Establishing a Ballast Water Discharge Standard

Mr. Lorne W. Thomas, Capt USCG (Ret)Governmental Affairs Officer

U.S. Coast Guard Ninth District

6th Annual Great Lakes Restoration Conference

Buffalo NY

Why a BW discharge standard? In U.S. waters, over 60% of

vessels can not exchange appropriately due to their routes (< 200 nm). (100% of GL ships)

Effectiveness of ballast water exchange varies

Provides a clearly defined benchmark for treatment technology development

Aids in verifying compliance with BWM requirements

Photo courtesy of SERC

Ballast Water Discharge StandardBWDS NPRM establishes (August 2009):

Phased Approach IMO Standard initially 1000 times more stringent than IMO after 2016

Practicability Review will determine if 1000x standard can be met

If Practicability Review determines 1000x cannot be met, then intermediary standards established

Type Approval Process

Phased Approach

Phase I is a significant improvement over BWE Minimizes introductions through environmentally

sound technologies

Phase I standard is achievable and verifiable

Technology presently under development can likely meet the Phase I standard by implementation date

Consistent with international community System developers have targeted IMO standard –

standardized testing/verification protocols

Phase One and Phase Two Discharge Standards

>50 μ(large

organisms)

>10 μ & ≤ 50 μ

(small organisms)

≤ 10 μ(very small organisms)

Phase 1 < 10 / m3 < 10 / ml N/A

Phase 2 < 1 / 100 m3 < 1 / 100 ml< 1,000 bacteria & 10,000 viruses

per 100 ml

Sizes and Concentrations Phase I standard for zooplankton = 50 μm

approx 0.00197 inches, or 2/1000 of an inch

Ten 50 μm particles equals 1.25 x 10-12 M3: Or, approx 1 trillionth of a M3

Equivalent to 1 second in 31,700 years One drop of water in 20 Olympic swimming pools 99.999999999% free of organisms

1 cubic meter of water weighs ~ 2,200 lbs Approx the weight of a VW Bug

Distribution of concentrations in unmanaged discharge (354 tanks)

Unmanaged

After BWE

IMO Standard vs BWE (Zooplankton)Minton, et al, 2005

IMO

Public Meetings & Comments: Common Themes

Standard not stringent enough Timeline not aggressive enough National standard issues

Pre-emption or not Adoption of state standards EPA CWA vs. NISA BWE equivalent

Niche vessels (e.g. tugs, OSVs, barges, Lakers) not adequately addressed

Practicability review

Type Approval of BWT Systems

Conducted by CG-certified Independent Labs12-24 month process for three existing labsUsing EPA ETV protocols as frameworkType Approval Testing by AdministrationsLand-based testing: 6-8 weeksShipboard testing: 12 months (may be reduced)Equivalency of foreign-flag administration type

approvalAudit of BWTS dossiers submitted for type approvalQA/QC, test methodology & data verification issues

Type Approval of BWT SystemsNo BWT systems with approval above IMO standard

Only one BWT system approved for fresh waterGreat Lakes challenges; fresh water, cold water, quantities BW,

power needs, small GL/FW market, short transit timesUSCG & EPA will not conduct type approval for standards

exceeding Phase I; Testing protocols don’t existChallenges with enforcing IMO/Phase I standard

Time & quantities of BW for statistical certaintyExponentially more difficult for higher standardsUSCG/EPA MOU on VGP compliance under

development

Impact of multiple BWDSs

Uncertainty

Re-capitalization of Canadian fleet

Shippers shunning Great Lakes; further reduces already small market for FW systems

Delay to Ballast Water ConventionWill enter into force 12 months after ratification by 30 states representing

35% of world shipping tonnage--- currently ratified by 21 states, 23% tonnage

Since US is world’s largest port state, uncertainty of US standard may be delaying ratification by other countries

Timeline for Implementation

Review of comments

Revise NPRM, PEIS, Economic Analysis

Publish Final RuleCertification of Independent LabsType Approval TestingNAS/NRC study- “Methods for Determining

Numeric Limits for Living Organisms” – will inform Phase II and EPA’s revision of VGP in 2013

? QUESTIONS ?

EXTRA SLIDES

Joint Ballast Water Working Group

U.S. Coast Guard Transport Canada St. Lawrence Seaway Development Corporation St. Lawrence Seaway Management Corporation

Mission: Reduce the risk of introducing aquatic invasive

species into the Great Lakes via ballast water by enforcing existing regulations and educating

mariners in best management practices

Compliance and Enforcement Objectives

Inspect all vessels with ballast on first voyage

Target and inspect high risk vessels on their subsequent voyages

Target 100% if resources available

Data collection (science and enforcement)

Increase compliance with regulatory requirements

2009 Statistics

100% (295) ships bound for Great Lakes examined 100% ballast water reporting forms checked 97.9% compliance rate 100% of non-compliant water retained on board