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Table 2
Preliminary comparison of the cost and cffectiveness of ballast water compliance verification alternatives
Method
Cost
Effectiveness
Reporting: Mandatory reporting by shipowner, master, operator, or person
in charge that BWTS has been installed, maintained, and used properly
and that it is performing adequately to achieve BW discharge standards.
Nearly zero
a
Very low
b
Inspections: Random or targeted onboard inspections of BWTS.
Relatively low
c
Relatively low
d
Monitoring (indirect measurement): Use of sensors and data reported out
by sensors to determine if BWTS is operating properly to infer
compliance or to determine if BW meets discharge standards.
Moderate
Installation:
$
5000–
$
10,000/vessel
Operation:
$
3,000/year/vessel
e
Relatively high
f
Sampling (direct measurement): Direct sampling and analysis of BW
discharge to determine if it meets BW discharge standards.
Very high
$
75,000–
$
125,000/vessel/
sampling event
g
Low–very high
h
Note:
Abbreviations
=
BWTS, ballast water treatment system; BW, ballast water, USCG, U.S. Coast Guard; IMO, International Maritime Organization.
a
Verification merely involves reviewing paperwork.
b
There is a high likelihood of misreporting and difficulty detecting misreporting.
c
USCG inspections of BWTS can be incorporated into the current USCG vessel inspection program.
d
Inspections of BWTS equipment cannot assure that equipment has been installed, maintained, and operated properly to achieve BW discharge standards.
e
Based on integrated water quality sensor packages placed on commercial vessels of opportunity for oceanographic research. Validation of sensor performance
and sensor output correlation with treatment system performance is critical prior to adoption of indirect measurements.
f
BWTS that are operated properly, especially if they are not installed or maintained properly, may not successfully treat BW at all times. On the other hand,
sensors designed to verify that BW discharge meets standards (e.g., conditions exist or have existed that are “proven” to adequately eliminate or kill organisms
to meet BW standards) can be very effective.
g
Because of the large volumes (and high flow rates) of ballast water being discharged and the relatively small concentrations of living organisms allowable,
a great deal of ballast water must be sampled and analyzed to make a statistically reliable determination that discharge does or does not meet standards. Draft
US EPA Environmental Technology Verification Program “Generic Protocol for the Verification of Ballast Water Treatment Technologies” suggest that 60 m
3
of water may need to be sampled and analyzed to determine if a treatment system meets IMO and Phase One U.S. discharge regulations with 95% confidence.
Actual costs, of course, depend on the intensity of sampling (% of ballast water analyzed per vessel) and the extent of sampling (% of vessels sampled). Cost
estimate based on current costs of shipboard testing of BWTS for certification.
h
Confidence in verification of BW discharge based on direct sampling depends on the intensity of sampling (% of BW analyzed per vessel) and the extent of
sampling (% of vessels sampled). In general, low and even moderate sampling results in relatively low confidence that BW discharge violations are detected.
Only intensive and extensive sampling (at very high cost) results in high levels of confidence that BW discharge violations will be detected.
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