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U.S. Ballast Water Regulations

U.S. Ballast Water Regulations. U.S . Coast Guard Headquarters Office of Operating and Environmental Standards. U.S. and IMO Milestones. 1988: Zebra mussels discovered in Great Lakes

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U.S. Ballast Water Regulations

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  1. U.S. Ballast Water Regulations U.S. Coast Guard Headquarters Office of Operating and Environmental Standards

  2. U.S. and IMO Milestones 1988: Zebra mussels discovered in Great Lakes 1990/96: Non-indigenous Aquatic Nuisance Prevention and Control Act, as amended by National Invasive Species Act (NISA) 1990’s: Coast Guard mandated BW exchange in Great Lakes and voluntary trial national-wide, IMO issued BWM guidelines 2004: Coast Guard mandates BW exchange in all waters of the U.S., IMO adopts Convention

  3. U.S. and IMO Milestones 2009: EPA publishes 1st Vessel General Permit, Coast Guard proposes BW discharge standard 2012: Coast Guard issues final rule, and partners with Independent Labs to evaluate BWMS 2013: EPA publishes 2nd Vessel General Permit 2016: Coast Guard type-approves three BWMS, IMO Convention ratified by enough countries (U.S. has not ratified) 2017: Coast Guard tightens compliance options, prepares for Convention to enter into force

  4. Complex Problem Biology Engineering Vessel operations

  5. Actually really complex Biology of organisms and habitat Naval architecture Mechanical/electrical Engineering Global vessel operations

  6. Actually really, really complex Invasion biology Naval engineering Fleet operations and management Compliance strategies Port operations and facilities Installation requirements Volume/frequency of discharge Regulations leading technology Cost

  7. USCG BWMS Program Overview Coast Guard Offices Involved BWM Regulations (and who regulates) Compliance Options for Ship Owners Coast Guard Type Approval & Independent Labs Alternate Management Systems (AMS) Extensions Compliance and Enforcement Next steps

  8. USCG Program Offices • Office of Operating & Environmental Standards • Regulation & policy program manager • Office of Design & Engineering Standards • 3rd Party Independent Lab manager • Marine Safety Center • Type approval manager • Office of Commercial Vessel Compliance • Compliance manager

  9. IMO BWM Convention Adopted in 2004 14 guidelines for BWMS development, testing Received enough ratifications by member States in 2016, entry into force o.o.a September 8, 2017 BWM Convention will not preempt Coast Guard, EPA, or U.S. state requirements Coast Guard offers Statement of Voluntary Compliance to U.S.-flagged vessels visiting foreign ports

  10. EPA Requirements EPA authority to regulate ballast water, among 27 discharges, incidental to vessel operations comes from Clean Water Act rather than NISA Current VGP has same BW discharge standard metrics as Coast Guard, but still independent U.S. states may add on requirements for their jurisdictions by section 401 certification letters Vessel General Permit is renewed every 5 years 3rd VGP comes into force December 18, 2018

  11. Applicability/Requirements

  12. Options for Compliance 2. Coast Guard Approved Ballast Water Management System Two Temporary Compliance Alternatives 1. No BW Discharge 1. Alternate Management System (AMS) – Temporary Designation for up to 5 years 3. Discharge to Facility Onshore or to Another Vessel for Purpose of Treatment 2. Receive an Extension toVessel’s Compliance Date - extension period will vary depending upon TA system availability 4. Use only water from a U.S. Public Water System

  13. Temporary Compliance: Alternate Management Systems A BWMS is accepted for use as an AMS based on its type approval by a foreign administration. AMS may be used for 5 years after expiry of the vessel’s extendedcompliance date

  14. Options for Compliance 2. Coast Guard Approved Ballast Water Management System Two Temporary Compliance Alternatives 1. No BW Discharge 1. Alternate Management System (AMS) – Temporary Designation for up to 5 years 3. Discharge to Facility Onshore or to Another Vessel for Purpose of Treatment 2. Receive an Extension toVessel’s Compliance Date - extension period will vary depending upon TA system availability 4. Use only water from a U.S. Public Water System

  15. Temporary Compliance: Extensions • The regulation allows the CG to grant compliance date extensions on a temporary basis. • Vessel owners/operators must apply at least 12 months prior to the vessel’s compliance date, or the extension request may be denied. • Failure to plan ahead may result in ship delays or lapse in eligibility to trade in U.S. waters.

  16. Options for Compliance 2. Coast Guard Approved Ballast Water Management System Two Temporary Compliance Alternatives 1. No BW Discharge 1. Alternate Management System (AMS) – Temporary Designation for up to 5 years 3. Discharge to Facility Onshore or to Another Vessel for Purpose of Treatment 2. Receive an Extension toVessel’s Compliance Date - extension period will vary depending upon TA system availability 4. Use only water from a U.S. Public Water System

  17. Type Approval Review Process Six-step application review process: Application screening Engineering review Land-based test review Shipboard test review Component test review Scaling review

  18. How Type Approval Works Two options to follow (in accordance with 46 CFR): 1. Evaluation of some/all existing test data and information from type approval testing for a foreign administration. • Applicant must include: • Data and information; • Explanation of how submission meets or exceeds Coast Guard type approval requirements. • Data and information must be reviewed by independent laboratory (IL). • Additional testing and evaluation by an IL may be required. 2. Evaluation of test data and information produced and submitted by an IL.

  19. Independent Lab Program USCG is working with ILs to ensure quality results, including regular teleconferences to discuss technical issues, certification reviews, and laboratory oversight. The IL program focuses on: Consistency in testing Best practices Lessons learned

  20. Accepted Independent Labs NSF International (Ann Arbor, MI) Det Norske Veritas-Germanischer Lloyd (DNV-GL; Norway) Korean Register of Shipping (ROK) Control Union Certifications (Netherlands) Lloyd’s Register EMEA (UK) Coast Guard is in contact with other test organizations interested in acceptance as IL for BWMS testing.

  21. Type Approval Process USCG v IMO • Discharge standards are similar but not exactly the same - Viable (IMO) v. Living (USCG) organisms • Differences between IMO and U.S. type approval testing (G8 revised in 2016, still non-mandatory) • Varying Flag Administration interpretations • Shipboard testing cycles (IMO: 3, USCG: 5) • O&M endurance test (IMO: No, USCG: Yes) • Many challenges remain: system scaling, and acceptance of alternate components

  22. Type Approval • IMO G8 –v– US Type Approval • Similarities • Administrative Differences • Technical Differences

  23. Type Approval Similarities • Readiness evaluation • Land-based testing • Shipboard testing • Environmental/ Component testing • Treatment system scaling

  24. Administrative Differences • Flag Administrations interpret IMO guidelines • USCG uses third-party Independent Labs (IL)

  25. Technical Differences 1. Discharge Standard 2. Shipboard Testing 3. Hold Time 4. Component / Environmental Testing

  26. 1. Discharge Standard Difference • Consideration of organisms that are rendered unable to reproduce Independent Lab Observation • Some systems able to meet viable standard but not living standard

  27. 2. Shipboard Testing Differences • Varying number of required consecutive successful test cycles • Control of treatment system during testing Independent Lab Observation • Some systems able to log 3 tests but fail on 4th or 5th cycle

  28. 3. Hold Time Difference • Time required to hold water in tanks before discharge & sampling Independent Lab Observation • Extended test program for systems where hold time is key parameter

  29. 4. Component/Environmental Testing Difference • Length of time required for vibration endurance test Independent Lab Observation • Some components able to meet 2 hour test but fail 4 hour test

  30. Summary of Technical Differences

  31. Compliance and Enforcement • Assess compliance during regular vessel inspections • BWM exams on foreign vessels: 9,300/year • Follow existing compliance approach • Documentation and crew knowledge • Equipment condition and operation • Sample discharge, if warranted • USCG R&D - Sampling and analysis method and tools in development

  32. Resources • Coast Guard Internet portal: http://homeport.uscg.mil/ballastwater • Approved Labs and BWMS: • Coast Guard Maritime Information Exchange (CGMIX): http://cgmix.uscg.mil • QUESTIONS? • Compliance: E-mail to the Office of Commercial Vessel Compliance: CGCVC@uscg.mil • Extensions: environmental_standards@uscg.mil

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