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USCG Ballast Water Update. Richard A. Everett Environmental Standards Division (CG-5224) US Coast Guard December 5, 2007. CG Ballast Water Initiatives. Development of a national BW Discharge Standard BW treatment system approval protocols STEP International Developments.

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USCG Ballast Water Update

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Uscg ballast water update

USCG Ballast Water Update

Richard A. Everett

Environmental Standards Division


US Coast Guard

December 5, 2007

Cg ballast water initiatives

CG Ballast Water Initiatives

  • Development of a national BW Discharge Standard

  • BW treatment system approval protocols

  • STEP

  • International Developments

Why issue a bwd standard

Why issue a BWD Standard?

Ballast Water Exchange issues:

-Safety and voyage constraints

-Effectiveness is variable

Benchmark to approve BWM systems:

-Easier to compare to than BWE

Should increase the level of BWM conducted by vessels

Legislative authority to issue a bwd standard

Legislative Authority to issue a BWD standard

  • National Invasive Species Act of 1996 (NISA):

    • Establishes our authority to approve BW treatment systems

    • Establishes our ability to implement a BWD standard

      • BWE clearly viewed as an initial step

      • Secretary (USCG) given discretion to promulgate additional regulations as necessary

Current rulemaking project

Current Rulemaking Project

The BWD Standard regulation would:

  • Set a concentration-based standard (# of organisms/volume of ballast water)

  • Be used to approve BWT technologies

  • Be environmentally protective, scientifically sound, and enforceable

Bwd standard rulemaking cont d

BWD Standard Rulemaking(cont’d)

  • Specifically, the BWD Standard should address the full range of organisms including:

    -Microbes (pathogens)

    -All life stages (adults, juveniles, larvae, resting stages)

    -Those that reproduce asexually

Components of the regulatory project

Components of the Regulatory Project

  • Regulatory Analysis

    • Cost/benefit

  • Environmental Analyses

  • Drafting the Regulatory Text

    • Notice of Proposed Rule-making (NPRM)

      • In progress

    • Final Rule

Regulatory assessment cost benefit analysis

Regulatory Assessment (Cost-Benefit Analysis)

  • Executive Order 12866

    -Assess cost and benefits

  • Regulatory Flexibility Act

    -Economic impacts to small businesses

  • Small Business RegulatoryEnforcement Fairness Act

    -Assistance to small businesses

Regulatory assessment

Regulatory Assessment

  • Addresses potential costs and benefits of implementing a BWD standard

  • Addresses costs and benefits of alternatives analyzed in the Programmatic Environmental Impact Statement (DPEIS)

  • This analysis is completed and is part of the DPEIS

Environmental analyses

Environmental Analyses

  • Programmatic Environmental Impact Statement (DPEIS)

  • ESA Consultation

  • CZMA Consistency Determination

Draft programmatic environmental impact statement dpeis

Draft Programmatic Environmental Impact Statement (DPEIS)

  • Required under:

    the National Environmental Policy Act


  • DPEIS consists of:

    -Purpose and Need

    -Range of Alternatives

    Different Standards

    -Affected Environment

    -Environmental Consequences

Dpeis approach

DPEIS Approach

  • Expert Panel Workshop:

    -Comprised of NEPA Experts and Biologists from the 5 cooperating agencies

    -Finish the DPEIS analysis and obtain interagency team agreement

    -Took place in May 2007 in Charleston, SC.

Dpeis status

DPEIS Status

  • Incorporated interagency comments in Summer 2007

  • DPEIS is in CG clearance

  • Anticipate publishing DPEIS in Winter 2007 and hold 3 Public Meetings to solicit comments (WC, GL, DC)

  • Incorporate comments into the NPRM and publish soon thereafter, with additional Public Meetings

Approving bwt technologies

Approving BWT Technologies

  • Must meet the BWD Standard

  • Must ALSO meet Engineering and Operational Requirements (46 CFR)

    - Approval of Equipment and Materials

    - Approval of Electrical Equipment

    - Approval of Engineering Equipment

    - Approval of Piping Equipment

Approving bwm systems

Approving BWM Systems

  • Type Approval of systems

    • Rigorous land-based testing

    • Shipboard qualification

  • Consistent with existing USCG procedures and BWM Convention

  • Requires development of standard test protocols

    • Efficacy in killing/removing wide range of organisms (bacteria – fish)

    • Under wide range of water quality conditions (blue water – turbid industrial estuaries – freshwater lakes)

    • Under wide range of operating conditions (temp, humidity, sea state)

Epa environmental technology verification program

NSF International

EPA Environmental Technology Verification Program

Performance Verification ofBallast Water Treatment Technologies

United States Coast Guard

Coastal Resource and

Environmental Management

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Etv tech panel

ETV Tech Panel

Research and development

Research and Development

Ballast Water Treatment Test Facility at NRL Key West

  • Test facility operational

  • EPA ETV Protocols largely validated

    • Some Improvements Req’d

    • Severn-Trent system used in validation

    • Test Report in Review

Step shipboard technology evaluation program

STEPShipboard Technology Evaluation Program

  • Intended to facilitate development of effective BW treatment options

  • Available to all vessels, foreign and domestic, subject to USCG regulations (33 CFR 151 Subparts C & D)

  • Currently reviewing 4 applications

    • Significant delays in CG ability to process first 3 applications.

    • Environmental Assessments (EAs) will be released soon for first 3 applications.

  • Currently assessing options to streamline and expand program

    • 3rd party review of applications and preparation of EAs?

      • Applicant expense

      • Applicant schedule

    • Multiple vessels per application?

      • Increased complexity for EAs…

      • Distribution of test effort among vessels…

Ballast water management convention of 2004

Ballast Water Management Convention of 2004

Key provisions for U.S.:

  • Phase out of BW Exchange

  • BW discharge standard

    • More protective than BWE, but not as stringent as many in U.S. want

    • Challenges to technology:

      • meet the standard

      • wide availability on the desired schedule

  • Parties may implement more stringent measures

  • Parties may test discharges to confirm compliance with the discharge standard

Ballast water management convention

Ballast Water Management Convention

  • Entry into force: 12 months after ratification by 30 member states representing 35% of the world’s merchant shipping tonnage

    • To date: Ratified by 10 states representing 3.42% of shipping tonnage

Guidelines supporting the convention

Guidelines supporting the Convention

  • Status

    • 14 of 15 sets of guidelines adopted

    • 1 remaining Guideline to be developed further at BLG 12 (Feb 08)

      • Sampling (G2)

      • Divergence of Opinion

        • Some Administrations and ship owners-

          • Specify details of sample acquisition, analysis, and interpretation

          • Average of samples to be below standard

        • U.S. – How to get a sample

          • Analysis and interpretation left to Administration

          • No averaging required

Ballast water treatment system approvals

Ballast Water Treatment System Approvals

IMO Active Substance approvals under G9

  • Paraclean Ocean System, proposed by Germany;

  • Electro Clean System, proposed by the Republic of Korea;

  • Special Pipe Ballast Water Management System combined with ozone treatment, proposed by Japan;

  • EctoSys. electrochemical System, proposed by Sweden;

  • NK Ballast Water Treatment System, proposed by the Republic of Korea; and

  • PureBallast System, proposed by Norway and Sweden, which was also given Final Approval.

    • Type approval pends successful shipboard tests

      Administration Type approvals under G8

  • NEI – VOS deoxygenation system by Liberia

Recent and upcoming meetings

Recent and Upcoming Meetings

  • Assembly (November 19-30, 2007)

    • Major BW decision

      • Resolution - Ships subject to Reg B-3.3 constructed in 2009 not required to meet Regulation D-2 until 2nd annual survey,, but no later than 31 December, 2011.

      • Due to lack of “available” treatment systems; build contracts already in place.

  • BLG 12 (February 4 - 8, 2007)

    • Sampling Guideline (G2)

    • Alignment of G8 and G9

    • G9 (Approval of BWT systems using AS)

      • Human Exposure Scenario

      • Criteria to evaluate systems using same substance (me too)

      • GESAMP Methodology

      • Procedure for assessing “same level of protection” when evaluating “other methods of BW management” under Regulation B-3.7

  • MEPC 57 (March 31 – April 4)

    • Review Group – availability of BWT technology

    • Applications for approval under G9 (7+)

    • Outcome of BLG 12

Biofouling at imo

Biofouling at IMO

  • Biofouling management proposed as a new work item for MEPC

  • Australia, New Zealand, United Kingdom proposal

  • MEPC 56 agreed to proposal in July 2007.

  • First phase will be a scoping effort to determine the best approach for IMO to take

    • New convention

    • Amend an existing convention

      • Ballast Water

      • Antifouling

    • Guidelines

Next steps

Next Steps

  • Publish and implement the BWD Standard Regulation to include BWTS test protocols and BWTS approval process

  • Continue and refine STEP

  • Continue to engage actively at IMO

    • Refine guidelines

    • Address biofouling

    • Exchange information on testing and approvals of technologies

  • Update existing BWM Reporting and Recordkeeping Regulations and NOBOB requirements

  • Develop improved methods and technologies for assessing compliance with BWD Standard

Uscg ballast water update

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