2016 American Bureau of Shipping. All rights reserved.

Ballast Water Management -

General Overview

Dietrich Dabels
Technology & Business Development Manager

Hamburg, Germany
22 February 2016

ABS SEMINAR: ENVIRONMENTAL & REGULATORY UPDATES

Topics

Ballast Water Management Options

USCG Type Approval Process
Information on Ballast Water Management Systems (BWMS)
Practical Means For Compliance with USCG Requirements
USCG extensions requests
Drydocking movements
Preparing for Compliance

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Understanding Requirements

Ships on Worldwide Voyages

Monitor progress in ratifying the BWM Convention
Identify the IOPP Renewals Survey
Monitor changes in the revision of the G8 Guidelines for approval of
BWMS
Ships Discharging in US Waters
Evaluate ship ballasting requirements
Follow USCG type approval process
Evaluate technology options

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BWM Convention Status
Entry into Force 12 months after ratification by 30 States representing 35% of World Tonnage
IMO 29th Assembly ratifications/accessions:
11/23 Morocco ratifies (0.03% world tonnage)
11/24 Indonesia ratifies (1.14% world tonnage
11/26 Ghana acceded (0.01% world tonnage)
IMO Press Briefing (15 January 2016) Criteria for entry into force of BWM Convention not yet
reached
34.56 % of World Tonnage
Needed 0.44% of World Tonnage
Announced preparations for ratification
Argentina 0.05% tonnage
India 0.82% tonnage
Panama 18.63%
Tentative Ratification (% tonnage):
Belgium 0.46%
Singapore 6.58%
Finland 0.14%
Italy 1.39%
Malta 4.81%

4
BWM Convention Implementation Schedule
28th IMO Assembly resolution adjusted the enforcement schedule of the BWM Convention
to align with the International Oil Pollution Prevention Renewal Survey.
Upon EIF, vessels are to comply with Regulation D-1 (Ballast Water Exchange Standard)
until the Regulation D-2 (Ballast Water Performance Standard) Compliance Date.
The BWM Convention will need to be amended upon ratification to incorporate an
implementation/enforcement schedule that takes into account the Entry Into Force (EIF)
date and appropriate time constrains for purchasing, installing, and commissioning a
BWMS.

Resolution A.1088(28) Enforcement Schedule

Ballast
Keel Laying Date D-2 Compliance Date
Water Capacity (m3)
First IOPP Renewal Survey following the
All < EIF
date of EIF

All >EIF At Delivery

5
BWM Requirements in the United States

The United States has not ratified the BWM Convention and
has established independent ballast water regulations
In the US, ships must be in compliance with:
USCG Ballast Water Regulations;
US EPA VGP; and
Individual State requirements
16 States have ballast water
requirements (California is the
most stringent)
BWMS require new testing and
type approval by the USCG
Compliance dates are based on
vessel drydocking

6
USCG BWM Regulations
General requirements for Ballast Water Management (BWM)
practices, reporting, and recordkeeping
New requirements for BWMS type approval
Ballast water discharge standards (BWDS) compliance schedule:
Vessel Ballast Capacity Compliance Date
New All Delivery
First Scheduled Drydocking
< 1,500 m3
after 1 January 2016
First Scheduled Drydocking
Existing 1,500 5,000 m3
after 1 January 2014
First Scheduled Drydocking
> 5,000 m3
after 1 January 2016
Notes:
New vessel constructed on or after 1 December 2013
CG-OES Policy Letter No. 13-01, Revision 2 (16 November 2015) - An underwater inspection in lieu of
drydocking (UWILD) is not considered the first scheduled drydocking.

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Additional Requirements in 2013 VGP
Active Ingredient Discharge Limitations (dependent on technology)
Limit
Biocide or Residual
(Instantaneous Maximum)
Chlorine Dioxide 200 g/l

Chlorine (Total Residual Oxidants (TRO as TRC)) 100 g/l

Ozone (Total Residual Oxidants (TRO as TRC)) 100 g/l

Peracetic Acid 500 g/l

Hydrogen Peroxide 1,000 g/l

Training - Promptly upon installation of system and significant change to

practices or equipment
BWM Plans - include written training plan and recording training dates
and personnel.
Mandatory BWM Practices listed in VGP Section 2.2.3.3
Monitoring to be submitted with VGP Annual Report

8
USCG: Ballast Water Management Options

U.S. Drinking Water No Discharge

Temporary Options

USCG Type
Approved BWMS USCG Extensions
USCG
On-shore Treatment Accepted AMS

9
Achieving USCG Type Approval

All testing in accordance with Environmental Technology Verification (ETV)

Protocol and Shipboard Testing Requirements (46 CFR 162.060-28)
Testing and evaluation of existing data needs to be conducted by USCG
accepted independent laboratory (IL)
USCG accepted ILs: NSF International (ABS subcontractor for construction
review), DNV-GL AS, Korean Register of Shipping, Control Unions Certifications
BV and Lloyds Register EMEA.
Existing data for most BWMS cannot be used due to differences in testing
requirements between USCG requirements and BWM Convention Guidelines
USCG has specific requirements for:
Test plans and quality assurance project plans
Operation and maintenance evaluation
Biological efficacy evaluation
Diagnostics evaluation
System documentation evaluation
Technical data package submission
Counting organisms (i.e., FDA/CMFDA method)

10
USCG Type Approval Process

Shipboard
Land-based
Testing Testing may
Testing
(20 weeks)
(minimum 6 occur in
months) Component parallel, but
Testing
the same
(~35 days) exact model
Vendor
makes a needs to be
Design &
contract
with IL
IL Construction
Review
(~90 days)
used for all
testing.

USCG Marine
IL Review and Test USCG Type
Report Generation
Safety Center
Approval
Approximately
Review 18 24 months
(~90 days) Awarded
(~90 days)

Note: Process is confidential until award of USCG type approval

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USCG Type Approval Status

No BWMS has received USCG Type Approval

32 BWMS vendors submitted Notices of Intent (NOI) to USCG
ABS has verified that 24 BWMS vendors have contracted with an IL
As of December 2015, testing for 17 units is currently underway
March 2015: 3 UV-based BWMS Vendors submitted type approval
packages to the USCG Marine Safety Center (MSC) for review
16 December 2015: USCG MSC denied request to use Most Probable
Number (MPN) for evaluation of 4 different BWMS manufacturers.
Limited BWMS testing for USCG type approval prior to 2015
September 2015 IL with largest capacity stated that no additional type
approval packages are to submitted to USCG MSC until last half of 2016.
Estimated earliest USCG type approved BWMS mid to late 2016
Note: USCG will not force shipowners to purchase first BWMS receiving
type approval. Extension requests will continue.

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USCG Extensions: Revised Request Policy
16 November 2015 USCG revised policy and process
for submitting extensions
Batch submittal for a fleet of vessels with compliance
dates in the same year is now permitted.
Supplemental extension process explained for vessels
with existing extensions
Shipowners are required to submit:
Excel-based Application for Extended Compliance Date
under U.S. Coast Guard Ballast Water Management
(BWM) Regulations
Statement in email documenting reason for extension
request.
All documentation needs to be written in English and
emailed to environmental_standards@uscg.mil. Text in
document needs to be in a format that provides optical
character recognition (OCR).
Extension request to be submitted 12 to 24 months prior
to compliance date
USCG clarified that newbuilds may request extensions.
ABS has revised documentation templates.

13
USCG Extensions Granted
USCG has listed over 4402 approved extension requests.
Initial period for Extensions: 1 January 2016, 1 January 2017, or 1 January 2018
firm date, not related to drydocking
As of 18 November 2015, extensions are being granted to the next scheduled
drydocking
Shipowners with initial extensions to firm dates will need to wait until 1 year
prior to expiration of initial extension to request new extensions to drydocking
date
USCG will not be revising the initially approved extensions

Shipowners are waiting approximately 3 to

6 months for USCG approval of extension
requests
USCG has not denied any extensions.
Shipowners are asked to be patient for
response.
EPA Issue with USCG extensions still exists.
EPA VGP does not include a provision for
USCG extensions. EPA published Enforcement
Memorandum with Low Priority Enforcement
statement.
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Extensions after USCG BWMS Type Approval

USCG extensions will be granted until:

Sufficient number of suitable BWMS have received USCG type approval
Sufficient, suitable models are available
Drydock availability is not limited
Issues from installation and commissioning are resolved.
Shipowners need to document:
Evaluation of BWMS and discussions with BWMS vendors for future and
supplemental extension requests
Suitable BWMS
Issues with availability of models from BWMS vendors
Lack of drydocking space
Problems encountered during purchasing, installation and
commissioning
Shipowners will need an operable BWMS at the expiration of all
requested and approved extensions

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Revised USCG Reporting Requirements
Submittal Times
Revision
Vessels equipped with ballast tanks and
bound for any US port or place, except
listed below 6 hours after arrival at or
prior to departure from the port or place of
destination, which ever is earlier
Revised reporting to reduce the number of
corrections
No changes for Vessels entering the Great
Lakes or Hudson River north of the
George Washington Bridge from outside
the Exclusive Economic Zone (EEZ) at
least 24 hours prior to arrival

16
New USCG Reporting Requirements
NEW - Annual Reports required for vessels
that exclusively operate in one Captain of
the Port (COTP) Zone.
New temporary requirement to determine if
further regulatory action is needed
Annual Reports on ballasting practices for
calendar years 2016, 2017, and 2018 by
31st March of the subsequent year.
USCG ballast water reporting is entered on
the National Ballast Information
Clearinghouse (NBIC) website
(http://invasions.si.edu/nbic/submit.html)
Revisions and new requirements effective
22 February 2016

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Shipowner Next Steps

Evaluate BWMS options

Identify BWMS suitable for vessel design and operation
Contact BWMS vendors request
Information on BWMS models
Status of USCG type approval testing
Plan BWMS retrofit
Design
Determine installation options

Note: ABS Technical Evaluation Services for BWMS assist with this
process. Refer to our brochure Technical Evaluation Services for
Ballast Water Management Systems

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BWMS for Use in US Waters:
USCG Accepted Alternate Management System (AMS)

If installed prior to USCG Type Approved BWMS, AMS may be used for 5-years
from the vessels specific compliance date
USCG Accepted AMS 53 BWMS by 47 Manufacturers
Aquarius-EC EcoBallast NiBallast
Aquarius-UV Ecochlor NK-O3 BlueBallast
AquaStar (inc. Ex models) ECOMARINE Ocean Protection System
ARA PLASMA Electro-Cleen OceanDoctor
BalClor ERMA FIRST OceanGuard
BallastMaster UltraV FineBallast MF OceanSaver MKII
BALPURE GloEn-Patrol Optimarin (inc. Ex models)
Bawat HiBallast (inc. Ex models) OxyClean
BIO-SEA Hyde GUARDIAN PACT Marine BWTS
BioViolet HY-BWMS PureBallast
Blue Ocean Shield JFE BallastAce (Models 250 to 2500, 2.0/2.0Ex, & 3.0)
BSKY (using NEO-CHLOR MARINE Purimar
Cathelco and TG Ballastcleaner) RayClean
CleanBallast KBAL SeaCURE
Coldharbour GLD BWTS MICROFADE Seascape
CrystalBallast Miura BWMS Smart Ballast
Cyeco BWMS MMC BWMS Trojan Marinex
NEI VOS YP-BWMS
As of 22 January 2016

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Approved BWMS Statistics
All Type
USCG
Category Approved
AMS
BWMS
No. of BWMS 56* 52
No. of BWMS requiring treatment during intake and
50 49
de-ballasting
No. of BWMS using active substances 26 22
No. of BWMS requiring storage of chemicals 22 20
No. of BWMS requiring storage of waste products 1 0
Maximum Capacity (m3/h)* 16,200 16,200
As of 22 January 2016

*Excludes one BWMS no longer available.

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Disinfection Technologies

IMO Type Approved USCG AMS

30

25

20

15

10

As of 22 January 2016
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California Amended Requirements
California Assembly Bill 1312
amending the Marine Invasive
Species Act
Interim ballast water performance
standards - implementation delayed:
Newly built vessels (constructed on
or after 1 January 2020) first
arrival in a CA port
Existing vessels First drydocking
on or after 1 January 2020

Final ballast water performance standards - implementation delayed

until 1 January 2030
Changed deadline for submitting Ballast Water Reporting Form from
upon departure from each port of call to 24 hours in advance of arrival.
CA authorized to take samples of ballast water, sediment, and
biofouling from at least 25% of arriving vessels
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California Ballast Water Treatment
Performance Standards
Interim
Organism Size Class Performance Standard
Larger than 50 m
(micrometer or one millionth of a meter) in No detectable living organisms
minimum dimension
10 50 m in minimum dimension Less than (<) 0.01 living organisms per ml (milliliter)
Less than 10 m in minimum dimension Less than 103 (1,000) bacteria per 100 ml
Less than 104 living viruses per 100 ml

Escherichia coli Less than 126 cfu (colony forming units) per 100 ml
Intestinal enterococci Less than 33 cfu per 100 ml
Toxicogenic Vibrio cholera Less than 1 cfu per 100 ml OR
(human cholera) Less than 1 cfu per gram of wet weight biological
material

Final Effective 1 January 2030

Zero detectable living organisms for all organism size classes

23
U.S. VGP Court Ruling

October 5th, 2015, the United States Court of Appeals

for the Second Circuit ruled that EPA acted arbitrarily
and capriciously in issuing the 2013 VGP
No impact to existing 2013 VGP that expires on
18 December 2018
Impacts to 2018 VGP
EPA needs to evaluate more stringent discharge
limitations that BWM Convention D-2
Onshore reception and treatment facilities need to be
evaluated
More detailed analysis of compliance options for Lakers
Expected dates for 2018 VGP
Late 2016/Early 2017 - Expected proposal of 2018 VGP
with public comment period
March/April 2018 Publish 2018 VGP
19 December 2018 Effective date for 2018 VGP

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Final Points

Understand the requirements and deadlines

Check ship schedules for drydocking and surveys
Review ship ballasting operations
Develop options for compliance
Request assistance from ABS

25
BWMS Technology Evaluation

Guidance for identifying effective solutions

Interactive multiphase process leveraging an extensive technical and
performance BWMS database
Delivers a customized solution set for decision support
Key steps of the ABS technology evaluation are:
Review the vessel or fleet, operational and life cycle information
Provide a preliminary list of BWMS options
including considerations to nuances of IMO,
USCG and regional requirements
Deliver a preliminary report for suitable BWMS
Design and Operations
Provide a comparative suitability assessment
Operational considerations
Assist understanding of vendor technical and
service offerings
Deliver a final report with options

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Recent ABS Environmental Publications

2014 ABS Ballast Water Treatment

Advisory
2014 ABS Guide for Ballast Water
Treatment (including BWMP template)
ABS Trends on:
Nitrogen Oxides (Nox) Emission
Compliance Inside Emission Control
Areas (ECAs) (December 2015)
Preparing for Compliance with USCG
Ballast Water Discharge Standards
(December 2015)
Sulfur Oxide (SOx) Limits Reduced in
ECAs (January 2015)
2013 VGP Sampling and Analysis
Requirements (June 2014)
2013 Requirements for EALs (May
2014)
New Requirement for the Upcoming
2013 VGP (October 2013)
US Ballast Water Management
Requirements (May 2013)

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 2016 American Bureau of Shipping. All rights reserved.

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