# Availability and Efficacy of Balla st Water Treatment Technology: Background and Issue Paper

June 2010

Ryan Albert 1 

# , Rich Everett 2 

# , John Lishman 3 

# , and Daniel Smith 4

1 

## US Environmental Protection Ag ency, Water Permits Division

2 

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

3 

## US Environmental Protection Agency, Oceans and Coastal Protection Division

4 

## US Environmental Protection Agency, Oak Ridge Institute of Science and Education Fellow, Oceans and Coastal Protection Division



# Prepared to Assist the Science Advisory Board Review of the Availability and Efficacy of Ba llast Water Treatment Technology

Washington, D.C.

## Table of Contents:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

6. Bibliography ............................................................................................................. 46 Appendix I – Science Advisory Board Charge ................................................................. 58 Appendix II. National Academy of Sciences Charge ...................................................... 62 Appendix III. List of Acronyms Used in this Paper ........................................................ 63 Appendix IV. Table of Contents for all documents provided to the Committee. ............ 65

List of Tables and Figures:



## Table 1. Selected Ballast Water Discharge St andards for Organisms (Current as of June 28, 2010). ............................................................................................................................ 9 Table 2. System Space and Power Characterist ics for Ballast Water Treatment Systems 19

Table 3. Additional G9 Decisions Made Subs equent to BWM.2/Circ.23 (List of ballast water management systems that make use of Active Substances which received Basic and Final Approvals). .............................................................................................................. 25 Table 4. Ballast Water Treatment System s for which we have provided additional

information. ....................................................................................................................... 28 Table 5 Summary Status of Ballast Water Treatment Systems which use Active Substances (Current as of J une 16, 2010, through MEPC 61/2/13). ................................ 35 Table 6 Acronyms and Abbreviations used in Table 5. .................................................... 43

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

## Disclaimer:

This paper has been written to provide background information for EPA’s Science Advisory Board in their eval uation of the technological availability of ballast water treatment systems. It has been drafted by EPA and USCG staff to assist the SAB board in its review. The contents of this paper do not necessarily reflect the views of the U.S. Environmental Protection Agency or the United States Coast Guard.

Acknowledgements:

The authors wish to thank the following indivi duals for their review and contributions to this paper: Shirley Fan, Elizabeth Fine, Ty ler Linton, Dawn Messier, Amanda Sage, Juhi Saxena, Craig Voros, and Marcus Zobrist.

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

## 1. Introduction

Ballast water discharges have historically been a major source of nonindigenous species introductions to marine, estuarine, and freshwater ecosystems in the United States. Aquatic organisms may be discharged when the vessel discharges ballast tanks that contains such species, or when the vessel adds ballast water to tanks that contain such organisms in the residual water or sediment in the tank, and later discharges that mixture. When such organisms in ballast tanks are transported between waterbodies and discharged, the organisms may have the potenti al to establish viab le new populations of species in waterbodies to which they are not native. Potentially, this introduction of nonnative aquatic nuisance species (ANS) via balla st water discharge ca n cause significant economic and ecological damage. Numerous studies and reports have documented the impacts of such discharges, a select few of which include Bolch & Salas, 2007, Dobbs et al., 2006, Doblin et al., 2007, Drake & Lodge, 2007, Drake et al., 2007, Endresen et al., 2004, Knight et al., 1999, Reynolds et al., 1999, Roman, 2006, Ruiz et al., 2000a, Ruiz et al., 2000b, Smayda, 2007, and US EPA, 2001.

Ballast water is necessary for the safe operation of the vast majority of larger vessels to assist with vessel draft, trim, and stability. Almost all large vessels have ballast tanks, pumps, piping and other equipment dedicated to th is purpose. In lieu of or in addition to such dedicated systems, some vessels may al so carry ballast water in otherwise empty cargo holds. Ballast water is typi cally drawn in from, and discharged directly to, ambient

waters. The ballast water discha rge rate and constituent concentrations of ballast water from vessels will vary by vessel type, ballast tank capacity, type of deballasting equipment, the quality of the ambient water from which the ballast water is drawn, the amount and quality of residual water or sediment in the ta nk, the efficacy of any ballast water management practices and/or ballast water treatment employed, and other factors. Vessels may discharge anywhere from less than a hundred cubic meters of ballast to tens

of thousands of cubic meters. For instan ce, passenger vessels ha ve a representative ballast capacity of about 3,000 cubic meters (about 792,516 gallons) while ultra large crude carriers (ULCCs) representative ba llast capacity is about 95,000 cubic meters (about 25,096,345 gallons) (ABS, 2010). The discharg e rate of ballast water is generally proportional to the size of the tanks, alt hough there are notable exceptions (e.g., bulk carriers on the Great Lakes are often designed to load and unload cargo and ballast water quickly).

Under current US regulation and permitting requirements (discussed in greater detail below), existing best management practices are required to help reduce the potential impacts of ballast water discharges. These include ballast water exchange 1 

## and saltwater

1 

### “Ballast Water Exchange” means to replace the wa ter in a ballast tank using either “Flow through exchange” or “Empty/refill exchange”. “Flow through exchange” means to flush out “ballast water” by pumping in water from the “mid-ocean” or “coastal ex change zone” (as applicable ) into the bottom of the tank and continuously overflowing the tank from the to p until three full volumes of water has been changed to minimize the number of original organisms remaining in the tank. “Empty/refill exchange” means to pump out the “ballast water” taken on in ports, estuarine, or territorial waters until the tank is empty, then refilling it with water from the “mid-ocean” or “coastal exchange zone” (as applicable); when conducting



## 1

## flushing 2 

## for certain vessels/voyages (collectivel y referred to as Ballast Water Exchange or BWE in this paper). These practices have been shown to offer some protection in mitigating the transfer and potential introdu ction of invasive species (Ruiz and Reid, 2007; McCollin et al., 2007a). While useful in reducing the presence of potentially invasive organisms in ballast water, BWE is not feasible for all vessels (e.g., vessels that cannot voyage off-shore), can have variable effectiveness, and in some circumstances may not be feasible due to vessel safety concerns.

One way to address these limitations associat ed with BWE is to require treatment of ballast water prior to discharge to meet an established standard for the concentration of living organisms. The United States Envi ronmental Protection Agency (EPA) and the United States Coast Guard (USCG) both de sire a stronger federal ballast water management program that will be more eff ective than current BWE-based requirements in preventing the ballast wa ter-mediated spread of ANS (Silva and Salerno, 2009; Hanlon et al., 2010).

Several peer-reviewed publicati ons have evaluated the efficacy of ballast water treatment systems, a small sampling of which include Gracki et al., (2002), Gregg & Hallegraeff, (2007b), McCollin et al. (2007b), Quilez-Badi a et al. (2008), Perri ns et al. (2006), Raikow et al. (2007), and Tamburri et al . (2002). Other review s have used vendor supplied survey information or data to evaluate the availability and/ or potential efficacy of these systems (Lloyds, 2010; Dobroski et al ., 2009). However, there are also several complications associated with evaluating ba llast water treatment technologies, including issues with sampling size, sufficient volume, and sufficient replicat es (Lee et al., 2010), limited availability of valid third party data, potential uncertainties regarding data quality control, and logistical difficulties of dem onstrating these systems work onboard ships. These complications are not trivia l and affect the ability to ev aluate the efficacy of ballast water treatment systems and, in some ways, how Agencies would be able to utilize existing effluent data (these issues ar e discussed in greater detail in Section 4 ).

EPA is specifically asking the committee to provide a written report assessing the availability and efficacy of ballast water tr eatment systems in neutralizing (killing or removing) living organisms contained in th e ballast water that would otherwise be discharged. 3 

## The scope of ballast water treat ment technologies we are asking the committee to consider includes both systems that have been indentified as currently

empty/refill exchange, masters/operators should pump out as close to 100 percent of the “ballast water” as is safe to do so (adapted from 33 C.F. R 151.2025(b) (definition of “exchange”)).

2 

### “Saltwater flushing” means the addition of “mid-o cean” or “coastal excha nge zone” water to empty ballast water tanks; the mixing of the added water with residual ballast water and sediment through the motion of the vessel; and the discharge of the mixed water until loss of suction, such that the resulting residual water remaining in the tank has either a salinity greater than or equal to 30 parts per thousand (ppt) or a salinity concentration equal to the ambient salinity of the location where the uptake of the added water took place (adapted from 33 C.F.R. 401.30(f)(1)).

3 

### EPA and USCG also recognize there is a need to be tter understand and relate the concentration of living organisms in ballast water discharges to the probability of introduced organisms successfully establishing populations in, and impacting, U.S. waters. EPA and USCG are currently sponsoring a separate study to address those types of issues by the National Academ y of Sciences’ National Research Council (NRC) (see Appendix II).



## 2

## available and systems that are known to be in the development process. Because of the current uncertainties and inherent complexiti es in determining the efficacy of ballast water treatment systems, an independent and credible review of th e capabilities of such systems would be very helpful to EPA and USCG as they implement their respective authorities. A copy of the specific questions on these matters as included in the SAB charge is provided in Appendix I.

2. Regulatory Background 4



## Ballast water discharges from vessels are presently subject to regulation at the federal, state, and inte rnational level. 5 

## This section provides a general summary of such regulatory frameworks to provide the SA B with contextual background on the requirements currently in place or under development.

At the federal level, there are two principa l statutes of interest : (1) the Nonindigenous Aquatic Nuisance Prevention and Control Act, as amended (“NANPCA,” 16 U.S.C. §§

4701 et seq. ); and (2) the Federal Water Pollution Control Act (commonly referred to as the Clean Water Act or “CWA,” 33 U.S.C. §§ 1251 et seq. ). The principal ballast water management requirements under NANPCA and the applicable permit requirements that implement the Clean Water Act presently rely on use of mid-ocean BWE. However, as exchange is of variable effectiveness and cannot always be carried out due to safety concerns, efforts are underway at the federal level to develop a regulatory regime that will phase out use of exchange in favor of treatment to meet a ballast water discharge standard specified in terms of concentrati ons of living organisms per unit of volume of ballast water discharged.

Both NANPCA and the CWA preserve state auth ority to more stringently regulate ballast water discharges that occur in state waters. See

, 16 U.S.C. § 4725 (NANPCA); 33 U.S.C. § 1370 (CWA). At the state level, regulati on of ballast water discharges varies, not only as to whether there are applicable state requirements, but also as to the substantive content of such requirements wher e they do exist. For examples of state numeric limits for ballast water discharges, See

, Table 1

.

At the international level, ballast water discharges from vessels are primarily addressed under provisions established through the au spices of the Inte rnational Maritime Organization ( IMO ). At present, the principal ballas t water management practice at the

international level involves th e voluntary use of mid-ocean exchange. However, as will be further discussed, the text of a ballast water management Convention was adopted in February 2004. Once that Convention enters in to force, it will in effect result in the phase out of the use of exchange in favor of treatment to meet a ballast water discharge

4 

### Note that throughout this section, and where feasible in other sections, several references are hyperlinked for readers viewing this document electronically.

5 

### Pursuant to § 657.1 of the Canada Shipping Act, Canada also has adopted Ballast Water Control and Management Regulations that are applicable in waters under Canadian jurisdiction, including Canadian

waters of the Great Lakes.



## 3

## standard specified in terms of concentrati ons of living organisms per unit of volume of ballast water discharged.

2.1. United States Federal Regulation

a) NANPCA In light of growing awareness and concer n about the impacts of invasive species introduced via discharges of ships’ ba llast water, Congre ss enacted NANPCA in November 1990. Pub. L. 101-646; 104 ST AT 4761. As enacted in 1990, NANPCA provided for the USCG to issue regulations to prevent the introduction and spread of ANS into the Great Lakes through the ballast water of vessels. 6 

## In particular, the Act directed that these regulations require vessels carrying ballast water that enter a US port on the Great Lakes after operating beyond the exclusive economic zone (“EEZ”) either carry out ballast water exchange prior to such entry or use environmentally sound

alternative ballast water mana gement methods that the USCG determines to be as effective as ballast water exchange in prev enting and controlling ANS infestations (§ 1101(b) of P.L. 101-646; 104 STAT 4763). Th e Coast Guard issued final mandatory ballast water management regu lations applicable to the Gr eat Lakes in 1993 (Federal Register, Vol. 58, No. 66, April 8, 1993, page 18330).

Subsequent to NANPCA of 1990, Congress enact ed the National Invasive Species Act (“NISA”), which amended and reauthor ized NANPCA. Pub. L. 104-332; 110 STAT 4073. Among other things, the amendments made by NISA directed the USCG to address waters besides the Great Lakes by developing a voluntary national ballast water management program. Following development of that voluntary program, NISA directed the USCG to submit a report to Congress eval uating the effectivene ss of the voluntary program. On June 3, 2002, USCG submitted that report to Congress, concluding that low participation in the voluntary program resu lted in insufficient data for an accurate assessment of its effectiveness. This finding in turn triggered a requirement in NISA that the voluntary ballast water management progr am be made mandatory. As a result, the USCG issued final mandatory ballast water management regulations applicable to US waters. 69 Fed. Reg. 44952 (July 28, 2004).

The existing USCG ballast water management requirements specific to the Great Lakes are codified in regulati ons at 33 C.F.R. Part 151, Subpart C . Those regulations apply to

“each vessel that carries ballast water and that after operating on the waters beyond the Exclusive Economic Zone during any part of its voyage enters the Snell Lock at Massena, New York, or navigates north of the George Washington Bridge on the Hudson River” (33 C.F.R. 151.1502). They generally require that such vessels either:

● Carry out an exchange of ballast water beyond the EEZ using exchange water from an area more than 200 nautical miles from any shore and more than 2,000 meters

6 

### With respect to non-Great Lakes waters, NANPCA of 1990 did not establish ballast water management requirements, but instead called for several studies, in cluding one to determine th e need for controls on vessels entering US waters other than the Great Lakes. § 1102 of P.L. 101-646; 104 STAT 4764.



## 4

## deep, such that any tank from which ballast water will be discharged contains water with a minimum salinity le vel of 30 parts per thousand;

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

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

● Use an alternative environmentally s ound method of ballast water management

that has been submitted to, and approved by, the USCG prior to the voyage. 33 C.F.R. 151.1510(a).

Recognizing that vessels decl aring No Ballast On Board or “NOBOB” (i.e., vessels with unpumpable residuals of ballast water) can non etheless potentially in troduce ANS if they uptake and then discharge ballas t water after entry into the Great lakes, the USCG also issued a policy directing such vessels to conduct saltwater fl ushing prior to entry onto the Great Lakes. 70 Fed. Reg. 51831 (Aug. 31, 2005). Saltwater flushing requirements for “NOBOBs” entering the Great Lakes via th e St. Lawrence Seaway were later made mandatory in regulations issued by the St Lawrence Seaway Development Corporation. 73 Fed. Reg. 9950 (Feb. 25, 2008).

The existing USCG ballast water management requirements for all US waters are codified in regulations at 33 C.F.R. Part 151, Subpart D . Those regulations, with limited exception, apply to all vessels, US and foreign, equipped with ballast tanks that operate in US waters and are bound for ports or plac es in the US. 33 C.F.R. 151.2005. With respect to Great Lakes vessels, both the Grea t Lakes-specific provisi ons of Subpart C as well as the relevant national provisi ons of Subpart D are applicable. See , 33 C.F.R 151.2040(a).

Among other things, these regulations esta blish a number of operational requirements with respect to ballast water up take or discharge practices a nd other vessel related vectors for ANS, such as:

● Avoiding the discharge or upt ake of ballast water in ar eas within or that may directly affect marine sanctuaries, marine preserves, marine parks, or coral reefs

● Minimizing or avoiding uptake of ballast water in areas known to have infestations or populations of harmful organisms, ar eas near sewage outfalls or dredging operations, or areas wi th poor tidal flushing

● Regular cleaning of ballast ta nks to remove sediments

● Discharge only the minimal amount of balla st water essential fo r vessel operations

while in the waters of the United States

● Rinsing of anchors and anchor chains re move organisms and sediments at their

place of origin

● Removal of fouling organism s from hull, piping, and ta nks on a regular basis

● Development of a ballast water management plan and training of master and crew on application of ballast water and sediment management and treatment procedures 33 C.F.R. 151.2035(a)

5

## In addition, for those vessels ca rrying ballast water that was taken on in areas less than 200 nautical miles from any shore into US waters after operating beyond the EEZ, the regulations require at leas t one of the following ballast water management practices 7 

## :

● Perform complete ballast water exchange in an area no less than 200 nautical miles from any shore prior to dischargi ng ballast water in U.S. waters;

● Retain ballast water onboard the vessel; or

● Use an alternative environmentally s ound method of ballast water management

that has been approved by the Coast Guard. 33 C.F.R. 151.2035(b)

As previously noted, there are limitations inherent in a BWE-based framework. The USCG has issued a notice of proposed ru lemaking that would gradually replace the current exchange-based regime with a regime requiring, treatment of ballast water to meet a concentration-based discharge standa rd – a standard that will increase in stringency over time. 74 Fed. Reg. 44632 (Aug. 28, 2009); See also

, Table 1

.

b) CWA Section 301(a) of the CWA provides that “the discharge of any pollutant by any person shall be unlawful” unless the discharge is in compliance with certain other sections of the Act. 33 U.S.C. 1311(a). The CWA defines “discharge of a pollutant” as “(A) any addition of any pollutant to na vigable waters from any point source, (B) any addition of any pollutant to the waters of the contiguous zone or the ocean from any point source other than a vessel or other floating craft. ” 33 U.S.C. 1362(12). A “point source” is a “discernible, confined and discrete conveya nce” and includes a “ve ssel or other floating craft.” 33 U.S.C. 1362(14). One way a pe rson may discharge a pollutant without violating the prohibition in CW A § 301 is by obtaining authoriz ation to discharge under a section 402 National Pollutant Discharge Elimination System (NPDES) permit (33 U.S.C. 1342). Under that section, EPA may issue a permit for the discharge of any pollutant, or combination of pollutants subject to certain conditions specified by the Act. The CWA requires that point source disc harges meet technol ogy-based effluent limitations representing the applicable leve ls of technology-based control and further requires water quality-based effluent limitati ons as necessary when the technology-based limitations are not sufficient to meet applicab le water quality standards. For a more detailed discussion of technology-based and water-quality based effluent limits and NPDES permitting refer to chapter 5 and chapter 6 of EPA’s NPDES Permit Writer’s Manual (US EPA, 1996).

Shortly after the CWA was enacted, EPA promulgated a regulation that excluded discharges incidental to the normal operati on of vessels from NPDES permitting. 38 Fed. Reg. 13528 (May 22, 1973). Following subsequent amendments, that regulation was codified at 40 C.F.R. 122.3(a) and identified several types of vessel discharges as being

7 

### The regulations in Subpart D also contain certain exceptions that allow for the discharge of the minimum amount of unmanaged ballast water that is operationally necessary. However, in the case of vessels subject to the ballast water management requirements of Subpart C, the discharge of unmanaged ballast water into

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



## 6

## subject to NPDES permitting, but specifically excl uded discharges incidental to the normal operation of a vessel (e.g., ballast water) from NPDES permitting, as follows:

The following discharges do not require NPDES permits: (a) Any discharge of sewage from vesse ls, effluent from pr operly functioning marine engines, laundry, shower, and galle y sink wastes, or any other discharge incidental to the normal operation of a vessel. This exclusion does not apply to rubbish, trash, garbage, or other such mate rials discharged over board; nor to other discharges when the vessel is operating in a capacity other than as a means of transportation such as when used as an en ergy or mining facilit y, a storage facility or a seafood processing facility, or when secured to a storage facility or a seafood processing facility, or when secured to the bed of the ocean, contiguous zone or waters of the United States for the pur pose of mineral or oil exploration or development.

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

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

determined that the exclusion exceeded th e agency’s authority under the CWA. The Court subsequently issued an order in that case that vacated (struck down) the vessel NPDES exclusion in 40 CFR 122.3(a) as of Fe bruary 6, 2009. As a result, discharges incidental to the normal operati on of vessels, such as ballast water, that were excluded from NPDES permitting by that regulation b ecame subject to CWA § 301’s prohibition against discharge unless author ized by an NPDES permit. See generally

, Northwest

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

## Cir 2008).

In light of the court’s decision, EPA deve loped two draft general NPDES permits for public comment addressing discharges incident al to the normal opera tion of vessels – one

for commercial vessels and thos e recreational vessels greater th an or equal to 79 feet, and

one for recreational vessels less than 79 feet. 73 Fed. Reg. 34296 (June 17, 2008). Subsequently, Congress enacted two laws exempting certain vessels from NPDES permitting. The first of these, the “Clean Boating Act,” amended the CWA to provide that discharges incidental to the normal ope ration of recreational ve ssels are not subject to NPDES permitting, and instead creates a new regulatory regime to be implemented by EPA and the USCG under new § 312(o) of th e CWA. Pub. L. 110-188; 122 STAT 2650. The second of these enactments provided for a temporary moratorium on NPDES permitting for: (1) commercial fishing vessels regardless of size and (2) those other nonrecreational vessels less than 79 feet in length. Pub. L. 110-299; 122 STAT 2995. However, that temporary moratorium is not ap plicable to ballast wa ter discharges from

such vessels.

As a result of the above legislation, EPA di d not finalize the recr eational vessel general permit and revised the other vessel general permit (for commercial vessel and large recreational vessels) to excl ude recreational vessels. EP A’s final vessel general permit (VGP) was issued in December 2008, and a ddresses 26 discharges incidental to the normal operation of commercial vessels, including ballast water. 73 Fed. Reg. 79473

7

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

terms and conditions.

With respect to ballast water discharg es, the VGP includes, among other things, technology-based effluent limits that gene rally reflect the ballast water exchange requirements contained in the USCG regula tions implementing NANPCA, as previously

described. The VGP also includes severa l additional requirements not found in the USCG regulations, such as requirements for near-shore exchange by vessels engaged in Pacific near-shore voyages and a national requirement for saltwater flushing by

NOBOBs. See , VGP § 2.2.3 and Fact Sheet § 4.4.3. In addition, the VGP includes water quality-based effluent limits to control discharges as stringently as necessary to meet applicable water quality standards. See , VGP § 2.3 and Fact Sheet § 4.5.

Under § 402(b)(1)(B) of the CWA, NPDES perm its are issued for fixed terms that may not exceed five years. The existing VGP will expire on December 19, 2013.

2.2. State Regulation

A number of States (e.g., California

, Michigan

, Minnesota, Wisconsin ) have specific State laws and regulations es tablishing ballast water discharge standards or management programs. In addition, other St ates without such specific balla st water related laws have included ballast water discharge standards as part of their Clean Water Act (CWA)

section 401 certifications 8 

## of the VGP (e.g., Illinois (see , VGP § 6.10), Indiana (see, VGP § 6.11), New York (see, VGP § 6.22), Ohio (s ee, VGP § 6.23), Pennsylvania (see, VGP § 6.24)).

The standards contained in state requirements applicable to ballast water vary in terms of their stringency, schedules for implementation, and types of vessels covered. While this paper will not attempt to describe state requirements in detail, readers can refer to Table 1 for a summary of selected state ballast water discharge standards for organisms.

8 

### As explained in the VGP Fact Sheet : “Part 6 of the final VGP identifie s provisions provided to EPA by States and Tribes in their CWA § 401 certifications that the States and Tribes deemed necessary to assure compliance with applicable provisions of the CWA and any other appropriate requirements of State and

Tribal law. See 33 U.S.C. 1341(d); 40 C.F.R. § 124.53(e)(1). Pursuant to CWA § 401(d), EPA has attached those State and Tribal provisions to the final VGP; those that constitute effluent or other limitations or monitoring requirements are enforcea ble conditions of the federal permit. American Rivers, Inc. v. FERC

, 129 F.3d 99, 107 (2 nd 

### Cir. 1997).”Table 1. Selected Ballast Water Discharge Standards for Organisms (Current as of June 28, 2010).Size:≥50micrometers(μm)*Size: < 50μm, but≥10 μmBacteriaViruses“Lakers**”Covered?Compliance DateIMO BWTreaty(Reg. D-2)< 10 “viable”organismsper m3< 10 “viable”organisms per mlVibrio cholera< 1 CFU per 100 mlE. coli< 250 CFU per 100 mlIntestinal enterococci< 100 CFU per 100 ml----N/A2009 – 2019(varies by vesselconstructiondate/BWcapacity/survey dateas per Reg B-3)USNegotiatingPosition(BWM/CONF/13 & 14)< 0.01 “living”organismsper m3< 0.01 “living”organisms per mlVibrio cholera< 1 CFU per 100 mlE. coli< 126 CFU per 100 mlIntestinal enterococci< 33 CFU per 100 ml----N/AASAP[PHASE 1STANDARD]< 10organismsper m3[PHASE 1STANDARD]< 10 organismsper ml[PHASE 1 STANDARD]Vibrio cholera< 1 CFU per 100 mlE. coli< 250 CFU per 100 mlIntestinal enterococci< 100 CFU per 100 ml[PHASE 1STANDARD]----YesOn delivery for allvessels constructedon or after 01/01/12All other vessels:varies by BWcapacity & drydockcycle with latestcompliance date of1stdrydock after01/01/16USCG NPRM(74 FR44632)[PHASE 2STANDARD]< 1 organismper 100 m3[PHASE 2STANDARD]< 1 organismper 100 ml[PHASE 2 STANDARD]Vibrio cholera< 1 CFU per 100 mlE. coli< 126 CFU per 100 mlIntestinal enterococci< 33 CFU per 100 ml< 103“living” bacterialcells per 100 ml[PHASE 2STANDARD]< 104virusesor viral-likeparticles per100 mlYesOn delivery for allvessels constructedon or after 01/01/16All other vessels: 1stdrydocking after01/01/2016, unlessprior installation ofPhase 1 BW system,in which case 5 yearsfrom such installation9Size:≥50Size: < 50μm, but“Lakers**”BacteriaVirusesCompliance Datemicrometers(μm)*≥10 μmCovered?[INTERIMSTANDARD]0 detectable“living”organisms[INTERIMSTANDARD]US negotiatingposition[INTERIM STANDARD]Vibrio choleraIMO Reg D-2 #E. coliUS negotiating positionIntestinal enterococciUS negotiating position< 103bacteria per 100 ml[INTERIMSTANDARD]< 104virusesper 100 mlN/A01/01/10 – 01/01/16(varies by vesselconstructiondate/BW capacity)CALIFORNIA(VGP 401cert/Stateregulations)[FINALSTANDARD]0 detectable“living”organisms[FINALSTANDARD]0 detectable“living” organisms[FINAL STANDARD]0 detectable “living”organisms[FINALSTANDARD]0 detectable“living”organismsN/A01/01/2020ILLINOIS(VGP 401cert)IMO Reg D-2#(as dailyaverage)IMO Reg D-2 #(as dailyaverage)Vibrio choleraa----E. coliIMO Reg D-2 #(as daily average)Intestinal enterococciIMO Reg D-2 #(as daily average)----YesConstructed before01/01/12:01/01/16Constructed after01/01/12:Prior to operationINDIANA(VGP 401cert)IMO Reg D-2#b(as dailyaverage)IMO Reg D-2 #b(as dailyaverage)Vibrio choleraa----E. coliIMO Reg D-2 #(as daily average)Intestinal enterococciIMO Reg D-2 #(as daily average)----NoConstructed before01/01/12:01/01/16Constructed after01/01/12:Prior to operation10Size:≥50Size: < 50μm, but“Lakers**”BacteriaVirusesCompliance Datemicrometers(μm)*≥10 μmCovered?MICHIGAN(VGP 401cert/Statepermit)Use atreatmentprocessapproved byMI DEQUse a treatmentprocessapproved by MIDEQUse a treatment processapproved by MI DEQUse atreatmentprocessapproved byMI DEQNo01/01/07MINNESOTA(VGP 401cert/Statepermit)IMO Reg D-2#b(as dailyaverage)IMO Reg D-2 #b(as dailyaverage)Vibrio choleraa-E. coliIMO Reg D-2 #(as daily average)Intestinal enterococciIMO Reg D-2 #(as daily average)----YesConstructed before01/01/12:01/01/16Constructed after01/01/12:Prior to operation[INTERIMSTANDARD]< 1 “living”organismper 10 m3[INTERIMSTANDARD]< 1 “living”organismper 10 ml[INTERIM STANDARD]Vibrio choleraIMO Reg D-2 #E. coliUS negotiating positionIntestinal enterococciUS negotiating position[INTERIMSTANDARD]----Yes(vessels operatingexclusively withinLakes Ontario andErie are exempt)01/01/12(subject to case-bycase time extension)NEW YORK(VGP 401cert)[FINALSTANDARD]Same asCalifornia #s[FINALSTANDARD]US negotiatingposition[FINAL STANDARD]Vibrio choleraIMO Reg D-2 #E. coliUS negotiating positionIntestinal enterococciUS negotiating positionOther bacteria:Same as CA interim #s[FINALSTANDARD]Same asCaliforniainterim #sYes(vessels operatingexclusively withinLakes Ontario andErie are exempt)Constructed on orafter 01/01/13(subject to case-bycase time extension)11Size:≥50Size: < 50μm, but“Lakers**”BacteriaVirusesCompliance Datemicrometers(μm)*≥10 μmCovered?OHIO(VGP 401cert)IMO Reg D-2#b(as dailyaverage)IMO Reg D-2 #b(as dailyaverage)Vibrio choleraa----E. coliIMO Reg D-2 #(as daily average)Intestinal enterococciIMO Reg D-2 #(as daily average)----Yes(in part -- seecolumn to right)Lakers “launched”after 01/01/16:ImmediateNon-Lakers“launched” before01/01/12: 01/01/16Non-Lakers“launched” after01/01/12: Prior tooperation[INTERIMSTANDARD]IMO Reg D-2 #[INTERIMSTANDARD]IMO Reg D-2 #[INTERIM STANDARD]IMO Reg D-2 #[INTERIMSTANDARD]----Yes(vesselsoperatingexclusively withinLake Erie areexempt)Constructed before01/01/12:01/01/16(subject to case-bycase timeextension)PENNSYLVANIA(VGP 401cert)[FINALSTANDARD]Same asCalifornia #s[FINALSTANDARD]< 0.01 “viable”organism per ml[FINAL STANDARD]Vibrio choleraIMO Reg D-2 #E. coliUS negotiating positionIntestinal enterococciUS negotiating positionOther bacteria:Same as CA interim #s[FINALSTANDARD]Same asCaliforniainterim #sYes(vesselsoperatingexclusively withinLake Erie or PAwaters areexempt)Constructed after01/01/12:Immediate(subject to case-bycase timeextension)1213Size:≥50micrometers(μm)*Size: < 50μm, but≥10 μmBacteriaViruses“Lakers**”Covered?Compliance DateWISCONSIN(11/18/09State permit)< 1 “viable”borganismsper10 m3(as dailyaverage)< 1 “viable”borganisms per10 ml(as dailyaverage)Vibrio choleraa----E. coliUS negotiating position(as daily average)Intestinal enterococciUS negotiating position(as daily average)----NocConstructed after01/01/12:dImmediateConstructed before01/01/12:d01/01/14* For some standards, the groupings actually are stated as organisms > 50 μm and organisms≤50 μm but > 10 μm. For sake of simplicity, this table uses theIMO groupings throughout as the default column header.** “Lakers” are vessels which generally voyage exclusively in the Great Lakes.a Indicator microbes specifiedby State do not includeVibrio cholera.b State has defined “viable” as living AND able to reproduce vs. IMO G8 (type approval) Guidelines (para 3.12) simply define viable as “living.”c Standards apply to oceangoing vessels only. However, WI permit does provide that Lakers shall implement BMPs as specified in§ 2.2.3 of EPA’s VGP(uptake and discharge practices).d WI DNR intends to conduct a review by 12/31/10 to determine ifBWT technology is available to meet the WI standards; if review concludes such BWTtechnology not available, the IMO Reg D-2 #will apply (subject to footnotes a & b). WI permit must be modified for this change to occur.

## 2.3. International Regulation

The role of ships’ ballast wa ter in introducing or spreadi ng ANS has been a concern in the international community si nce the early 1990s. Beginning in 1991, the IMO, which is the principal UN body that addresses pollution from ships, adopted a series of resolutions containing recommended practices to help prevent the introduction of ANS by ballast water. The current resolution was adopted in 1997 and contains guidelines calling for mid-ocean ballast water exchange and other ballast water management practices. IMO Assembly Resolution A.868(20) . (Many of the practices cont ained in that resolution are now, in effect, mandatory with respect to vesse ls with ballast tanks that operate in US waters by virtue of their inclusion in th e previously discusse d USCG ballast water regulations at 33 C.F.R. Part 151, Subpart D.)

Following adoption of that resolution in 1997, a ballast water working group was then regularly convened as part of the meetings of the IMO’s Marine Environment Protection Committee (“MEPC”), with a charge of developing legally binding requirements for a ballast water management treaty. Over the course of such meetings, there was a gradual evolution away from reliance on ballast water exchange as the primary control mechanism to one requiring compliance with ba llast water discharge standards stated in

the form of concentrations of organisms per unit of volume of ballast water discharged. The culmination of this effort was a Diplomatic Conference held at the IMO in February 2004 which adopted the text of a balla st water management Convention. International Convention for the Control and Management of Ships’ Ballast Water and Sediments,

2004 (hereinafter referred to as “the BW Treaty”). The BW Treaty will not enter into force until it has been signed (and, if necessary, ratified) by at least 30 countries representing not less than 35% of the gross tonnage of the world’s merchant shipping. BW Treaty Article 18(1). The US is presently not a signatory, nor, as of the date of this paper, has the treaty entered into force inte rnationally. Informati on on the status of IMO Conventions (as posted on the IMO website http://www.imo.org/home.asp ) indicates that as of May 31, 2010, the BW Treaty has 25 Par ties, representing 24.28% gross tonnage of the world’s merchant shipping.

In effect, the provisions of the BW treaty will apply to Parties’ commercial ships that engage in interna tional voyages. See , BW Treaty Article 3. Subj ect to certain exceptions as set out in BW Treaty Regulations A-3 th rough A-5, such vessels must conduct ballast water exchange, and over time, according to a schedule dependent on vessel build date and ballast water capacity, comply with the Tr eaty’s ballast water di scharge standards. BW Treaty Regulation B-3. Those discharge standards address three size groupings of organisms, and as previously noted, are expr essed as a concentration of organisms per unit of volume discharged. BW Treaty Regulation D-2; see also Table 1 (summarizing those standards). The three size groupings used in Regulation D-2 are based on

minimum dimension and are as follows: 1) organisms >50 microns (to address macrofauna and zooplankton); (2) organisms >10 but < 50 micron (to address phytoplankton); and (3) specified indicator bacteria (to ad dress pathogens). During development of the 2004 treaty, the US took a negotiating position that the standards for

14

## the two larger size groupings, ought to be 1,000 times more st ringent than those ultimately adopted (see Table 1 ). However, the treaty does preserve the ability of Parties to adopt more stringent standards as necessary. BW Treaty Regulation C-1; see also , BW Treaty Article 2(3).

Under the Treaty, ballast water treatment syst ems are subject to a review and approval process, taking into account Guidelines developed by MEPC for such reviews. BW Treaty Regulation D-3. With respect to sy stems using “Active Substances” (biocidal agents) to comply with the BW Treaty, review and approval by the MEPC is conducted

as to the environmental and safety aspects rela ted to the system's use of biocides . The technical procedures for that review (comm only referred to as the “G9 Guidelines” or “G9 Procedure”) are set forth in Resolution MEPC.169(57 ). Under the G9 Procedure, systems using Active Substances are subject to an initial “Basic Approval” and then a “Final Approval” by MEPC as to the environm ental and safety aspects of the biocide’s use. In addition, all systems (whether or not using Active Substan ces) are subject to a separate testing and approval process, this ti me by the Administration (typically the Flag state), as to the ability of the system to kill or remove organisms such that the results of the tests conducted on the system indicate it can meet the BW Treaty Regulation D-2 discharge standards (this type of testing is commonly referred to in IMO as “typeapproval testing”). That type -approval testing is conducte d under guidelines developed by the MEPC (the “G8 Guidelines”) for ev aluating compliance with the Regulation D-2

standards. MEPC Resolution MEPC.174(58) . Typically, for those systems using Active Substances, final approval by MEPC under the G9 Procedure will precede flag state typeapproval under G8.

Although the BW Treaty is not yet in force, a number of systems nonetheless have been submitted for review under the processes desc ribed above. The outcome of such reviews provides some third-party perspective regard ing the development of the technologies so reviewed. Copies of such IMO documents have been provided to the SAB and are discussed in greater detail in Section 4.3

.

3. General Overview of Ballast Wate r Treatment System Design

Treatment of ships’ ballast water can take place either on the vessel or off the vessel following discharge of the ball ast to a reception/treatment vessel (where the water would no longer be considered ballast water) or to a land-based reception facility. Treatment systems intended for onboard use by vessels disc harging their ballast water directly into receiving waters have received the most at tention by technology developers. Information

in this overview section comes from the Lloyd’s Register Review of Ballast Water Treatment Technology (February 2010) (hereinafter refe rred to as “Lloyd’s Register Review”). While providing the most comprehe nsive summary of the current status of treatment technology, that revi ew is based entirely on in formation supplied by the technology vendors. It is not ba sed on an independent analysis or verification of claims made by the authors of th e Lloyd’s Register Review.

15

## 3.1. Treatment Processes

BWT systems are broadly based on three main processes: physical separation, biocidal treatment, and physical-chemical processe s. Some BWT syst ems incorporate a combination of these processes. A brie f description of each process is below.

Physical separation

While separation in the broader water treat ment industry includes several different processes, for ballast water treatment it is e ssentially limited to screen and disk filters and/or hydrocyclonic separators . The former are almost all self-backwashing designs. Some media filters have been examined, but weight and cleaning issues have generally proved discouraging – although at least one novel concept for use of compressed crumb rubber has been published (Tang et al., 2006; Tang et al., 2009).

In general, hydrocyclones have not proven to be very effective, and only a few BWT systems using them are still in active de velopment (Gregg et al., 2009). Separation is used as part of a process tr ain to both remove larger organisms (generally, pore sizes of 25 – 100 um are used), and represent a balanc e between the need to remove organisms, the need to move large amount s of BW very rapidly (hundreds to many thousands of cubic meters per hour), and the need to reduc e the amount of solids in ballast water to facilitate the action of various biocidal proc esses. As nominal pore size decreases, backwash cycling increases, and effective pumpi ng rates decrease. Lowered pumping rates can significantly slow cargo ope rations, with consequent ec onomic impacts to carriers (vessel owners/operators) and shippers (the companies paying vessels to carry cargo).

At least one system developer (the Hi tachi Ballast Water Purification System (“Clearballast”)) has incorporat ed flocculants or coagulants to facilitate the separation processes. This is particularly important fo r the use of hydrocyclones, which work on the basis of differential density, and most of th e organisms that need to be removed from

ballast water are not much denser than the water.

Biocidal treatment

Biocides used in BWT systems include chemicals such as oxidizing solutions (usually created by electrolytic processes using sea water as the source of ions), chlorine dioxide, and peracetic acid; non-oxidizing chemicals su ch as menadione/vitamin K (trade name

SeaKleen © 

## ).

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

concentrations of residual biocide. A furthe r issue with systems using chemical biocides is the potential for producti on of disinfection by-products, such as trihalomethanes and

halo-acetic acids.

Many of the systems currently available or in development use chemical neutralizing agents prior to discharge. According to the Lloyd’s Regi ster Review, most ozone and

16

## chlorine systems neutralize treated ballast water before discharge, but some do not. Some treatment system developers rely on minimum hold times to provide an opportunity for sufficient degradation of residuals. In at least one case this has proven problematic for a type-approved system. The Hamman-SEDNA ® 

## ballast water treatment system using PERACLEAN ® 

## Ocean, which uses the prop rietary biocide PERACLEAN ® 

## Ocean, a peracetic acid-based oxidant, was found to have significantly longer degradation rates in cold water than was expected, and the sy stem has subsequently been taken off the market (Eason, 2010; Lloyds, 2010). This i ssue may not be unique to PERACLEAN ®



## Ocean, as other biocides have also been found to have variable degradation rates dependent upon temperature (Landrum et al., 2003). This example provides an indication

of the current limitations of the internationa l approval process in that the G8 and G9 Guidelines were not subject to validation prior to their use. Furthermore, the challenge conditions that are specified in the G8 Guidelin es may not provide for an adequate test of system performance under the full range of vessel operations for which the systems are intended. Temperature and salinity are two important examples, as it is possible under the current test procedures for systems to be type approved for all temperatures and salinities, while only being subjected to testing under a relatively narrow, and nonextreme, range of both. See Section 4.4 for additional discussion.

Physical-Chemical Processes

Physical-chemical processes used as means to kill organisms include Ultraviolet (UV) and ultrasonic (US) radia tion, shear/cavitation; and deoxygenation (through lowered pressure via venturi or vacuum, or lowered partial pressure via gas sparging with inert gasses).

Most of the systems using UV employ medi um pressure amalgam lamps, although some low-pressure systems exist. UV effectiven ess depends on the applied UV dose/power of the lamp, however, the Lloyd’s Register Review states that this information has not been given by all suppliers. The transmissivity of the water being treated is another critical variable affecting the effectiv eness of UV systems. Without accessory filtration, or other separation of solids, UV will not likely be as effective as necessary. While all UV-based systems to date employ front-end separation processes to improve transmission of UV, the challenge conditions required for type a pproval under the G8 Guidelines (TSS > 50 mg/L for brackish and fresh water; POC > 5 mg/L for brackish and fresh water) are far

below the levels that can be encountered in estuarine harbors around the world (by 2 orders of magnitude for TSS).

Although most of the systems that currently ex ist are based on traditional water treatment processes, deoxygenation-based technologies have been specifically developed for ballast water treatment. Deoxygenation is accomp lished through a variety of mechanisms, including pressure drops and gas sparging of inert gases. Deoxygenation may take longer than other processes (between one and four days seems likely, given current information), and thus represents the only type of tec hnology where voyage length is a primary factor in process efficacy – although as mentioned above, some of the systems using chemical

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

17

## Deoxygenation may not be as broadly effective as other means of disinfection, as some organisms, particularly microorganisms, are able to survive for extended periods of time under low oxygen conditions.

3.2. Treatment Systems

Most treatment systems make use of 2 or more treatment processes in a train, for example, physical separation followed by some type of biocidal treatment(s). In practice, some systems, particularly those using se paration and UV, are used on both uptake and discharge of ballast water. On uptake the full process train is engaged, with back-flushed solids from the filter being discharged overboard at the point of uptake. On discharge of the ballast water, the filter is bypassed and the water is exposed to the UV process immediately prior to discharge. An appare nt assumption by many of the developers of these separation+UV systems is that there is no regulatory or environmental concern about the discharge of the filter backwash to the environment, since the water and sediment is “just being put back where it was taken up...”. However, some jurisdictions have regulatory limits on suspended solids, a nd concentrations of ot her substances such as metals that such backwashing may exceed.

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

• Filter+UV+O 3



## • Filter+US+O 3



## • Filter+electrolysis+US

• Filter+deoxygenation+cavitation

• Filter+cavitation+electrolysis+O 3



## • Shear+cavitation+O 3



## The expected relative contributions of each pr ocess to the system efficacy, under the wide range of conditions under which the systems w ill be expected to work, is not always apparent in the information available for many of these systems.

3.3. Treatment System Requirements

Size (foot-print, volume, weight) and power re quirements are key issues of concern for vessel operators considering th e pros and cons of alternat ive treatment systems. For operational and logistical reason s, most treatment systems are intended for use in engine or pump rooms, where space is quite limited. Until the last year or two, provision of sufficient space in these areas for BWT syst ems have not been requirements in vessel designs. Consequently, installation often requires fitting the different modules into available spaces on an ad hoc basis. The larger the system , or the more inflexible its physical arrangement, the more negatively it is likely to be viewed by ship owners/operators. The availability of pow er is an issue because ships often have competing demands on available power during cargo operations when most ballast water

18

## is taken on and discharged; and upgrading generator capacities to provide additional power necessary for ballast water treatment is an additional expense, both in capital costs and on-going fuel costs. This also results in other increased e nvironmental impacts by increasing green house gas and other emissions. Consequently, the systems currently in play have a fairly narrow range of space and power requirements (Table I). However, it is important to keep in mind that in most cases, these numbers are for individual, or a small number of ganged, units. Many of th ese systems are designed to handle high flow rates by using multiple units, each rated for 200 – 300 m 3 

## /h. In such situations, both space and power requirements would be signi ficantly larger, although the relationship between flow and size is not necessarily linear.

Table 2. System Space and Power Characteri stics for Ballast Water Treatment Systems ( From Table 4 in Lloyd’s Register Review)

.


## Footprint 200

m 3 

## /h (m 2 

## ) Footprint 2000

m 3 

## /h (m 2 

## ) Height (m) Power (kW

/1000 m 3 

## )

Mean 7 21 3 68

Data Points 37 30 37 33

Min 0.3 1 1 0

Max 30 145 4.6 220

3.4. Treatment System Flow Capacities

While more than half of the vendors polled by Lloyd’s claim to offer systems that can handle flow rates of >10,000 m 3 

## /h, in many cases, this would be achieved through ganging multiple system units rated individually at 200-300 m 3 

## /hr. However, systems are not generally tested for type approval in su ch ganged configurations and at such high

flow rates.

3.5. Availability of Treatment Systems

Since the adoption of the IMO BWM Conven tion in 2004, and more particularly since the initial adoption of the G8 Guidelines for approval of ballast water management systems in 2005, a substantial number of treatment systems have been put into development globally ( Figure 1 ). The apparent decline in new systems as shown in Figure 1 may reflect a real plateau in the number of systems, or may be an artifact of the process. Many systems do not come to publ ic light until they apply for G9 Basic Approval by the MEPC, and it is at that time that estimates are made for their timelines for Final Approval by MEPC and G8 type appr oval by an Administration. For instance, applications for Basic Approval of five sy stems not identified in the Lloyd’s Register Review of February 2010 have been submitte d for consideration by MEPC in September of 2010; however, we have included these systems in Table 5 of this paper.

19

### Figure 1. Number of systems approved by year. BA= MEPC Basic Approval; FA= MEPC Final Approval; TA= Administration Type Approval. All numbers from 2010 onwards are predictions made in February 2010. Data from Lloyd’s Register Review (2010).



## 4. Technical Documents Provided to the Committee

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

water treatment vendors must show that th eir systems meet the IMO Regulation D-2 Standards (see Table 1 ) in three consecutive valid shi pboard test cycles and five consecutive valid land-based cycl es to obtain type approval. Much of the living organism effluent data discussed below, particularly that collected in recent years, was gathered with the intention of seeking type approval from a given flag Administration. Other data were assembled in applications for accepta nce of vessels in the vessel’s Shipboard Technology Evaluation Program (STEP), di scussed in greater detail on page 26 of this paper. Because this is pre- existing information developed under procedures not subject to our control, EPA nor Coast Guard staff cannot provide any quality assurance or quality control on any of the data or reports provided to the committee for this review, nor confirm the testing results reported actual ly meet the minimum guideline standard of passing three consecutive valid shipboard test cycles and five consecutive valid landbased cycles.

In order to assist with the committee’ s evaluation, EPA has provided numerous background documents discussing ballast wate r treatment systems and reporting results from their testing. For purposes of this pa per, these documents have been divided into three major categories. The first category c ontains summary reports produced by parties evaluating the availability of existing ballast water treatment systems or their potential

20

## efficacy (Section 4.1 ). These reports will help inform the committee about ballast water treatment systems in general, issues that ma y be present in their testing, and in some cases, provide summary data. These repor ts thus should be useful or provide introductory background to help the committ ee answer all seven charge questions.

The second category of background documents contains the primary performance data reports available to EPA and USCG (Section 4.2 ). These are land based and/or ship based testing reports, provided by either flag Administrations 9 

## or the manufacturers, to EPA or USCG. Performance reports or summ aries of evaluations are available for 8 systems; many of these reports go into consid erably more detail than the summary reports above. Many of these documents also give engineering details which may prove useful to the committee in answering questions 1c, 2, and 3 of the charge. However, detailed results discussing the quality of the effluent produced during the test s are notably absent

from several of these available sources. Additionally, although we are aware that data have been collected on other additional systems, those data are not all available to us to provide to this committee: see a dditional discussion on page 30.

The third grouping of background documents are being provided to serve as a reference library for the committee (Section 4.3 ). With one exception, these documents have been prepared as reports for, or submissions t o, IMO as part of the G9 Procedure review process and contain additional background on system design for committee members. An additional document written by a class society 10 

## is also included in this section. Because this is provided as background information for that purpose, we do not expect each

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

Additionally, we discuss the pot ential availability of other information, which we would

welcome committee members to introduce at the first committee meeting. Section 4.3 also contains a table ( Table 5 ) which committee members can use as a guide to get a

sense of all known ballast wate r treatment systems and where they stand in development and testing. For instance, if a treatment has been type appr oved, clearly data have been collected regarding treatment system performance, however, in many cases, those data are not currently available to us for supply to the committee.

All of the documents being provided to the committee are being supplied on a supplemental CD 11 

## . On that CD, an Excel index is provided which includes the system discussed, the title of the documen t, the date, and a hyperlink from that file to the targeted file. That index listing all documents supplie d to the committee is also provided here as Appendix IV. We believe that committee memb ers can use this resource as a tool to

assist in their evaluation of the informa tion provided, and to identify strengths and shortcomings in data availability to a ssist in answering th e charge questions.

9 

### Flag Administration means the Government of a State whose flag the ship is entitled to fly (from 33 CFR § 169.5 ).

10 

### The IACS defines class societies as “organizations th at establish and apply technical standards in relation to the design, construction and survey of marine related facilities including ships and offshore structures.”

11 

### All documents provided on this CD and listed in Appe ndix IV are also included in a public docket. That docket, number EPA-HQ-OW-2010-0582, can be accessed at www.regulations.gov

.



## 21

## 4.1. Third Party Reports or General Evaluations

There are six documents being provided to th e committee which are third party reports or general evaluations. We believe that these documents will prove a significant resource for the committee by providing additional us eful background information and an overview of system engineering designs, th e complexities associated with evaluating these systems, and in the case of Dobroski et al., (2009a), summary data. These

documents are:

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

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

2010 );

• A June 2010 report produced by American Bureau of Shipping (ABS), which examines ballast water treatment systems and discusses considerations for shipowners when th ey select and inst all these systems; (ABS 2010)

• A January 2009 assessment of the efficacy, availability and environmental impacts of ballast water treatment sy stems for use in California Waters prepared for the California State Legi slature by staff from the California State Lands Commission ( Dobroski et al., 2009a );

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

2009b );

• A September 24, 2009, Circular prepared by the IMO Secretariat on the international approval status for various ballast water treatment systems that make use of Active Substances (IMO, 2009);

• Excerpts from a white paper titled “Density Matters,” produced by Lee et al. (2010), which, in part, examined Dobroski’s et al . analyses (2009a, 2009b) of systems that may be potential ly available to meet the California

Standard.

Lloyd’s Register Review

The February 2010 Lloyd’s Regist er Review discusses the st atus and availability of existing ballast water treatment systems. Th is review, based upon ba llast water treatment manufacturer survey responses, addresses i ssues such as space requirements, system costs, system capacities, and systems’ IMO approval status 12



## .

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

In June 2010, the classification society AB S published an Advisory on Ballast Water Treatment Technologies. Similar to the Ll oyd’s Register Review, the ABS Advisory gives an overview of treatment technologies a nd lists the status of various ballast water treatment systems. However, this document also goes into detail for factors vessel

12 

### Note that we have provided an updated status as to ballast water approval of various systems by the IMO that is current as of June, 2010 in in Section 4.3 of this document. Table 4



## 22

## operators should consider when they purch ase and install various systems such as corrosion and safety concerns, power ratings, total lifecycle costs, and ease of operation.

In addition to providing information targeted to shipowners, the appe ndix of that report also provides summary information on 14 differe nt ballast water treatment systems, with

links to each of those manufacturers’ websites. The ballast water treatment systems for which it lists summary information are the Alfa Laval Ballast Water Management

( 

## PureBallast) System, Electro-Cleen TM 

## System (ECS), OceanSaver ® 

## Ballast Water Management System, Venturi Oxygen Stripping (VOS) System, Hyde Guardian TM


## Ballast Water Treatment System , NK-O3 BlueBallast, OptiMari n Ballast System (OBS),

Hitachi Ballast Water Purification ( 

## ClearBallast) System, GloEn-Patrol TM 

## System, Resource Ballast Technologies System/U nitor BWTS, JFE BW MS, Hyundai Heavy

Industries ( 

## HHI) EcoBallast System, RWO GmbH Marine Water Technology, Veolia Water Solutions & Technologies (C leanBallast) System and Greenship Sedinox ® 

## Ballast Water Management System. Note that the only systems for which we are able to provide primary data in Section 4.2 are the NEI Venturi Oxygen Stripping (VOS) system and the Hyde Marine (Hyde Guardian TM 

## ) System (both underlined above).

2009 Assessment of the Efficacy, Availability and Environmental Impacts of Ballast Water Treatment Systems for Use in California Waters ( Dobroski et al., 2009a )

The California State Lands Commission has prepared a report, as directed by the California Coastal Ecosystems Protection Act of 2006, as to “the efficacy, availability, and environmental impacts, including water qua lity, of currently available ballast water treatment technologies.” ( Dobroski et al., 2009a ). The authors provide summaries of various treatment technologies, explanations of how they used vendor supplied data to evaluate those technologies, and conclusions on what they believe those data might mean for system availability. Based on their criter ion of “at least one replicate in compliance with the performance sta ndards” for each size grouping 13 

## , irrespective of failure rate, the

CSLC concluded that: “at least two treatment systems have demonstrated the potential to comply with California’s performance standards.” 14 

## However, the authors of the report take pains to note that: “t he [California State Lands] Commission does not approve ballast water treatment systems” and that a “positive compliance assessment for the purpose of th[eir] report, however, does not relieve the vessel ow ner/operator of the responsibility of complying with California’s performance st andards for the discharge of ballast water.” In addition to descriptions of ballast water treatment systems and their analyses, the authors provide vendor-supplied summary data in the Appendices, which may be useful for the committee in an swering question 1 of the study charge.

Lee et al. (2010), discussed below, also de scribes the California report, which may further inform the SAB’s analys es of technology availability.

13 

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

effluent.

14 

### California Performance Standa rds are listed in Tab . le 1



## 23

## October 2010 Update: Ballast Water Treatme nt Technologies for Use in California Waters ( Dobroski et al., 2009b)

In October, 2009, Dobroski et al . updated the previous versio n of the report. In this update, the authors evaluated additional data and concluded on the basis of the same criterion as in the first report that “at leas t seven ballast water treatment systems: Alfa Laval, Ecochlor ® 

## , SEDNA ® 

## ballast water treatment system using PERACLEAN ® 

## Ocean, Hyde Marine TM 

## , OceanSaver ® 

## , OptiMarin, and Techcross have demonstrated the capability to comply with California’s perfor mance standards for the discharge of ballast water.” Similar to the first report, the author s note that the report does not: “constitute an endorsement or approval of any treatment system or system manufacturer by the

Commission. The Commission doe s not approve ballast wa ter treatment systems.”

Unlike the 2009a full report, the interim report does not contain an appendix with the primary vendor-supplied data used in the analys is. According to CSLC staff, an updated version of this report, containing such data , may be available in summer of 2010. If finalized, that report woul d be made available at: http://www.slc.ca.gov/Spec_Pub/MFD/Ballast_Water/Reports_Presentations.html

.

IMO’s International Convention for the Contro l and Management of Ships’ Ballast Water and Sediments, 2004 - List of ballast water ma nagement systems that make use of Active

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

The September 24, 2009 IMO Secretariat Circul ar (BWM.2/Circ 23) provides a list of systems that have received G9 ”Basic” or “Final” approval for their use of Active Substances, reflecting the decisions made up to and including the 59 th 

## meeting of the MEPC. Note that such approvals only appl y to evaluating the potential risk from the biocides or by products used by the ballast water treatment system and do not evaluate the efficacy of the system in neutralizing li ving organisms. Hence, these approvals are not directly relevant in terms of showi ng the degree of treatment these systems can achieve; rather this document is being provided in this se ction to serve two purposes. First, the document provides a compendium of ballast water treatment systems which use Active Substances as of September, 2009. S econd, it gives the reviewer a general sense of where these treatment systems are in the international approval process.

Additionally, so as to provide the most updated information possible, we have summarized subsequent G9 decisi ons that were made at the 60 th 

## meeting of the MEPC in

the Table 3 . This Table should be used as a supp lement to the IMO Circular 23 to update the Active Substance approval status for the systems it addresses.

24

### Table 3. Additional G9 Decisions Made Subse quent to BWM.2/Circ.23 (List of ballast water management systems that make use of Active Substances which received Basic and Final Approvals).



# MEPC 60 G9 Decisions (March 26, 2010) 15



## Basic Approval GRANTED

Siemens SiCURE TM 

### Ballast Water Management System Proposed by Germany in document MEPC

59/2/11 Sunrui Ballast Water Management System Proposed by China in document MEPC 60/2/3 DESMI Ocean Guard Ballast Water Management System Proposed by Denmark in document MEPC

60/2/4 Blue Ocean Guardian (BOG) Ballast Water Management System Proposed by the Republic of Korea in

document MEPC 60/2/5 Hyundai Heavy Industries Co., Ltd. (HHI) Ballast Water Management System (HiBallast) Proposed by the Republic of Korea in

document MEPC 60/2/6

Kwang San Co., Ltd. (KS) Ballast Water Management System "En-Ballast" Proposed by the Republic of Korea in

document MEPC 60/2/7 OceanGuardTM Ballast Water Management System Proposed by Norway in document MEPC

60/2/8 Severn Trent DeNora (BalPure ® 

### ) Ballast Water Management System Proposed by Germany in document MEPC

60/2/9 

## Basic Approval DENIED
ATLAS-DANMARK Ballast Water Treatment System Proposed by Denmark in document MEPC

60/2 

## Final Approval GRANTED

GloEn-Patrol TM 

### Ballast Water Management System Proposed by the Republic of Korea in

document MEPC 59/2/7 Resource Ballast Technologies System Proposed by South Africa in document MEPC

59/2/10 JFE Ballast Water Management System (BallastAce) Proposed by Japan in document MEPC 60/2/2 HHI Ballast Water Management System (EcoBallast) Proposed by the Republic of Korea in

document MEPC 60/2/1 

## Final Approval DENIED

Ecochlor ® 

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



## Density Matters: Review of Approaches to Setting Organism-Based Ballast Water Discharge Standards (Lee et al., 2010).

Density Matters (Lee et al., 2010) was sp ecifically written to supply background information to the ongoing NRC study examini ng approaches to setting environmentally protective organism-based balla st water discharge standards 16 

## . There are two major

15 

### Source: Report of the 60th Meeting of the Marine Environment Protection Committee, MEPC 60/22 (see discussions therein under agenda item 2).

16 

### As discussed in the introduction to this paper, EPA and USCG are currently sponsoring a contemporaneous study led by the National Academy of Sciences’ National Research Council (NRC) to examine that issue (see Appendix II ). In that NRC study, EPA and USCG are requesting that the NRC broadly assess and make recommendations about various approaches for assessing the risk of establishment of new ANS from ballast water discharges.



## 25

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

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

of the data evaluation in Dobroski et al. ( 2009a

, 2009b ). The second relevant section

examines the statistical considerations in es timating concentrations of organisms larger than 50 microns in ballast water discharg es. This section discusses statistical

considerations which were not considered in development of the G8 Guidelines, and points to limitations in arriving at statistically significant or conclusive results based on data collected using methods cons istent with the G8 Guidelines. 17 

## Additional extracts from this report include regulatory backgr ound and another table li sting ballast water discharge standards to serve as additional references for the committee as needed. Additionally, the bibliography from the Lee et al. (2010) paper is in cluded to serve as a

reference list if needed.

4.2. Available Information for Specific Ballast Water Treatment Systems

In order to evaluate the efficacy of their ba llast water treatment systems, several vendors have conducted land-based and/or ship-based evaluations of their systems. The reports provided to the committee fall into three categor ies: (1) those that include data reports from the testing of ballast water treatment sy stems provided to foreign Administrations in granting type approval under the BW Treaty a nd (2) data reports gathered by vendors in preparation to apply for type approval by a fl ag Administration, or (3) application packets prepared by the vendor and submitted to the USCG under the Shipboard Technology Evaluation Program ( STEP ). We believe the information in this section should help the committee answer questions 1, 2, and 3 of the charge.

As previously discussed, in order to be type -approved in terms consistent with the BW Treaty (International Maritime Organization, 20 04), all ballast water systems (whether or not using Active Substances) are subject to a testing and approval process by an Administration (typically the Flag state or their authorized representative). These tests must demonstrate the ability of the system to kill or remove organisms such that the results of the tests conducted on the system indicate it can meet the Treaty’s Regulation D-2 discharge standards (see Table 1 ). This type of testing is commonly referred to as “type-approval testing” and it is to be c onducted under G8 Guidelines as set forth in resolution MEPC.174(58) (Octobe r 10, 2008). Many of the reports included below were prepared as part of a system manufacturer’s preparations for seeking such G8 typeapproval.

STEP was established by the US Coast Guard in 2004 as a way to encourage onboard ballast water treatment system development and testing. According to the US Coast Guard’s: January 2, 2004, Navigation and Vessel Inspection Circular No. 01-04 for the STEP program:

17 

### EPA and USCG are working toward finalizing an ETV Ballast Water Protocol, which will include updates to discharge testing recommendations to address issues associated with such monitoring complexity, including discussing statistical limitations.



## 26

### “STEP is intended to facilitate the developm ent of effective BWT technologies, thus creating more options for vessel owners/opera tors seeking alternatives to ballast water exchange. Technology develope rs and vessel owners/operators have agreed on the need for incentives that will encourage the development of prototype treatment systems and shipboard testing. However, vessel owners /operators have expressed a reluctance to invest the resources to install and operate an experimental treatment system that might not meet discharge standards mandated by futu re regulations. To address this concern, vessels accepted into this program may be gran ted an equivalency to future ballast water discharge standard regulations, for up to th e life of the vessel or the system, while the prototype system operates satisfactorily.”



## Systems entering the STEP program are genera lly in the advanced prototype stage. Hence, the data provided as part of STEP application may not be the most current data, and may also not reflect the most current changes to a system. For example, the

Ecochlor ® 

## system, discussed below, has data in its STEP application, and then more current data in a land-based report. Betw een preparation of these two packages, the system underwent a modification, whereby a filter was added to increase system performance.

Systems for which Data Reports are Provided to the Committee

This section contains reports or papers on eight separate treatment systems, most of which contain at least some primary summa ry data. These reports generally do not contain significant raw data. This section is organized by treatment manufacturer, with each data report briefly introduced in that sect ion. In many cases, we have not been able to obtain primary data reports for this co mmittee’s review. Generally, data on systems provided by willing flag Admini strations are more thorough and developed than data provided under STEP, through peer reviewed papers, or simply flag Administration papers submitted to the IMO. The systems fo r which flag administrations either provided reports to the Coast Guard or made those reports publically available were Hamann AG (Sedna ® 

## BWMS), Hyde Marine, and NEI Treatme nt Systems LLC (all noted below).

Echoclor ® 

## , NEI Treatment Systems LLC, and Severn Trent De Nora include information provided to the Coast Guard as part of th e STEP application process. Additionally,

Echoclor ® 

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

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

Oceansaver ® 

## , OptiMarin, and PureBallast) contains examples of several type approval certificates for certain systems for which we do not have data or summary reports from the flag Administration or the treatment system developer.

Table 4 lists each individual system for which we were able to provide the committee with additional specific information beyond th eir G9 summary reports or type approval certificates Type Approval Cert ificates, highlights how that system functions, and where that additional information can be found. Note that the names of systems which have been type-approved are shaded in green (see section 2.3 for discussion regarding type approval and Table 5 for additional treatment system specific information).

27

### Table 4. Ballast Water Treatmen t Systems for which we have provided additional information.

Supplier System Technology Have shipbased or

land-based testing been

conducted? Are data available

to this committee in this package (other than G9 summary

reports or Type Approval Certificates)? Document where

Data can be found

Alfa Laval Tumba AB (Pureballast) Filtration, UV, TiO 2 Y 2 N Norwegian Maritime Directorate (2008)

Ecochlor Inc. (Ecochlor® BWMS) Filtration, chlorine

dioxide Y Y Veldhuis et. al (2009) and Ecochlor (2006)

Environmental Technologies Inc. Filtration, ozone,

ultrasound 1 Y Y 3 Dobroski et al. (2009a )

Greenship (Sedinox ®
BWMS) Hydrocyclone, electrolysis/

electrochlorination Y Y Siefert and Siers (2007)

Hamann AG (SEDNA® 250 BWMS) Hydrocyclone, filtration, peracetic acid Y Y Veldhuis and Fuhr (2008) and Eason (2010)

Hi Tech Marine Pty Ltd. Heat 1 Y Y 3 Dobroski et al. (2009a ) Hyde Marine; Lamor Corporation, LLC (Hyde Guardian) Filtration, UV Y Y ten Hallers et al (2009); Veldhuis et al (2009b); Wright (2009)

Marenco Technology Group, Inc. Filtration, UV 1 Y Y 3 Dobroski et al. (2009a )

Mitsui Engineering and Shipbuilding Co. Ltd. (SP-Hybrid BWMS Ozone Version) Hydrodynamic shear, cavitation, ozonation 1 Y Y 3 Dobroski et al. (2009a )

NEI Treatment Systems

LLC (Venturi Oxygen Stripping (VOS)) Deoxygenation,

cavitation Y Y NEI (2007)

Oceansaver AS (OceanSaver® BWMS) Filtration, deoxygenation,

cavitation Y 2, Y 3 Norwegian Maritime Directorate (2009b),

Dobroski et al. (2009a )

OptiMarin (OptiMarin Ballast System) Filtration, UV 1 Y 2, Y 3 Norwegian Maritime Directorate (2009a)

and Dobroski et al. (2009a )

Severn Trent De Nora (BalPure®) Filtration, electrolysis/ electrochlorination, Cl

neutralization Y Y 3 Dobroski et al. (2009a )

Siemens (SiCURETM BWMS) Filtration,

electrochlorination Y Y Cangelosi, (2010a

, 2010b )

Techcross (Electro-Clean System (ECS)) Electrolysis/

electrochlorination Y Y Kim et al (2008)

Vitamar, LLC (SeakleenTM) Menadione / Vitamin K3 (as SeakleenTM) 1 Y Y 3 Dobroski et al. (2009a ) 1 Information from Lloyd's Register Review (2010). 2 Land-based testing results, which to date, have not been given to US EPA or the US Coast Guard 3 Information on whether testing had taken place came from Dobroski et al. 2009 discussed in Section 4.1 . Summary data only



## 28

## Ecochlor ® 

## Inc. (Ecochlor® BWMS):

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

The first document is Section 4 of Ecochlor 's 2006 STEP application and were provided to USCG to enroll a testing vessel into STEP (Echoclor, 2006). These data are from early shipboard testing of the full- scale Ecochlor system and do not reflect current system design (a filter has subsequently been incorpor ated in the system) or use the most current testing approaches. The second document by Veldhuis et al. (2009a ) reports on the landbased testing results from the current design of the Ecochlor system. The authors of that report tested the Ecochlor system (includi ng the mechanical filter) and noted that no regrowth of organisms in treated efflue nt was observed for more than 15 days. Environmental acceptability tests showed that the growth of plankton was not limited by the discharge water indicating that the disc harged water was not significantly toxic. Furthermore, upon discharge, no residual eff ects of the chemical treatment to the receiving environment were observed. The third document is the final Environmental Assessment prepared by USCG to accept this syst em for a particular vessel into the STEP program ( USCG, 2008 ).

Note that the Ecochlor ® 

## system has not yet been type -approved. Also, as noted in Table

5 , the Ecochlor ® 

## system was denied final approva l at a recent MEPC meeting, as recommended by GESAMP. The manufacturers of the system have submitted

information to MEPC to seek this final a pproval and are preparing a package to submit for type approval of the system by the Germ an Administration. See, MEPC 61/2/8.

Electro-Clean Ballast Water Management System:

Kim et al. (2008) discuss constructing a large test barge for land-based testing for Type Approval of ballast water management system s in the Republic of Korea. The paper describes the Electro-Clean System. This paper provides no data on the efficacy of the treatment system. The second document is the MEPC 59/INF.6 paper submitted by the Republic of Korea on the G8 type approval of this system. This paper notes that the system has ‘passed’ various components of testing, without discussing methods in depth or giving any specific results. Also note th at this MEPC paper includes the table of contents for a more detailed report; however, at this time, we do not have a copy of these

results.

Greenship’s Sedinox ® 

## ballast water treatment system:

A single document for the Greenship (Sedinox ® 

## BWMS) is included here (Siefert and Siers, 2007). This short 10 page report, published in 2007, described the land based testing for discharges from a moored ve ssel utilizing the Greenship ballast water

treatment system.

Note that the Greenship Sedinox ® 

## BWMS has received IMO G9 Basic and Final approval, but has not yet received type approval.

29

## Hamann AG (Sedna ® 

## BWMS) 18 

## (note: recently removed from the market):

Four documents in this secti on reference the Hamann AG (Sedna ® 

## ) system. The Hamann AG (Sedna ® 

## ) system uses a hydrocyclone to se parate out some solids (potentially including living organisms) and then treats the less turbid water with a proprietary

biocide known as Peraclean ® 

## . The first document, Siefert and Siers (2007), is a summary data report. The second document, the Vel dhuis and Fuhr (2008) re port, describes the

land-based tests which were run on the Sedna ® 

## system, and provides some summary data on the residual discharge. The researchers in this report also found that there were no

residual biocidal effects and the Active Subs tance was found to decompose in 24 hours. After 5 days in seawater test s, the authors noted a slight but insignificant effect from remaining acetic acid.

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

## in coldwater and freshwater ecosystems. Further testing revealed that Peraclean ® 

## remained toxic in these environments, and Hamann subse quently pulled this treatment system from the market (Eason, 2010; Lloyds, 2010). Hence, though this treatment system received G9 Basic and Final approval, and was type -approved under the G8 Guidelines, it was later found to pose an unacceptable ecological risk.

Even though the Hamann AG system has b een removed from the market, we have included these data here for two purposes. First, this data report adds another example of primary summary data for the committee to consider in what might be possible for existing treatment systems. Secondly, it also serves as an example that, even though treatment systems undergo significant toxicologi cal testing and G9 review, they may still be found to cause unacceptable secondary enviro nmental impacts in receiving waters at a

later date due to the bi ocide residual discharge.

Hyde Marine Lamor Corporation, LLC 19 

## (Hyde Guardian TM 

## ):

Five documents are included which exclusivel y discuss the Hyde Marine System. The first document does not discuss the efficacy of the system in neutralizing living organisms, instead, ten Hallers et al. (2009) provides a de scription of how the system

works and its use of filtration and UV treatment . The report further discusses the risk to safety of the ship, ship integrity, if the syst em can be installed safely in a hazardous area, corrosivity, risk for fire and explosion, the absence of risk from chemicals (there are no active substances used), risk to the crew, risk to human health, risk to the aquatic environment, and noise level. The report’s authors also examine information on potential byproducts and end products, th eir toxicological profile, a nd the actual presence or absence of those products under potential cond itions the system might meet. The authors

note the environmental benefits of the H yde System not using Active Substances.

18 

### Note that the data for this system were made publicly available by the German Government as a flag

Administration.

19 

### Note that the data for this system were made publicly available by the British government as a flag

Administration.



## 30

## The second document by Veldhuis et al. (2009b) summarizes results from tests run on the Hyde Guardian TM 

## system. The authors report that tr eatment by the system was found not to deactivate the entire plankton communit y, and environmental acceptability tests showed that growth of organisms was not limited by the discharge water (and therefore, did not have notable toxicity). The thir d document by Wright (2009) summarizes the results of shipboard testing of the Hyde System.

The final two documents are the MEPC 59/INF.20 report where the United Kingdom reports to the IMO that the Hyde System has been type approved by that flag Administration and a copy of th e type approval certificate.

NEI Treatment Systems LLC (V enturi Oxygen Stripping (VOS)) 20



## Six documents are provided to support the an alysis of the NEI Treatment Systems LLC, representing one of the more complete data packets available to the committee. These documents generally discuss results for both the efficacy of the system at neutralizing organisms and its potential toxicity, testing methods, a nd give an overview of the engineering of the systems. One document is the USCG STEP Application (NEI, 2006). This application contains the study plan for evaluation onboard a test vessel, a description of how the system functions, and other info rmation including discussions of vessel and crew safety. A second document is the a pplication for type approval certification submitted by NEI to the Liberian Flag Admini stration. Similar to the STEP application,

this document contains an overview of how the system functions and testing results regarding the efficacy of the treatment system, among other things. A third document, Tamburri and Ruiz (2005), is a peer review ed paper which provides summary data of the efficacy of the NEI system. The fourth and fifth documents are acute and chronic toxicity reports (Burton et al., 2008; Fischer et al., 2009). These short reports summarize the results of Whole Effluent Toxicity testi ng of effluent from lab scale NEI units. The final document contains three type approva l certificates (Liberia, Malta, and The Marshall Islands), which show that this system has received flag Administration approval from three separate Administrations.

Severn Trent De Nora (BalPure ® 

## )

Three documents are provided which discu ss the Servern Trent De Nora BalPure ®


## system. The first is an application package the company submitted to the State of Washington to obtain approval to use the system in that State’s waters (Severn Trent De Nora, 2005). That package c ontains detailed informati on about how the company’s

BalPure ® 

## system works, and alludes to work conducted which examined the efficacy of that system in land-based testing. The second document (Herwig, 2004), a mesocosmscale study, examines the efficacy of this type of system at eliminating certain organisms, and whether the residuals from the system contain significant tota l residual oxidant (TRO). The third document is the Envir onmental Assessment prepared for the USCG discussing the design of the system and its potential impacts on th e aquatic environment

20 

### Note that much of the data for this system were provided by the Liberian Government as a flag

Administration.



## 31

## ( Volpe, 2009 ). Though these documents do not provi de the level of discharge data provided by other systems discussed in this section (e.g., NEI, Hyde Marine), these documents provide engineering overviews, a nd some early monitoring results collected for this system. Additionally, note that summary data on the BalPure ® 

## system are presented in Dobroski et al., 2009a

.

Siemens (SiCURE TM 

## BWMS)

Two documents are included which summarize treatment efficacy from the Siemens (SiCURE TM 

## BWMS) ballast water treatment system ( Cangelosi, 2010a ; Cangelosi

2010b ). In Cangelosi (2010a ), the Siemens SiCURE TM 

## system was evaluated for its ability to remove living orga nisms from ballast water, meet the BW Treaty Regulation D2 discharge standards after a 5-day holding time, and discharge non- toxic water after a 5- day retention period. Researchers noted th at further testing would be needed to characterize residual toxicity after a 5-day retention pe riod, but that no effect was detected during these trials. In Cangelosi (2010b ), the author disc usses ballast water management system’s use in the Great Lake s. The researchers discussed what they deemed “below the radar” zooplankton, and ot her issues related to State ballast water discharge limits compared to the Regulation D-2 standard. In this report, the authors note that this system likely needs a neutralization step for residual chlori ne for ballast water discharges into the Great Lakes from Great La kes confined vessels (Lakers) due to short voyage times.

Note that as of the writing of this paper, th is system has received G9 Basic Approval, but has not yet received such Final Approval, nor has it been type approved under the G8 Guidelines by a flag Administration.

Oceansaver ® 

## , OptiMarin, and PureBallast:

Oceansaver ® 

## , OptiMarin, and PureBallast are three separate ballast systems which have all received type approval from thei r respective flag Administrations (see Table 5 ). As of June 15, 2010, Oceansaver ® 

## has announced that they have system contracts or signed

letters of intent for 11 ballast water treat ment systems for Very Large Crude Carriers ( Maritime Executive, 2010 ). According to the manuf acturer, this represents approximately 40 million dollars of anticipated ballast water treatment system installation. In short, this indicates that this system has obtained some degree of commercial desirability.

Two documents are available for Oceansaver ® 

## , neither of which contain primary summary data. One document is the MEPC 59/INF.17 submitted by the government of Norway describing that they type approved the Oceansaver ® 

## system. The second document is a type approval certificate from the Norwegian flag Administration (Norwegian Maritime Directorate, 2009b).

However, neither the government of Norway nor the Norwegian Institute for Water Research testing facility (NIOZ) have released sampling methodologies or data from their

32

## sampling to USCG 21 

## . As such, EPA and USCG have not been able to independently evaluate data on the efficacy of these ballast water treatment systems.

For both the Alfa Laval PureBallast (Nor wegian Maritime Directorate, 2008) and OptiMarin (Norwegian Maritime Directorate, 2009a) systems, onl y the type approval

certificates are available. The Alfa Laval Pu reBallast system was granted type approval by the flag Administration of Norway in 2008 while the OptiMarin system was granted type approval in 2009 (see Table 5 ).

4.3. G9 Papers and Other Information

Several papers (including G9 applications and resulting technical reviews) have been assembled for the committee collectively la beled “G9 Papers.” These papers are

included to serve as a reference section for committee members 22 

## . As discussed above in

Section 2.3 , systems using “Active Substances” ar e subject to approval by the IMO’s Marine Environment Protection Committee (M EPC) under BW Treaty Regulation D-3 as to the environmental and safety aspects relate d to the system's use of biocides. The G9

Procedure for that review is set forth in MEPC resolution MEPC.169(57) (April 4, 2008). Under the G9 Procedure, systems using Active S ubstances are subject to an initial “Basic Approval” and then a “Final Approval” by ME PC as to the environmental and safety aspects of the active substances as used in that system.

In addition to discussing the environmenta l and safety impacts of the biocide’s use 23


## (which is beyond the direct scope of the co mmittee’s charge), each of the G9 Papers outlines how a given ballast water treatment system functions, and in some cases, its expected mechanism of neutralizing living or ganisms. Hence, these documents might have some utility in providing gene ral information on systems’ designs.

Table 4 below was derived in large part from these MEPC documents and lists 52 different ballast water treatment systems. Systems for which Primary Data Reports are

available in Section 4.2 are underlined under the “Supp lier System” column. The reference library of MEPC documents cont ains the MEPC documents describing 26 of these systems. The reference library also contains several meeting reports which, in

21 

### Despite several requests to the Flag Administrati ons, neither Norway nor th e Republic of Korea have provided test reports for systems granted type approval by those countries

22 

### We do not expect committee members to review all of these documents, nor do we expect feedback on their quality, but we are making them available so committee members could read more about ballast water treatment systems with biocides if they need additional general information about a given treatment system’s design.

23 

### Ballast water treatment systems are designed to kill living organisms – if not properly managed, these systems may discharge harmful levels of residuals into neighboring waters. We have not asked the committee to delve into these issues merely so as not to distract from answering the important question at hand – what is the status of technology for effectively and practicably killing or removing living organisms before discharge. However, the committee should be cognizant that some of these systems use biocides; the use of which must be carefully managed so as no t to create one environmental problem while solving

another.



## 33

## 34 addition to discussing these 26 systems, discuss many of the other systems listed in Table

5

.

As part of these reference documents, we are also including an additional document developed for vessel owners about how to appr oach purchase and installation of a ballast water treatment system which was produced by a vessel classificati on society (ClassNK, 2010). Like many of the documents in Section 4.1 , the document provides background information on the 2004BW Treaty, testing of systems, and generalized information about how treatment system works. The document also contains frequently asked questions which illustrate some of the comp lexities with installing these systems onboard existing vessels.

As noted above, G8 type approval has been gr anted for several systems for which neither EPA nor USCG have full primary data packs. As shown in Table 5 , ten systems currently have type approval; how ever, as discus sed in Section 4.2 , we only have type approval packages for 3 of these systems. Because these systems have been type approved, efficacy data on the numbers of liv ing organisms must exist which would have been provided to the flag Administ rations granting th at type approval. 24 

## Additionally, numerous systems, similar to Ecochlor ® 

## as discussed in section 4.2 , are advanced in their development: system designers and developers have likely taken a reasonable level of sampling data for these systems before continui ng to invest millions of dollars in their development. We have not been able to gath er and consolidate all existing, available data

for the committee. Provided that such data ar e taken by a credible third party within the relatively recent past using appropriate test methods, we would encourage introduction

and use of these data for the committee’s delib erations. We would particularly encourage use of these supplemental data for those systems which are type approved by a flag Administration. In short, we recognize that there must be relevant additional data

besides that which we have been able to obtain and provide to the committee. If

committee members have access to credible ad ditional data, we would encourage their

use to inform the committee's deliberations.

24 

### Certain system manufacturers and testing facilities ar e treating the data collected and methods used as proprietary or confidential information, which unfortunately impedes additional independent evaluation of the availability and efficacy of those systems.Table 5 Summary Status of Ballast Water Treatment Systems which use Active Substances(Current as of June 16, 2010, through MEPC 61/2/13).SupplierSystemProcessG9 ActiveSubstance Approval(Basic)1G9 ActiveSubstanceApproval(Final)1G8 SystemApproval2Test SiteType ApprovalUnitsInstalled3ProjectedProduction(Units/Year)3Notes21st CenturyShipbuilding Co.,Ltd.(ARA Ballast)Filtration,plasma arcshockwave,and ultravioletMarch 2010MEPC 60/22 ¶ 2.4.4MEPC 60/2/12 Annex8 [GESAMP]MEPC 60/2/5MEPC 61/2/5-TongYeong,Korea---The name of this system waschanged from "Blue OceanGuardian BWMS" to "ARABallast;" see MEPC 61/2/5 ¶5.Alfa Laval TumbaAB(Pureballast)Filtration andultravioletTiO2July 2007MEPC 56/23 ¶ 2.8MEPC 55/2/5July 2007MEPC 56/23 ¶2.8MEPC 56/2/2Annex 5[GESAMP]MEPC 56/2/1April 2008NIVA27 June 2008NorwayMEPC 58/2/12Annex ¶ 6.35-MEPC 53/2/6, MEPC 53/2/14,MEPC 53/2/16, MEPC55/INF.3, MEPC 57/2/9AQUA Eng. Co.,Ltd.(AquaStar BWMS)Filtration andelectrolysiselectrochlorinationMEPC 61/2/1------The "Smart Pipe Unit" formspart of the AquaStar BallastWater Management System.Aquaworx ATCGmbH(AquaTriCombTMBWTS)Filtration,ultraviolet, andultrasoundJuly 2009MEPC 59/24 ¶ 2.5.3MEPC 59/2/19 Annex6 [GESAMP]MEPC 59/2/8------ATG WillandFiltration andultraviolet-----1-ATLAS-DANMARK(ATLAS-DANMARKBWTS)Filtration and"mixed oxidantapproach"(oxidation);electrolysisMEPC 60/22 ¶ 2.6MEPC 60/2/12 Annex4 [GESAMP]MEPC 60/2-----3This system uses ANOLYTEand CATHOLYTE.AuramarineFiltration andultraviolet--Land (Jan-10)NIVA-0UnlimitedBrillyant MarineLLCElectric pulse---Maryland-0Unlimited35G9 ActiveG9 ActiveProjectedSupplierSystemProcessSubstance Approval(Basic)1SubstanceG8 SystemUnitsTest SiteType ApprovalApproval(Final)1Approval2Installed3ProductionNotes(Units/Year)3China OceanShipping (Group)Company(COSCO)/TsinghuaUniversity(BlueOcean ShieldBWMS)Hydrocyclone,filtration, andultravioletJuly 2009MEPC 59/24 ¶ 2.5.1MEPC 59/2/16 Annex7 [GESAMP]MEPC 59/2/2------Coldharbour MarineDeoxygenation andcavitation---NIOZ---DESMI OceanGuard A/S(DESMI OceanGuard BWMS)Filtration,ultraviolet, andozonationMarch 2010MEPC 60/22 ¶ 2.4.3MEPC 60/2/12 Annex7 [GESAMP]MEPC 60/2/4--DHI---Ecochlor Inc.(Ecochlor®BWMS)Filtration andClO2October 2008MEPC 58/23 ¶ 2.6.3MEPC 58/2/8 Annex 5[GESAMP]MEPC 58/2/2MEPC 61/2/8MEPC 60/22 ¶2.11MEPC 60/2/11Annex 5[GESAMP]MEPC 59/2/9Land (Jun08)SeaOngoingNIOZ-2100This system uses Purate®.Ecochlor®BWMS is installedon board Atlantic ContainerLines' ATLANTIC COMPASSand Matson Shipping'sMOKU PAHU as a part of theUSCG STEP (73 FR 72814;73 FR 72819). MEPC53/2/14, MEPC 53/2/16ElectrichlorHypochloriteGenerators Inc.Filtration andelectrolysiselectrochlorination-----3240EnvironmentalTechnologies Inc.Filtration,ozone, andultrasound-----0-MEPC 53/2/14Envirotech andConsultancy Pte.Ltd.(BlueSeas BWMS)Filtration andelectrolysiselectrochlorinationMEPC61/2/12------ERMA FIRSTE.S.K. EngineeringSolutions S.A.(ERMA FIRSTBWMS)Filtration,hydrocyclone,andelectrolysiselectrochlorinationMEPC 61/2/11----->100ERMA FIRST E.S.K.Engineering Solutions S.A. isassociated withEnvironmental ProtectionEngineering S.A. (MEPC61/2/11 Annex, ¶ 1.1).36G9 ActiveG9 ActiveProjectedSupplierSystemProcessSubstance Approval(Basic)1SubstanceG8 SystemUnitsTest SiteType ApprovalApproval(Final)1Approval2Installed3ProductionNotes(Units/Year)3GaussFiltration andultraviolet-----0-MEPC 53/2/11 Annex 2,MEPC 53/2/16, MEPC56/2/10Greenship(Sedinox®BWMS)HydrocycloneandelectrolysiselectrochlorinationOctober 2008MEPC58/23 ¶ 2.6.2MEPC58/2/7 Annex 6[GESAMP]MEPC57/2/7July2009MEPC59/24 ¶2.8.4MEPC59/2/19 Annex5[GESAMP]MEPC 59/2/6Land (Oct07)Sea(Jun-08)Harlingen-2UnlimitedMEPC 53/2/16Hamann AG(SEDNA®250BWMS)Filtration andPeraclean®March 2006MEPC 54/21 ¶ 2.8MEPC 54/2/12 Annex5 [GESAMP]MEPC 53/2/12April 2008MEPC 57/21 ¶2.16MEPC 57/2/10Annex 7[GESAMP]MEPC 57/2/5June 2007NIOZ10 June 2008GermanyMEPC 58/INF.17265This system uses Peraclean®Ocean. MEPC 53/2/11Annex 3, MEPC 53/2/14,MEPC 53/2/16, MEPC55/2/17 Annex 5, MEPC56/2/10, MEPC 57/2/9. Thissystem has been withdrawnfrom the market (Lloyd's,2010).Hi Tech Marine PtyLtd.Heat--Land (Feb-03)Sydney-0-Hitachi(Hitachi BallastWater PurificationSystem -ClearBallast)Filtration andprecoagulation(enhancedflocculation)April 2008MEPC 57/21 ¶ 2.11MEPC 57/2 Annex 5[GESAMP]MEPC 57/2/2July 2009MEPC 59/24 ¶2.8.3MEPC 59/2/19Annex 4[GESAMP]MEPC 59/2/5Land (Jun08)Sea (Jul08)-5 March 2010Japan050MEPC 54/2/9, MEPC 55/2/15Hyde Marine;Lamor Corporation,LLC(Hyde Guardian)Filtration andultravioletN/AN/ALand (Apr09)Sea (Apr09)NIOZ29 April 2009UKMEPC 59/INF.2015500This system is installed onboard Princess Cruise Lines'CORAL PRINCESS as a partof the USCG STEP (73 FR72817). MEPC 53/2/14,MEPC 53/2/16Hyundai HeavyIndustries (HHI)(EcoBallast)Filtration andultravioletJuly 2009MEPC 59/24 ¶ 2.5.2MEPC 59/2/16 Annex8 [GESAMP]MEPC 59/2/4March 2010MEPC 60/22 ¶2.13MEPC 60/2/1MEPC 59/24 ¶2.7MEPC 59/2/16[GESAMP] ¶4.7Land (2008)Sea (2009)HHI-19837G9 ActiveG9 ActiveProjectedSupplierSystemProcessSubstance Approval(Basic)1SubstanceG8 SystemUnitsTest SiteType ApprovalApproval(Final)1Approval2Installed3ProductionNotes(Units/Year)3Hyundai HeavyIndustries (HHI)(HiBallast)Electrolysiselectrochlorination andoptionalfiltrationMarch 2010MEPC 60/22 ¶ 2.4.5MEPC 60/2/16 Annex4 [GESAMP]MEPC 60/2/6-Land (2009)HHI-1165JFE EngineeringCorporation(JFE BWMS(BallastAce))Filtration,chlorination,and cavitationOctober 2008MEPC 58/23 ¶ 2.6.1MEPC 58/2/7 Annex 5[GESAMP]MEPC 57/2/8March 2010MEPC 60/22 ¶2.7.360/2/12 Annex5 [GESAMP]MEPC 60/2/2Land (Mar09)Sea (Sep09)NIVA-1300JFE and Toagosei Groupwere originally categorizedseparately. The supplierswere combined because: 1.JFE is partnered with TGCorporation (Lloyd's, 2008and 2010), the manufacturerof TG BallastCleaner; and 2.Language used in MEPC60/2/2 indicates that thecompanies are developingone treatment system (theJFE BWMS).MEPC 55/2/15. This systemuses TG Ballastcleaner andTG Environmentalguard.Kuraray Co., Ltd.(Kuraray BWMS)Filtration andcalciumhypochloriteMEPC 61/2/6------Kwang San Co.,Ltd. (KS)(En-Ballast)Filtration andelectrolysiselectrochlorinationMarch 2010MEPC 60/22 ¶ 2.4.6MEPC 60/2/16 Annex5 [GESAMP]MEPC 60/2/7------M H SystemsDeoxygenation with inertgas and CO2---SIO-0300Mahle NFV GmbHFiltration andultraviolet--Land (2009)Sea (2010)NIOZ-1At least 50MarencoTechnology Group,Inc.Filtration andultraviolet--20074MLML-1240-360MEPC 53/2/1438G9 ActiveG9 ActiveProjectedSupplierSystemProcessSubstance Approval(Basic)1SubstanceG8 SystemUnitsTest SiteType ApprovalApproval(Final)1Approval2Installed3ProductionNotes(Units/Year)3Mexel IndustriesNon-oxidizingbiocidetreatment-----2UnlimitedMitsubishi HeavyIndustries,Ltd.(Hybrid BWTS)Filtration andelectrochlorinationMEPC 56/23 ¶2.10MEPC 56/2/2Annex 7[GESAMP]MEPC56/2------This system uses the"Marine-Growth-PreventionSystem." MEPC 55/2/15Mitsui Engineeringand ShipbuildingCo. Ltd.(FineBallast MF)Filtration (prefiltration andmembranefiltration)MEPC 61/2/3------Mitsui Engineeringand ShipbuildingCo. Ltd.(Special PipeHybrid BWMSCombined withPERACLEAN®Ocean (SPOSYSTEM))Shear,cavitation, andPERACLEAN®OceanApplicant states thatBasic Approval ofPERACLEAN®wasgranted at MEPC 54(see entries forHamann AG'sSEDNA®system)MEPC 61/2/10Land (2008)ImariCity,Japan---It is assumed that MitsuiEngineering and ShipbuildingCo. Ltd. manufactures thissystem because:- The name of the system issimilar to that of another Mitsuiproduct, the "Special PipeHybrid BWMS" (or "SP-HybridBWMS Ozone Version; seeMEPC 59/2/1 ¶ 3- MEPC 61/2/10 Section 1.1states that the SPO-SYSTEM"representsone versionof SPHybrid BWMS" (emphasisadded)- MEPC 61/2/10 wassubmitted to IMO by Japan, aswere the applications for Basicand Final approval of Mitsui'sSP-Hybrid BWMS OzoneVersionMitsui Engineeringand ShipbuildingCo. Ltd.(SP-Hybrid BWMSOzone Version)Hydrodynamicshear,cavitation, andozonationOctober 2006MEPC 55/23 ¶ 2.16MEPC 55/2/16 Annex5 [GESAMP]MEPC 55/2MEPC 61/2/2MEPC 59/24 ¶2.10MEPC 59/2/16Annex 4[GESAMP]MEPC 59/2/1Land (Feb08)Sea (Jul09)JAMS-140-100The name of this system waschanged to "Special PipeHybrid Ballast WaterManagement Systemcombined with Ozonetreatment version (SP-HybridBWMS Ozone Verision);" seeMEPC 61/2/2 ¶ 3. MEPC53/2/16, MEPC 54/2/9, MEPC55/2/15, MEPC 57/2/939G9 ActiveG9 ActiveProjectedSupplierSystemProcessSubstance Approval(Basic)1SubstanceG8 SystemUnitsTest SiteType ApprovalApproval(Final)1Approval2Installed3ProductionNotes(Units/Year)3NEI TreatmentSystems LLC(Venturi OxygenStripping (VOS))Deoxygenation andcavitationN/AN/A-NOAA11 October2007Liberia6200MEPC 53/2/14, MEPC53/2/16NK-O3(BlueBallastOzone)OzonationJuly 2007MEPC 56/23 ¶ 2.9MEPC 56/2/2 Annex 6[GESAMP]MEPC 55/2/27MEPC 55/23 ¶ 2.16MEPC 55/2/16 Annex6 [GESAMP]MEPC 55/2/3July 2009MEPC 59/24 ¶2.8.2MEPC 59/2/16Annex 6[GESAMP]MEPC 59/2/3MEPC 58/23 ¶2.11MEPC 58/2/8Annex 6[GESAMP]MEPC 58/2/3Land (2008)Sea (2008)KOMERI24 November2009KoreaMEPC 60/INF.144400-700NK-O3 is affiliated withNutech O3(as listed in Lloyd'sRegister Reports). MEPC53/2/14, MEPC 55/2/21,MEPC 57/2/9Oceansaver AS(OceanSaver®BWMS)Filtration,deoxygenation, andcavitationApril 2008MEPC 57/21 ¶ 2.17MEPC 57/2/10 Annex8 [GESAMP]MEPC 57/2/6October 2008MEPC 58/23 ¶2.10MEPC 58/2/8Annex 4[GESAMP]MEPC 58/2/1Land (Nov07)Sea (Sep08)NIVA17 April 2009NorwayMEPC 59/INF.176>200MEPC 53/2/16, MEPC55/INF.3OptiMarin(OptiMarin BallastSystem)Filtration andultravioletN/AN/ALand (May08)Sea (Jan09)NIVA12 November2009Norway111000MEPC 53/2/14, MEPC53/2/16, MEPC 55/INF.3Panasia Co LtdKorea(GloEn PatrolTM)Filtration andultravioletApril 2008MEPC 57/21 ¶ 2.15MEPC 57/2/10 Annex6 [GESAMP]MEPC 57/2/4March 2010MEPC 60/22 ¶2.7.1MEPC 60/2/11Annex 4[GESAMP]MEPC 59/2/7Land (Dec08)Sea (Oct09)KORDI4 December2009Korea21400Pinnacle OzoneSolutionsFiltration andozonation---GSI---Qingdao HeadwayTechnology Co.,Ltd.(OceanGuardTM)Filtration,electrolysiselectrochlorination, andultrasoundMarch 2010MEPC 60/22 ¶ 2.4.7MEPC 60/2/16 Annex6 [GESAMP]MEPC 60/2/8MEPC 61/2/7Land (Oct09)Sea (Early10)NIVA-12000This system uses "AdvancedElectrocatalysis Enhanced byUltrasonic Technology(EUT)."40G9 ActiveG9 ActiveProjectedSupplierSystemProcessSubstance Approval(Basic)1SubstanceG8 SystemUnitsTest SiteType ApprovalApproval(Final)1Approval2Installed3ProductionNotes(Units/Year)3QwaterFiltration andultrasound-----0-MEPC53/2/16Resource BallastTechnologies (Pty)Ltd.(ResourceBallastTechnologiesSystem / UnitorBWTS)Cavitation,ozonation,electrochlorination, andfiltrationApril 2008MEPC57/21 ¶ 2.14MEPC57/2/10 Annex 5[GESAMP]MEPC56/2/3March2010MEPC60/22 ¶2.7.2MEPC60/2/11 Annex7[GESAMP]MEPC 59/2/10Land(2010)Sea(2010)CapeTown-42000+MEPC 53/2/16RWO GmbHMarine WaterTechnology, VeoliaWater Solutions &Technologies(CleanBallast!)Filtration,electrolysiselectrochlorination, andadvancedoxidationOctober 2006MEPC 55/23 ¶ 2.16MEPC 55/2/16 Annex7 [GESAMP]MEPC 55/2/4July 2009MEPC 59/24 ¶2.8.1MEPC 59/2/16Annex 5[GESAMP]MEPC 59/2MEPC 57/21 ¶2.12MEPC 57/2/13MEPC 57/2Annex 6[GESAMP]MEPC 57/2/3Land (Sep07)Land (Nov08)Sea (Jan10)Bremen2007NIVA2008-16UnlimitedThis system uses EctoSys®.MEPC 53/2/11 Annex 1,MEPC 53/2/16, MEPC54/INF.6, MEPC 55/2/17Annex 1, MEPC 56/2/10,MEPC 57/2/9Sea KnightCorporationVacuum deoxygenationand bioremediation---Virginia-0UnlimitedSevern Trent DeNora(BalPure®)Filtration andelectrolysiselectrochlorinationMarch 2010MEPC 60/22 ¶ 2.4.8MEPC 60/2/16 Annex7 [GESAMP]MEPC 60/2/9MEPC 61/2/9Land (Jul-09)NIOZ-2100This system is installed onboard SeaRiver Maritime'sS/R AMERICAN PROGRESSas a part of the USCG STEP(74 FR 38666). MEPC53/2/16Siemens(SiCURETMBWMS)Filtration andelectrochlorinationMarch 2010MEPC 60/22 ¶ 2.4.1MEPC 60/2/11 Annex6 [GESAMP]MEPC 59/2/11--GSI andMERC---This system uses Siemens'Chloropac®electrochlorinationtechnology.4142SupplierSystemProcessG9 ActiveSubstance Approval(Basic)1G9 ActiveSubstanceApproval(Final)1G8 SystemApproval2Test SiteType ApprovalUnitsInstalled3ProjectedProduction(Units/Year)3NotesSunrui Corrosionand Fouling ControlCompany(BalClorTMBWMS)Filtration andelectrolysiselectrochlorinationMarch 2010MEPC 60/22 ¶ 2.4.2MEPC 60/2/12 Annex6 [GESAMP]MEPC 60/2/3MEPC 61/2/4Land (Late09)Sea (Late09)Qingdao,China---The name of this system waschanged from "SunruiBWMS" to "BalClorTMBWMS;" see MEPC 61/2/4 ¶3.Techcross(Electro-CleanSystem (ECS))ElectrolysiselectrochlorinationMarch 2006MEPC 54/21 ¶ 2.8MEPC 54/2/12 Annex6 [GESAMP]MEPC 54/2/3October 2008MEPC 58/23 ¶2.8MEPC 58/2/7,Annex 7[GESAMP]MEPC 58/2MEPC 57/21 ¶2.9MEPC 57/2Annex 4[GESAMP]MEPC 57/2/1August2007KORDI31 December2008KoreaMEPC 59/INF.6131200Possibly MEPC 53/2/31.MEPC 55/2/21, MEPC 57/2/9.Explosion-proof type approvalcertificate issued September2009 (Lloyd's, 2010).Techwin Eco Co.,Ltd. (TWECO)(PurimarTM)Filtration andelectrolysiselectrochlorinationMEPC 61/2------Vitamar, LLC(SeakleenTM)Menadione /Vitamin K(SeakleenTM)-----0-Former supplier: HydeMarine; Lamor Corporation,LLC.Additional Notes:Data sources for this spreadsheet include Ballast Water TreatmentTechnology - Current Status, Lloyd's Register Review (September 2008), Ballast Water TreatmentTechnology - Current Status, Lloyd's Register Review (February 2010), and MEPC Reports. System names in this table and elsewhere in this paper may be subject tocopyright or trademark protection by their owners.1 Where applicable. Systems that employ an“Active Substance,” defined by BW Treaty Regulation A-1(7) as ”a substance or organism, including a virus or a fungus that hasa general or specific action on or againstharmful aquatic organisms and pathogens,” are assessed according to the MO G9 Procedure for Approval of Ballast WaterManagement Systems that make use of Active Substances (International Maritime Organization, 2008a).2 The ballast water treatment system testing procedure is outlined in the IMO’s G8 Guidelines (International Maritime Organization, 2008b).3 Data on units installed and on projected production was provided by vendors to Lloyd's Register Review during Lloyd's research of ballast water treatment systems. Thenumbers listed here are based solely on this vendor-supplied information as reported by Lloyd's (see Ballast Water Treatment Technology - Current Status, Lloyd's RegisterReview (February 2010).4 Per Lloyd's Register Review (Ballast Water Treatment Technology - Current Status (September 2008)), testing may not strictlymeet IMO standards.

### Table 6 Acronyms and Abbreviations used in Table 5

. 

## BWMS Ballast Water Management System

BWTS Ballast Water Treatment System

CBL Chesapeake Biological Laboratory

IMO International Maritime Organization

JAMS Japan Association of Marine Safety

KORDI Korean Oceanic Research and Development Institute

MEPC Marine Environment Protection Committee (IMO)

MLML Moss Landing Marine Laboratories

N/A Not Applicable or Available

NIOZ Royal Netherlands Institute for Sea Research

NIVA Norwegian Institute for Water Research

NOAA National Oceanic and A tmospheric Administration

SIO Scripps Institute of Oceanography

STEP Shipboard Technology Evaluation Program

USNRL United States Naval Research Laboratory

4.4. Implications of Sampling Protocols for Data Quality

To date, efforts to quantify the efficacy of ba llast water treatment systems, either in landbase or shipboard tests have been hampered by a range of methodological and practical constraints. The BW Treaty’s G8 Guidelin es were developed through a process of best professional judgment and policy negotiations. Significant aspects, such as guidance on how to analyze samples for the different type s of organisms are treated very loosely in the G8 Guidelines because it was not possible to come to agreement on such complicated

issues in the short timeframe allowed. Othe r sections, such as those on challenge water conditions and sample sizes, are quite detailed, but were not formally validated prior to their use by different entities. The conseque nce has been the evolution of a mosaic of procedures, developed individually by each of the facilities conducting testing internationally, within the general conceptu al framework of the G8 Guidelines, but differing substantially in specific details. With in the last several months the various test facilities have begun to discuss approaches to achieve “harmonizati on” of test methods.

In the U.S., efforts to develop standard prot ocols for testing the e fficacy of ballast water treatment systems were begun by EPA and th e USCG under the auspices of the EPA Environmental Technology Verification (ETV) Program in 2002. An early version of the draft ETV protocol was used by the U.S. as the basis for a submission to MEPC during negotiation of the G8 Guidel ines, and much of the ETV conceptual approach was incorporated into the G8 Guidelines. Howeve r, as the ETV process continued to develop the protocols, and then validate their pr acticability and appropriateness, the ETV protocols evolved substantially (Lemieux et al., 2008b, Lemieux et al., 2009), and the version now nearing finalization (U.S., EPA, 201 0) differs significantly from the version

under discussion at the time the G8 Guidelin es were being developed. Unlike the ETV protocols, however, the G8 Guidelines we re never subjected to rigorous validation.

43

## Validation of the ETV protocols has revealed that the initial approaches to sampling design had substantial limitations. In particul ar, the early ETV protoc ols, and the current G8 Guidelines, called for collecting three 1m 3 

## samples of water to quantify concentrations of living orga nisms larger than 50 um following treatment. For the BW Treaty Regulation D-2 standard of less than 10 organisms in this size group, this means that quantification would have to be able to detect the presence of 10 organisms, each as small as 50 um in diameter, in one cubic me ter of water. In practice, this involves concentrating the organisms in the cubic meter samples down to a liter, or in some cases,

several hundred milliliters. These concentrated samples are then examined, either in their entirety, or by sub-sampling, and the number of living organisms is counted.

Even if the entire concentrated sample is enumerated, counting 10 organisms as small as 50 um in a liter with adequate precision is a significant challenge. Five to ten cubic meters of sample, concentrated to a liter w ould provide a much better basis for counting. Sub-sampling would greatly increase th e original sample volume required. NRL, in validating the ETV protocols, dete rmined that for the circumstances at Key West, FL, where the NRL test facility is located, 20 1 ml subsamples was about the maximum that could be processed within th e allowable time before sample degradation introduced significant artifacts (e.g., increased organism mort ality in the concentrated sample).

Enumeration of the organisms from these samples is represented by the Poisson distribution, and therefore the cumulative or total count is the key test statistic (Lemieux et al., 2008). Further, a chi-square transformation can be utilized to approximate the confidence intervals. Assuming, for organisms ≥ 50 μ m, that the desired minimum precision is that the upper bound of the chi-square statistic should not exceed twice the observed mean (this corresponds to a coefficient of variation of 40%), a count of 6 organisms is required. The volume required to successfully count 6 organisms is dependent on the whole water sample volume, concentration factor, number of sub-samples counted, and the target concentration. 

## For enumeration using 20 one ml subsamples, statistical analysis indicated that 30 m 3 

## must be sampled to enumerate 10 organisms/m 3 

## , with the desired level of precision.



## The complexities associated with minimum sample volumes raise additional important issues. First, counts of less than 10 organism s as small as 50 um in size per cubic meter are inherently susceptible to error. To date, none of the test reports available to the Coast Guard and EPA have contained QA/QC valid ation that the counts were made with necessary precision and repeatability. In validating the ETV protocols, NRL validated their measurement precision using different concentrations of various diameter microbeads. Second, samples begin to degrad e very quickly, and all enumeration must be completed within a narrow window, and th is window is to a gr eat degree dependent on time and place and holding conditions. As with measurement precision, the test reports

available to the Coast Guard and EPA do not contain QA/QC documentation of the safe period for sample processing and analysis or that this safe period limitation was met.

44

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

In its 2008 Fact Sheet to the VGP ( EPA, 2008a ), EPA noted that the Agency “will evaluate the availability of t echnologies that are able to m eet appropriate living organism limitations. Once technologies are commercially available and economically achievable, EPA would require that these standards be me t as a BAT effluent limit for ballast water discharges under subsequent iterations of this permit.” Under § 402(b)(1)(B) of the CWA, NPDES permits are issued for fixed te rms that may not exceed five years and the existing VGP will expire on December 19, 2013. The SAB’s response to the charge will better inform EPA as to the status of ballast water treatment systems as the Agency develops new technology-base d effluent limits and conditions for the next VGP.

As a co-regulator, the US Coast Guard is s upporting EPA in this effort. Additionally, the SAB’s findings may also help inform the Co ast Guard in their future evaluations of technological availability. We are not asking the committee to propose or strongly support any specific technology or treatment train, rather, we are asking for advice on the state and efficacy of ballast water treatment technology today and where that is likely to go in the near term. This information will as sist regulatory agencies in moving toward a strong US federal ballast water manageme nt program which accurately captures the current state of ballast water technologies.

45

## 6. Bibliography

33 Code of Federal Regulations 151 Subpart C. Ballast Water Management for Control of Nonindigenous Species in the Great Lakes and Hudson River. Available at: http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&tpl=/ecfrbrowse/T itle33/33cfr151_main_02.tpl . Accessed June 18, 2010.

33 Code of Federal Regulations 151 Subpart D. Ballast Water Management for Control of Nonindigenous Species in Waters of the United States. Available at: http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&tpl=/ecfrbrowse/T itle33/33cfr151_main_02.tpl . Accessed June 18, 2010.

69 Federal Register 44952. Mandatory Ballast Water Management Program for U.S. Waters. July 28, 2004.

Available at: http://edocket.access.gpo. gov/2004/pdf/04-17096.pdf . Accessed June 18, 2010.

70 Federal Register 51831. Ballast Water Management for Vessels Entering the Great Lakes That Declare No Ballast Onboard. August 31, 2005. Available at: http://edocket.access.gpo.gov/2005/pdf/05- 17426.pdf . Accessed June 18, 2010.

73 Federal Register 9950. Seaway Regulations and Rules: Periodic Updates, Various Categories. February 25, 2008. Available at: http://edocket.access.gpo.gov/2008/pdf/E8-3323.pdf . Accessed June 18, 2010.

73 Federal Register 34296. Draft National Pollutant Discharge Elimination System (NPDES) General Permits for Discharges Incidental to the Normal Operation of a Vessel. June 17, 2008. Available at: http://edocket.access.gpo. gov/2008/pdf/E8-13615.pdf . Accessed June 18, 2010.

73 Federal Register 79473. Final National Pollutant Discharge Elimination System (NPDES) General Permit for Discharges Incidental to the Normal Operation of a Vessel. December 29, 2008. Available at http://edocket.access.gpo. gov/2008/pdf/E8-30816.pdf . Accessed June 18, 2010.

74 Federal Register 44632. Standards for Living Orga nisms in Ships’ Ballast Water Discharged in U.S.

Waters. Available at: http://edocket.access.gpo.go v/2009/pdf/E9-20312.pdf . Accessed June 18, 2010.

American Bureau of Shipping (ABS). 2010. Ballast Wa ter Treatment Advisory. 8 June 2010. Available at: http://www.eagle.org/eagleExternalPortalWEB/ShowProperty/BEA%20Repos itory/References/ABS %20Advisories/BWMAdvisoryNotice . Accessed June 16, 2010.

Bolch, C.J.S. & Salas, M.F.d. 2007. A review of the molecular evidence for ballast water introduction of the toxic dinoflagellates Gymnodinium catenatum and the Alexandrium "tamarensis complex" to

Australasia. Ballast Water, 6, 465-485.

Bundesamt für Seeschifffahrt und Hy drographie (BSH). Summary of add itional provisions of the Type Approval certificate of Ballast Water Management System SEDNA 250 of Hamann AG. Certificate

No. BSH/18282/Hamann-1/Z12 2008.

Burton, D.T., D.J. Fisher, L.T. Yonkos, G. Ziegler, S.T. Turley & M. Osborne. 2008. Short-term Toxicity Testing of a De-oxygenation Ballast Water Treatment to Receiving Water Organisms. Final Report. Wye Research and Education Center. University of Maryland, Queenstown, MD.

California State Lands Commission. 2007. Marine Invasive Species Program. ( http://www.slc.ca.gov/Spec_P ub/MFD/Ballast_Water/Ballast_Water_Default.html ). Accessed June 21, 2010.



## 46

### Cangelosi, A. 2010a. Report of the land-based freshwater testing of the Siemens SiCURE Ballast Water Management System. Great Ships Initiative. GSI/LB/F/A/1.

Cangelosi, A. 2010b. A Great Lake relevancy preamble to the GSI report on land-based testing outcomes for the Siemens SICURE Ballast Water Management System. Great Ships Initiative.

ClassNK. 2010. Guidelines on the installation of ballast water treatment systems. Nippon Kaiji Kyokai. Material and Equipment Department. Tokyo, Japan.

Dobbs, F., Doblin, M., & Drake, L. 2006. Pathogens in ships' ballast tanks. EOS, Transactions, American Geophysical Union, 87.

Doblin, M., Coyne, K., Rinta-Kanto, J., Wilhelm, S., & Dobbs, F. 2007. Dynamics and short-term survival oftoxic cyanobacteria species in ballast water from NOBOB vessels transiting the Great Lakesimplications for HAB invasions. Harmful Algae, 6, 519-530.

Dobroski, N., Scianni, C., Gehringer, D., & Falkner M.. 2009a. 2009 assessment of the efficacy, availability and environmental impacts of ballast water treatment systems for use in California. California State Lands Commission, Marine Facilities Division. Produced for the California State Legislature. Final Report available at: http://www.slc.ca.gov/Spec_P ub/MFD/Ballast_Water/Rep orts_Presentations.html

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Fisher, D.J., Burton, D.T., Yonkos, L.T., Ziegler, G., Turley, S.T., Osborne, M. & Friedel., E. 2009. Shortterm Chronic Toxicity Testing of a De-oxygenation Ballast Water Treatment to Receiving Water Organisms. Final Report. Wye Research and Education Center. University of Maryland, Queenstown,

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Gracki, J.A., Everett, R.A., Hack, H., Landrum, P.F., Long, D.T., Premo, B.J., Raaymakers, S.C., Stapleton, G.A., & Harrison, K.G. 2002. Critical review of a ballast water biocides treatment demonstration project using copper and sodium hypochlorite. Michigan Environmental Science Board, Lansing, Michigan. http://www.michigan.gov/documen ts/Ballast_Water_Report_43716_7.pdf.



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### Knight, I.T., Wells, C.S., Wiggins, B., Russell, H. , Reynolds, K.A., & Huq., A. 1999. Detection and enumeration of fecal indicators and pathogens in the ballast water of transoceanic cargo vessels entering the Great Lakes. In General Meeting of the American Society for Microbiology, pp. 546, Chicago, IL, Abstract Q71.

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chemical biocides with application to ballast water trea tment. NOAA Technical Memorandum GLERL-123. Ann Arbor, Michigan

Lee II, H., Reusser, D.A., Frazier, M., & Ruiz, G. 2010 . Density matters: Review of approaches to setting organism-based ballast water discharge standards. U.S. EPA, Office of Research and Development, National Health and Environmental Effects Research Laboratory, Western Ecology Division.

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Lemieux, E. J., Lucas, K., Grant, J.F., Wier, T.P., Robbins, S.H., Riley, S., Hyland, W., Davbis, L., Donowick, T., Stingham, B., Kinee, W. J., and Brown, B. 2008b. Pilot Environmental Technology Verification (ETV) Test Report of the Severn Trent DeNora BalPure TM Ballast Water Treatment System. Naval Research Laboratory Letter Report 3900.6130/6098 (20 Oct 2008).

Lemieux, E. J., Grant, J.F., Wier, T.P., Drake, L.A., Ro bbins, S.H., & Burns, K.C. 2009. Generic Protocol for the Verification of Ballast Water Treatment Technologies, Ver. 3.2. Naval Research Laboratory Letter Report 3900.6130/0927 (08 Sep 2009).

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2005.



## 49

### MEPC (Marine Environment Protection Committee). 2005. Application for Basic Approval of Active Substances used by Electro-Clean (electrolytic disinfection) Ballast Water Management System. Submitted by Republic of Korea. MEPC 54/2/3. 16 December 2005.

MEPC (Marine Environment Protection Committee). 2006. Application for Final Approval of Ballast Water Management System Using Active Substances. Submitted by Norway. MEPC 56/2/1. 15 December

2006.

MEPC (Marine Environment Protection Committee). 2006. Basic Approval of Active Substance used by EctoSysTM electrochemical system. Submitted by Sweden. MEPC 55/2/4. 21 April 2006.

MEPC (Marine Environment Protection Committee). 2006. Basic Approval of Active Substance used by the Hybrid Ballast Water Treatment System using Seaw ater Electrolytic Process. Submitted by Japan.

MEPC 56/2. 14 December 2006.

MEPC (Marine Environment Protection Committee). 2006. Basic Approval of Active Substances used by NK Ballast Water Treatment System. Submitted by the Republic of Korea. MEPC 55/2/3. 20 April 2006.

MEPC (Marine Environment Protection Committee). 20 06. Basic Approval of Active Substances used by PureBallast Management System. Submitted by Sweden. MEPC 55/2/5. 21 April 2006.

MEPC (Marine Environment Protection Committee). 20 06. Basic Approval of Active Substances used by Special Pipe Ballast Water Management System (combined with Ozone treatment). Submitted by Japan. MEPC 55/2. 12 April 2006.

MEPC (Marine Environment Protection Committee). 2006. Report of the first meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 54/2/12. 28 February 2006.

MEPC (Marine Environment Protection Committee). 20 06. Report of the second meeting of the GESAMPBallast Water Working Group (GES MP-BWWG). Note by the Secretariat. MEPC 55/2/16. 7 July

2006.

MEPC (Marine Environment Protection Committee). 2006. Request for re-evaluation of the proposal for the approval of Active Substances. Submitted by the Republic of Korea. MEPC 55/2/27. 18 April 2006.

MEPC (Marine Environment Protection Committee). 2006. A Swedish Disinfection System. Submitted by Sweden. MEPC 54/INF.6. 13 January 2006.

MEPC (Marine Environment Protection Committee). 2007. Application for Basic Approval of Active Substances used by Hitachi Ballast Water Purification System (ClearBallast). Submitted by Japan. MEPC 57/2/2. 7 September 2007.

MEPC (Marine Environment Protection Committee). 2007. Application for Basic Approval of a ballast water management system using Active Substances. Submitted by the Norway. MEPC 57/2/6. 7 September

2007.

MEPC (Marine Environment Protection Committee). 2007. Application for Basic Approval of a ballast water management system using “TG Ballastcleaner and TG Environmentalguard” as Active Substances (Toagosei Group). Submitted by the Japan. MEPC 57/2/8. 26 December 2007.



## 50

### MEPC (Marine Environment Protection Committee). 2007. 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. MEPC 57/2/7.

20 December 2007.

MEPC (Marine Environment Protection Committee). 2007. Application for Final Approval of a ballast water management system using Active Substances. Submitted by Germany. MEPC 57/2/3. 7 September

2007.

MEPC (Marine Environment Protection Committee). 2007. Application for Final Approval of a ballast water management system using Active Substances. Submitted by Germany. MEPC 57/2/5. 7 September

2007.

MEPC (Marine Environment Protection Committee). 2007. Application for Final Approval of a ballast water management system using Active Substances (Electro-Clean Electrolytic Disinfection). Submitted by the Republic of Korea. MEPC 57/2/1. 7 September 2007.

MEPC (Marine Environment Protection Committee). 2007. Basic Approval of Active Substance used by GloEn-PatrolTM Ballast Water Management System. Submitted by the Republic of Korea. MEPC 57/2/4. 7 September 2007.

MEPC (Marine Environment Protection Committee). 20 07. Basic Approval of Active Substances used by Resource Ballast Technologies Systems (Cavitation combined with Ozone and Sodium Hypochlorite treatment). Submitted by South Africa. MEPC 56/2/3. 6 April 2007.

MEPC (Marine Environment Protection Committee). 20 07. Report of the third meeting of the GESAMPBallast Water Working Group (GES MP-BWWG). Note by the Secretariat. MEPC 56/2/2. 13 April

2007.

MEPC (Marine Environment Protection Committee). 20 07. Report of the fourth meeting of the GESAMPBallast Water Working Group (GESAMP-BWWG). Note by the Secretariat. MEPC 57/2. 19

December 2007.

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the AquaTriCombTM Ballast Water Treatment System. Submitted by Germany. MEPC 59/2/8. 16

December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the Blue Ocean Shield Ballast Water Management System. Subm itted by China. MEPC 59/2/2. 5 December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the Ecochlor® Ballast Water Treatment System. Submitted by Germany. MEPC 58/2/2. 20 March 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the HHI Ballast Water Management System (EcoBallast). Submitted by the Republic of Korea. MEPC 59/2/4. 9

December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Basic Approval of the Siemens SiCURETM Ballast Water Management System. Submitted by Germany. MEPC 59/2/11. 19 December

2008.



## 51

### MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of a ballast water management system using Active Substances (Electro-Clean Electrolytic Disinfection). Corrigendum. Submitted by the Republic of Korea. MEPC 57/2/1/Corr.1. 12 March 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Ecochlor® Ballast Water Management System. Submitted by Germany. MEPC 59/2/9. 16 December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the ElectroClean System (ECS). Submitted by the Republic of Korea. MEPC 58/2. 20 March 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the GloEnPatrolTM Ballast Water Treatment System. Submitted by the Republic of Korea. MEPC 59/2/7. 16

December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Greenship Sedinox Ballast Water Management System. Submitted by the Netherlands. MEPC 59/2/6. 12

December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Hitachi Ballast Water Purification System (ClearBallast). Submitted by the Japan. MEPC 59/2/5. 11

December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the NK-O3 BlueBallast System (Ozone). Submitted by the Republic of Korea. MEPC 58/2/3. 21 March 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the NK-O3 BlueBallast System (Ozone). Submitted by the Repub lic of Korea. MEPC 59/2/3. 8 December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the OceanSaver® Ballast Water Management System (O S BWMS). Submitted by Norway. MEPC 58/2/1.

19 March 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Resource Ballast Technologies System (Cavitation combined with Ozone and Sodium Hypochlorite treatment). Submitted by South Africa. MEPC 59/2/10. 19 December 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the RWO Ballast Water Management System (CleanBallast). Submitted by Germany. MEPC 59/2. 28

November 2008.

MEPC (Marine Environment Protection Committee). 2008. Application for Final Approval of the Special Pipe Hybrid Ballast Water Management System (combined with Ozone treatment). Submitted by Japan.

MEPC 59/2/1. 4 December 2008.

MEPC (Marine Environment Protection Committee). 2008. Comments on the report of the fourth meeting of the GESAMP-BWWG. Submitted by Germany. MEPC 57/2/13. 4 February 2008.

MEPC (Marine Environment Protection Committee). 20 08. Report of the fifth meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 57/2/10. 25 January

2008.

MEPC (Marine Environment Protection Committee). 20 08. Report of the sixth meeting of the GESAMPBallast Water Working Group. Note by the Secretariat. MEPC 58/2/7. 14 July 2008.



## 52

### MEPC (Marine Environment Protection Committee). 20 08. Report of the seventh meeting of the GESAMPBallast Water Working Group. Note by the Secretariat. MEPC 58/2/8. 28 July 2008.

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of the AquaTriCombTM Ballast Water Treatment System. Corrigendum. Submitted by MEPC

59/2/8/Corr.1. 29 June 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of Blue Ocean Guardian (BOG) Ballast Water Management System. Submitted by Republic of Korea. MEPC 60/2/5. 24 August 2009.

MEPC (Marine Environment Protecti on Committee). 2009. Application fo r Basic Approval of DESMI Ocean Guard Ballast Water Management System. Submitted by Denmark. MEPC 60/2/4. 19 August 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of Hyundai Heavy Industries Co., Ltd. (HHI) Ballast Water Management System (HiBallast). Submitted by the Republic of Korea. MEPC 60/2/9. 24 August 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of Kwang San Co., Ltd. (KS) Ballast Water Management System "En-Ballast". Submitted by the Republic of Korea. MEPC 60/2/7. 25 August 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of OceanGuardTM Ballast Water Management System. Submitted by Norway. MEPC 60/2/8. 26 August 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of the Severn Trent DeNora BalPure® Ballast Water Management System. Submitted by Germany. MEPC 60/2/9. 28 August 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Basic Approval of Sunrui ballast water management system. Submitted by China. MEPC 60/2/3. 24 August 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Final Approval of HHI Ballast Water Management System "EcoBallast". Submitted by the Republic of Korea. MEPC 60/2/1. 20 August 2009.

MEPC (Marine Environment Protection Committee). 2009. Application for Final Approval of (JFE-BWMS) that makes use of "TG Ballastcleaner® and TG Environmentalguard®". Submitted by Japan. MEPC 60/2/2. 20 August 2009.

MEPC (Marine Environment Protection Committee). 2009. Information on the Type Approval Certificate of the Electro-CleenTM System (ECS). Submitted by the Republic of Korea. MEPC 59/INF.6. 20 February 2009.

MEPC (Marine Environment Protection Committee). 2009. Information on the Type Approval Certificate of the OceanSaver® Ballast Water Management System. Submitted by Norway. MEPC 59/INF.17. 6 May 2009.

MEPC (Marine Environment Protection Committee). 20 09. Report of the eighth meeting of the GESAMPBallast Water Working Group (GES MP-BWWG). Note by the Secretariat. MEPC 59/2/16. 8 April

2009.



## 53

### MEPC (Marine Environment Protection Committee). 20 09. Report of the ninth meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 59/2/19. 5 May

2009.

MEPC (Marine Environment Protection Committee). 20 09. Report of the tenth meeting of the GESAMPBallast Water Working Group (GES MP-BWWG). Note by the Secretariat. MEPC 60/2/11. 30 October

2009.

MEPC (Marine Environment Protection Committee). 2009. Report of the eleventh meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 60/2/12. 1

December 2009.

MEPC (Marine Environment Protection Committee). 2009. Type Approval of the Hyde GUARDIANTM Ballast Water Management System. Submitted by the United Kingdom. MEPC 59/INF.20. 7 May

2009.

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of Techwin Eco Co., Ltd. (TWECO) Ballast Water Management Sy stem (PurimarTM). Submitted by the Republic of

Korea. MEPC 61/2. 9 March 2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the Special Pipe Hybrid Ballast Water Management System combined with Ozone treatment version (SP-Hybrid BWMS Ozone version). Submitted by Japan. MEPC 61/2/2. 17 March 2010.

MEPC (Marine Environment Protection Committee). 20 10. Report of the twelfth meeting of the GESAMPBallast Water Working Group (GESMP-BWWG). Note by the Secretariat. MEPC 60/2/16. 8 February

2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of AquaStar Ballast Water Management System. Submitted by Republic of Korea. MEPC 61/2/1. 18 March 2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of the BlueSeas Ballast Water Management System. Submitted by Singapore. MEPC 61/2/12. 31 March 2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of the ERMA FIRST Ballast Water Management System. Subm itted by Greece. MEPC 61/2/11. 29 March 2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of the Kuraray Ballast Water Management System. Submitted by Japan. MEPC 61/2/6. 25 March 2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Basic Approval of the MES Ballast Water Management System (Fine Ballast MF). Submitted by Japan. MEPC 61/2/3. 17 March

2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the Special Pipe Hybrid Ballast Water Management System comb ined with PERACLEAN® Ocean (SPO-SYSTEM). Submitted by Japan. MEPC 61/2/10. 29 March 2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of “ARA Ballast” Ballast Water Management System. Submitted by Republic of Korea. MEPC 61/2/5. 23 March 2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the Ecochlor® Ballast Water Management System. Submitted by Germany. MEPC 61/2/8. 28 March 2010.



## 54

### MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the OceanGuardTM Ballast Water Management System. Submitted by Norway. ME PC 61/2/7. 25 March

2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval of the Severn Trent De Nora BalPure® Ballast Water Management System. Submitted by Germany. MEPC 61/2/9. 28

March 2010.

MEPC (Marine Environment Protection Committee). 2010. Application for Final Approval BalClorTM ballast water management system. Submitted by China. MEPC 61/2/4. 22 March 2010.

Merchant Shipping Directorate. 2010. Ballast Water Management System Type Approval Compliance Certificate. Malta Transport Centre.

Michigan Department of Natural Resources and Envi ronment. 2001-2010. Ballast Water Control. ( http://www.michigan.gov/deq/0,1607,7-135-3313_3682_3713-153446--,00.html ). Accessed June 21,

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NEI Treatment Systems, LLC. 2007. Application for Type Approval Certification: NEI Treatment Systems' Venturi Oxygen Stripping Ballast Water Management System. International Maritime Organization International Convention for the Control and Management of Ships' Ballast Water and Sediments. Los Angeles, CA.

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Quilez-Badia, G., McCollin, T., Josefsen, K.D., Vourdach as, A., Gill, M.E., Mesbahi, E., & Frid, C.L.J. 2008. On board short-time high temperature heat treatment of ballast water: A field trial under operational conditions. Marine Pollution Bulletin, 56, 127-135.

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## 56

### ten Hallers, C., Leppakoski, E., Sassi, J., Granitto, M. , Mackey T., & Bjorkendahl, M. 2009. Environmental acceptability evaluation of the Hy de GUARDIAN ballast water treatment system as part of the Type Approval process, version 3.

U.S. Coast Guard. 2004. Navigation and Vessel Inspection Circular No. 01-04 for the STEP program. January 2, 2004.

U.S. Coast Guard. 2008. Final evaluation assessment review of the application by Atlantic Container Lines for acceptance of the vessel M/V Atlantic Compass and the EcochlorTM Inc. Technology into the USCG Shipboard Technology Evaluation (STEP) Program.

U.S. EPA. 1996. U.S. EPA NPDES Permit Writers’ Manual. Chap ter 5: Technology-Bas ed Effluent Limits. EPA-833-B-96-003. U.S. Environmental Protection Agency. Washington D.C. Available at: http://www.epa.gov/npdes/pubs/chapt_05.pdf . Accessed June 18, 2010.

U.S. EPA. 1996. U.S. EPA NPDES Permit Writers’ Manual. Chap ter 6: Water Quality-Based Effluent Limits. EPA-833-B-96-003. U.S. Environmental Protection Agency. Washington D.C. Available at: http://www.epa.gov/npdes/pubs/chapt_06.pdf . Accessed June 18, 2010.

U.S. EPA. 2001. Aquatic nuisance species in ballast water discharges: issues and opinions. http://epa.gov/owow/invasive_species/ballast_report_attch5.pdf

.

U.S. EPA. 2008a. 2008 Final issuance of National Pollutant Discharge Elimination System (NPDES) Vessel General Permit (VGP) for Discharges Incidental to the Normal Operation of Vessels Fact Sheet. ( www.epa.gov/npdes/vessels )

U.S. EPA. 2008b. Vessel General Permit. Finalized December 19, 2008. ( www.epa.gov/npdes/vessels )

U.S. EPA. 2010. Environmental Technology Verification Program Generic Protocol for the Verification of Ballast Water Treatment Technologies, Ver. 4.2. NSF, International, Ann Arbor, MI.

Veldhuis, M.J.W. & Fuhr, F., 2008. Final report of th e land-based testing of th e SEDNA® -System, for Type Approval according to the Regulation D-2 and the relevant IMO Guideline (April - July 2007). Royal

Netherlands Institute for Sea Research.

Veldhuis, M.J.W., Fuhr, F., & Stehouw er, P., 2009a. Final report of the land-based testing of the Ecochlor®- system, for Type Approval according to regulation-D2 and the relevant IMO guideline (April – July 2008). Royal Netherlands Institute for Sea Research.

Veldhuis, M.J.W., Fuhr, F., & Stehouw er, P., 2009b. Final report of the land-based testing of the HydeGuardianTM -System, for Type Approval according to the Regulation D-2 and the relevant IMO Guideline (April - July 2008). Royal Netherlands Institute for Sea Research.

Volpe Transportation Research Center. 2009. Environmental assessment review of the application for acceptance of the SeaRiver Maritime Inc. S/R American Progress and Severn Trent de Nora BalPureTM System into the Shipboard Technology Evaluation Program (STEP). U.S. Coast Guard.

Wisconsin Department of Natural Resources. 2010. Ballast Water Discharge General Permit. ( http://dnr.wi.gov/news/mediakits/mk_ballast.asp ). Accessed June 21, 2010.

Wright, D.A. 2009. Shipboard Trials of Hyde "Guardian" System in Caribbean Sea and Western Pacific Ocean, April 5th - October 7th, 2008. University of Maryland Center for Environmental Science, Chesapeake Biological Laboratory.



## 57

## Appendix I – Science Advisory Board Charge

OFFICE OF

WATER 

## July 1, 2010

MEMORANDUM

SUBJECT: Science Advisory Board Review of the Av ailability and Efficacy of Ballast Water Treatment Technology for EPA’s Office of Water and the United States Coast

Guard

FROM: Linda Boornazian, Director

Water Permits Division

Office of Water

TO: Vanessa Vu, Director Science Advisory Board Staff Office

This memorandum provides an introduction, background information, and specific charge questions to the Science Advisory Board (S AB) for their review of the status of ballast water treatment technology. To assist the SAB in their efforts, a member of my staff, in

collaboration with other EPA and Coast Guard colleagues, has prepared a white paper titled “Availability and Efficacy of Ballast Wate r Treatment Technology: Background and Issue Paper” (hereinafter the “White Paper”). This paper provides additiona l background information and introduces the numerous documents we have pr ovided to the SAB to a ssist in your analyses.

Background

Ballast water is typically drawn in from surrounding ambient water and used to assist with vessel draft, buoyancy, and stab ility. Almost all large vessels have ballast tanks dedicated to this purpose; some vessels may also ballast empty cargo holds. The ballast water discharge

rate and constituent concentrations of ballast wa ter from vessels will vary by vessel type, ballast tank capacity, and type of deballasting equipmen t. Under current U.S. regulation and permitting

58

## requirements (discussed in greater detail in the White Paper), ther e are existing best management practices to reduce the potential impacts of ballast water discharg es. These include ballast water exchange and salt water flushing (col lectively referred to as BWE).

While useful in reducing the presence of poten tially invasive organisms in ballast water, BWE can have variable effectiveness and may not always be feasible due to vessel safety concerns. In order to make progress beyond us e of BWE, establishing a standard for the concentration of living organisms in ballast wate r that can be discharg ed is necessary. The United States Environmental Protection Agency (EPA) and the United States Coast Guard (USCG) both desire a stronger federal ballast water management program.

To help develop the next Clean Water Act Vessel General Permit (VGP), EPA needs an objective evaluation of the status and efficacy of ballast water trea tment technologies and systems that are in existence or in the development process. A second major scientific question for regulatory agencies is to better understand an d relate the concentration of living organisms in ballast water discharges to th e probability of introduced or ganisms successfully establishing populations in U.S. waters. Given the complex ity of the issues, EPA’ s Office of Water is seeking advice from the Science Advisory Bo ard (SAB) on the first issue and the National Academy of Sciences’ National Research Council (NRC) on the second issue. In Particular, EPA is seeking advice from the SAB re garding the availability and efficacy of ballast water treatment systems in neutralizing (killing) living organisms that might be discharged from ballast water tanks. For the other NRC study, EPA has request ed that the NRC broadly assess and make recommendations about various approaches for assessing the risk of establishment of new aquatic non-indigenous species from ballast wate r discharges (see attachment 2 of the White Paper for the NRC charge).

Specific Charge in Evaluating the Effica cy of Ballast Water Treatment Technology

OW is seeking SAB advice in the fo llowing four general categories:

1. Performance of shipboard systems with available effluent testing data 25



## 1a. For the shipboard systems with availabl e test data, which have been evaluated with sufficient rigor to permit a credible assessment of performance capabilities in

terms of effluent concentr ations achieved (living orga nisms/unit of ballast water discharged or other metric)?

1b. For those systems identified in (1a), wh at are the discharge standards that the available data credibly demonstrate can be reliably achieved (e.g., any or all of the

standards shown in Table 1 of the White Pa per? Furthermore, do data indicate that certain systems (as tested) will not be able to reliably reach any or all of the discharge standards shown in that table?

25 

### EPA and the US Coast Guard have provided data they currently have to the panel on the attached CD. Where feasible, the panel is encouraged to find additional data if they have appropriate avenues to obtain those data.



## 59

## 1c. For those systems identified in (1a), if any of the system tests detected “no living organisms” in any or all of their replicates, is it reasonable to assume the systems are able to reliably meet or closely approach a “no living organism”

standard or other standard s identified in Table 1 of the White Paper, based on their engineering design and treatment processes?

2. Potential performance of shipboard systems withou t reliable testing data

2. Based on engineering design and treat ment processes used, and shipboard conditions/constraints, what types of balla st water treatment systems (which may include any or all of the systems liste d in Table 4 of the White Paper) can reasonably be expected to reliably achieve any of the standards shown in Table 1 of the White Paper, and if so, by what dates? Based on engineering design and treatment processes used, are there systems which conceptually would have difficulty meeting any or all of the disc harge standards in Ta ble 1 of the White Paper?

3. System Development

3a. For those systems identified in qu estions 1a and 2, are there reasonable changes or additions to their treatmen t processes which can be made to the systems to improve performance?

3b. What are the principal te chnological constraints or other impediments to the development of ballast water treatment technologies for use onboard vessels to reliably meet any or all of the discharg e standards presented in Table 1 of the White Paper and what recommendations doe s the SAB have for addressing these impediments/constraints? Are these impe diments more significant for certain size classes or types of organisms (e.g., zoopl ankton versus viruses)? Can currently available treatment processes reliably achie ve sterilization (no living organisms or viable viruses) of ballast water onboard ve ssels or, at a minimum, achieve zero or near zero discharge for certain organism size classes or types?

4. Development of Reliable Information

4. What are the principal limitations of the available studies and reports on the

status of ballast water treatment tech nologies and system performance and how

can these limitations be overcome or co rrected in future assessments of the availability of technology for tr eating ballast water onboard vessels?

60

## 61 Background Reading Materials

A more in depth introduction to these issues can be found in the attached White Paper, for which we have included both a hard copy an d an electronic copy on the attached CD. The documents on the CD are divided into three groups. The first set of documents on that CD are summary reports produced by parties evaluating th e availability of existing ballast water treatment systems or reports evaluating their potential efficacy. The second set of documents contains additional available test data and engi neering information for specific ballast water treatment systems. The third set of documents primarily consist of International Maritime Organization papers and submissi ons, and were provided to serve as a reference library for the

committee should the committee therein useful. Most of those documents have been prepared as reports for IMO as part of the “G9” review proce ss (discussed in greater detail in White Paper). There is also an index file on the CD, which lists all of the document names and contains hyperlinks to the location of each file on the CD. Additionally, we have created an on-line

docket which will contain all of the document s found on this CD: it is docket number EPA-HQOW-2010-0582 and can be accessed at www.regulations.gov

.

Thank you for considering these important issues in your review. Your work will prove valuable

as we move forward with fe deral ballast water regulation.

Attachments:

1. June, 2010 White Paper: Albert, R., Ever ett, R., Lishman, J., and Smith, D. (2010) Availability and Efficacy of Ballast Water Trea tment Technology: Background and Issue Paper. Paper prepared to assist the Science Advisory Bo ard Review of the availability and efficacy of ballast water treatment technology. 2. Compact Disc containing all documents referenced in Appendix IV of the above White Paper.

## Appendix II. National Acad emy of Sciences Charge

62

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

ABS American Bureau of Shipping

ANS Aquatic nuisance species

BA Basic Approval

BAT Best available technology economically achievable

BMP Best management practice

BOG Blue Ocean Guardian

BW Ballast water

BWE Ballast Water Exchange

BWM Ballast Water Management

BWT Ballast Water Treatment

BWTS Ballast Water Treatment System

CFR Code of Federal Regulations

COSCO China Ocean Shipping (Group) Company

CSLC California State Lands Commission

CWA Clean Water Act

ECS Elector-CleenTM (Electro-Clean) System

EEZ Exclusive Economic Zone

EPA Environmental Protection Agency

ETV Environmental Technology Verification Program

EUT Advanced Electrocatalysis Enhanced by Ultrasonic Technology

FA Final Approval

GESAMP Joint Group of Experts on th e Scientific Aspects of Marine

Environmental Protection

GSI Great Ships Initiative

HHI Hyundai Heavy Industries

IMO International Maritime Organization

JAMS Japan Association of Marine Safety

KOMERI Korean Marine Equipment Research Institute

KORDI Korean Oceanic Research and Development Institute KS Kwang San

LLC Limited Liability Company

MEPC Marine Environment Protection Committee

MERC Maritime Environmental Resource Center

MLML Moss Landing Marine Laboratories

N/A Not applicable or available

NANPCA Non-indigenous Aquatic Nuisance Prevention and Control Act

NIOZ Royal Netherlands Institute for Sea Research NIS Non-indigenous species

NISA National Invasive Species Act NIVA Norwegian Institute for Water Research

NOAA National Oceanic and Atmospheric Administration

NOBOB No Ballast On Board

NPDES National Pollutant Discharge Elimination System

NPRM Notice of Proposed Rulemaking

NRC National Research Council

NRL Naval Research Laboratory

OBS OptiMarin Ballast System



## 63

### POC Particulate organic carbon QA/QC Quality assurance/quality control

SAB Science Advisory Board

SIO Scripps Institute of Oceanography SP Special pipe

STEP Ship Technology Evaluation Program

TA Type Approval TG Toagosei Group

TRO Total residual oxidant

TSS Total suspended solids

TWECO Techwin Eco Company

ULCC Ultra large crue carrier

UN United Nations

US Ultrasonic

USC United States Code

USCG United States Coast Guard

UV Ultraviolet

VGP Vessel General Permit

VOS Venture Oxygen Stripping

WI DNR Wisconsin Department of Natural Resources



## 64

## Appendix IV. Table of Contents for all documents provided to the Committee.
Note that hyperlinks in this table to documents link to other files containe d on a CD provided to the

SAB committee. If this white paper is viewed from that CD, hype rlinks will open the documents.

These documents have also been added to the docket number EPA-HQ-OW-2010-0582 and can be accessed at www.regulations.gov.

System Title Date File name

Group 1: 3rd Party Reports

General Ballast Water Treatment Technology:

Current Status Feb

‐ 10 0210LloydsReport

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

Ballast Water Treatment Systems for Use in

California Waters Jan

‐ 09 2009CSLCTechReportFinal

General October 2010 Update: Ballast Water

Treatment Technologies for Use in

California Waters 10/15/2009 CSLCTechUpdate2009_final

General Density Matters: Review of Approaches to
Setting Organism

‐ Based Ballast Water Discharge Standards 2010 Lee_Density Matters ‐ Excerpts for SAB

General International Convention for the Control

and Management of Ships’ Ballast Water

and Sediments, 2004 ‐ List of ballast water

management systems that make use of

Active Substances which received Basic and

Final Approvals 9/24/2009 BWM.2

‐ Circ.23.pdf

General Ballast Water Treatment Advisory 6/8/2010 ABS_BWMAdvisoryNotice.pdf



### Group 2: Direct Data Reports on Separate BWMS

Ecochlor® Ballast

Water Treatment
System STEP 2006 Application Form ‐ Section 4.0:

Proof of Ballast Water Treatment

Performance 2006 Final ‐ STEP Section 4

Ecochlor® Ballast

Water Treatment
System Final report of the land

‐ based testing of the

Ecochlor®

‐ system, for Type Approval
according to regulation

‐ D2 and the relevant

IMO guideline (April

– July 2008) Feb

‐ 09 G8

‐ Eco

‐ _report_BSH

‐ v8

‐ final

Ecochlor® Ballast

Water Treatment
System Final Environmental Assessment Review of

the Application by Atlantic Container Lines

for Acceptance of the Vessel M/V Atlantic

Compass and the EcochlorTM Inc. Technology into the USCG Shipboard
Technology Evaluation (STEP) Program Aug

‐ 08 USCG

‐ 2007

‐ 0042

‐ 0010.1

Electro

‐ Clean Ballast

Water Management
System Development of technologies on test facility and procedures for the land

‐ based

test as a type approval test at ballast water

treatment system 2008 Electroclean barge



## 65

### System Title Date File name

Electro

‐ CleenTM

System Information on the Type Approval

Certificate of the Electro

‐ CleenTM System (ECS) 2/20/09 59

‐ INF.6_Electroclean

‐ TypeApp

‐ ROK

GloEn

‐ PatrolTM Ballast

Water Management
System Type Approval Certificate of Ballast Water
Management System 12/4/09 GloEn

‐ Patrol Type Approval Certificate

Greenship's Ballast

Water Management
System Landbased Test Report ‐ Test Cycle

Summary 2007 Landb_Test_Rep_Summ_07_07

Hyde GUARDIAN

Ballast Water

Treatment System Environmental Acceptability Evaluation of

the Hyde GUARDIAN Ballast Water

Treatment System as Part of the Type Approval Process 4/20/2009 environmental_acceptability_evaluation

Hyde GUARDIAN

Ballast Water

Treatment System Final report of the land

‐ based testing of the
Hyde

‐ GuardianTM ‐ System, for Type Approval according to the Regulation D

‐ 2

and the relevant IMO Guideline (April
‐ July
2008) Jan

‐ 09 G8

‐ HM

‐ final report MCA

Hyde GUARDIAN

Ballast Water

Treatment System Type Approval Certificate of Ballast

Management System 4/29/2009 hyde_mca_cert

Hyde GUARDIAN

Ballast Water

Treatment System Shipboard Trials of Hyde "Guardian" System

in Caribbean Sea and Western Pacific

Ocean, April 5th ‐ October 7th, 2008 Apr

‐ 09 hyde_shipboard_tests

Hyde GUARDIAN

Ballast Water

Treatment System Type Approval of the Hyde GUARDIANTM

Ballast Water Management System 5/7/2009 59

‐ INF20_TypeApp

‐ UK

OceanSaver® Ballast

Water Management
System Det Norske Veritas Type Approval

Certificate 4/8/2009 Oceansaver type approval certificate

OceanSaver® Ballast

Water Management
System Type Approval Certificate of the

OceanSaver ® BWMS 4/17/2009 Nor

‐ OceanSaver

OceanSaver® Ballast

Water Management
System Information on the Type Approval

Certificate of the OceanSaver® Ballast

Water Management System 5/6/2009 59

‐ INF17_OceanSaver

‐ TypeApp

‐ Nor

OptiMarin Ballast

System Det Norske Veritas Type Approval

Certificate 11/12/2009 Optmarin type approval certificate

Z3_600_8349_20091112_133619

Peraclean Toxic Shock as New Ballast Water

Treatment Fails Test 2/9/2010 lloyds 2010 peraclean article

SEDNA® ballast water

treatment system
using PERACLEAN®

Ocean Effective Protection Against “Stowaways”:

Ballast Water Management System of

Hamann and Evonik Receives Final
Approval 6/11/2008 PeraClean

‐ TypeApproval_PR



## 66

### System Title Date File name

SEDNA®

‐ System Final report of the land

‐ based and
shipboard testing of the SEDNA®

‐ system Mar

‐ 08 SEDNA Type Appr Test_results.nioz

SEDNA®

‐ System Summary of Additional Provisions of the

Type Approval Certificate of Ballast Water
Management System SEDNA 250 of

Hamann AG Aug

‐ 08 Type Approval Additional Provisions_HAMANN

SEDNA ® 250 Type Approval Certificate of Ballast Water
Management System 8/16/2008 Ger_Sedna

PureBallast 250

‐ 2500 Det Norske Veritas Type Approval

Certificate 6/27/2008 PureBallast Type Approval Certificate

Siemens SICURE

Ballast Water
Management System A Great Lake Relevancy Preamble to the GSI
Report on Land

‐ Based Testing Outcomes

for the Siemens SICURE Ballast Water
Management System 4/28/2010 GLPreamble

Siemens SICURE

Ballast Water
Management System Report of the Land

‐ Based Freshwater
Testing of the Siemens SiCURE Ballast

Water Management System 5/15/2010 GSI

‐ LB

‐ F

‐ A

‐ 1

NEI Venturi Oxygen
Stripping (VOS) Application for Type Approval Certification:

NEI Treatment Systems' Venturi Oxygen
Stripping Ballast Water Management
System. Mar

‐ 07 VOS Application for Type Approval Certification

NEI Venturi Oxygen
Stripping (VOS) Short

‐ term Toxicity Testing of a De

‐ oxygenation Ballast Water Treatment to
Receiving Water Organisms. Final Report. 8/29/2008 Short

‐ term Acute Toxicity Testing

NEI Venturi Oxygen
Stripping (VOS) Short

‐ term Chronic Toxicity Testing of a De

‐ oxygenation Ballast Water Treatment to
Receiving Water Organisms. Final Report. 3/27/2009 Short

‐ term Chronic Toxicity Testing

NEI Venturi Oxygen
Stripping (VOS) STEP 2006 Application Form. Mar

‐ 06 STEP Final Version 6

‐ 23

‐ 09

NEI Venturi Oxygen
Stripping (VOS) Evaluations of a Ballast Water Treatment to
Stop Invasive Species and Tank Corrosion. 2005 Tamburri SNAME_2005_D09

NEI Venturi Oxygen
Stripping (VOS) Type Approval Certificate of Ballast Water
Management System; Ballast Water
Management System Type Approval
Compliance Certificate 7/6/2009;
7/8/2007;
1/19/2010 NEI_IMO_BWM_TYPE_APPROVAL_CERTIFICATE

Severn Trent De Nora (BalPure) Washington State Dept. of Fish and Wildlife
Application Package Ballast Water

Treatment System 8/8/2005 BWT System Application Package 8

‐ 8

‐ 05

Severn Trent De Nora (BalPure) Marrowstone Sodium Hypochlorite

Mesocosm September 2004 Sep

‐ 04 Marrowstone Sodium Hypochlorite Mesocosm September 2004

Severn Trent De Nora (BalPure) Environmental Assessment Review of the
Application for Acceptance of the SeaRiver

Maritime Inc. S/R American Progress and

Severn Trent de Nora BalPureTM System into

the Shipboard Technology Evaluation

Program (STEP) Feb

‐ 09 USCG

‐ 2008

‐ 0126

‐ 0007.1



## 67

### System Title Date File name

Group 3: G9 Files

Alfa Laval Ballast

Water Management
System (PureBallast) Basic Approval of Active Substances used
by PureBallast management system 4/21/2006 55

‐ 2

‐ 5_PureBal

‐ Swe

‐ Basic

Alfa Laval Ballast

Water Management
System (PureBallast) Application for Final Approval of a ballast

water management

system using Active Substances 12/15/2006 56

‐ 2

‐ 1_PureBal

‐ Nor

‐ Final

AquaStar Ballast

Water Management
System Application for Basic Approval of AquaStar

Ballast Water Management System 3/18/2010 61

‐ 2

‐ 1_AquaStar

‐ Jap

‐ Baasic

AquaTriComb

BallastTM Water

Treatment System Application for Basic Approval of the
AquaTriComb Ballast Water Treatment
System 12/16/2008 59

‐ 2

‐ 8_AquaTriComb

‐ Ger

‐ Basic

AquaTriComb

BallastTM Water

Treatment System Application for Basic Approval of the
AquaTriCombTM Ballast Water Treatment
System Corrigendum 6/29/2009 MEPC 59

‐ 2

‐ 8

‐ Corr.1

"ARA Ballast" Ballast

Water Management
System (formerly

Blue Ocean Guardian
BWMS) Application for Final Approval of "ARA

Ballast" Ballast Water Management System 3/23/2010 61

‐ 2

‐ 5_ARA

‐ ROK

‐ Final

BalPure® Application for Basic Approval of the Severn

Trent DeNora BalPure® Ballast Water
Management System 8/28/2009 60

‐ 2

‐ 9_BalPure

‐ Ger

‐ Basic

BalPure® Application for Final Approval of the Severn

Trent DeNora BalPure® Ballast Water
Management System 3/28/2010 61

‐ 2

‐ 9_BalPure

‐ Ger

‐ Final

Blue Ocean Guardian
(BOG) Ballast Water
Management System Application for Basic Approval of Blue

Ocean Guardian (BOG) Ballast Water
Management System 8/24/2009 60

‐ 2

‐ 5_BlueOceanGuardian

‐ ROK

‐ Basic

Blue Ocean Shield

Ballast Water
Management System Application for Basic Approval of the Blue

Ocean Shield Ballast Water Management
System 12/5/2008 59

‐ 2

‐ 2_BlueOceanShield

‐ China_basic

BlueSeas Ballast

Water Management
System Application for Basic Approval of the

BlueSeas Ballast Water Management
System 3/31/2010 61

‐ 2

‐ 12_BlueSeas

‐ Sing

‐ Basic

DESMI Ocean Guard

Ballast Water
Management System Application for Basic Approval of the DESMI

Ocean Guard Ballast Water Management
System 8/19/2009 60

‐ 2

‐ 4_OceanGuard

‐ Den

‐ Basic

EcoBallast Application for Basic Approval of the HHI

Ballast Water Management System (EcoBallast) 12/9/2008 59

‐ 2

‐ 4_HHI

‐ EcoBallast

‐ ROK

‐ Basic

EcoBallast Application for Final Approval of HHI Ballast

Water Management System "EcoBallast" 8/20/2009 60

‐ 2

‐ 1_EcoBallast

‐ ROK

‐ Final



## 68

### System Title Date File name

Ecochlor® Ballast

Water Treatment
System Application for Basic Approval of the

Ecochlor® Ballast Water Treatment System 3/20/2008 58

‐ 2

‐ 2_Ecochlor

‐ Ger

‐ Basic

Ecochlor® Ballast

Water Treatment
System Application for Final Approval of the

Ecochlor® Ballast Water Management
System 12/16/2008 59

‐ 2

‐ 9_EcoChlor

‐ Ger

‐ Final

Ecochlor® Ballast

Water Treatment
System Application for Final Approval of the

Ecochlor® Ballast Water Management
System 3/28/2010 61

‐ 2

‐ 8_EcoChlor

‐ Ger

‐ Final2

EctoSysTM A Swedish Disinfection System 1/13/2006 54

‐ INF

‐ 6_EctoSys

‐ Swe

‐ Basic

EctoSysTM Basic Approval of Active Substances used
by EctoSysTM electrochemical system 4/21/2006 55

‐ 2

‐ 4_EctoSys

‐ Swe

‐ Basic

ERMA FIRST Application for Basic Approval of the ERMA

FIRST Ballast Water Management System 3/29/2010 61

‐ 2

‐ 11_ERMA FIRST

‐ GR

‐ Basic

CleanBallast! Comments on the report of the fourth
meeting of the GESAMP

‐ BWWG 2/4/2008 57

‐ 2

‐ 13_CleanBallast

‐ Ger

‐ Rebut

CleanBallast! Application for Final Approval of a ballast

water management system using Active

Substances 9/7/2007 57

‐ 2

‐ 3_CleanBallast

‐ Ger

‐ Final

‐ 1

CleanBallast! Application for Final Approval of the RWO

Ballast Water Management System (CleanBallast) 11/28/2008 59

‐ 2_CleanBallast

‐ Ger

‐ Final

‐ 2

Electro

‐ Clean Ballast

Water Management
System Application for Basic Approval of Active

Substances used by Electro

‐ Clean (Electrolytic Disinfection) Ballast Water
Management System 12/16/2005 54

‐ 2

‐ 3_ElectroClean

‐ ROK

‐ Basic

Electro

‐ Clean Ballast

Water Management
System Application for Final Approval of a ballast

water management system using Active

Substances (Electro

‐ Clean Electrolytic
Disinfection) 9/7/2007 57

‐ 2

‐ 1_ElectroClean

‐ ROK

‐ Final

Electro

‐ Clean Ballast

Water Management
System Application for Final Approval of a ballast

water management system using Active

Substances (Electro

‐ Clean Electrolytic
Disinfection). Corrigendum 3/12/2008 57

‐ 2

‐ 1

‐ Corr.1

Electro

‐ Clean Ballast

Water Management
System Application for Final Approval of the

Electro

‐ Clean System (ECS) 3/20/2008 58

‐ 2_ElectroClean

‐ ROK

‐ Final

En

‐ Ballast Application for Basic Approval of Kwang

San Co., Ltd. (KS) Ballast Water
Management System "En

‐ Ballast" 8/25/2009 60

‐ 2

‐ 7_EnBallast

‐ ROK

‐ Basic

GloEn

‐ PatrolTM Ballast

Water Management
System Basic Approval of Active Substance used by

GloEn

‐ PatrolTM 9/7/2007 57

‐ 2

‐ 4_GloEnPatrol

‐ ROK

‐ Basic

GloEn

‐ PatrolTM Ballast

Water Management
System Application for Final Approval of the GloEn

‐ PatrolTM Ballast Water Treatment System 12/16/2008 59

‐ 2

‐ 7_GloEnpatrol

‐ ROK

‐ Final



## 69

### System Title Date File name

Greenship's Ballast

Water Management
System Application for Basic Approval of a
combined ballast water management

system consisting of sediment removal and

an electrolytic process using seawater to produce Active Substances (Greenship Ltd) 12/20/2007 57

‐ 2

‐ 7_Greenship

‐ Neth

‐ Basic

Greenship Sedinox

Ballast Water
Management System Application for Final Approval of the
Greenship Sedinox Ballast Water
Management System 12/12/2008 MEPC 59

‐ 2

‐ 6_Greenship

‐ Neth

‐ Final

HiBallast Application for Basic Approval of Hyundai

Heavy Industries Co., Ltd. (HHI) Ballast

Water Management System (HiBallast) 8/24/2009 60

‐ 2

‐ 6_HiBallast

‐ ROK

‐ Basic

Hitachi Ballast Water

Purification System (ClearBallast) Application for Basic Approval of Active

Substances used by Hitachi Ballast Water

Purification System (ClearBallast) 9/7/2007 57

‐ 2

‐ 2_ClearBallast

‐ Jap_Basic

Hitachi Ballast Water

Purification System (ClearBallast) Application for Final Approval of the Hitachi

Ballast Water Purification System (ClearBallast) 12/11/2008 59

‐ 2

‐ 5_ClearBallast

‐ Jap

‐ Final

Hybrid Ballast Water

Treatment System
using Seawater Electrolytic Process Basic Approval of Active Substances used
by the Hybrid Ballast Water Treatment
System using Seawater Electrolytic Process 12/14/2006 56

‐ 2_Hybrid

‐ Jap

‐ Basic

Kuraray Ballast

Water Management
System Application for Basic Approval of Kuraray

Ballast Water Management System 3/25/2010 61

‐ 2

‐ 6_Kuraray

‐ Jap

‐ Basic

MES Ballast Water
Management System (FineBallast MF) Application for Basic Approval of the MES

Ballast Water Management System (FineBallast MF) 3/17/2010 61

‐ 2

‐ 3_FineBallast

‐ Jap

‐ Basic

NK Ballast Water

Treatment System Request for re

‐ evaluation of the proposal

for the approval of Active Substances 8/18/2006 55

‐ 2

‐ 27_NK

‐ ROK

‐ ReSubmit

NK Ballast Water

Treatment System Basic Approval of Active Substances used
by NK Ballast Water Treatment System 4/20/2006 55

‐ 2

‐ 3_NK

‐ ROK

‐ Basic

NK

‐ O3 BlueBallast

System Application for Final Approval of the NK

‐ O3

BlueBallast System (Ozone) 3/21/2008 58

‐ 2

‐ 3_NK

‐ ROK

‐ Final

‐ 1

NK

‐ O3 BlueBallast

System Application for Final Approval of the NK

‐ O3

BlueBallast System (Ozone) 12/8/2008 MEPC 59

‐ 2

‐ 3_NK

‐ ROK

‐ Final

‐ 2

OceanGuardTM Ballast

Water Management
System Application for Basic Approval of the

OceanGuardTM Ballast Water
ManagementSystem 8/26/2009 60

‐ 2

‐ 8_OceanGuard

‐ Nor

‐ Basic

OceanGuardTM Ballast

Water Management
System Application for Final Approval of the

OceanGuardTM Ballast Water
ManagementSystem 3/25/2010 61

‐ 2

‐ 7_OceanGuard

‐ Nor

‐ Final

OceanSaver® Ballast

Water Management
System Application for Basic Approval of a ballast

water management system using Active

Substances 9/7/2007 57

‐ 2

‐ 6_OceanSaver

‐ Nor

‐ Basic



## 70

### System Title Date File name

OceanSaver® Ballast

Water Management
System Application for Final Approval of the

OceanSaver® Ballast Water Management
System (OS BWMS) 3/19/2008 58

‐ 2

‐ 1_OceanSaver

‐ Nor

‐ Final

Peraclean® Ocean Application for approval of an Active

Substance for Ballast Water Management 4/15/2005 53

‐ 2

‐ 12_PeraClean_Ger

‐ Basic

Peraclean® Ocean Application for approval of an Active

Substance for Ballast Water Management. Corrigendum 5/27/2005 53

‐ 2

‐ 12

‐ corr.1

Peraclean® Ocean &

Sedna system Application for Final Approval of a ballast

water management system using Active

Substances 9/7/2007 57

‐ 2

‐ 5_PeraClean(Sedna)

‐ Ger

‐ Final

PurimarTM Ballast

Water Management
System Application for Basic Approval of Techwin

Eco Co., Ltd. (TWECO) Ballast Water
Management System (PurimarTM) 3/9/2010 61

‐ 2_Purimar

‐ ROK

‐ Basic

Resource Ballast
Technologies System (cavitation combined

with Ozone and

Sodium Hypochlorite
treatment) Basic Approval of Active Substances used
by Resource Ballast Technologies System (Cavitation combined with Ozone and

Sodium Hypochlorite treatment) 4/6/2007 56

‐ 2

‐ 3_Resource

‐ SAfr

‐ Basic

Resource Ballast
Technologies System (cavitation combined

with Ozone and

Sodium Hypochlorite
treatment) Application for Final Approval of the

Resource Ballast Technologies System (Cavitation combined with Ozone and

Sodium Hypochlorite treatment) 12/19/2008 59

‐ 2

‐ 10_Resource

‐ SAfr

‐ Final

Siemens SiCURE Application for Basic Approval of the

Siemens SiCURE Ballast Water
Management System 12/19/2008 MEPC 59

‐ 2

‐ 11_SiCure

‐ Ger

‐ Basic

Special Pipe Hybrid

Ballast Water
Management System

combined with

Ozone treatment

version Basic Approval of Active Substances used
by Special Pipe Ballast Water Management
System (combined with Ozone treatment) 4/12/2006 55

‐ 2_SpecialPipe

‐ Jap

‐ Basic

Special Pipe Hybrid

Ballast Water
Management System

combined with

Ozone treatment

version Application for Final Approval of the Special
Pipe Hybrid Ballast Water Management
System (combined with Ozone treatment) 12/4/2008 59

‐ 2

‐ 1_SpecialPipe

‐ Jap

‐ Final

‐ 1

Special Pipe Hybrid

Ballast Water
Management System

combined with

Ozone treatment

version Application for Final Approval of the Special
Pipe Hybrid Ballast Water Management
System combined with Ozone treatment

version (SP

‐ Hybrid BWMS Ozone version) 3/17/2010 61

‐ 2

‐ 2_SpecialPipe

‐ Jap

‐ Final

‐ 2



## 71

### System Title Date File name

Special Pipe Hybrid

Ballast Water
Management System

combined with

PERACLEAN ® Ocean (SPO

‐ SYSTEM) Application for Final Approval of the Special
Pipe Hybrid Ballast Water Management
System combined with PERACLEAN ® Ocean (SPO

‐ SYSTEM) 3/29/2010 61

‐ 2

‐ 10_SpecialPipeSPO

‐ Jap

‐ Final

Sunrui ballast water

management system Application for Basic Approval of Sunrui

ballast water management system 8/24/2009 60

‐ 2

‐ 3_Sunrui

‐ China

‐ Basic

BalClor TM ballast

water management

system (formerly

Sunrui BWMS) Application for Final Approval of BalClor TM

ballast water management system 3/22/2010 61

‐ 2

‐ 4_Sunrui

‐ China

‐ Final

TG Ballastcleaner and

TG Environmentalguard Application for Basic Approval of the ballast

water management system using “TG

Ballastcleaner and TG Environmentalguard”

as Active Substances (Toagosei Group) 12/26/2007 57

‐ 2

‐ 8

‐ TG

‐ Jap

‐ Basic

TG Ballastcleaner and

TG Environmentalguard Application for Final Approval of the JFE

Ballast Water Management System (JFE

‐ BWMS) that makes use of "TG

Ballastcleaner® and TG Environmentalguard®" 8/20/2009 60

‐ 2

‐ 2

‐ TG

‐ Jap

‐ Final

Peraclean Ocean,

ElectroClean Report of the first meeting of the GESAMP

‐ Ballast Water Working Group (GESMP

‐ BWWG) 2/28/2006 54

‐ 2

‐ 12_GESAMP

‐ Rpt_1

Special Pipe Ballast

Water Management
System (combined

with Ozone treatment), NK

Ballast Water

Treatment System,
EctoSys Report of the second meeting of the

GESAMP

‐ Ballast Water Working Group (GESMP

‐ BWWG) 7/7/2006 55

‐ 2

‐ 16_GESAMP

‐ Rept_2

Hybrid Ballast Water

Treatment System
using Seawater Electrolytic Process,

NKO3 BWTS,
PureBallast,

PureBallast Report of the third meeting of the

GESAMP

‐ Ballast Water Working Group (GESMP

‐ BWWG) 4/13/2007 56

‐ 2

‐ 2_GESAMP

‐ Rpt_3

Electo Clean System,

Clear ballast System,

CleanBallast! System Report of the fourth meeting of the

GESAMP

‐ Ballast Water Working Group (GESAMP

‐ BWWG) 12/19/2007 57

‐ 2_GESAMP

‐ Rpt

‐ 4

Resource Ballast
Technologies System,

GloEn Patrol, SEDNA
using Percaclean

Ocean, OceanSaver Report of the fifth meeting of the GESAMP

‐ Ballast Water Working Group (GESMP

‐ BWWG) 1/25/2008 57

‐ 2

‐ 10_GESAMP

‐ Rpt_5



## 72

### System Title Date File name

TG Ballastcleaner and

TG Environmentalguard,
Greenship's Ballast

Water Management
System, Electro

‐ Clean System (ECS) Report of the sixth meeting of the GESAMP

‐ Ballast Water Working Group 7/14/2008 58

‐ 2

‐ 7_GESAMP

‐ Rpt

‐ 6

OceanSaver,
Ecochlor,

NK

‐ O3 BlueBallast

System Report of the seventh meeting of the

GESAMP

‐ Ballast Water Working Group 7/28/2008 58

‐ 2

‐ 8_GESAMP

‐ Rpt

‐ 7

Special Pipe Hybrid

Ballast Water
Management System (with Ozone),
CleanBallast,

NK

‐ O3 BlueBallast

System, Blue Ocean
Shield, EcoBallast Report of the eighth meeting of the

GESAMP

‐ Ballast Water Working Group (GESMP

‐ BWWG) 4/8/2009 59

‐ 2

‐ 16_GESAMP

‐ Rpt_8

ClearBallast,
Greenship Sedinox,
AquaTriComb Report of the ninth meeting of the

GESAMP

‐ Ballast Water Working Group (GESMP

‐ BWWG) 5/5/2009 59

‐ 2

‐ 19_GESAMP

‐ Rpt_9

GloEn

‐ Patrol,
Ecochlor,

SiCURE, Resource

Ballast Technologies

System Report of the tenth meeting of the

GESAMP

‐ Ballast Water Working Group (GESMP

‐ BWWG) 10/30/2009 60

‐ 2

‐ 11_GESAMP

‐ Rpt_10

ATLAS

‐ DANMARK, TG

Ballastcleaner and TG Environmentalguard,

Sunrui Ballast Water
Management
System,

DESMI Ocean Guard,

Blue Ocean Guard
(BOG) Report of the eleventh meeting of the

GESAMP

‐ Ballast Water Working Group (GESMP

‐ BWWG) 12/1/2009 60

‐ 2

‐ 12_GESAMP

‐ Rpt_11

HiBallast, En

‐ Ballast,
OceanGuard, Severn

Trent DeNora Report of the twelfth meeting of the

GESAMP

‐ Ballast Water Working Group (GESMP

‐ BWWG) 2/8/2010 60

‐ 2

‐ 16_GESAMP

‐ Rpt_12

General Guidelines on the Installation of Ballast

Water Treatment Systems Mar

‐ 10 0310_ClassNK

‐ BWMS

‐ Intsallation



## 73