Page 1 of 1

Telephone Record 

Date: February 23, 2012 

From: Mary Willett To: Mr. Peter McNulty

Company: ERG NEI Marine 

Phone #: 213-383-5855

RE: Feasibility of Ballast Water Treatment (BWT) for Small Vessels 

Identified myself and the purpose of my call. Indicated that we are not authorized to 

handle CBI and information provided could be made public without notice. 

Asked about capacity of BWT systems for small vessels. Mr. McNulty did not have any 

information on capacity for smaller vessels. 

Asked about feasibility and safety of using deoxygenation/cavitation for smaller vessels. 

Mr. McNulty commented that he believed the technology could be scaled down for use 

with small vessels and that they looked at lab-scale units several years ago when they 

were first developing the technology for larger vessels. He thought that the technology 

would not be used on passenger vessels (and they have made a decision not to 

recommend it for cruise ships) because of the potential proximity of deoxygenation 

equipment to a passengers room. For smaller vessels it is possible that smaller 

compressed gas cylinders for use in the BWT system may be possible and could be 

automated for use. 

Asked about effectiveness of the technology and whether he thought it would be as 

effective if scaled down to a small vessel. Mr. McNulty commented that the technology 

should be just as effective regardless of the size. 

Asked what the limiting issues would be to try to incorporate the 

deoxygenation/cavitation BWT technology onto a small vessel. Mr. McNulty 

commented that space might be the most limiting factor, however noted that one of the 

first prototypes was installed on a large tug boat (with part of the system on the tug and 

part on barge) 

Asked if he was aware of any costing data for smaller type systems. Mr. McNulty 

commented that he was not aware of any costing data for smaller systems. For their 

technology the costs generally go up as the size decreases, however, if the system were 

designed with small compressed gas cylinders you could make it more cost effective. 
Telephone Record 

Date: February 22, 2012 

From: Mary Willett To: Mr. Jon Stewart

Company: ERG IMTC 

Phone #: 954-565-4044

RE: Feasibility of Ballast Water Treatment (BWT) for Small Vessels 

Identified myself and the purpose of my call. Indicated that we are not authorized to 

handle CBI and information provided could be made public without notice. 

Asked about capacity of BWT systems for small vessels. 

Mr. Stewart indicated that the smallest systems he has seen have a 100 m3/hr capacity. 

Asked whether it is feasible to scale BWT technologies to vessels that are <1,600 metric 

tons or have ballast tanks <8 m3. 

Mr. Stewart felt that many BWT systems could be scaled down. However, the economics 

of designing such systems have precluded the vendor industry from looking at what 

would be considered a “niche” market. It is still not a robust market even for the systems 

that have been designed and tested for large vessels. He commented that UV and 

electrolytic chlorination systems exist for swimming pools and “under the sink” drinking 

water systems that are essentially scaled down versions of the some of the technologies 

used for ballast water. He commented that the industry uses electrolytic systems for 

cooling water on ships. He thought that stand alone technologies (UV, ozone, filter) 

would lend themselves better to scaling down compared to more complicated integrated 

process systems. He indicated that there is not a pure chemical solution to BWT at this 

point and integrated technologies are required to address the problem. He also 

commented that scaling down deoxygenation type systems would likely be more difficult 

than chemical based systems. 

Asked whether there is a minimum footprint for BWT systems on small vessels. 

Mr. Stewart commented that if the smallest BWT system available now is 100 m3/hr, that 

size of a system would be too big for placement on a small vessel. 

Asked whether a scaled down BWT system would be likely to create weight concerns. 

Mr. Stewart felt that scaling down a system would result in a similar drop in the system’s 

weight. 

Asked about any safety issues with the use of BWT systems on smaller vessels. 
Page 2 of 2

Mr. Stewart commented that whatever system was designed for a smaller vessel would 

still need to meet the same safety requirements of the systems available now so the same 

safety measures would apply regardless of the system size. 

Asked if he thought scaled down technology would be as effective as current systems and 

likely to comply with the IMO D-2 standards. 

Mr. Stewart indicated that for technologies, such as chemical dosing systems, so long as 

the appropriate dose of chemical is applied it wouldn’t matter what the system size was 

and he did not think that scaling down the technology would be likely to impact its 

effectiveness for treatment. 

Asked what the limiting issues would be for trying to incorporate BWT technology to 

smaller vessels. 

Mr. Stewart had several points regarding the feasibility of trying to incorporate BWT to 

smaller vessels as follows: 

1. The small vessel market would be a niche market for technology developers. 

2. He did not think that smaller BWT systems would be economically viable given 

the required design costs that would be required. These systems are not currently 

available and would require specific design for automation and installation into 

smaller vessels. 

3. Any system will require certification to meet the current requirements including 

land testing at 200 m3/hr. 

4. Use of these systems on smaller vessels will still require meeting monitoring and 

reporting requirements and Mr. Stewart felt that these requirements would be 

costly for smaller vessels. 
From: "M. Merksamer" <marcie.merksamer@ecochlor.com> 

To: "'Mary Willett'" <Mary.Willett@erg.com> 

CC: <tom.perlich@ecochlor.com> 

Date: 2/23/2012 7:00 PM 

Subject: RE: Feasibility of Filter + Chlorine Dioxide Ballast Water Treatment Systems to Small Vessels 

Attachments: Ralph Michael.vcf 

Dear Ms. Willet, 

Thank you for your inquiry. At this time, the very small treatment systems 

that would be required for the vessels you are seeking information for are 

not Ecochlor's target market. 

For smaller treatment systems, Ecochlor refers inquiries to Mahle, which 

offers a UV/Filtration ballast water treatment system. I've included 

contact information below. 

Ralph Michael 

If I can be of further assistance, please let me know. 

Best Regards, 

Marcie Merksamer 

Regulatory Consultant/Compliance Manager 

Ecochlor, Inc. 

P.O. Box 2136 

Pismo Beach, CA 93448 

Phone: 805-331-0740 

Fax: 805-473-3961 

marcie.merksamer@ecochlor.com 

www.ecochlor.com 

From: Mary Willett [mailto:Mary.Willett@erg.com] 

Sent: Wednesday, February 22, 2012 9:59 AM 

To: marcie.merksamer@ecochlor.com 

Subject: Feasibility of Filter + Chlorine Dioxide Ballast Water Treatment 

Systems to Small Vessels 

 

Ms. Merksamer: 

 

Hello, I am Mary Willett an engineer with ERG. We are a technical 

contractor for EPA's Office of Wastewater Management and are supporting EPA 

in their evaluation of the Vessel General Permit. As part of that effort, 

we are supporting EPA in evaluating whether ballast water treatment systems 

are feasible for smaller vessels. Specifically, whether they might be 

feasible for commercial vessels that are smaller than 1,600 metric tons 

and/or vessels with ballast tanks smaller than 8 cubic meters. I would like 

to see if you could provide some information about the feasibility of a 

filter + ClO2 system for smaller vessels. 

 

Under our EPA contract for this work, we are not authorized to handle 

Confidential Business Information. Therefore, I would like to see what 

information you could provide that could be made public without notice. If 

you have information that would be useful but would need to be handled as 

CBI, I can provide you with contact information for our EPA client and the 
information could be sent directly to him. [Ryan Albert, EPA/OWM, Program 

Manager for Vessel General Permit] 

 

The types of vessels that fall into these smaller size categories include: 

commercial fishing vessels, 

freight ships (such as a Gate Lifter or general cargo), 

passenger vessels (such as crew boats, inland river towboats, vessels for 

less than 100 passengers, small cruise boats, and small ferries), 

utility vessels (such as liftboats, offshore crewboats and supply vessels, 

tug boats, etc.) 

 

Do you know of any Ballast Water Treatment (BWT) systems currently being 

marketed that would be applicable to a smaller vessel? The smallest systems 

that we have identified as available are for at least 100 m3/hr. Do you 

know of any smaller? 

 

 

 

Would be it feasible to scale a filter + ClO2 BWT technology to vessels < 

1,600 MT? 

 

If a filter + ClO2 system were scaled down to you know whether its footprint 

could be made small enough to fit on a smaller vessel? 

 

Can you estimate what the weight of such a system would be? [would be likely 

that if a system could be scaled down its weight would also be lower] 

 

Would there be safety issues with the use of a filter + ClO2 BWT technology 

on a smaller vessel that would be different than on a larger vessel? 

 

Would a scaled down version of the technology be as effective and likely to 

comply with the IMO D-2 standards? 

 

What would you see as the limiting issues for trying to incorporate a filter 

+ ClO2 BWT technology into a smaller vessel? (for example, design costs, 

the footprint of the technology, cost, effectiveness of treatment, 

complexity of the system?) 

 

Are you aware of any costing information that would apply to a scaled down 

BWT technology system? 

 

I understand from your voicemail that you are out this week and will try to 

contact you next week when you are back. Any information that you might 

have to address these issues is greatly appreciated! 
 

Mary R. Willett 

Mary R. Willett 

ERG 

(703) 633-1615 

mary.willett@erg.com 
From: Mark Riggio <MRiggio@hydemarine.com> 

To: "Mary Willett" <Mary.Willett@erg.com> 

CC: Jim Mackey <JMackey@hydemarine.com>, "Tom Mackey" <TMackey@HydeMarine.com> 

Date: 2/24/2012 11:38 PM 

Subject: Re: Fwd: Feasibility of Ballast Water Treatment Systems to Small Vessels 

Mary: 

Thank you for your email and interest in our system. With Jim out of the office this week, I took a few minutes today to get you the information 

you requested. The answers to your questions are listed below: 

Do you know of any BWTS that are currently being marketed that would be applicable to a smaller vessel? Yes, the Hyde GUARDIAN HG60 

is a UV/Filter treatment system designed specifically for low flow, space constrained locations. We designed this product with the small vessel 

market in mind. 

Would it be feasible to scale a solids separation and UV BWT technology to vessels <1600 MT? Absolutely. 

If a solids separation and UV system were scaled down, do you know whether its footprint could be made small enough to fit on a smaller vessel? 

We currently install our systems on offshore supply vessels and are in the process of installing in a small passenger tour-vessel in the Great Lakes 

for the National Parks Service. Each of these applications have very narrow space restrictions. The footprint of our HG60 skid-mounted system 

is 2.1m long x 1.5m wide. This system, however, may be further broken down in size as a component system. 

Would it be likely that if a system could be scaled down its weight would be low enough not to create stability issues in smaller vessels? Yes. 

Our HG60 system weighs less 1000 kg including the skid. 

Would there be safety issues with the use of a solids separation and UV BWT technology on a smaller vessel that would be different than on a 

larger vessel? No, there would be no difference for our system between a large or small vessel. 

Would a scaled down version of the technology be as effective and likely to comply with the IMO D-2 standards.? Yes. Our scaled down HG60 

is one of our highest performing systems based upon computational flow dynamics analysis. The small size of the reactor shell combined with 

the relatively low flow rates exposes the stream to a high dose of UV in relation to our larger reactors. 

What would you see as the limiting issues for trying to incorporate a solids separation and UV BWT technology into a smaller vessel? Primary 

limitations on these applications are power requirements, pump configuration and initial installation of the equipment. Access to piping and 

engine spaces is restricted to bring larger items into them, which means accesses may need to be cut in the hull or superstructure to install the 

systems. Also, as smaller vessels often use multi-purpose pumps for ballasting, their performance curves, piping configurations and location in 

the engine room may create specific challenges to retrofit. 

Are you aware of any costing information that would apply to a scaled down BWT technology system? An HG60 skidded system would cost 

less than $200,000 for typical installations. Installation costs would be separate. 

Hopefully that helps. Please feel free to contact me if you need any additional information. 

Best regards, 

Mark Riggio 

Hyde GUARDIAN Product Manager 

+1.412.298.5772 

mriggio@hydemarine.com 

-----Jim Mackey/HQPGH/CCC wrote: ----- 

To: "Mary Willett" <Mary.Willett@erg.com> 

From: Jim Mackey/HQPGH/CCC 

Date: 02/22/2012 05:50PM 

Cc: "Mark Riggio" <MRiggio@hydemarine.com>, "Tom Mackey" <TMackey@HydeMarine.com> 

Subject: Re: Fwd: Feasibility of Filter + Chlorine Dioxide Ballast Water Treatment Systems to Small Vessels 
Dear Ms Willett, 

Thank you for your questions. We won't be able to reply in detail until next week but I will tell you that Hyde does have a type approved BWT 

system using filtration and UV (no chemicals) with approved capacity lower than 100 m3/hr. Hyde GUARDIAN Model HG60 (60 m3/hr) that 

has been ordered for projects in 30 to 60 m3/hr range. We have delivered a number of these and so have a rather unique perspective on this 

subject. Thank you for the opportunity to cooperate in your study. 

Best regards, 

Jim Mackey 

mob: +1(440)725-3813 

 ----- Original Message ----- 

 From: "Mary Willett" [Mary.Willett@erg.com] 

 Sent: 02/22/2012 04:07 PM EST 

 To: Jim Mackey 

 Subject: Fwd: Feasibility of Filter + Chlorine Dioxide Ballast Water Treatment Systems to Small Vessels 

Mr. Mackey: 

 

Hello, I am Mary Willett an engineer with ERG. We are a technical contractor for EPA's Office of Wastewater Management and are supporting 

EPA in their evaluation of the Vessel General Permit. As part of that effort, we are supporting EPA in evaluating whether ballast water 

treatment systems are feasible for smaller vessels. Specifically, whether they might be feasible for commercial vessels that are smaller than 

1,600 metric tons and/or vessels with ballast tanks smaller than 8 cubic meters. I would like to see if you could provide some information about 

the feasibility of using a solids separation and UV system for smaller vessels. 

 

Under our EPA contract for this work, we are not authorized to handle Confidential Business Information. Therefore, I would like to see what 

information you could provide that could be made public without notice. If you have information that would be useful but would need to be 

handled as CBI, I can provide you with contact information for our EPA client and the information could be sent directly to him. 

 

The types of vessels that fall into these smaller size categories include: 

commercial fishing vessels, 

freight ships (such as a Gate Lifter or general cargo), 

passenger vessels (such as crew boats, inland river towboats, vessels for less than 100 passengers, small cruise boats, and small ferries), 

utility vessels (such as liftboats, offshore crewboats and supply vessels, tug boats, etc.) 

 

Do you know of any Ballast Water Treatment (BWT) systems currently being marketed that would be applicable to a smaller vessel? The 

smallest systems that we have identified as available are for at least 100 m3/hr. Do you know of any smaller? 

 

Would be it feasible to scale a solids separation and UV BWT technology to vessels < 1,600 MT? 

 

If a solids separation and UV system were scaled down to you know whether its footprint could be made small enough to fit on a smaller vessel? 

 

Would it be likely that if a system could be scaled down its weight would be low enough not to create stability issues in smaller vessels? 

 

Would there be safety issues with the use of a solids separation and UV BWT technology on a smaller vessel that would be different than on a 

larger vessel? 

 

Would a scaled down version of the technology be as effective and likely to comply with the IMO D-2 standards? 

 

What would you see as the limiting issues for trying to incorporate a solids separation and UV BWT technology into a smaller vessel? (for 

example, design costs, the footprint of the technology, equipment cost, effectiveness of treatment, complexity of the system?) 

 

Are you aware of any costing information that would apply to a scaled down BWT technology system? 

 

I understand from your voicemail that you are out this week and will try to contact you next week when you are back. Any information that you 

might have to address these issues is greatly appreciated! 

 

Mary R. Willett 

Mary R. Willett 

ERG 

(703) 633-1615 

mary.willett@erg.com 

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Telephone Record 

Date: February 27, 2012 

From: Mary Willett To: Mr. Mario Tamburri

Company: ERG University of Maryland, Center for Envr. Science 

Phone #: 410-326-7440 

RE: Feasibility of Ballast Water Treatment (BWT) for Small Vessels 

Identified myself and the purpose of my call. Indicated that we are not authorized to 

handle CBI and information provided could be made public without notice. 

Asked about capacity of BWT systems for small vessels. Mr. Tamburri indicated that for 

small vessels (such as fishing boats and small passenger vessels) it is likely that the boat 

is taking on ballast to replace the fuel as it is used or potentially to help during severe 

weather conditions that dictate the need for more ballast. For these purposes the ballast 

water rate would be slow. 

Asked if he thought it would be feasible to scale down the current existing technologies 

to small vessels. Mr. Tamburri commented that yes, current technologies can be scaled 

down and specifically mentioned the potential for UV and electrochlorination systems. 

For small ballast needs (to replace fuels) there are other options than ballast water 

treatment. Specifically, the NOAA research fleet is looking at ballast water from potable 

water systems that would be on the ship, or use of city potable water. Alternatively, boat 

route changes are an option that would allow a boat to avoid leaving an invasive species 

zone. 

Asked if he thought there would be safety issues associated with small vessel BWT 

technologies vs. large vessel safety issues. Mr. Tamburri indicated that he didn’t think 

there would be additional safety issues that would arise with small vessels. 

Asked if he thought the BWT systems in use now would be as effective at treatment if 

scaled down. Mr. Tamburri felt that existing BWT technologies would be as effective on 

small vessels as large. 

Asked what he thought the limiting issues would be in trying to incorporate BWT 

technologies onto small vessels. Mr. Tamburri indicated that space and power 

consumption needs would likely be the biggest limiting factors and that the holding time 

required by the BWT technology could also be an issue. 
Page 2 of 2

Asked if he was aware of any costing data sources. Mr. Tamburri was not aware of any 

costing data for smaller systems. He felt that the initial purchase price of the BWT 

system would lower for small systems but that the engineering design costs would likely 

be similar to those incurred for larger vessels. The installation costs could be lower. 
Page 1 of 1

Telephone Record 

Date: February 27, 2012 

From: Mary Willett To: Mr. Jim Mackey

Company: ERG Hyde Marine 

Phone #: 440-725-3813 (cell) 

RE: Feasibility of Hyde Marine Ballast Water Treatment (BWT) for Small Vessels 

I sent email to Mr. Mackey that identified myself and the purpose of my contact, 

indicated that we are not authorized to handle CBI, and indicated information provided 

could be made public without notice. He responded to my email with a phone call. He 

was also aware of the email response that I had from Mark Riggio of Hyde Marine on 

February 24, 2012. 

I asked about the smallest capacity of the Hyde Marine BWT system for small vessels. 

Mr. Mackey indicated that the smallest system that Hyde Marine markets for small 

vessels has a process capacity as low as 30-35 m3/hr (which is about 100 gallons/minute). 

He indicated that this would be the minimum flow rate for the system and below that rate 

they would need to look at the system design. He also noted that for smaller vessels there 

may be a minimum pumping capacity since you would combine ballast pumping with fire 

fighting pumping rather than have a separate pump. 

I asked Mr. Mackey specifically about challenges for smaller vessel ballast water 

treatment systems. He noted the following issues that should be considered: 

1. Modular treatment design is important for small vessels due to space constraints. 

2. Smaller vessels have limited holding time for the ballast tanks and the ballast 

water treatment systems that require significant holding times may not work. He 

noted that the filtration + UV system Hyde Marine markets does not have a 

minimum holding time for efficacy. 

3. Smaller vessels may operate in “brown water conditions” unlike larger vessels 

and operation of a system with high sediment could be an issue for smaller 

vessels. 

4. Some smaller vessels (research vessels) may operate in very cold climates and he 

noted that some of the ballast water treatment technologies do not operate or do 

not operate at full efficiency below certain temperatures. 

Mr. Mackey indicated that they will have an article in the March issue of Marine News 

on ballast water treatment for small vessels. He was not aware of any published costing 

data for small systems but they would be willing to provide a quote if requested. 
From: "DJ Seo 서 서서" <djseo@techcross.com> 

To: <mary.willett@erg.com> 

Date: 3/16/2012 7:41 AM 

Subject: RE: Feasibility of Electro-Clean Ballast Water Treatment System toSmall Vessels 

Attachments: CSLC_update_on_BWTS-Summary_ENG.pdf; ECS_Models.jpg; ECS150Bx1Set_Footprint.pdf; 

TP_201202_109_ECS150Bx1Set.pdf 

Dear Mary R. Willett 

Good day to you. 

This is DJ Seo at the sale and marketing department of Techcross. We would like to send you this email to answer for your questions. 

The answers are below. 

Do you know of any Ballast Water Treatment (BWT) systems currently being marketed that would be applicable to a smaller vessel? The 

smallest systems that we have identified as available are for around 100m3/h. Do you know of any smaller? 

l First, please note that our system name is “Electro Cleen System” not “Electro Clean System”. 

l ECS-150B Type which has been developed by Techcross and Type Approved is the smallest BWMS for around 100m3/hr. Techcross is also in 

the process of developing stage for even smallest capacity of 50m3/hr. As we understand, the other systems such as UV and injection type 

systems with filters and TRO generators require larger foot prints than ECS without filter. The technical proposal 

(“TP_201202_109_ECS150Bx1Set”) and footprint of ECS150B (“ECS150Bx1Set_Footprint”) are attached. 

Would be it feasible to scale the Electro-Clean technology to vessels < 1,600 MT? 

l It depends on the structure and installation space of the vessels for BWMS. As other electrical equipments – Auto Neutralization Unit (ANU), 

TRO Senor Unit (TSU), and Power Distributor Equipment (PDE) -- are able to be installed in any place independently, if ECU (the main part of 

ECS and which requires modification on main ballast pipeline after the ballast pump) can be installed at the main ballast pipe line, it is feasible to 

fit to vessels < 1,600 MT. 

l Development of newly upgraded ECS-B type which is simpler than ECS-A type has been completed and just waiting for type approval. Also, 

Techcross is developing much smaller and simpler version of ECS than ECS-B type. 

If your system were scaled down, do you know whether its footprint could be made small enough to fit on a smaller vessel? 

l Techcross can assure that ECS-B type is small enough to fit on a smaller vessels or vessels having smaller space for BWMS installation. The 

system would not need to be scaled down to make it suitable for any smaller vessels. 

Can you estimate what the weight of such a system would be? [would be likely that if a system could be scaled down its weight would also be 

low enough not to create stability issues in the vessel] 

l ECS150B is small and simple enough to treat 100m3/h. You can find the information on the weight as per the attached technical proposal. 

Please review the attachment, “TP_201202_109_ECS150Bx1Set”. 

Would there be safety issues with the use of Electro-Clean technology on a smaller vessel that would be different than on a larger vessel? 

l There would not be any safety issue, as small ECS like ECS150B does not have any difference from large ECS like ECS1000B in term. Only 

the size of the chamber is getting larger as the capacity of the chamber is getting bigger. Please review the attached file, “ECS_Models“; then, 

you can find what the differences between ECS150 and ECS1000. 

Would a scaled down version of the technology be as effective and likely to comply with the IMO D-2 standards? 

l The scaled down version of technology would be effective enough to comply with the IMO D-2 standard, as all ECS models have the 

appropriate level of its performance depending on its capacity. Please find the attached file called “CSLC_update_on_BWTS-Summary_ENG” 

which proves all types of ECS can comply with IMO D-2 standard. 

What would you see as the limiting issues for trying to incorporate a BWT technology (like Electro-Clean) into a smaller vessel? (for example, 

design costs, the footprint of the technology, equipment cost, effectiveness of treatment, complexity of the system?) 

l Since existing vessels (especially small vessels < 1,600 MT) were constructed without considering sufficient installation space for BWMS, 

making installation space in vessels in order to install ECS would be an issue 

Are you aware of any costing information that would apply to a scaled down BWT technology system? 

l ECS150B costs about U$150K for system price only and we expect even lower cost for smaller version.

l Currently, ECS150B is the smallest size of BWMS in the lineup. However, the smaller ECS is being developed to meet the demands of the 
BWMS market. As it is an on-going project, data for expected R&D costs for the scaled down project are not available. 

The files we mentioned on this email are attached. Please find the attachments, and if there are any attachments you cannot read, do not hesitate 

to contact us. 

Also, if you have other requests or questions, please give us an opportunity of providing you with the feedbacks. 

Thank you for your time. We hope that you are satisfied with our answers for your questions. 

Sincerely, 

DJ Seo. 

----------Origin Message---------- 

From: Mary.Willett@erg.com (Mary Willett) 

To: mike@techcross.net; 

Cc: 

Date: 2012/02/23 03:47 

Subject: Feasibility of Electro-Clean Ballast Water Treatment System toSmall Vessels 

Mike: 

Hello, I am Mary Willett an engineer with ERG and have your contact information from Shirley Fan of EPA. We are a technical contractor for 

EPA's Office of Wastewater Management and are supporting EPA in their evaluation of the Vessel General Permit. As part of that effort, we are 

supporting EPA in evaluating whether ballast water treatment systems are feasible for smaller vessels. Specifically, whether they might be 

feasible for commercial vessels that are smaller than 1,600 metric tons and/or vessels with ballast tanks smaller than 8 cubic meters. I would like 

to see if you could provide some information about the feasibility of a electrolysis/residual hypochlorite system for smaller vessels. If you would 

prefer to talk to me by phone about any of this please give me a call at 703-633-1615. 

Under our EPA contract for this work, we are not authorized to handle Confidential Business Information. Therefore, I would like to see what 

information you could provide that could be made public without notice. If you have information that would be useful but would need to be 

handled as CBI, I can provide you with contact information for our EPA client and the information could be sent directly to him. 

The types of vessels that fall into these smaller size categories include: 

commercial fishing vessels, 

freight ships (such as a Gate Lifter or general cargo), 

passenger vessels (such as crew boats, inland river towboats, vessels for less than 100 passengers, small cruise boats, and small ferries), 

utility vessels (such as liftboats, offshore crewboats and supply vessels, tug boats, etc.) 

Do you know of any Ballast Water Treatment (BWT) systems currently being marketed that would be applicable to a smaller vessel? The 

smallest systems that we have identified as available are for around 100 m3/hr. Do you know of any smaller? 

Would be it feasible to scale the Electro-Clean technology to vessels < 1,600 MT? 

If your system were scaled down do you know whether its footprint could be made small enough to fit on a smaller vessel? 

Can you estimate what the weight of such a system would be? [would be likely that if a system could be scaled down its weight would also be 

low enough not to create stability issues in the vessel] 

Would there be safety issues with the use of Electro-Clean technology on a smaller vessel that would be different than on a larger vessel? 

Would a scaled down version of the technology be as effective and likely to comply with the IMO D-2 standards? 

What would you see as the limiting issues for trying to incorporate a BWT technology (like Electro-Clean) into a smaller vessel? (for example, 

design costs, the footprint of the technology, equipment cost, effectiveness of treatment, complexity of the system?) 

Are you aware of any costing information that would apply to a scaled down BWT technology system? 

Also, Shirley Fan asked that we let you know that Ryan Albert (EPA/OWM) will be getting back to you and is waiting to get more information 

from USCG. Any information that you might have to address these issues is greatly appreciated! 

Mary R. Willett 

Mary R. Willett 

ERG 

(703) 633-1615 

mary.willett@erg.com 

 
Page 1 of 1

Telephone Record 

Date: March 27, 2012 

From: Mary Willett To: Ms. Allegra Cangelosi

Company: ERG Northeast Midwest Institute (NEMW) 

Phone #: 202-464-4014

RE: Ballast Water Treatment (BWT) for Small Vessels 

Identified myself and the purpose of my call. Indicated that we are not authorized to 

handle CBI and information provided could be made public without notice. 

Asked about the size of vessels studied by the Great Ships Initiative, explained the vessel 

types we believe to be in the “small vessel” category (< 1,600 grt and ballast tank size > 8 

m3), and asked which technologies Ms. Cangelosi was aware of that would be candidates 

for small vessel ballast water treatment. 

Ms. Cangelosi indicated: 

The smallest vessel studied by the Great Ships Initiative for ballast water treatment was a 

cruise ship (the Regal) which had ballast water flow rates in the 200 - 300 m3/hr range. 

 

Other ballast water treatment technologies that she would recommend for analysis on 

small vessels include a ultrasonic technology (she will send contact information on the 

vendor/developer of this technology), UV (though the quality of water will impact how 

well this technology can work), and filtration (she noted that 25 micron vs. 50 micron 

filters may be feasible but do create greater backwashing flow). 

Asked whether she was aware of any data sources that would help define the ballast tank 

size or ballast water flow rates that apply to small vessels. Ms. Cangelosi indicated: 

She was not aware of any specific sources to look at to identify typical ballast water tank 

size or flow rates for "small vessels" but did suggest that contacting the trade associations 

representing the various vessel types (e.g., tug boats etc.) might result in information of 

this nature.