performance standards, technology assessment and the next steps for california’s marine invasive...
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Performance Standards, Technology Performance Standards, Technology Assessment and the Next Steps for Assessment and the Next Steps for California’s Marine Invasive Species California’s Marine Invasive Species
ProgramProgram
N. Dobroski, L. Takata, N. Dobroski, L. Takata, C. Scianni, and M. FalknerC. Scianni, and M. Falkner
California State Lands CommissionCalifornia State Lands Commission
Pacific Ballast Water Group MeetingPacific Ballast Water Group MeetingDecember 2007December 2007
MISP Recent/Future Activities MISP Recent/Future Activities
Development of performance standards and Development of performance standards and associated report (2005/2006)associated report (2005/2006)
Coastal Ecosystems Protection Act (2006)Coastal Ecosystems Protection Act (2006) Performance standards regulation and Performance standards regulation and
technology assessment report (2007)technology assessment report (2007) System testing guidelines and vessel System testing guidelines and vessel
compliance verification protocols (2008)compliance verification protocols (2008)
Performance Standards: Performance Standards: Marine Invasive Species ActMarine Invasive Species Act
Why?
• Variable efficacy of exchange
• Safety
• Deviation & delay
• Slow advancement of technologies
Mandates Mandates • Protect beneficial usesProtect beneficial uses
• Consult with USCG, Water Board, Consult with USCG, Water Board, Technical Advisory Group Technical Advisory Group
• Best available technologyBest available technology
• Economically achievableEconomically achievable
• Deadline: January 31, 2006Deadline: January 31, 2006
Technical Advisory PanelTechnical Advisory Panel
Meeting #1March 7, 2005
Introductions
Orientation to Panel requirements as per P.R.C.
Discussion:
Panel information needs
Meeting #3June 22, 2005
Discussion:
Prototype ballast treatment technologies
Economic considerations
Data on exchanged and unexchanged ballast water
Performance standards of other programs: Rationale
Meeting #5August 8, 2005
Discussion:
Standards and implementation schedule for CA
Panel recommendations
Information Sharing
Development of Key Considerations
Recommendation Development
Meeting #2April 27, 2005
Presentations:
Ballast water data
R&D treatment technologies
Invasion rate theories
Water quality regulatory frameworks
Discussion:
Preliminary key considerations
Meeting #4July 13, 2005
Discussion:
Performance standards & implementation schedules of other programs: Suitability for CA
Economic considerations
Invasion rate theories
Framework for CA performance standards
Agreement and DisagreementAgreement and Disagreement
AgreementAgreement Concentration-based standards Concentration-based standards
over percent reductionover percent reduction Much better than BW exchangeMuch better than BW exchange Standards should drive Standards should drive
technologies, not the reversetechnologies, not the reverse Need a finite implementation Need a finite implementation
scheduleschedule DisagreementDisagreement
Numeric values for standardsNumeric values for standards
Performance Standards Performance Standards (as recommended by Panel Majority)(as recommended by Panel Majority)Organism Size Class California1,2 IMO Regulation D-21 Washington
Organisms greater than 50 µm in minimum dimension
No detectable living organisms
< 10 viable organisms per cubic meter
Technology to inactivate or remove:
95% zooplankton99% bacteria and phytoplankton
Organisms 10 – 50 µm in minimum dimension
< 0.01 living organisms per ml
< 10 viable organisms per ml
Organisms less than 10 µm in minimum dimension
Escherichia coli
Intestinal enterococci
Toxicogenic Vibrio cholerae (01 & 0139)
< 103 bacteria/100 ml< 104 viruses/100 ml
< 126 cfu3/100 ml
< 33 cfu/100 ml
< 1cfu/100 ml or < 1cfu/gram wet weight
zoological samples
< 250 cfu/100 ml
< 100 cfu/100 ml
< 1 cfu/100 ml or < 1 cfu/gram wet weight
zooplankton samples
Ballast Water Capacity of Vessel Standards apply to new vessels in this size class constructed on or after
Standards apply to all other vessels in this size class beginning in
< 1500 metric tons 2009 2016
1500 – 5000 metric tons 2009 2014
> 5000 metric tons 2012 2016
FINAL DISCHARGE STANDARD: Zero detectable living organisms by January 2020FINAL DISCHARGE STANDARD: Zero detectable living organisms by January 2020
Performance Standards ReportPerformance Standards Report Presented to Legislature January 2006Presented to Legislature January 2006 Recommendations included:Recommendations included:
Adopt Interim Performance Standards and Adopt Interim Performance Standards and Implementation Schedule (as presented by Panel Implementation Schedule (as presented by Panel Majority in report)Majority in report)
Adopt Final Performance Standard (zero detectable)Adopt Final Performance Standard (zero detectable) Require initial and periodic review of treatment Require initial and periodic review of treatment
technologiestechnologies Grandfather vessels with existing CSLC or USCG-Grandfather vessels with existing CSLC or USCG-
approved experimental technologiesapproved experimental technologies Consider incentives to promote continued technology Consider incentives to promote continued technology
developmentdevelopment
Coastal Ecosystems Coastal Ecosystems Protection Act RequirementsProtection Act Requirements
Implementation of performance standards Implementation of performance standards for the discharge of ballast water (as for the discharge of ballast water (as specified in the Performance Standards specified in the Performance Standards Report) Report)
Report assessing efficacy, availability and Report assessing efficacy, availability and environmental impacts, including water environmental impacts, including water quality, of currently available quality, of currently available ballast water treatmentballast water treatmenttechnologiestechnologies
Performance Standards RegulationPerformance Standards Regulation
Standards prescribed by Standards prescribed by statutestatute
Comments/objections Comments/objections from industry focused on from industry focused on standards themselvesstandards themselves
Approved October 2007Approved October 2007 Effective January 1, 2008Effective January 1, 2008 Text of regulation Text of regulation
available on CSLC available on CSLC websitewebsite
Technology Assessment ReportTechnology Assessment Report
Key components:Key components: EfficacyEfficacy AvailabilityAvailability Environmental impacts, including water qualityEnvironmental impacts, including water quality
If technologies to meet the standards are If technologies to meet the standards are unavailable – why not? unavailable – why not?
Approved by Commission on December 3Approved by Commission on December 3 Due to Legislature by January 1Due to Legislature by January 1 Similar reports due 18 months prior to each Similar reports due 18 months prior to each
implementation dateimplementation date
Information Gathering for Technology Information Gathering for Technology Assessment ReportAssessment Report
Literature search – scientific Literature search – scientific literature, white papers, literature, white papers, gray papers, promotional gray papers, promotional materialsmaterials
Discussions with technology developersDiscussions with technology developers Technical workshop – May, 2007 in Technical workshop – May, 2007 in
BostonBoston Advisory panel meeting – October, 2007 in Advisory panel meeting – October, 2007 in
SacramentoSacramento
Treatment Technologies/Methods Treatment Technologies/Methods
Shipboard vs. ShoresideShipboard vs. Shoreside Mechanical – filtration, hydrocyclonic separation, Mechanical – filtration, hydrocyclonic separation,
filtration medium filtration medium Chemical (biocide)Chemical (biocide)
oxidizing (Cl, ClOoxidizing (Cl, ClO22, ozone, bromine, , ozone, bromine, hydrogen peroxide, peroxyacetic acid)hydrogen peroxide, peroxyacetic acid)
non-oxidizing (Acroleinnon-oxidizing (Acrolein™™, glutaraldehyde, , glutaraldehyde, menadione/SeaKleen)menadione/SeaKleen)
Physical – UV, heat, ultrasoundPhysical – UV, heat, ultrasound Combination – deoxygenation, electrolytic Combination – deoxygenation, electrolytic
oxidation (physical + chemical)oxidation (physical + chemical)
Treatment SystemsTreatment Systems Information collected on 28 systemsInformation collected on 28 systems 9 countries9 countries 17 systems use two or more treatment methods 17 systems use two or more treatment methods
(often mechanical separation + secondary (often mechanical separation + secondary method)method)
Four main types systems:Four main types systems: Oxidants/oxidative technologies (18) Oxidants/oxidative technologies (18)
• Electrochemical oxidation (7), Electrochemical oxidation (7), Cl/ClOCl/ClO22 (6), Ozone (4), Ferrate (1) (6), Ozone (4), Ferrate (1)
UV (4) UV (4) Deoxygenation (3) Deoxygenation (3) Other (3)Other (3)
EfficacyEfficacy Results of system efficacy only available for 20 Results of system efficacy only available for 20
(of 28) systems(of 28) systems Lenient review of results by Staff – Lenient review of results by Staff –
demonstration of “potential” for compliancedemonstration of “potential” for compliance Evaluation difficult due to variable testing Evaluation difficult due to variable testing
methods and results in metrics inconsistent with methods and results in metrics inconsistent with standardsstandards
Only 11 systems tested onboard vesselsOnly 11 systems tested onboard vessels No single technology has yet demonstrated No single technology has yet demonstrated
capability to meet more than four (out of 7) of capability to meet more than four (out of 7) of California’s performance standardsCalifornia’s performance standards
IMO CA IMO CA IMO CA IMO CA IMO CA IMO CAAlfa Laval Y Y Y N N/A Unknown Y Y Y Y
Degussa AG Y2 Y2Y Y N/A Unknown Y Y
Ecochlor Y Y Y Y N/A Unknown Y Y Y Y
ElectrichlorETI Y N N/A N
Ferrate Treatment Tech. N Y N N N
Greenship Y Y Y Y N/A Unknown Y Y Y Y
Hamann AG Y Y Y Y N/A N
Hi Tech Marine N/A
HitachiHyde Marine Y Y N/A Unknown Y Y
JAMS Y N Y Unknown N/A Unknown
JFE Engineering Corp.L. Meyer GMBHMARENCO Y Y Y N N/A Unknown
Maritime Solutions Inc.MH Systems N/A
Mitsubishi Heavy Ind.NEI Y Y Y Unknown N/A Unknown Y Y Y Y Y Y
NK0Nutech 03 Inc. Y Y N/A Unknown
OceanSaver Y Y N/A
OptiMarin Y N N/A Unknown3
Resource Ballast Tech.
RWO Marine Water Tech. Y4 Y4 Y5 Y5N/A
SeaKleen Y Y Y Y N/A Unknown Y Y
Severn Trent DeNora Y Y Y Y N/A Unknown
Techcross Inc. Y Y Y Y N/A Unknown
Unknown
Unknown
Unknown Unknown
Unknown
Unknown
Unknown
Unknown
Unknown Unknown
Unknown
Unknown Unknown Unknown
Unknown
Unknown
Manufacturer > 50 µm 10 - 50 µm E. coli V. cholerae< 10 µm1 Enterococci
Summary of Efficacy AssessmentSummary of Efficacy Assessment
EfficacyEfficacyOrganisms Organisms greater than greater than 50 50 µmµm
Organisms Organisms 10 – 50 10 – 50 µmµm
Organisms Organisms less than 10 less than 10 µmµm
E. coliE. coli Intestinal Intestinal enterococcienterococci
Vibrio Vibrio choleraecholerae
Number of Number of systems systems with results with results to reviewto review
1818 1717Bacteria: Bacteria:
1515
Viruses: 2Viruses: 21010 99 66
Number of Number of systems systems that meet that meet StandardStandard
1414 88Bacteria: Bacteria:
00
Viruses: 0Viruses: 077 33 22
• 4 systems meet standards for 4 size classes• 2 systems meet standards for 3 size classes• 5 systems meet standards for 2 size classes• 3 systems meet standards for 1 size class• 4 systems do not meet any (0) size classes
AvailabilityAvailability
Function of market demand, system production, Function of market demand, system production, government approval, and efficacy government approval, and efficacy considerationsconsiderations
How many vessels will be subject to regulation How many vessels will be subject to regulation (BW capacity <5000 MT) in 2009?(BW capacity <5000 MT) in 2009?
79183
2711
0
500
1000
1500
2000
2500
3000
<1500 1500 - 5000 >5000
Ballast Water Capacity (MT)
Nu
mb
er o
f V
esse
ls D
isc
ha
rgin
g in
CA
(2
000
- Ju
ne
, 200
7)
AvailabilityAvailability
Many systems will be Many systems will be commercially available by commercially available by 20092009
Lack of federal standards Lack of federal standards & system approval & system approval mechanisms may be mechanisms may be hindrance to market hindrance to market demanddemand
Because no single Because no single system meets CA system meets CA standards, none truly standards, none truly available at this timeavailable at this time
Environmental ImpactsEnvironmental Impacts
21 of 28 systems use biocide/active substance 21 of 28 systems use biocide/active substance and will require toxicological testing and analysisand will require toxicological testing and analysis
Several systems have been evaluated and Several systems have been evaluated and approved for use by International Maritime approved for use by International Maritime Organization (IMO) and State of WashingtonOrganization (IMO) and State of Washington Preliminary guidance as to system acceptabilityPreliminary guidance as to system acceptability
No evaluation procedure in CA yetNo evaluation procedure in CA yet Commission Staff working with SWRCB and Commission Staff working with SWRCB and
RWQCB to identify applicable water quality RWQCB to identify applicable water quality controls plans and regulationscontrols plans and regulations
Assessment of Environmental ImpactsAssessment of Environmental Impacts
ManufacturerManufacturer ApprovalsApprovals
Alfa LavalAlfa Laval IMO Basic, IMO FinalIMO Basic, IMO Final
Degussa AGDegussa AG IMO Basic, WA ConditionalIMO Basic, WA Conditional
EcochlorEcochlor WA ConditionalWA Conditional
Hamann AGHamann AG IMO Basic (Peraclean)IMO Basic (Peraclean)
Japan Assoc. Marine SafetyJapan Assoc. Marine Safety
NK03NK03 IMO BasicIMO Basic
RWO Marine Water TechnologyRWO Marine Water Technology
SeaKleenSeaKleen WA Single TestWA Single Test
Severn Trent DeNoraSevern Trent DeNora WA ConditionalWA Conditional
Techcross Inc.Techcross Inc. IMO BasicIMO Basic
ConclusionsConclusions
Current lack of efficacy and environmental Current lack of efficacy and environmental testing and evaluation procedures makes testing and evaluation procedures makes it unlikely systems will be available by it unlikely systems will be available by 20092009
Commission staff will continue to gather Commission staff will continue to gather information on and support research information on and support research addressing technology development and addressing technology development and system evaluationsystem evaluation
Systems will meet CA standards in futureSystems will meet CA standards in future
Recommendations to the LegislatureRecommendations to the Legislature
Change initial implementation date for new Change initial implementation date for new vessels with a ballast water capacity less vessels with a ballast water capacity less than 5000 metric tons from 2009 to 2010than 5000 metric tons from 2009 to 2010
Authorize the Commission to Authorize the Commission to amend reporting requirementsamend reporting requirementsvia regulationsvia regulations
Support continued research Support continued research promoting technology promoting technology developmentdevelopment
Looking ForwardLooking Forward
Treatment system testing and evaluation Treatment system testing and evaluation guidelines guidelines
Protocols and criteria for verification of Protocols and criteria for verification of compliance with performance standardscompliance with performance standards
Work with SWRCB to identify applicable Work with SWRCB to identify applicable water quality requirementswater quality requirements
Support alignment of testing and evaluation Support alignment of testing and evaluation guidelines along the West Coastguidelines along the West Coast
Testing GuidelinesTesting Guidelines
Recommended testing guidelines instead Recommended testing guidelines instead of CSLC-approval of systemsof CSLC-approval of systems
Self-certification procedure for use by Self-certification procedure for use by technology developers and 3technology developers and 3rdrd party party independent testing labsindependent testing labs
Should reduce use of tests inconsistent Should reduce use of tests inconsistent with California standards with California standards
Will be made available to industry in late-Will be made available to industry in late-20082008
Compliance Verification ProtocolsCompliance Verification Protocols
Procedures to verify vessel compliance Procedures to verify vessel compliance with discharge standardswith discharge standards
Detailed protocols – how to sample, where Detailed protocols – how to sample, where to sample, chain of custody, labs to to sample, chain of custody, labs to conduct analysis, fees for testing, conduct analysis, fees for testing, timeframetimeframe
Plans to complete regulatory process by Plans to complete regulatory process by late-2008late-2008
The ProcessThe Process
Technical advisory panel meeting beginning in Technical advisory panel meeting beginning in January 2008January 2008
Two main components: administration and Two main components: administration and technical aspectstechnical aspects
Work with USCG to standardize assessment Work with USCG to standardize assessment methods as much as possible with future federal methods as much as possible with future federal programprogram
Questions?
Photo courtesy of the Smithsonian Environmental Research Center
More information: