Capabilities of Shipboard 

Water Treatment Techn

Ryan Albert, US Environmental Prote

Rich Everett, US Coast Gua

Presentation to EPA’s Science Advi

July 29, 2010
Regulatory Applicab

• In the United States, ballast wate

from vessels are primarily regulatfederal regimes:

– Under the Clean Water Act, implem

the Vessel General Permit (VGP) by 

– Under the National Invasive Species 

implemented under regulations pro

the Coast Guard
Who is covered by the V

• Vessels which discharge into waters o

States need to have an NPDES permi

discharge(s), unless they are one of t

types of vessels:

– Recreational Vessels, regardless of size 

CWA section 502(25))

– Vessels of the Armed Forces, as defined 

C.F.R. § 1700.3.

– Vessels less than 79 feet (unless dischar

water)

– Commercial fishing vessels of any size (u

discharging ballast water)
VGP Applicabil

available at: www.epa.gov/npd

• Estimated to cover approx. 61,000 

commercial vessels and 8,000 fore

• As of July 27, 2010, more than 50,

of Intent (NOIs) were submitted to nearly 44,000 of which are active.
US Coast Guard Ballast W

Regulatory Applicabi

• Applies to all vessels with ballast t

a few statutory exceptions, includ

– Crude oil tankers engaged in the co

– Department of Defense and Coast G
DOD and Coast 

Guard Vessels

Regulatory Overlap of Balla

Discharges for NPDES program 

USCG

NISA

Note: Discharges 

from Recreational 

Vessels are regulated 

by Section 312 of 

the CWA

Recreational Vessels with 

Ballast Tanks Most non- recreational, non- military vessels
Vessel Characteristics (base

NOIs submitted)

• Vessels range from inland barges and tugs to 

container ships and tankers

– Ballast water capacity ranges from 0 to more than – Of the 29,000 NOIs which contain both tonnage a

information, more than 10,000 vessels have less t

meters – most of these vessels are less than 2,000 

but some as large as 40,000 GT

• Of the 50,000 vessels having submitted NOIs

16,500 report leaving the US Exclusive Econo

4,400 report being engaged in Pacific nearsh

– More than 29,000 total vessels are barges – many 

unpowered and travel either inland or coastal rou
Category Description

Capesize Bulker Chemical Carrier 

Combination Vessel 

Feeder Container Ship 

Feedermax Container Ship 

Gas Carrier General Cargo Vessel 

Handy Bulker 

Handy Container Ship 

Handy Tank Ship 

Handymax Tank Ship 

Panamax Bulker 

Panamax Container Ship 

Panamax Tank Ship 

Passenger Ship 

Postpanamax Container Ship 

RORO Subpanamax Container Ship 

ULCC Tank Ship 

VLCC Tank Ship 

Minimum 

Maximum 

Average (not weighted) 

The average 

ballast capacities 

of vessels as 

determined by a 

USCG analysis

For a comparison, the volume in an Olympic Size swimming pool is about minimum 2,500 m3
Existing VGP Ballast Wate

• The permit:

– Incorporates Coast Guard mandatory 

and exchange requirements

– In addition, vessels engaged in Pacific 

voyages must conduct exchange greanm from the coast

– Mandatory saltwater flushing for all v

residual ballast water and sediment (

coming from outside the USEEZ
Existing VGP Ballast Wat

(cont.)

• Must use shore‐based treatmen

and economically practicable an

• Must conduct exchange as early 

• Exchange/flushing requirements 

exemption and do not mandate 
Technology‐Based Num

Water Limits

• EPA did not require numeric ballast w

limits in the 2008 VGP. Why not?

– At the time of permit issuance (12/18/2008), 

treatment technologies that could form the b

limits were not:

• “Available” and• Economically achievable

– Lack of data meeting these tests as of permit 

• Some states added numeric ballast w

limits for their state waters pursuant 

401 certification
BWM Technology

Unit Processes

• Mechanical

– Filtration (screen, media*)– Separation (cyclonic, Ionic*)– Shear

• Chemical

– Deoxygenation (pressure, N2, inert gas ge

– Oxidizing biocides (OCl‐, ClO2, O3, AOT)

– Non‐oxidizing biocides (SeaKlean, glutera

acrolein)

• Energy

– Radiation (UV, heat, ultrasonic)

– Micro‐Cavitation
Living Organism Stand

• Most existing standards express li

acceptable value of living organism

• Classes typically include:

– >50 μm: <10/m3 ‐ < 1/100 m3– 10 um – 50 μm: <10/ml ‐ < .01/ml– Microbiologicals (Indicator bacteria

and viruses or virus‐like particles)
Two other approach

• “No detectable living

organisms” (CA)

• Requirements

prescribing certain

treatment approaches(Michigan Approach)
Examples of standards suggested or used by the interna

domestic regulatory agencies

NARRATIVE 

DESCRIPTION Size: ≥ 50 μm

Size: < 50μm, 

but ≥ 10 μm Bac

“IMO” < 10 living organisms per m3 < 10 living organisms per ml

Vibrio 

< 1 CFU 

E. 

< 250 CFU 

Intestinal 

< 100 CFU 

“100 x IMO” [1] < 0.1 living organisms per m3 < 0.1 living organism per ml

Vibrio 

< 1 CFU 

E. 

< 126 CFU 

Intestinal 

< 33 CFU 

“1000 x IMO” 1 < 0.01 living organisms per m3 < 0.01 living organism per ml

Vibrio 

< 1 CFU 

E. 

< 126 CFU 

Intestinal 

< 33 CFU 

“CA Interim 

Standards”

0 detectable 

living organisms

< 0.01 living 

organism per ml

Vibrio cholera< 1 CFU per 100 mE. coli< 126 CFU per 10Intestinal enteroco< 33 CFU per 100 < 103 bacteria pe

“CA Final 

Standards”

0 detectable 

living organisms

0 detectable 

living organisms

0 dete

living or

[1] Note – the “100 x” and “1,000 x” refer only to the “≥ 50 μm” and the “< 50μm, but ≥ 

See Table 1 in the White Paper for more detail 
Questions/Discussi
The Study Charge

• Question 1: Designed to evaluate the p

shipboard systems with available efflu

data

– 1a. For the shipboard systems with available test data, 

evaluated with sufficient rigor to permit a credible asse

performance capabilities in terms of effluent concentra

organisms/unit of ballast water discharged or other me

– 1b. For those systems identified in (1a), what are the di

the available data credibly demonstrate can be reliably 

all of the standards shown in Table 1 of the White Pape

data indicate that certain systems (as tested) will not be 

any or all of the discharge standards shown in that tabl

– 1c. For those systems identified in (1a), if any of the sys

living organisms” in any or all of their replicates, is it rea

systems are able to reliably meet or closely approach a 

standard or other standards identified in Table 1 of the 

their engineering design and treatment processes?
The Study Charge

• Question 2: Designed to evaluate 

performance of shipboard system

reliable testing data

– Based on engineering design and treatme

used, and shipboard conditions/constrain

ballast water treatment systems (which m

or all of the systems listed in Table 4 of th

can reasonably be expected to reliably ac

standards shown in Table 1 of the White P

by what dates? Based on engineering destreatment processes used, are there syste

conceptually would have difficulty meetin

the discharge standards in Table 1 of the W
The Study Charge

• Question 3: Designed to evaluate futur

potential performance

– 3a. For those systems identified in questions 1a an

reasonable changes or additions to their treatmen

can be made to the systems to improve performa

– 3b. What are the principal technological constrain

impediments to the development of ballast water 

technologies for use onboard vessels to reliably m

discharge standards presented in Table 1 of the W

recommendations does the SAB have for addressi

impediments/constraints? Are these impediment

for certain size classes or types of organisms (e.g., 

viruses)? Can currently available treatment proce

sterilization (no living organisms or viable viruses) 

onboard vessels or, at a minimum, achieve zero o

for certain organism size classes or types?
The Study Charge

• Question 4: Designed to ident

limitations in data and how w

those limitations

– What are the principal limitations o

studies and reports on the status of 

treatment technologies and system 

and how can these limitations be ovcorrected in future assessments of t

of technology for treating ballast wa

vessels?
The Study Charge

• Related sub‐questions of interest

– What is current ballast water treatm

technology capable of under best in

circumstances? Are there technolo

– What might current ballast water tr

technologies be able to achieve undcircumstances of operating ships?

• Issues:

– Space– Power– Time– Conditions (source water, vessel design & mat
Questions/Discussi
Overview

Treatment Technolo

• Treatment technologies/processe

summarized in reports by Lloyd’s 

– Most based on existing ballast wate

• Separation (mostly screen filters, 25‐5

hydrocyclones, some flocculation)

• Non‐chemical biocides (ultraviolet, ult

pressure, heat)

• Chemical biocides (hypochlorite, ClO2

REDOX reactants, non‐REDOX organics
Overview

Treatment Conditio

• Full range of natural salinities – inclu

saline

• Full range of organic and inorganic W

constituents – including urbanized ha

wo WQ protections

• Tropical to polar temperatures

• Wide range of:

– Capacities (101 – 105 m3)

– Flow rates (101 – 104 m3/h)– Available time (hours – months)
Challenge: Space is Lim
26 

Treatment Systems are C

NEI

Alpha L

MSI
Operational Issues

BW TANK CONFIGURATIONS
28 

Ballast Systems Are Co
IMO Type Approva

• Convention requires that ballast w

management systems (= treatmen

used to meet the Regulation D‐2 d

standard be approved by the Adm

(government) under whose flag a 

operates.

• Recommended approval procedu

described in the Guidelines for ApBallast Water Management Syste
G‐8 Approval Guidel

• Type approval

– A “type unit” of a treatment system model tes

“standardized” test protocols in both land‐bas

circumstances

• Ability to consistently achieve the discharg

evaluated

– Electronic control and monitoring components 

standardized environmental testing (vibration, 

humidity)

– Design and construction specifications reviewe

• Appropriate for shipboard

– Manufacturing arrangements reviewed

• Ability to manufacture to “type” specificat

– Administration issues type approval certificate
G‐8 Treatment Efficacy 

Protocols

• Caveats

– Negotiated compromise

• Reflects many technical, economic, an

agendas

– Relatively short preparation time

– Key sections left vague– Never validated prior to implement

• Different fixes at different facilities
G‐8 Treatment Efficacy 

Protocols

• Land‐based tests

– Treatment and control– 200 m3 volume minimum

– 200 m3/h flow‐rate minimum

– Sample sizes

• >50 um: 1 m3• 10‐50 um: 1 L

• Bacteria: 500 ml

– 3 “replicate” samples at each time

• Before treatment, after treatment, a
G‐8 Treatment Efficacy 

Protocols

• Shipboard tests

– Treatment tank(s) (multiple??)

– Control tank

– Volumes and flows consistent with 

operation of vessel

– 3 consecutive valid test runs require

• Uptake organism concentrations >10x • Discharge organism concentrations > D
G‐8 Land‐based Schem

Source

BWTS

Tanks

Pump

Samples

Trt Cnt
35 

CONSISTENCY & RELIABILITY AMO

FACILITIES, DOMESTICALLY & INTER

NIVA - Norway

Also South Africa, Republic of Korea

MERC - Baltimore, MD

NIOZ - Netherlands
G‐8 Shipboard Schem

Source

BWTS

Tanks

Pump

Samples

Trt Cnt
Questions/Discussi
Data Presented to the Co

• Information divided into three ma

– Summary reports produced by part

the availability of existing ballast wa

systems or their potential efficacy

– Primary performance data reports a

information available to EPA and US

– Reference library for the committee 

documents and one class society ad
Data Presented to the Co

Summary Report

• Reports include:

– Lloyd’s Register Review

– American Bureau of Shipping (ABS) adviso

– California State Lands Commission Report

– IMO circular

– Excerpts from Lee et al. white paper “Den

• Reports provide (some or all of the fol

– summary information on specific systems

– general information on how systems work

– presentation and evaluation of summary 

– conclusions about potential commercial a

systems
Data Presented to the Co

Primary Performance D

other Informatio

• Most data collected with intent of ultim

type approval. Data are from:

– data reports from the testing of ballast wa

systems provided to foreign Administratio

type approval under the BW Treaty or

– data reports gathered by vendors in prep

for type approval by a flag Administration

– application packets prepared by the vend

to the USCG under the Shipboard TechnoProgram (STEP)
Data Presented to the Co

Reference Librar

• G9 Papers

– Submitted for systems seeking activ

approval

• Primary purpose for papers is to explo

active substance impact on receiving w

– Outline how a given ballast water tr

system functions

– May discuss mechanism for neutral

organisms

• ClassNK class society advisory doc
Other Regulatory Eval

(concurrently being conducted 

be conducted in the near 

• California

– Biennial basis

• Staff evaluate data, seek input from an adviso

whether systems are potentially available to m

seek report approval by commissioners

• Updated report may be finalized this summer

• Wisconsin

– Required by state legislation– Evaluation being conducted with advice fr

“Ballast Water Collaborative”

• US Coast Guard practicability reviews

• US EPA BAT evaluation for next VGP
Acquiring credible third pa

from flag administrations o

• EPA and USCG have not been able 

all available data for the SAB’s use

– Some flag states have been unable/

share all data with US government, 

by the Coast Guard

– EPA and Coast Guard unable to con

group vendors

– Some vendors unresponsive regard

data reports for this project
Use of Additional Inform

• EPA and USCG are strongly suppo

committee using additional, third

submitted via public comment or 

by any committee member, provi

– Peer reviewed published data or– Third‐Party laboratory data or shipb

data in final or similar report
Questions/Discussi
Testing Data Concerns: G

• Non‐standard methods among te• Lack of available facility validation

documentation

– Ability to control spec’d conditions– Ability to measure with acceptable 

accuracy

• Lack of available QA/QC documen

tests

• Independence of testers and vend
• Representative samples?

– Sample port design

– Installation

• Sample volume

– “replicates” are not independent

– Volume = 1 m3, 3 m3, or 9 m3 depen

• Not sufficient for measuring very low c

(1/10 m3, 1/100 m3)

• Sampling artifacts

– Source of mortality

Testing Data Concerns: S
Testing Data Concerns: 

• Sample analysis

– Viability assays

– Accuracy and precision in detection 

enumeration

– Safe window for processing
Questions/Discussi