, and how 

compliance verification will be completed. Though that problem applies to 

IMO, the USCG, as well as California. 

o Dobroski: The majority of systems that appear to meet CA standards are 

going through the robust, go-to land-based facilities/testing organizations 

such as NIOZ (Royal Netherlands Institute for Sea Research) or NIVA

(Norwegian Institute for Water Research).

o Welschmeyer: The IMO G8 testing protocols are probably not appropriate to 

evaluate California‟s standards. 

o Dobroski: Some systems have met standards in only one replicate, but 

some have made it for many replicates. Our goal is to demonstrate potential 

compliance – really it depends on the vessel type, its route, etc. to select a 

truly appropriate system.

Berge: Comments to the USCG proposed rule by University of Maryland scientists 

(Tamburri, Wright) attest that no system has been proven to meet standards better than 

IMO. When the industry approaches vendors, they now say they are not confident they 

can meet anything more stringent than IMO. This report is providing the information 

that systems can meet California‟s performance standards. There appears to be a 

disconnect there.

o Falkner: Perhaps we need to chat again with vendors and see if they still

believe they can meet CA standards (they have claimed in the past that they 

could). 
136

o Dobroski: Oceansaver has told us that they can meet California‟s standards. It 

is possible that vendors may not being totally honest, as they want governments 

to go ahead with implementing standards laws.

o Falkner: Depending on what kind of feedback we get from vendors, perhaps we 

need to reevaluate our report. We don‟t want to impose a law that no one can 

meet. 

Berge: Is it possible to give CSLC more flexibility/control without going through the 

legislature which is too slow? As it stands we have to guess two years in advance on 

what will happen with advancing technologies. It would be better if it can be dealt with 

more nimbly by the Commission.

o Gregory: There is probably not support for that amongst the Commission. The 

report does need to address the current and real situation, and we‟ll have to 

decide what a recommendation from this report might say. 

o Berge: The intention would not be to change the standard in statute, but to have 

more flexibility with implementation extensions. This issue has only recently 

come about – vendors are now realizing they must be more honest to shipping 

companies about the capabilities of their systems, or they eventually have no one 

buying their systems.

o Baker: There doesn‟t appear to be a system that can meet the standards 100% 

of the time. Vendors will probably say this too. They probably won‟t say that their 

system will meet a standard unless it passes tests 99% of the time. If the data 

from the 2009 CSLC report indicates that two systems passed one test

(replicate) out of five, are we saying that this will meet CA„s standard? Most 

people will not agree. 

o Falkner: At this point we say such systems have the “potential”. A huge problem 

in the past has been limited data. Since then data has gotten much better, so 

perhaps we should verify from vendors how confident they are that they can 

meet CA standards, and how often and under what circumstances they think

their systems can do it. 
137

o Gregory: From a legal perspective, 75% compliance isn‟t good enough. If I was 

a ship owner, I wouldn‟t like that either. Short of a legislative change, we (CSLC)

don‟t have the authority to say at 75% compliance you‟re okay. You‟re either in 

compliance or not. From a practical perspective, if no one can comply, we may

have to look into changing the standards.

o Falkner: From the perspective of this report, it is important to know at what level 

systems can comply, and what situations are better or worse. 

o Berge: The fact is that shipping lines will install systems that meet IMO 

standards and show promise to meet CA standards too. I don‟t think looking into 

this issue will stop progress. 

Welschmeyer: Is the topic of concern that the CSLC report is too optimistic? Is there 

something wrong with being too optimistic? I agree that testing to non-detect is not 

possible to do well at the moment, but is there something misleading or detrimental 

about the report‟s claims? Aren‟t we doing a disservice to the currently rapid and 

wonderful progress of treatment technologies if we are not optimistic? 

o Berge: In discussions with Washington, DC folks on the debate surrounding

what‟s achievable consistently, it has come up that you as a ship owner/operator

can be held legally accountable, even if you‟re hearing different stories about a 

system‟s capabilities from vendors, the USCG and CSLC (and others). From a 

public policy perspective, if you are to be held legally liable, you need a higher 

level of assurance than “probably.” 

o Gregory: We should call it as straight as possible, and not be overly optimistic. 

If ship owners can‟t find a vendor that will say they can meet CA‟s standard, and 

we say they can, it‟s a problem.

o Hooff: The crux of the issue is what measuring stick is used to evaluate 

systems. The report started during a time when there was a lack of data 

available. So, the measure of at least one replicate may have been appropriate 

back then, but it may be that that stick needs to be revised now that more data is 

available. Perhaps as data gets better, the reports need to step up evaluation 

criteria. This report isn‟t being misleading, because it‟s using the same 
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measuring stick as in the past, but perhaps it‟s time to use a different one. 

Regardless, these reports provide an excellent service to managers like me and 

ship owners as well, with all the information included.

o Berge: Agrees that the information is great, but the conclusion is very optimistic, 

and conclusions are what policymakers/legislators focus on, not all the details. 

o Swanson: Matson engineers are not putting systems on ships unless they have 

better assurances (certifications or vendor assurance). It is a big problem that 

California is not approving systems. If you look only at the conclusions or tables

in this report (as policy makers do) there will be misunderstandings.

o Welschmeyer: I appreciate that honesty is needed but at same time it‟s 

heartening to see now that vendors are having a chance to meet someone‟s 

standards somewhere. There‟s an optimism also amongst labs testing for 

standards. It‟s going to get more difficult that California has standards that are 

impossible to measure with statistical certainty, but does that mean that the state

and the vendors should throw up their arms and give up efforts to protect the 

environment at the levels that we want to? We‟re on our way to doing something 

that is environmentally wise and constructive. 

o Berge: To be fair, though, someone will be found liable, and the only party 

bearing that burden is the shipping industry.

o Berge: Aren‟t systems that are meeting the IMO standards really designed to 

meet zero? 

o Falkner: Yes, and in discussions with folks at NIOZ, systems are either going 

way beyond IMO or completely crashing and burning. There‟s very few that are 

barely meeting IMO. 

Baker: Optimism is good, but I am having difficulty with the conclusion that we are 

there [ready to meet the CA standard]. In my opinion, we are not. 

o Falkner: A big difficulty is that we have to put a report out 18 months in advance 

of an implementation date, so we have to pontificate a bit, which is hard. 

o Berge: Could we state something in the conclusions like there are indications for 

compliance potential, however it‟s questionable that systems can meet the 
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standards consistently under a regulatory regime? It‟s one thing to say that 

promising systems are out there, but consistency is difficult. 

o Falkner: But no system is going to work 100% of the time, that‟s not realistic. 

Even when a system doesn‟t work, the CSLC policy has always been to try to 

work with industry to meet the intent/letter of the law. 

o Berge: However, there‟s a concern for the industry over citizen lawsuits

Swanson: How does the viral standard play out? It‟s not testable, but the standard

remains as is. That will be a problem if we have to install systems now that may have to 

meet a viral system later. Again, lack of certification by California is a problem.

o Gregory: There are lots of things on ships that, if operated according to 

established rules, are accepted by regulatory entities. 

o Swanson: It doesn‟t seem like this program is going that way. You‟re not 

certifying. It‟s up to ships to self-certify, yet we‟ve got a standard we can‟t test 

for. It‟s all on the shipping industry, there„s nothing that puts responsibility on the 

vendor. 

o Gregory: Disagrees. It‟s dependent on the contract established by the vendor 

and ships. MSDs are like that, oily water separators are that way, etc... 

o Berge: Perhaps it should be written into the report that a contract must be 

established between vendor and ship owner. 

o Shiba: If something is not testable, then is it considered non-detectable, and so 

meets the standard? At the time that viruses become testable, perhaps then you 

change the law and allow the Commission to make a determination about 

grandfathering.

o Gregory: Recall that performance standards were meant to be technology 

pushing, if it can‟t be developed it must be go to the legislature for addressing. 

o Berge: Those caveats should be added to the conclusion. 

o Morin: I understand the concept of contracts like MSDs, but the issue is that 

those have been around for decades. If I ask for an indemnity clause from a 

vendor, and they say no, then what do we do? 

o Gregory: Then there‟s no system that can be considered available. 
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o Falkner: This isn‟t the first “new technology” issue for ships. How was this done 

in the past? 

o Gregory: What about air emissions? The manufacturer is certifying that the 

engine will meet standards if operated properly, and vessels get fined if they 

don‟t meet them. It‟s the same thing – engines are not certified by a regulatory 

agency. A ship owner would be crazy to buy a system that the manufacturer 

won‟t certify for meeting a requirement. The regulatory scheme here is the 

same. The indemnification issue is up to shipping companies. 

o Berge: If we get to the point that vendors will certify and provide indemnification, 

we‟d be comfortable. 

Berge: On availability, did you look at service and repair worldwide? 

o Dobroski: That section (included in the last report) was removed from this 

report. The 9 systems mentioned here claim that they will be available worldwide 

for service. We can put that information back in the report.

Hooff: Are the max pump rates in Figure 6.2-6.3 for all vessels? What if you just 

break out the only the 20% that discharge? 

o Dobroski: Pump rates were analyzed for all vessels visiting California with a 

ballast water capacity over 5000 MT, but not broken down by dischargers vs. 

nondischargers. 

o Falkner: About 75% of vessels operating in CA don‟t discharge, but vessels are 

not consistent on when they do or don‟t. They can go years without discharging, 

then suddenly do. That‟s why we used all ships. 

o Hooff: Suggest adding that clarifying language. 

o Falkner: Given time constraints, we might be able to look at vessel activity 

history, and refine the data.

Berge: Are there any vessels under 5000 MT that have installed systems? 
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o Dobroski: Not that we‟re aware of, but vendors have said they‟ve gotten 

inquiries. But vessels that visit California are only a small percentage of all 

vessels out there.

Welschmeyer: The report contained all elements of the issue very nicely. Is a very 

complex problem – I‟ve come to appreciate all the content included, and have found 

many ideas I would have never thought of on my own. It is very spot on, including the 

optimism. I generally feel that all vendors/developers are doing such a much better job 

than before.