United States Environmental Protection Agency
Office of Wastewater Management
Washington, DC 20460
Ballast Water Self Monitoring
EPA 800-R-11-003
November 2011
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Ballast Water Discharges from Vessels Contents
Contents
Page
1 INTRODUCTION 1
1.1 What is Ballast Water? 1
1.2 Environmental Impacts of Ballast Water Discharges 2
1.3 Current Ballast Water Discharge Regulations 3
2 BALLAST WATER TREATMENT TECHNOLOGIES 7
3 BALLAST WATER COMPLIANCE MONITORING 11
3.1 Physical-Chemical Indicators of Treatment Performance 11
3.2 Biological Indicators of Exceedances 17
3.3 Effluent Monitoring for Residual Biocides 18
3.4 Effluent Monitoring for Biocide Derivatives 22
3.5 Ballast Water Sampling Methods 22
4 BALLAST WATER TREATMENT MONITORING COSTS 23
5 REFERENCES 26
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Ballast Water Discharges from Vessels List of Tables
LIST OF TABLES
Page
1 Select Ballast Water Discharge Standards for Organisms 4
2 Anticipated Ballast Water Treatment System Sensors and Measurement
Equipment for Physical/Chemical Indicator Monitoring 12
3 List of Possible Treatment Performance Measures and Analytical Methods for
Biological Indicator Compliance Monitoring 17
4 Possible Biological Indicator Compliance Monitoring Analytical Methods and
Effluent Limits 20
5 Residual Biocides Compliance Monitoring Sampling Analytical Methods and
Possible Action Levels 21
6 Biocide Derivative Monitoring Analytical Methods 22
7 Estimated Capital Cost for Vessels Needing Additional Ballast Water Treatment
System Monitoring Equipment 23
8 Estimated Labor and Analytical Costs for Ballast Water Treatment System
Discharge Sampling 24
LIST OF FIGURES
Page
1 Generic Ballast Water Treatment Technology Options 7
The EPA technical contact for this document is Ryan Albert (202) 564-0763.
ii
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Ballast Water Discharges from Vessels Section 1 - Introduction
SECTION 1
INTRODUCTION
The 2008 Vessel General Permit (VGP) regulates discharges incidental to the normal
operation of vessels operating as a means of transportation. The VGP, like other general permits,
is issued by the permitting authority (in this case, EPA) and covers multiple facilities within a
specific category for a specific period of time (not to exceed 5 years). The 2008 VGP includes
the following limits or requirements: general effluent limits; technology-based effluent limits
applicable to 26 specific discharge streams; narrative water-quality based effluent limits;
inspection, monitoring, recordkeeping, and reporting requirements; and additional requirements
applicable to certain vessel types (USEPA, 201 Ob).
Because EPA plans to reissue the VGP, the Agency continues gathering information on
vessel wastewater sources while examining treatment technologies that can be used before
discharge into waters of the United States.1 This document contains updated information on both
recent developments in ballast water treatment technologies and the monitoring requirements to
verify ballast water treatment systems are functioning properly.
1.1 WHAT is BALLAST WATER?
Ballast water is fresh or saltwater held in the ballast tanks and cargo holds of ships. It is
used to provide stability and maneuverability during a voyage when ships are not carrying cargo,
not carrying heavy enough cargo, or when more stability is required due to rough seas. Ballast
water may also be used to add weight so that a ship sinks low enough in the water to pass under
bridges and other structures. Ballast water is taken from port areas and transported with the ship
to the next port of call where the water may be discharged. If a ship is receiving or delivering
cargo to a number of ports, it may release or take on a portion of ballast water at each port. In
such cases, the ships ballast water contains a mix of waters from multiple ports (MIT, 2002).
Large commercial vessels (e.g., container ships, bulk carriers, other cargo vessels,
tankers, and passenger vessels) normally have ballast tanks dedicated to this purpose, and some
vessels may also ballast empty cargo holds. The discharge volume varies by vessel type, ballast
tank capacity, and type of deballasting equipment. Volumes of ballast water discharged are
significant and can be several hundred or thousand cubic meters of water. For instance,
passenger vessels have an average ballast capacity of about 2,600 cubic meters (about 686,850
gallons) while ultra large crude carriers (ULCCs) have an average ballast capacity of about
93,000 cubic meters (about 24,568,000 gallons) (USEPA, 2008). A modern tanker ship working
on the Great Lakes can contain as much as 53,000 cubic meters (14,000,000 gallons) (USEPA,
2001). Its estimated that tank vessels like ULCCs account for approximately 40 percent of all
ballast water discharged, followed by bulk carriers and container ships. Passenger vessels
account for only about 1 percent of ballast water discharges (Faulkner, 2009).
"Waters of the United States" as defined in 40 CFR 122.2.
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Ballast Water Discharges from Vessels Section 1 - Introduction
1.2 ENVIRONMENTAL IMPACTS OF BALLAST WATER DISCHARGES
Ballast water discharges have been cited as one of the primary sources or vectors for the
spread of aquatic nuisance species (ANS) (Carlton et al., 1995). The transfer of alien water
species in ships ballast tanks at modern rates, scales and shipping routes facilitates very fast and
practically global distribution of some species (Kasyan, 2010). Depending on where ships take
on ballast water, virtually all organisms in the water column, either swimming or stirred up from
bottom sediments, can be taken into ships' ballast tanks. These organisms include holoplakton
(free-floating), meroplakton (larval stages of bottom dwelling organisms), upper water column
nekton (active swimming), and demersal (near bottom dwelling nekton) organisms (California
EPA, 2002). Well known examples of ANS or pathogens that have been introduced to U.S.
waters include Hydrilla, European Loosestrife, Eurasian water milfoil, melaluca, salt cedar, and
Viral Hemorrhagic Septicemia (VHS).
One of the best known examples of ANS is the zebra mussel (Dreissena polymorpha\
which was introduced from the Black Sea to the Great Lakes in the mid-1980s and was
discovered in California in 2008. This tiny striped mussel attaches to hard surfaces in dense
populations that clog municipal water systems and electric generating plants, causing
approximately $1 billion a year in damage and control for the Great Lakes alone (California
State Lands Commission, 2010). In San Francisco Bay, the overbite clam (Corbula amuremis) is
believed to be a major contributor to the decline of several pelagic fish species in the
Sacramento-San Joaquin River Delta by reducing the plankton food base of the ecosystem
(California State Lands Commission, 2010). Because of the global shipping network, it is
possible that new ANS could arrive from virtually any port world-wide (Keller and Drake,
2011).
ANS can enter new aquatic environments when the vessel operator discharges ballast
tanks. These organisms may also be released when vessel operators load ballast water into ballast
tanks with residual water or sediment, mix the new ballast water with these residuals, and then
later discharge this ballast water. On any given day, approximately 7,000 individual species may
be "in motion" in ballast tanks (Carlton, 2001). There is no evidence that ship age, seasonal
timing, or age of ballast water affects the abundance of individuals or species in the ballast tanks
(Drake and Lodge, 2007).
When ANS in ballast tanks are transported between water bodies and discharged, they
have the potential for establishing new, non-indigenous populations that have the potential to
cause physical and behavioral disturbances to native organisms, out competing them for food,
space and other valuable resources (Hayes and Landis, 2004). Although pelagic marine systems
appear to be least susceptible to invasion by ANS, mixed island systems and lake, river and near-
shore marine systems are especially vulnerable (Deines et al., 2005 and Perings, 2002).
Potentially, this can cause severe economic and ecological damage (Lodge and Finnoff, 2008
and Lovell and Drake, 2009). Associated damages and costs of controlling aquatic invaders in
the United States are estimated to be $9 billion annually (Pennsylvania Sea Grant, 2003). The
spread of ANS can be mitigated if either their introduction to the receiving water is prevented, or
if the ANS cannot establish a population.
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Ballast Water Discharges from Vessels Section 1 - Introduction
1.3 CURRENT BALLAST WATER DISCHARGE REGULATIONS
A thorough evaluation of the availability of ballast water treatment technologies requires
an understanding of the regulatory framework associated with the development and
implementation of performance standards for the discharge of ballast water, including knowledge
of mechanisms for the testing and evaluation of treatment systems to meet those standards. This
section summarizes the ballast water regulations currently in effect. A more robust regulatory
analysis of the current ballast water regulations is available in the Science Advisory Board's
Background and Issue Paper on the Availability and Efficacy of Ballast Water Treatment
Technologies (Albert et al., 2010).
At the international level, ballast water discharges from vessels are primarily addressed
under provisions established through the auspices of the International Maritime Organization
(IMO). 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 (BWE) and other ballast water
management practices.
Following adoption of the resolution, a ballast water working group was 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 these meetings, there was a gradual evolution away from
reliance on BWE as the primary control mechanism to one requiring compliance with ballast
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
IMO, which adopted the International Convention for the Control and Management of Ships'
Ballast Water and Sediments in February 2004. Among its provisions, the Convention contains
performance standards for the discharge of ballast water (Regulation D-2) with an associated
implementation schedule based on vessel ballast water capacity and date of construction (see
Table 1). During development of the 2004 Convention, the U.S. took a negotiating position that
the discharge standards for the two larger size groupings of organisms in the D-2 regulation
should be 1,000 times more stringent than adopted (see Table 1). As of November 30, 2011, the
2004 Convention is not in force, nor is the U.S. a party.
At the federal level, there are two principal 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 VGP requirements that implement the Clean
Water Act presently rely on use of BWE. However, since ballast water 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 concentrations of living
organisms per unit of volume of ballast water discharged. The USCG issued proposed
regulations in August, 2009 containing such standards, and these USCG proposed Phase I and
Phase II standards are shown in Table 1.
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Ballast Water Discharges from Vessels
Section 1 - Introduction
Both NANPCA and the CWA preserve state authority to more stringently regulate ballast
water discharges that occur in state waters. At the state level, regulation of ballast water
discharges varies, as shown in Table 1.
Table 1. Select Ballast Water Discharge Standards for Organisms
Regulation
IMOBW
TREATY (Reg.
D-2)
US
NEGOTIATING
POSITION
USCG
PROPOSED
RULE (74 FR
44632)
California
(VGP 401
cert)
Organism
Size: > 50
(um)*
<10
"viable"
organisms
perm3
<0.01
"living"
organisms
perm
Organism
Size: <
50um, but
> 10 jim
<10
"viable"
organisms
per ml
<0.01
"living"
organisms
per ml
Bacteria
Vibrio cholera < 1 CPU
per 100 ml;
E. coli < 250 CPU per
100 ml; Intestinal
enterococci < 100 CPU
per 100 ml
Vibrio cholera < 1 CPU
per 100 ml;
E. coli < 126 CPU per
100 ml; Intestinal
enterococci < 33 CPU
per 100 ml
Viruses
—
—
Lakers
Covered?**
N/A
N/A
Compliance Date
2009 -20 19 (varies
by vessel
construction date/BW
capacity /survey date
as per Reg B-3)
ASAP
PHASE 1 STANDARD
<10
organisms
perm3
<10
organisms
per ml
Vibrio cholera < 1 CPU
per 100 ml;
E. coli < 250 CPU per
100 ml; Intestinal
enterococci < 100 CPU
per 100ml
—
Yes
Vessels constructed
on or after 01/01/12
on delivery; All other
vessels varies by BW
capacity & drydock
cycle with latest
compliance date of
1 st drydock after
01/01/16
PHASE 2 STANDARD
< 1 organism
per 100 m3
< 1 organism
per 100 ml
Vibrio cholera < 1 CPU
per 100 ml;
E. coli < 126 CPU per
100 ml; Intestinal
enterococci < 33 CPU
per 100 ml
< 103 "living" bacterial
cells per 100 ml
<104
viruses
or viral-
like
particles
per 100
ml
Yes
Vessels constructed
on or after 01/01/16
on delivery; All other
vessels 1st
dry docking after
01/01/2016, unless
prior installation of
Phase 1 BW system,
in which case 5 years
from such installation
INTERIM STANDARD
0 detectable
"living"
organisms
US
negotiating
position
Vibrio cholera IMO Reg
D-2; E. coli US
negotiating position;
Intestinal enterococci US
negotiating position <
10 bacteria per 100 ml
<104
viruses
per 100
ml
N/A
01/01/10-01/01/16
(varies by vessel
construction date/BW
capacity)
FINAL STANDARD
0 detectable
"living"
organisms
0 detectable
"living"
organisms
0 detectable "living"
organisms
0
detectable
"living"
organisms
N/A
01/01/2020
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Ballast Water Discharges from Vessels
Section 1 - Introduction
Table 1. Select Ballast Water Discharge Standards for Organisms
Regulation
Illinois
(VGP 401
cert)
Indiana
(VGP 401
cert)
Michigan
(VGP 401
cert)
Minnesota
(VGP 401
cert)
New York
(VGP 401
cert)
Ohio
(VGP 401
cert)
Organism
Size: > 50
(M™)*
IMO Reg D-
2 (as daily
average)
IMO Reg D-
2b (as daily
average)
Use a
treatment
process
approved by
MDEQ
IMO Reg D-
2b (as daily
average)
Organism
Size: <
50um, but
> 10 jim
IMO Reg D-
2 (as daily
average)
IMO Reg D-
2b (as daily
average)
Use a
treatment
process
approved by
MIDEQ
IMO Reg D-
2b (as daily
average)
Bacteria
Vibrio cholera;" E. coli
IMO Reg D-2 (as daily
average); Intestinal
enterococci IMO Reg D-
2 (as daily average)
Vibrio cholera11',
E. coli IMO Reg D-2 (as
daily average); Intestinal
enterococci IMO Reg D-
2 (as daily average)
Use a treatment process
approved by MI DEQ
Vibrio cholera11', E. coli
IMO Reg D-2 (as daily
average); Intestinal
enterococci IMO Reg D-
2 (as daily average)
Viruses
—
—
Use a
treatment
process
approved
by MI
DEQ
—
Lakers
Covered?**
Yes
No
No
Yes
Compliance Date
Vessels constructed
before 01/01/12
01/01/16; Vessels
constructed after
01/01/1 2 prior to
operation
Vessels constructed
before 01/01/12
01/01/16; Vessels
constructed after
01/01/1 2 prior to
operation
01/01/07
Vessels sonstructed
before 01/01/12
01/01/16; Vessels
constructed after
01/01/1 2 prior to
operation
INTERIM STANDARD
< 1 "living"
organism per
10m3
< 1 "living"
organism per
10ml
Vibrio cholera IMO Reg
D-2;
E. coli US negotiating
position; Intestinal
enterococci US
negotiating position
—
Yes
(vessels
operating
exclusively
within Lakes
Ontario and
Erie are
exempt)
01/0 1/1 2 (extended to
August 1,2013 in
subsequent state
action)
FINAL STANDARD
Same as CA
#s
IMO Reg D-
2b (as daily
average)
US
negotiating
position
IMO Reg D-
2b (as daily
average)
Vibrio cholera IMO Reg
D-2;
E. coli US negotiating
position; Intestinal
enterococci US
negotiating position;
Other bacteria CA
interim standard
Vibrio cholera11', E. coli
IMO Reg D-2 (as daily
average); Intestinal
enterococci IMO Reg D-
2 (as daily average)
Same as
CA
interim
#s
—
Yes (vessels
operating
exclusively
within Lakes
Ontario and
Erie are
exempt)
Yes (in part —
see column to
right)
Vessels constructed
on or after 01/0 1/1 3
(extended to August
1, 2013 in subsequent
State action)
Lakers "launched"
after 01/0 1/1 6
immediate; Non-
Lakers "launched"
before 01/01/12
01/01/16; Non-
Lakers "launched"
after 01/01/12 prior
to operation
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Ballast Water Discharges from Vessels
Section 1 - Introduction
Table 1. Select Ballast Water Discharge Standards for Organisms
Regulation
Wisconsin
(11/18/09
State Permit)
Organism
Size: > 50
(M™)*
IMO Reg D-
2 (as daily
average)
Organism
Size: <
50um, but
> 10 jim
IMO Reg D-
2 (as daily
average)
Bacteria
Vibrio cholera3',
E. coli IMO Reg D-2 (as
daily average); Intestinal
enterococci IMO Reg D-
2 (as daily average)
Viruses
Lakers
Covered?**
Noc
Compliance Date
Vessels constructed
after 01/0 1/1 2d
'mmediate; Vessels
constructed before
01/01/12d 01/01/14
Source: Modified from Albert et al., 2010.
* For some standards, groupings are stated as organisms > 50 |im and organisms < 50 |im but > 10 |im. For sake of simplicity,
this table uses the IMO groupings throughout as the default column header.
** "Lakers" are vessels which generally voyage exclusively in the Great Lakes.
a Indicator microbes specified by State do not include Vibrio cholera.
b State has defined "viable" as living and able to reproduce. In contrast, IMO G8 (type approval) Guidelines (para 3.12) 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 2008 VGP (uptake and discharge practices).
d WI DNR conducted a review to determine if BWT technology was available to meet WI standards more stringent than those
finalized in 2009; that review concluded such BWT technology was not available and therefore, Wisconsin instead determined
that the IMO Reg D-2 standards applied (subject to footnotes a & b).
ASAP - As soon as possible.
BW - Ballast water.
CA - California.
N/A - Not applicable.
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Ballast Water Discharges from Vessels
Section 2 - Ballast Water Treatment Technologies
SECTION 2
BALLAST WATER TREATMENT TECHNOLOGIES
Two general platform types have been explored for the development of ballast water
treatment technologies. Shore-side ballast water treatment would occur at a barge- or land-based
facility following transfer from a vessel; to date, such shore side treatment facilities for ANS in
ships' ballast water do not exist at U.S. ports. Shipboard treatment occurs onboard vessels
through the use of technologies that are integrated into the ballasting system; a number of such
systems have been developed or are in development. The remaining discussions in this
document address such shipboard treatment systems.
To be effective, ballast water treatment systems must operate under a wide range of
challenging environmental conditions, including variable temperature, salinity, nutrients and
suspended solids. They must also function under difficult operational constraints, including high
flow-rates of ballast water pumps, large water volumes, and variable retention times (time ballast
water is held in tanks). Treatment systems should be capable of eradicating a wide variety of
organisms ranging from viruses and microscopic bacteria, to free-swimming plankton, and must
operate so as to minimize or prevent impairment of the water quality conditions of the receiving
waters. The development of effective treatment systems is further complicated by the variability
of vessel types, shipping routes and port geography (California State Lands Commission, 2010).
Most vessel owner/operators treating ballast water have indicated that they will select
shipboard ballast water treatment systems. Treatment systems generally include physical
separation, biocidal treatment, and physical-chemical processes (Albert et al., 2010). Most
commercial systems comprise two stages of treatment with a physical solids-liquid separation
followed by biocidal disinfection as shown in Figure 1 (Lloyds Register, 2010).
Physical
solid-liquid
separation
Treatment:
» Hydrocyclone
• Surface
filtration
|
Chemical
enhancement:
• Coagulation/
Flocculation
Disinfection
Chemical treatment:
• Chlorination
• Electrochlorination
or electrolysis
* Ozonation
• Peracetic acid
• SeaKleen
• Chlorine dioxide
Physical
• UV irradiation
• UV + Ti02
• Deoxygenation
* Gas injection
• Ultrasonic
treatment
• Captation
h
Residual control:
• Chemical reduction
-»- (sulphitefeulphite)
Physica I
enhancement:
• Ultrasonic
b treatment
Captation
I
Source: Lloyds Register, 2010.
Figure 1. Generic Ballast Water Treatment Technology Options
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Ballast Water Discharges from Vessels Section 2 - Ballast Water Treatment Technologies
Different treatment processes are more effective for certain types or size classes of
organisms. Larger size classes of organisms typically require a filtration system or other physical
process to limit their intake into the ships ballast tanks; however, smaller size classes of living
organisms typically require additional chemical, physical or heat treatment to kill organisms that
bypass the filtration system (Prince William Sound Regional Advisory Council, 2005).
The filtration processes used in ballast water treatment systems are generally of the
automatic backwashing type using either discs or fixed screens. Removal of larger organisms
such as plankton by filtration requires a filter of equivalent mesh size between 10 and 50 jim.
Such filters are the most widely used solid-liquid separation process employed in ballast water
treatment, and their effective operation relates mainly to the flow capacity attained at a given
operating pressure. Maintaining the flow normally requires that the filter is regularly cleaned,
and it is the balance between flow, operating pressure and cleaning frequency that determines the
efficacy of the filtration process. In principle, surface filtration (membrane filtration) can remove
sub micron (i.e., less than Ijim in size) micro-organisms; however, such processes are not viable
for ballast water treatment due to the relatively low permeability of the membrane material
(Lloyds Register, 2010).
Hydrocyclone technology is used as an alternative to filtration. This technology provides
enhanced sedimentation by injecting the water at high velocity to impart a rotational motion
which creates a centrifugal force, increasing the velocity of particles relative to the water,
allowing them to be separated and removed. The effectiveness of the separation depends upon
the difference in density of the particle and the surrounding water, the particle size, the speed of
rotation and residence time.
A number of different chemical biocides or chemical processes have been employed in
the ballast water treatment systems for disinfection including:
• Chlorination
• Electrochlorination
• Ozonation
• Chlorine dioxide
• Peracetic acid
• Hydrogen peroxide
• Menadione/Vitamin K
The efficacy of these processes varies by water conditions such as pH, temperature and,
most significantly, the type of organism. While relatively inexpensive, chlorine is a highly
effective disinfectant for most organisms, but is virtually ineffective against cysts unless
concentrations of at least 2 mg/1 are used (Lloyds Register, 2010). Chlorine also reacts to form
undesirable chlorinated byproducts, particularly chlorinated hydrocarbons and trihalomethanes.
Ozone yields far fewer harmful byproducts, the most prominent being bromate, but requires
relatively complex equipment to both produce ozone and dissolve it into the water. Chlorine
dioxide is normally produced in situ, although this presents a challenge since the reagents used
are themselves chemically hazardous. Peracetic acid and hydrogen peroxide (provided as a blend
of the two chemicals in the form of the proprietary product Peraclean®) are infinitely soluble in
water, produce few harmful byproducts and are relatively stable. However Peraclean® is
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Ballast Water Discharges from Vessels Section 2 - Ballast Water Treatment Technologies
relatively expensive, is dosed at quite high levels, has been documented to have unacceptable
toxicity in cold waters, and requires considerable storage facilities.
For all these chemicals, pre-treatment of the water using solid-liquid separation (i.e.,
filtration or hydrocyclones) is desirable to reduce the 'demand' on the disinfectant, because the
chemical can also react with organic and other materials in the ballast water. In addition, while
chemical biocides may be effective for disinfection of organisms in the water column, they may
be relatively ineffective in disinfecting species buried in sediment in ballast tanks, especially
invertebrates in resting stages (Raikow and Reid, 2006). Vessel owners/operators should consult
with technology vendors to ensure the selected system is appropriate for the vessel of interest
under normal ballasting conditions (Dobroski et al., 2009).
According to EPA's Science Advisory Board (USEPA, 201 la), five ballast water
management system types (listed below) have been demonstrated to meet the IMO D-2 discharge
standard, when tested under the International Maritime Organization G8 guidelines (IMO, 2008),
and will likely meet USCG Phase 1 standards, if tested under EPA's more detailed
Environmental Technology Verification (ETV) Protocol (USEPA, 2010a).2 No current ballast
water treatment technologies are demonstrated to meet standards more stringent than IMO D-
2/Phase 1 (USEPA, 2011 a).
• Deoxygenation + cavitation;
• Filtration + chlorine dioxide;
• Filtration + UV;
• Filtration + UV + TiO2; and
• Filtration + electro-chlorination.
Deoxygenation is a physical-chemical process that kills organisms by creating severe
hypoxia (through lowered pressure via venturi or vacuum, or lowered partial pressure via gas
sparging with inert gasses). Cavitation is a physical-chemical process that kills organisms by the
high pressure, shear forces, and shock waves generated by the collapse of vapor bubbles induced
into the ballast water. Filtration describes a variety of physical separation processes, including
screening to remove sediment and larger organisms resistant to disinfection, reduction of organic
matter to reduce oxidant demand, and reduction of turbidity to increase transmittance of UV
radiation. Chlorine dioxide and electro-chlorination are biocidal technologies that disinfect
ballast water using the chemical disinfectants chlorine dioxide and chlorine; chlorine is generated
by electrolytic processes using sea water as the source of ions. UV is a physical-chemical process
that disinfects ballast water using photochemical reactions generated by ultraviolet light
radiation. In the UV + TiO2 physical-chemical process, UV light also activates the surface of the
titanium catalytic semiconductor, disinfecting ballast water using both photochemical and
photocatalytic reactions (USEPA, 201 la).
Of the 15 individual ballast water treatment systems for which information was provided, the Panel concluded that
nine ballast water treatment systems had reliable data for an assessment of performance and that five categories of
ballast water treatment systems had been evaluated with sufficient rigor to permit a credible assessment of
performance capabilities. (Source: USEPA, Science Advisory Board (SAB), Ecological Processes and Effects
Committee, Efficacy of Ballast Water Treatment Systems, June 2011). This list does not exclude other technologies
that may provide similar treatment results but were not evaluated by the panel due to lack of available data.
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Ballast Water Discharges from Vessels Section 2 - Ballast Water Treatment Technologies
While ballast water treatment technologies reduce the probability of invasion of ANS,
such treatment may introduce other water quality impacts, such as toxicity. For example, the
addition or in-process generation of disinfecting chemicals may result in an effluent with some
residual toxicity. Depending on the predicted or measured oxidant levels in the ballast water, a
chemical neutralizing agent may need to be applied before ballast water discharge to comply
with effluent limitations (USEPA, 201 la).
10
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Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring
SECTION 3
BALLAST WATER COMPLIANCE MONITORING
Ballast water treatment systems are designed to reduce the number of living organisms
discharged in ballast water. Such reductions in these organisms will help reduce the risk of ANS
establishing viable populations in new water bodies. To ensure the treatment systems are being
operated properly once installed on a vessel, samples of ballast water effluent can be collected
and analyzed, and specific treatment system operating parameters can be monitored, to indirectly
verify the treatment system is achieving the intended effluent levels on an ongoing basis.
Measures of treatment performance for ballast water systems can include a variety of
techniques ranging from collection of ballast water effluent samples for analysis of target
organisms to monitoring operational parameters for the treatment technologies to verify they are
within predetermined limits. Monitoring systems may also include features that provide
automated operation and alarms, plus reporting and data logging to ensure treatment systems are
continuously operating according to the manufacturer's specifications (Hurley et al., 2001). The
three categories of compliance monitoring are:
• Physical/chemical indicators of treatment performance;
• Biological indicators of exceedances; and
• Effluent monitoring for residual biocides and biocide derivatives.
3.1 PHYSICAL-CHEMICAL INDICATORS OF TREATMENT PERFORMANCE
Physical/chemical indicators of treatment performance can be used to verify that the
ballast water treatment system is operating according to the manufacturers' requirements. Most
ballast water treatment systems have control and self diagnostic equipment such as sensors that
continuously measure treatment parameters to verify performance (Tamburri, 2011). Sensors
commonly incorporated into the most frequently installed systems include flow meters, pH
sensors, dissolved oxygen sensors, OPR and amperometric (TRO) sensors, and on-line chlorine
analyzers (Tamburri, 2011). All of these meters and sensors have broad application in the water
and wastewater treatment industry and are available off-the-shelf from many major equipment
suppliers. Other ballast water treatment systems are provided with testing meters or kits, such as
portable chlorine and dissolved ozone monitors, to verify adequate levels of treatment chemicals
are being maintained within the ballast tanks. Vessel operators can monitor and record this data
and make adjustments, maintenance, or repairs to the ballast water treatment system to ensure the
equipment is functioning properly. Table 2 provides the anticipated control equipment and
potential monitoring and reporting metrics for physical/chemical indicators by treatment
technology.
11
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Ballast Water Discharges from Vessels
Section 3 - Ballast Water Compliance Monitoring
Table 2. Potential Ballast Water Treatment System Sensors and Measurement Equipment for Physical/Chemical Indicator
Monitoring
Technology Type
Alkylamines
Bioremediation
Cavitation
Chlorination:
electrochlorination or
chlorine addition (e.g.,
hypochlorite or chlorine
dioxide)
Measurement
PH
Alkylamines
Treatment chemical
Acoustic
Pressure
Oxidation reduction potential
(ORP)
Total residual oxidizers
(TRO)
Chlorine
Chlorine Dioxide
Power consumption, voltage
and current
Conductivity /salinity
Colored dissolved organic
matter (CDOM)
Potential Control Sensor,
Equipment, or Procedure
pH sensor
Chemical analysis and
treatment monitoring
Chemical analysis and
treatment monitoring
Passive acoustic sensor or
acoustic interferometry
Pressure sensors (before/after)
ORP sensor
Amperometric sensor
On-line N,N diethyl-p-
phenylene
diamine (DPD) sensor, sample
analysis, and treatment
monitoring
On-line chlorine dioxide
amperometric sensor,
Lissamine Green B (LGB)
sample analysis, and treatment
monitoring
System power diagnostics
Conductivity and temperature
sensor
Fluorometer (before/after)
Possible Compliance
Monitoring
PH
-Alkylamines concentration at
injection
-Alkylamines dosage and
usage
-Treatment chemical
concentration at injection
-Treatment chemical dosage
and usage
Acoustic
Pressure
ORP at injection
TRO at injection
-Chlorine concentration at
injection
-Chlorine dosage and usage (if
chlorine addition)
-Chlorine dioxide
concentration at injection
Chlorine dosage and usage (if
chlorine addition)
Conductivity and temperature
at injection
Possible Metrics to be
Reported
pH readings
-Alkylamines sample
concentration
-Alkylamines dosage and
usage
-Treatment chemical sample
concentration
-Treatment chemical dosage
and usage
Acoustic readings
Pressure readings
OPR readings
TRO readings
-Chlorine readings from both
on-line sensor and sample
analysis
-Chlorine dosage and usage (if
chlorine addition)
-Chlorine dioxide readings
from both on-line sensor and
sample analysis
Chlorine dioxide dosage and
usage (if chlorine addition)
Conductivity /salinity and
temperature readings
12
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Ballast Water Discharges from Vessels
Section 3 - Ballast Water Compliance Monitoring
Table 2. Potential Ballast Water Treatment System Sensors and Measurement Equipment for Physical/Chemical Indicator
Monitoring
Technology Type
Coagulation (flocculent)
Deoxygenation
Electric pulse
Filtration
Heat
Hydrocyclone
Menadione/Vitamin K
Measurement
Coagulant
Turbidity
Dose of inert gas (if used)
pH(ifCO2used)
Dissolved Oxygen (DO)
Power consumption, voltage
and current
Water clarity
Flow rate
Pressure
Back flush frequency
Temperature
Water clarity
Back flush frequency
Power consumption, voltage
and current
Menadione
Potential Control Sensor,
Equipment, or Procedure
Chemical analysis and
treatment monitoring
Turbidity sensor
Treatment monitoring
pH sensor
DO sensor
System power diagnostics
Sight glass, water sample,
turbidity sensor,
transmissometer
Flow meter
Pressure sensors (before/after)
Treatment monitoring
Thermistors
Sight glass, water sample,
turbidity sensor,
transmissometers
Treatment monitoring
System power diagnostics
Chemical analysis and
treatment monitoring
Possible Compliance
Monitoring
-Treatment chemical
concentration at injection
-Treatment chemical dosage
and usage
Coagulation effluent turbidity
Deoxygenation gas dosage and
usage
PH
Deoxygenation module
dissolved oxygen
concentration
Electric pulse module power
consumption, voltage and
current
Filter effluent clarity
Filter effluent flow
Filter pressures (before/after)
Filter backwash frequency
Treatment temperature
Hydrocyclone effluent clarity
Hydrocyclone back flush
frequency
Hydrocyclone power
consumption, voltage and
current
-Menadione/Vitamin K
concentration at injection
-Menadione/Vitamin K dosage
and usage
Possible Metrics to be
Reported
- Treatment chemical sample
concentration
-Treatment chemical dosage
and usage
Coagulation effluent turbidities
Deoxygenation gas dosage and
usage
pH readings
Dissolved oxygen
concentrations
Electric pulse module power
consumption, voltage and
current readings
Clarity readings
Flow readings
Filter pressures (before/after)
Filter backwash frequencies
Temperature readings
Clarity readings
Hydrocyclone back flush
frequencies
Hydrocyclone power
consumption, voltage and
current
-Menadione/Vitamin K
concentration at injection
-Menadione/Vitamin K dosage
and usage
13
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Ballast Water Discharges from Vessels
Section 3 - Ballast Water Compliance Monitoring
Table 2. Potential Ballast Water Treatment System Sensors and Measurement Equipment for Physical/Chemical Indicator
Monitoring
Technology Type
Ozone
Peracetic acid
Plasma pulse
Shear
Measurement
ORP
TRO
Ozone
Bromate
Power consumption, voltage
and current
Conductivity /salinity
CDOM
Hydrogen peroxide
Peracetic acid
PH
CDOM
Power consumption, voltage
and current
Temperature
Acoustic
Pressure
Potential Control Sensor,
Equipment, or Procedure
ORP sensor
Amperometric sensor
On-line ozone sensor (if used)
and sample analysis
Sample analysis
System power diagnostics
Conductivity and temperature
sensor
Fluorometer (before/after)
On-line sensor, chemical
analysis, treatment monitoring
On-line sensor, chemical
analysis, treatment monitoring
pH sensor
Fluorometers (before/after)
System power diagnostics
Thermistors
Passive acoustic sensor or
acoustic interferometry
Pressure sensors (before/after)
Possible Compliance
Monitoring
ORP at ozone injection
TRO at ozone injection
Ozone concentration at
injection
Bromate at ozone injection
Conductivity and temperature
at injection
-Hydrogen peroxide
concentration at injection
-Hydrogen peroxide dosage
and usage
-Peracetic acid concentration
at injection
-Peracetic acid dosage and
usage
pH at injection
Plasma pulse module power
consumption, voltage and
current
Treatment temperature
Acoustic
Pressure
Possible Metrics to be
Reported
OPR readings
TRO readings
Ozone readings from both on-
line sensor (if used) and
sample analysis
Bromate measurements
Conductivity /salinity and
temperature readings
-Hydrogen peroxide readings
from both on-line sensor and
sample analysis
-Hydrogen peroxide dosage
and usage
-Peracetic acid readings from
both on-line sensor and sample
analysis
-Peracetic acid dosage and
usage
pH readings
Plasma pulse module power
consumption, voltage and
current readings
Temperature readings
Acoustic readings
Pressure readings
14
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Ballast Water Discharges from Vessels
Section 3 - Ballast Water Compliance Monitoring
Table 2. Potential Ballast Water Treatment System Sensors and Measurement Equipment for Physical/Chemical Indicator
Monitoring
Technology Type
Ultrasound
UVandUV+TiO2
Measurement
Power consumption, voltage
and current
Acoustic
Power consumption, voltage
and current
Lamp status and age
UV dose, intensity,
transmittance
Flow rate
CDOM
Potential Control Sensor,
Equipment, or Procedure
System power diagnostics
Passive acoustic sensor or
acoustic interferometry
System power diagnostics
Treatment monitoring
UV sensors and monitors
Flow meter
CDOM fluorometer
Possible Compliance
Monitoring
Ultrasound power
consumption, voltage and
current
Acoustic
UV module power
consumption, voltage and
current
UV lamp status and age
UV dose, intensity,
transmittance
UV effluent flow
Possible Metrics to be
Reported
Ultrasound module power
consumption, voltage and
current readings
Acoustic readings
UV module power
consumption, voltage and
current
UV dose, intensity,
transmittance
Flow readings
Source: Adapted from USCG, Proceedings of Ballast Water Discharge Standards Compliance Subject Matter Expert (SME) Workshop, August 2011.
15
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Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring
Treatment Equipment Inspection and Maintenance
Ballast water treatment systems are designed and manufactured with various sensors and
other control equipment to automatically monitor and adjust system operating conditions to
ensure proper operation and to alert vessel personnel when intervention, maintenance, or repair is
required. Sensors and other control equipment, interfaced to monitoring equipment to record
operating parameters, also help vessel operators determine data trends while providing a
mechanism for EPA to verify continuous compliance. The vendor's Operating and Maintenance
Manual typically specifies the applicable sensors and other control equipment for the ballast
water treatment system, what constitutes a range of stable operating conditions for the system,
factors that may affect operating conditions, and any adjustments required to reach or to maintain
stable operating conditions (USEPA, 2010a). System monitoring and recording is expected to be
continuous during discharge.
When alarms are initiated, or when sensors indicate the ballast water treatment system is
not functioning properly, adherence with effluent limitations cannot be assured. To ensure
effluent quality, consistent with vessel and crew safety, vessels should not discharge ballast
water during alarm or upset conditions and should resume discharge only after correcting the
problems with the system and reestablishing stable operating conditions.
Routine maintenance of the ballast water treatment system and troubleshooting
procedures are typically defined in the system's Operating and Maintenance Manual kept
onboard the vessel. All maintenance activities related to the ballast water monitoring system and
overboard discharge control unit can be recorded and the information can be retained on board
for inspection purposes. In addition, vessel staff training could include familiarization with the
operation and maintenance of the ballast water overboard discharge control and monitoring
equipment. Ballast water treatment systems could be inspected on a monthly basis to determine
both short-term and long-term maintenance needs as specified in the vendor's Operating and
Maintenance Manual.
Monitoring Equipment Calibration
All applicable sensors and other control equipment could be calibrated when warranted
based on device drift and as recommended by sensor and equipment manufacturers, or by ballast
water treatment system manufacturers. Due to the operating characteristics of sensors and control
equipment, many sensor types (e.g., pH probes) may need to be calibrated on a more frequent
basis to correct for instrument drift and ensure the measurement system is functioning properly.
Calibration of the sensors and equipment could be conducted on-board the vessel, or the sensors
and equipment could be removed and shipped to the manufacturer for calibration. During the
period when the sensors are not installed and operating on the ballast water treatment system, the
vessel should not discharge ballast water.
Ballast water treatment systems that are equipped with automated control systems that
initiate a sequence to stop the overboard discharge of the effluent in alarm conditions could be
subjected to an annual functional test to verify they are working correctly. The detailed program
for a functional test of such equipment would typically be developed by the manufacturer, taking
into account the features and functions of the specific design of the equipment and the operating
16
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Ballast Water Discharges from Vessels
Section 3 - Ballast Water Compliance Monitoring
and discharge conditions monitored. A copy of the functional test protocol could be carried
onboard the vessel at all times so that functional testing can be conducted any time it is suspected
the system is not operating as designed.
3.2 BIOLOGICAL INDICATORS OF EXCEEDANCES
Biological indicators of treatment performance are estimates of the number of living
organisms or biomass in the ballast water effluent following treatment, regardless of species. The
intent of biological indicator monitoring is to measure the number of living organisms or
biomass in a small volume of treated ballast water. If there are significant levels of living
organisms or biomass in a small volume of ballast water, then the ballast water treatment system
is likely ineffective and monitoring large volumes of treated ballast water to enumerate specific
organism numbers is of little value. Table 3 lists possible treatment performance measures for
biological indicators compliance monitoring that could serve as indirect measurements of the
numbers of living organisms remaining in ballast water following treatment.
Table 3. List of Possible Treatment Performance Measures and Analytical Methods for
Biological Indicator Compliance Monitoring
Analyte
Biomass
Estimates
Live
Organisms,
10-50 urn
Bacteria
Measurement
Adenosine
triphosphate
(ATP)
Chlorophyll
fluorescence
Chlorophyll
fluorescence
Total
heterotrophic
bacteria
E. coli
Enterococci
V. cholerae
(toxigenic)
Instrument
or Analysis
ATP firefly
(luciferin-
luciferase)
method
Chlorophyll
fluorometer
Chlorophyll
fluorometer
Plate counts
Selective
substrate
Selective
substrate
Colorimetric
immunoassay
kits
EPA
Method
Method
445.0
Method
445.0
EPA
Method
1103.1
and 1603
EPA
Method
1106.1
and 1600
Standard
Method
SM 10200
H
SM 10200
H
SM9215
SM 9223B
SM 9230C
SM 9260
ASTM
ASTM
D4012-
81
ASTM
D3731-
87
ASTM
D3731-
87
ASTM
D5465
ASTM
D5392 -
93
ASTM
D5259 -
92(2006)
ISO
ISO
6222:1999
ISO 9308-
1:2000
ISO 7899-
2:2000
Other
Colilert®
Enterolert®
As indicated in Table 3, only E. coli and enterococci have approved EPA analytical
methods. Analytical methods for ATP, total live bacteria and V. cholera are available from
Standard Methods, ASTM, or ISO.
17
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Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring
Care should be taken when collecting ballast water samples to enumerate living
organisms. For example, sample volumes as large as 6,000 liters are necessary to measure
organisms between 10 and 50 microns at levels as low as 0.01 individuals per milliliter (USEPA,
2010a). Due to the large sample volumes required for analysis and the anticipated costs when
enumerating large organisms, self monitoring by counting large classes of living organisms of
ballast water could be expensive, and it could be challenging to find sufficient numbers of
qualified scientists and laboratories. For more information about the state of science enumerating
living organisms in ballast water, see USEPA, 2010a or USEPA, 201 la.
Sampling for Exceedance
Biological indicator compliance monitoring sampling is intended to verify the treatment
system is operating properly by collecting a small volume sample and analyzing the sample for
concentrations of certain indicator parameters. Analysis of concentrations of indicator organisms
should include at least E. coli and enterococci bacteria as these tests are cost effective and the
methods are well developed. Biological indicator compliance monitoring sampling of ballast
water effluent should be conducted over multiple sampling events to verify the system is
operating properly. Vessels that enter U.S. waters on only a limited basis (e.g., one time per
year), should conduct ballast water effluent monitoring within the previous three months and
upon discharge into U.S. waters. Table 4 lists possible biological indicator compliance
monitoring sampling analytical methods and the levels of indicator organisms (IMO, 2008) for
treated ballast water. Vessel owners/operators could also sample and analyze ballast water
discharges for other performance measures previously listed in Table 3.
If any of the biological indicator compliance monitoring effluent limits is exceeded, this
is a clear indicator that the system is not meeting its discharge limits.
3.3 EFFLUENT MONITORING FOR RESIDUAL BIOCIDES
Some ballast water treatment systems generate or use biocides (e.g., chlorine dioxide) to
reduce living organisms present in the ballast water tank. In the 2008 VGP, EPA required that
any ballast water technology must not use any biocide that is a "pesticide" within the meaning of
the Federal Insecticide, Fungicide, Rodenticide Act unless that biocide has been registered for
use in ballast water treatment under such Act. Additionally, EPA required that vessels that used
active substances must conduct additional monitoring as conditions of that permit (see Part 5.8 of
the 2008 VGP) (USEPA, 201 Ob).
To assure that vessels are not discharging harmful quantities of active substances, for
those vessels which have ballast water treatment systems that either add or generate biocides for
treatment (e.g., chlorine, chlorine dioxide, ozone, etc.), the vessel should conduct monitoring of
the vessel ballast water discharge for any residual biocides. For example, if chlorine is used as a
biocide in ballast water treatment, the vessel owner/operator could test for residual chlorine in
the vessel ballast water discharge. Table 5 provides a list of residual biocides and possible
effluent limits3 for ballast water discharges. To verify residual biocide concentrations in ballast
treatment effluent, vessel operators could initially collect a number of samples over the first few
3 Please see the 2013 proposed VGP fact sheet (EPA, 201 Ic) for discussion regarding the development of proposed
effluent limits for the 2013 VGP.
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Ballast Water Discharges from Vessels Section 3 - Ballast Water Compliance Monitoring
months of system operation (e.g., 3 to 5 samples spread over 3 months) and then continue to
collect additional samples each year (e.g., 2 to 4 samples per year) to verify residual biocide
levels are below discharge standards.
All sampling and testing for residual biocides should be conducted using sufficiently
sensitive 40 CFR Part 136 methods or other methods if specifically listed to assure that high
quality data are generated. Sensors or other test equipment that continuously monitor residual
biocide in ballast water discharge would need to be sufficiently sensitive to measure biocide
concentrations before and after any neutralization process to verify discharge concentrations and
to control the neutralizer dose.
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Ballast Water Discharges from Vessels
Section 3 - Ballast Water Compliance Monitoring
Table 4. Possible Biological Indicator Compliance Monitoring Analytical Methods and Effluent Limits
Analyte
E. Coli
Enterococci
Total heterotrophic
bacteria
Analytical Method
EPA Method 1103. land
1603;SM9223B; ASTM
D5392-93;orISO9308-
1:2000; Colilert®
EPA Method 1106. land
1600; SM 9230C; ASTM
05259-92(2006); or ISO
7899-2:2000; Enterolert®
SM9215;ASTMD5465;
ISO 6222: 1999
Sample
Volume
100 mL
100 mL
100 mL
Sample
Holding Time
6 hours
6 hours
6 hours
Method Detection
Limit
1 MPN or cfu/100 mL
1 MPN or cfu/100 mL
1 MPN or cfu/100 mL
Possible
Effluent Limits
<250 cfu/100 mLa
<100 cfu/100 mLa
N/A
Limit Type
Daily
Maximum
Daily
Maximum
Daily
Maximum
a USCG Phase I Standard
b USCG Phase II Standard
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Ballast Water Discharges from Vessels
Section 3 - Ballast Water Compliance Monitoring
Table 5. Residual Biocides Compliance Monitoring Sampling Analytical Methods and Possible
Action Levels
Biocide or
Residual
Alkylamines
Chlorine
(expressed as Total
Residual Oxidizers
(TRO as TRC))
Chlorine dioxide
Ozone (expressed
as Total Residual
Oxidizers (TRO as
TRC))
Peracetic Acid
Hydrogen Peroxide
(for systems using
Peracetic Acid)
Analytical
Methods
EPA Method
8360B and
8270D
SM 4500-C1 G;
ISO 7393/2
EPA Method
327.0-1; SM
4500 C102 E
SM 4500-O3 B
ISO /DIS 7157
ISO /DIS 7157
Sample
Volume
25 mL (8260B)
50mL
16 mL (327.0-1)
50 mL
25ml
25ml
Sample
Holding Time
14 days
(8260B)
1 5 minutes
4 hours (327.0-
1 ); As soon as
possible (SM)
As soon as
possible
As soon as
possible
As soon as
possible
MDL
Varies by compound
(8260D); 10 jjg/L
(8270C)
10 |ig/L, under ideal
conditions
Varies (327.0-1); 10
to 100 jjg/L (SM)
10ng/L
500 ng/L
500 ng/L
Possible
Effluent
Limit
Report
100 ng/L
200 ng/L
100 ng/L
500 ng/L
1,000 ng/L
Limit Type
NA
Instantaneous
Maximum
Instantaneous
Maximum
Instantaneous
Maximum
Instantaneous
Maximum
Instantaneous
Maximum
SM: Standard Methods
MDL: Method detection limit
NA: Not applicable
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Ballast Water Discharges from Vessels
Section 3 - Ballast Water Compliance Monitoring
3.4 EFFLUENT MONITORING FOR BIOCIDE DERIVATIVES
Biocides can also generate derivatives during ballast water treatment that can have
harmful effects when released to the environment. For example, chlorine combined with organic
material can generate short chain volatile hydrocarbons (e.g., trihalomethanes) which have
human health implications (New Hampshire Department of Environmental Services, 2006).
Table 6 lists biocide derivatives expected in ballast water treatment effluent along with the
derivatives analytical methods. To verify biocide derivative concentrations in ballast treatment
effluent are below levels harmful to the environment, vessel operators could initially collect a
number of ballast water treatment effluent samples over the first few months of system operation
(e.g., 3 to 5 samples spread over 3 months) to determine biocide derivative concentrations.
Vessel operators could collect ballast water treatment effluent samples periodically throughout
the year (e.g., 2 to 4 samples per year) to verify biocide derivative concentrations remain below
harmful levels.
Table 6. Biocide Derivative Monitoring Analytical Methods
Biocide
Chlorine or
chlorine
dioxide
Chlorine
dioxide
Ozone
Measured
Biocide
Derivative
Total
trihalomethanes3
Haloacetic acidsb
Chlorite
Chlorate
Bromate
Bromoform
Analytical Methods
EPA Method 8260
EPA Method 552.2
EPA Method 327.0-1; SM
4500 C1O2 E
EPA Method 300.1
EPA Method 3 17; ASTM
D 6581-00
EPA Method 8260
Sample
Volume
40 mL
40mL
250 mL
250 mL
250 mL
40 mL
Sample
Holding
Time
14 days
14 days
28 days
28 days
28 days (3 17)
14 days
MDL
Varies
Varies by
Compound
Varies
Varies
Varies (3 17)
Varies
a Total trihalomethanes is the sum of the concentrations of chloroform, bromodichloromethane, dibromochloromethane,
and bromoform.
b Haloacetic acids is the sum of the concentrations of mono-, di-, and trichloroacetic acids and mono- and dibromoacetic
acids.
MDL: Method detection limit
3.5 BALLAST WATER SAMPLING METHODS
EPA has developed and published techniques for sampling ballast water discharges
(USEPA, 2010a). In accordance with EPA's ETV Program, samples should be collected on a
time-integrated basis such that a composite sample of the entire discharge is acquired. To assure
that samples reflect actual discharge concentrations, effluent samples for biological indicators
(i.e., E. co//', enterococci, total heterotrophic bacteria), residual biocides and biocide derivatives
would need to be collected during an actual ballast water discharge. The sample flow rate should
be appropriately controlled to maintain an even distribution of sample collection over the entire
ballast water discharge period, and the sample should be collected at a location where the
discharging ballast water is representative of the entire ballast water stream, h
22
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Ballast Water Discharges from Vessels
Section 4 - Ballast Water Treatment Monitoring Costs
SECTION 4
BALLAST WATER TREATMENT MONITORING COSTS
There are three main categories of costs for ballast water treatment and monitoring as
contemplated in this document: 1) costs associated with the purchase, installation, and operation
of the treatment system; 2) costs associated with ballast water treatment system functionality
monitoring and equipment calibration; and 3) costs associated with discharge monitoring.
Although ballast water treatment systems should include the necessary sensors, probes
and monitoring equipment needed for performance monitoring, EPA decided to be conservative
and estimate the incremental cost for a vessel to purchase and install additional monitoring
equipment. Using a filtration and chlorine ballast water treatment system as an example, EPA
estimated costs to add additional pressure transducers to monitor pressure drop across the filter
and costs for an on-line chlorine analyzer. Table 7 provides these example capital costs. EPA
estimated that capital costs for installation of additional monitoring equipment for a filtration and
chlorine system would be approximately $10,000.
Table 7. Estimated Capital Cost for Vessels Needing Additional Ballast Water
Treatment System Monitoring Equipment
Treatment Unit
Filter
Chlorine
Monitoring
Equipment
Pressure
Transducers
On-line DPD
Chlorine Analyzer
Equipment
Purchase Cost
$l,550a
$3,448b
Installation
Cost Factor0
2
2
Total Installed Capital Cost
Installed
Capital Cost
$3,100
$6,900
$10,000
a Costs provided by Sentra for two pressure transducers with ranges from 15 to 1,000 psi.
b Costs provided by Hach Company for the CL 17 Free Chlorine Analyzer with AquaTrend Network.
c Installation cost factor developed by Eastern Research Group, Inc. for installation of wastewater treatment equipment on cruise
ships.
Annual monitoring costs would be incurred for monthly inspection of the system,
quarterly sampling for performance indicators and residual biocides, annual sampling for biocide
derivatives, and annual recordkeeping and reporting. EPA estimated the total labor needed to
conduct monthly inspections of the ballast water treatment system, annually recalibrate any
monitoring equipment, and complete the necessary recordkeeping amounts to about 22 hours per
year. Labor estimates assume equipment inspection requires approximately 1 hour per month
plus an additional 9 minutes per month to record the inspection information. Recalibration of the
monitoring equipment is estimated to be 8 hours per year with an additional 15 minutes to record
the recalibration information.
The third potential cost component relates to discharge monitoring from the ballast water
treatment system. For these estimates, EPA assumed three types of discharge monitoring:
biological indicators, residual biocides and biocide derivatives. EPA's assumptions regarding the
parameters to be analyzed and the frequency of monitoring differ depending on the type of
treatment system installed. The total cost of each sampling event would consist of both labor
23
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Ballast Water Discharges from Vessels
Section 4 - Ballast Water Treatment Monitoring Costs
hours for vessel staff to collect samples and either on-board sample analysis or send the samples
to an onshore laboratory for analysis. EPA assumed that compliance testing of ballast water
effluent would be conducted 2 times per year for vessels with type approved ballast water
treatment systems and 4 times per year for non-type approved ballast water treatment systems.
EPA also assumed discharge testing for the presence of residual biocides and biocide
derivatives, if applicable, several times during the initial 90 days of permit coverage, followed by
maintenance monitoring thereafter. The number of sampling events assumed during the first 90
days (3 to 5 events) and the frequency of subsequent monitoring events (2 or 4 events per year) is
dependent on the type of system.
EPA estimated that each sampling event would require 2 hours to complete and 0.5 hour
to record. Additional sampling for biocides and biocide derivatives, in the case of vessels
equipped with systems that have the potential to discharge residual biocides or biocide
derivatives, is estimated to require an additional 1 hour to complete, and 0.5 hours to record.
Table 8 presents the estimated costs for discharge sampling and analytical testing of ballast water
discharges.
Table 8. Estimated Labor and Analytical Costs for Ballast Water Treatment System
Discharge Sampling
Monitoring
Requirement
Sample Collection
Labor (hrs/event)
Sample
Analysis and
Incidentals
Cost ($/event)
Sampling
Frequency (#
events/yr)
Annual Cost"
If using type approved ballast water treatment systems for which all type approval data is available
Biological Indicator
Sampling and Testingb
Initial Biocide
Derivative Monitoring0'"1
Biocide Derivatives
Monitoring"1
2.5
1.5
1.5
$150
$150
$150
2
3
2
$468
$98e
$401
If using non-type approved ballast water treatment systems or type approved systems which type
approval data are not available
Biological Indicator
Sampling and Testingb
Initial Biocide
Derivative Monitoring0'"1
Biocide Derivatives
Monitoring"1
2.5
1.5
1.5
$150
$150
$150
4
5
4
$937
$196e
$802
a Annual cost calculated as burden hours times the average labor rate of $33.72/hour plus lab and incidental costs times the
frequency.
b Costs for analysis of E. coli, enterococci and total live bacteria from Energy Laboratories
c Analysis of residual biocide oxidizers such as chlorine, ozone and chlorine dioxide performed onboard due to short sample
hold time
d Cost for analysis of trihalomethanes or bromoform from Energy Laboratories
e Annual cost represents one-time costs of initial testing annualized over 5 years of the VGP (assumes that the initial round of
biocide sampling and testing replaces one periodic monitoring event).
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Ballast Water Discharges from Vessels Section 4 - Ballast Water Treatment Monitoring Costs
Note that EPA assumed that vessels would test for the presence of residual biocides and
their corresponding derivatives and analytes listed in Tables 5 and 6, namely: alkylamines,
bromated, chlorate, chlorine or chlorine dioxide, hydrogen peroxide, ozone, and peracetic acid.
More information on the costs associated with ballast water treatment system monitoring are
provided in EPA's Economic and Benefits Analysis of the 2013 Vessel General Permit (USEPA,
201 Ib).
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Ballast Water Discharges from Vessels Section 5 - References
SECTION 5
REFERENCES
Albert, R., Everett, R., Lishman, J., and Smith, D. (2010). Availability and Efficacy of Ballast
Water Treatment Technology: Background and Issue Paper. Prepared for Science
Advisory Board, June 2010.
California State Lands Commission. (2010). 2010 Assessment of the Efficacy, Availability, and
Environmental Impacts of Ballast Water Treatment Systems for Use in California
Waters, August 2010.
California Environmental Protection Agency. (2002). Evaluation of Ballast Water Treatment
Technology for Control ofNonindigenous Aquatic Organisms, December 2002.
Carlton, J.T. (2001). The Scale of Ecological Consequences of Biological Invasions in the
Worlds Oceans. Invasive Species and Biodiversity Management. Kluwer Academic
Publishers.
Carlton, J.T., Reid, D.M., and van Leeuwen, H. (1995). Shipping Study: The Role of Shipping in
the Introduction ofNonindigenous Aquatic Organisms to the Coastal Waters of the
United States (other than the Great Lakes) and an Analysis of Control Options (USCG
Report No. CG-D-11-95).
Deines, A.M, Chen, V.C, and Landis, W.G. (2005). Modeling the Risks ofNonindigenous
Species Introductions Using a Patch-Dynamics Approach Incorporating Contaminant
Effects as a Disturbance. Risk Analysis, 25(6): 1637-1651.
Dobroski, N. Scianni, C., and Takata, L. (2009). October 2009 Update: Ballast Water Treatment
Technologies for Use in California Waters. Prepared for the California State Lands
Commission by the Marine Invasive Species Program, October 2009.
Drake, J.M., and Lodge, D.M. (2007). Rate of Species Introductions in the Great Lakes via Ships
Ballast Water and Sediments. Canadian Journal of Fisheries and Aquatic Sciences,
64(3): 530 - 538.
Energy Laboratories. (2011). Energy Laboratories Pricing Guide. November 2011.
Faulkner, M. (2009). California Marine Invasive Species Program Update. Proceedings of the
Pacific Ballast Water Group. Seattle, Washington, January 14, 2009.
Hach Company. (2011). CL17 Free Chlorine Analyzer with AquaTrendNetwork. October 2011.
Hayes, E.H. and Landis, W.G. (2004). Regional Ecological Risk Assessment of a Near Shore
Marine Environment: Cherry Point, WA. Human and Ecological Risk Assessment, 10:
299 - 325.
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Ballast Water Discharges from Vessels Section 5 - References
Hurley, W., Schilling, S.S, and Mackey, T. (2001). Contract Designs for Ballast Water
Treatment Systems on Container Ship R.J. Pfeiffer and Tanker Polar Endeavor. Marine
Environmental Engineering Technology Symposium (MEETS). Arlington, VA. June 1,
2001.
International Maritime Organization (IMO). (2008). Resolution Marine Environmental
Protection Committee (MEPC) 174(58), Guidelines for Approval of Ballast Water
Management Systems (G8).
Kasyan, V. (2010). Holoplankton of ship ballast water in the Port of Vladivostok. Russian
Journal of Marine Biology. 36(3):167-175.
Keller, R.P. and Drake, J.M. (2011). Linking Environmental Conditions and Ship Movements To
Estimate Invasive Species Transport Across the Global Shipping Network. Journal of
Conservation Biogeography, 17, 1.
Lodge, D., and Finnoff, D. (2008). Invasive Species in the Great Lakes: Costing Us Our Future.
Preliminary Results. University of Notre Dame.
Lovell, S.J., & Drake, L.A. (2009) Tiny stowaways: analyzing the economic benefits of a U.S.
Environmental Protection Agency permit regulating ballast water discharges.
Environmental Management, 43, 546-555.
Lloyd's Register. (2010). Ballast water treatment technology: current status. London, England:
Lloyd's Register. February, 2010.
MIT Sea Grant. (2002). Marine Bio-Invasion Fact Sheet: Ballast Water. Retrieved from
http://massbay.mit.edu/exoticspecies/ballast/fact.html
New Hampshire Department of Environmental Services. (2006). Trihalomethanes: Health
Information Summary (ARD-EHP-13).
Pennsylvania Sea Grant. (2003). Proceedings Aquatic Invaders of the Delaware Estuary
Symposium. Penn State Great Valley Campus.
Perrings, C. (2002). Biological Invasions in Aquatic Systems: The Economic Problem. Bulletin
of Marine Science, 70(2), 541-552.
Prince William Sound Regional Citizens' Advisory Council. (2005). Prince William Sound
Alaska Crude Oil Tankers, Fact Sheet. Ballast Water Treatment Methods .
Raikow, D.F. and Reid, D. (2006). Sensitivity of Aquatic Invertebrate Eggs to SeaKleen: A Test
of Potential Ballast Tank Treatment Options. Environmental Toxicology and Chemistry,
25, 2, 552-559.
Sentra. (2011). AccuSense Model ASM High Accuracy Pressure Transducer.
27
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Ballast Water Discharges from Vessels Section 5 - References
Tamburri, M. (2011). Personal Communication. Maritime Environmental Resource Center
(MERC), University of Maryland Chesapeake Biological Laboratory.
USCG. (2011). Draft Proceedings of Ballast Water Discharge Standards Compliance Subject
Matter Expert (SME) Workshop.
USEPA. (2011 a). Science Advisory Board (SAB), Ecological Processes and Effects Committee,
Efficacy of Ballast Water Treatment Systems.
USEPA. (201 Ib). Economic and Benefits Analysis of the 2013 Vessel General Permit.
USEPA. (2010a) Generic Protocol for the Verification of Ballast Water Treatment Technologies
(EPA/600/R-10/146). Environmental Technology Verification (ETV) Program
USEPA. (201 Ob) Vessel General Permit.
USEPA. (2008). Vessel General Permit Fact Sheet.
USEPA. (2001). Aquatic Nuisance Species in Ballast Water Discharges: Issues and Options.
USEPA. (1986). Quality Criteria for Water [Gold Book].
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