1. UPDATE ON US BWM REQUIREMENTS
TECHNICAL WORKSHOP May 22, 2015
UPDATE ON US BWM REQUIREMENTS
JOSEPH ANGELO DEPUTY MANAGING DIRECTOR

2. Ballast Water Management – USCG
Final Regulations issued March 23, 2012
BWM plan and recordkeeping (same as IMO)
BWM discharge standard (same as IMO), review in 4 yrs
Schedule for installation of BWMS similar to IMO, BUT NO intent to align schedule with Resolution A.1088
BWMS not required if no discharge of ballast water into US waters (12 miles)
Acceptance of “Alternative” (AMS) BWMS for 5 years
All ships must eventually install CG approved BWMS
Ships may request an extension to compliance date for installation of a USCG approved BWMS

3. Ballast Water Management – USCG
INTERTANKO Assisting Members with USCG regulations
Implementation Schedule
Decision Tree …

4. USCG Ballast Water Decision Tree

5. Ballast Water Management – USCG
US Coast Guard
INTERTANKO assisting Members
Implementation Schedule
Decision Tree
Model Extension Request (MER) Letter

6. Ballast Water Management – USCG
US Coast Guard – Extension requests
January 1, 2016 extension date given to ships whose drydocking was scheduled for 2014
January 1, 2017 extension date given to ships whose drydocking was scheduled for 2015
Extensions for ships with drydockings in 2016 being considered
Availability of USCG approved BWMS will be a factor in determining the length of time for future extensions
INTERTANKO has developed Model Extension Request (MER) letter for members wishing to request extension

7. Ballast Water Management – USCG
US Coast Guard – APPROVED BWM Systems
CG has advised that 17 BWMS manufacturers have submitted “Letter of Intent” to pursue USCG approval (54 AMS accepted by USCG)
For proprietary reasons, USCG cannot tell who those BWMS manufacturers are
INTERTANKO has contacted BWMS manufacturers to determine which of them have submitted “Letter of Intent” (results on INTERTANKO web site)
Only after the testing is completed and the results have been evaluated, will a BWMS manufacturer then submit an application to the USCG for approval of their BWMS

8. Ballast Water Management – USCG
NK 03
Optimarine – OBS EX (UV)
Coldharbour Marine
Oceansaver Mk II
Erma First BWTS
Wartsila – Aquarius EC
RWO – Cleanballast
Severn Trent – Balpure
Hyde Guardian (UV)
DESMI – Ray Clean (UV)
Techcross Electrocleen
Samsung – Purimar
Alfa Laval – Pureballast (UV)
Trojan Marinex (UV)
Evoqua – SeaCure BWTS ??
NEI – Venturi Oxygen Stripping

9. Ballast Water Management – USCG
US Coast Guard – APPROVED BWM Systems
USCG has received three applications for BWMS type approval (all three make use of UV treatment)
UV BWMS need further USCG “validation” of methodology for biological efficacy
CG indicates that they expect to have a USCG approved BWMS “sometime in 2015”
CG indicates they will be “realistic” in requiring when a ship calling at US ports must have a CG approved BWM system installed

10. Ballast Water Management
Shipowner dilemma!!
US is not party to IMO BWM treaty. USCG regs:
Allow use of Alternate Management System (AMS) for five years
After five years, require installation of USCG approved BWMS
Currently no BWMS is USCG approved
Ship operator must decide to either install AMS (and hope it gets USCG approval!) OR request an extension and hope there is a CG approved BWMS available for installation on their ship prior to the required installation date under the IMO Convention.

11. Ballast Water Management
If I owned a tanker, I would –
Conduct preparatory work to determine:
a. which type of BWMS is best for my ship
b. there is proper space to install the BWMS I want on my ship
Request extension from US Coast Guard
Once I know when IMO BWM convention will enter into force, request the issuance of new MARPOL Annex 1 IOPP Certificate
When available, purchase USCG approved BWMS that is best for my ship

12. Ballast Water Management – USEPA
EPA Vessel General Permit issued December 19, 2013
To a large extent EPA VGP requirements are the same as USCG (discharge standard, compliance schedule, etc.)
Approval of BWMS is not required
BWMS monitoring required (functionality, equipment calibration, effluent, biocides)
New ship (keel laid after December 1, 2013) is required to install a BWMS to comply with the VGP, i.e. no acceptance of USCG extension provision in the VGP
EPA /USCG MoU – EPA Enforcement Policy, 27 Dec 2013
Vessel with USCG extension is non-compliant (if discharges in US waters – 3 miles), but EPA regards as a low-enforcement priority, provided all other regs are met

13. Ballast Water Management – USEPA
Potential issue with EPA Enforcement Policy??
Charter party agreements require tanker to be in compliance with all applicable laws and regulations
Tanker that receives CG extension would be in compliance with CG requirements
Tanker that has CG extension and discharges ballast water within US waters (3 miles) would be in violation of EPA Vessel General Permit
Would this violate charter party agreements???
Thus far, not aware of any comments from oil majors or charterers on this issue

14. THANK YOU!
COMMENT: the +3 are BWMS with model variations, so there are 3 within the 13 BWMS approved that are simply variations of the approved BWMS, e.g. BWMS Mark 1 and BWMS Mark 2.