Update on Ballast Water Management

Latin American Panel MeetingCartagena, Columbia

November 1, 2011

The present challenge

Gaining certainty is the principle challengeBut the investment in technology is filled with uncertainty

Regulatory uncertainty

Operational uncertainty

Regulatory Uncertainty: IMO Convention

Ratification and Entry into Force• Requires 30 countries and 35% tonnage

• Currently 30 countries and 26.44% tonnage

• But – deadlines for compliance are retroactive

• Ships constructed 1 before 2009 with a ballast water capacity of between 1500 and 5000m3 must conduct ballast water management that at least meets the ballast water exchange standards or the ballast water performance standards until 2014, after which time it shall at least meet the ballast water performance standard.

• Ships constructed before 2009 with a ballast water capacity of less than 1500 or greater than 5000m3 must conduct ballast water management that at least meets the ballast water exchange standards or the ballast water performance standards until 2016, after which time it shall at least meet the ballast water performance standard.

• Ships constructed in or after 2009 with a ballast water capacity of less than 5000m3 must conduct ballast water management that at least meets the ballast water performance standard.

• Ships constructed in or after 2009 but before 2012, with a ballast water capacity of 5000m3 or more shall conduct ballast water management that at least meets the standard described in regulation D-1 or D-2 until 2016 and at least the ballast water performance standard after 2016.

• Ships constructed in or after 2012, with a ballast water capacity of 5000m3 or more shall conduct ballast water management that at least meets the ballast water performance standard.

Regulatory Uncertainty: IMO Convention

MEPC 62

Another review of the treatment technologyWith respect to...the technical challenges for the installation and operation of BWMS on certain vessel types, the Review Group invited the Committee to urge Member States and industry representatives to provide criteria and data to MEPC 63 in order to allow an informed and focused review at a later stage when the Convention achieves its ratification requirements.

Regulatory Uncertainty: IMO Convention

1. Federal level:– USCG: NPRM – INTERTANKO submit comments in 2009 with 3000

others!– EPA: Clean Water Act and the VGP requirements

2. Proliferation of State regulations– California– New York

3. Raising compliance standards - 100x or 1000x IMO D-2California and New York, does the owner seek BWTM systems to meet these requirements?

Will the EPA’s Science Advisory Board Report make a difference?

Regulatory Uncertainty: US Legislation

EPA Science Advisory Board: report on the efficacy of ballast water treatment systems (July 2011)

‘due to technological, logistical, and personnel constraints imposed by shipboard operations…wholly new systems would need to be developed in order to meet more stringent proposed standards (i.e., standards that are 100x, or 1000x more stringent than D-2/Phase 1)’

A discharge standard of 1000x that of the IMO D-2 discharge standard is akin to a ballast sterilization, noting this the SAB suggest that, ‘[g]iven the volumes of water involved, onboard sterilization of ballast water is not possible using current technologies. It is not possible to verify zero (sterilization) or near-zero discharge. Such values cannot be measured in a scientifically defensible way’

Foundation of INTERTANKO template letter to New York State for extension of 1 January 2013 date for newbuildings

Regulatory Uncertainty: US Legislation

Operational Uncertainty:Ballast Water Treatment (BWT) Systems

Finding, installing and operating systems on tankers?

Finding, installing and operating systems on tankers?

INTERTANKO’s Guidance on the Selection and Installation of Ballast Water Management Systems for Tankers

• Physical Installation• Pumping• Control – system approval and certification• Treatment type• Operating practicalities

Operational Uncertainty:Ballast Water Treatment (BWT) Systems

• Biological discharge standard– IMO BWM Convention, Reg. D-2– California/New York proposals, 1000x more stringent

• IMO Ballast Water Working Group on Sampling– Led by EMSA

• Proposed US state standards will fail on biological sampling

Consequently:1. Sampling / testing a last resort for PSC2. If sampling / testing required, likelihood of direct monitoring

being first step for PSC compliance assessment

Operational Uncertainty:Compliance – Sampling and Testing

Overcoming the challengesINTERTANKO activity

Regulatory certainty

1. Provide data to the IMO Review in assessing industry’s readiness to meet the Convention dates

2. Develop Legal Guidance note to members on implementation dates of the Convention

3. Assisting members in gaining exemption to the New York requirements (exemption letter template)

4. Contribute to process of developing USCG proposed rules

The Ballast Water Challenge

Overcoming the challengesINTERTANKO activity

Operational certainty

1. INTERTANKO Guidance on Selecting and Installing BWM Systems

2. Recommendation for HAZID to be undertaken on all tankers prior to installation of a BWM system

3. Contribute to IMO Sampling Guidelines

4. Promote/encourage exchange of information on BWM systems installed on members tankers

The Ballast Water Challenge

Muchas Gracias