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Stricter regulation of ballast water from vessels operating in waters of the United States has been a long time coming, despite the introduction of many invasive species credited directly to ballast water discharges. With the new 2013 VGP, however, vessel owners and operators have to comply with more stringent numeric discharge standards for non-indigenous invasive species in ballast water as well as additional requirements specific to vessels operating on the Great Lakes.
Section 2.2.3 of the VGP defines the new ballast water requirements for all owners/operators of vessels with ballast water tanks including the following:
Training: Must be provided to those crew members that actively take part in management of ballast discharges, or who “may affect the discharge, on the application of ballast water and sediment management and treatment procedures,” including the master, the operator, person-in-charge, and crew members. Training must be provided promptly upon installation of treatment technology and in the event of a significant change in ballast water treatment practices or technology.
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Ballast Water Management Plans: Must be developed specifically for that vessel to ensure all trained personnel responsible for implementing the plan understand and follow the vessel’s ballast water strategy. The management plan must contain;
- A stand-alone training plan that describes the training to be provided as well as records of training dates for each person receiving training,
- Mandatory ballast water management practices specifically designed to avoid areas of high risk contaminants (such as toxic algae blooms), high-risk populations like whales, coral reefs and marine parks/sanctuaries, and other common-sense precautions such as avoiding areas where dredging is taking place or where sediment can be stirred up, to list a few of the stipulations. Operational tactics also include when and where to clean ballast tanks, discharge prohibitions and best practices for pumping and reducing sediment intake.
Regarding Great Lakes vessels or “Lakers,” additional ballast water management practices include development and implementation of sediment removal policies, limitations on dock-side ballast water uptake, and annual inspections of vessel sea chest screens as a first line of defense against large living organisms entering the ballast tanks.
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Numeric Discharge Limits: Perhaps the most important aspect of the new ballast water requirements is the numeric discharge limitations defined in Part 2.2.3.5 of the 2013 VGP. Unless excluded from the requirements (under Parts 2.2.3.5.3 or 2.2.3.8 of the permit) the following discharge limits expressed as instantaneous maximums must be met:
1. For organisms greater than or equal to 50 micrometers in minimum dimension: discharge must include fewer than 10 living organisms per cubic meter of ballast water.
2. For organisms less than 50 micrometers and greater than or equal to 10 micrometers: discharge must include fewer than 10 living organisms per milliliter (mL) of ballast water.
3. Indicator microorganisms must not exceed:
(i) For Toxicogenic Vibrio cholerae (serotypes O1 and O139): a concentration of less than 1 colony forming unit (cfu) per 100 mL.
(ii) For Escherichia coli: a concentration of fewer than 250 cfu per 100 mL.
(iii) For intestinal enterococci: a concentration of fewer than 100 cfu per 100 mL.
The EPA also notes that as new and better technologies become available and “when warranted” effluent limitations will be made more stringent.
The VGP also provides very detailed requirements for ballast water treatment systems, monitoring of systems, equipment and biological organisms, recordkeeping and reporting, and other requirements specific to certain vessels and vessel operations, geographic areas, and different types of ballast water practices, prevention methods and prohibitions.
The entire 2013 VGP can be downloaded at http://cfpub.epa.gov/npdes/vessels/vgpermit.cfm.
Now there is legislation in congress (s2094), and the question is: If the St. Lawrence river, Mississippi River, etc. are classified as international seaways or trade routes etc., will the language in the legislation stating that the legislation will comply with all treaties, agreements, etc., eliminate the provision for states to petiton, for a stronger regulation. Will the legislation add the extra protection needed for the pristine St. Lawrence river, Great Lakes, and any other waters deemed for use by the international shipping industry (composed of primarily foreign ships) from the impending damage that will happen if only the weak Coast Guard “final rule” mirroring the international standard is legislated? Sadly if they do not increase standards and timelines, an ocean flush ( known to be inadequate for many invasive s such as VHSV, and cholera) will be relied on long into the future.
It is known that many virus’s exist in ballast water, but little if any test are done to determine what they are. As many virus’s are activated be temperature change, invasive s will only become more problematic in the future. As the earth warms many unknown health problems may arise. If the Senate approves ratification of the Law of The Sea treaty will they include provisions to allow the US autonomous rights to add environmental regulations at its discreation as an autonomous country protecting their environment?