April 28, 2010



## A Great Lakes Relevancy Preamble

to the

GSI Report on Land

‐ Based Testing Outcomes

for the Siemens SiCURETM Ballast Water Management System

Allegra Cangelosi, PI

Siemens SiCURE TM Ballast Water Management System performance evaluation tests were

undertaken at the Great Ships Initiative (GSI) land

‐ based test site in Superior, WI in September and

October 2009. The independent GSI tests were arranged under agreement with the Siemens Water

Technologies for submission to the German Administration which is considering type approving the

system. The GSI report, Report of the Land

‐ Based Freshwater Testing of the Siemens SiCURETM Ballast

Water Management System, on the performance of the SiCURETM system in the fresh water context was

therefore prepared specifically for use by the German Administration in making a determination as to

whether the system performed in keeping with the International Maritime Organization (IMO)

standards.

The GSI land

‐ based tests showed the SiCURETM system performance to be in keeping with IMO

standards for biological performance and U.S. EPA discharge limits for residual chlorine. However, Great

Lakes regulators, advocates and maritime industry representatives may wish to know how relevant the

test outcomes are to potential biological performance in the Great Lakes. In particular,

 What was the system’s effectiveness relative to the taxonomic categories of organisms in the

Great Lakes, which may differ in size and morphology from their counterparts in brackish and

saltwater systems?

 How did biological performance in these tests relate to potential performance relative to New

York, Wisconsin or Minnesota ballast discharge standards?

 How did residual toxicity of discharge relate to State chemical discharge standards?

In addition, the Siemens Water Technologies designed the SiCURETM system to meet the needs of

ships that have long voyages and large ballasting flow rates. How applicable currently, or potentially, is

this technology from an operational performance standpoint to ships that trade in the Great Lakes?

For example,

 In what ways is the system currently compatible to Great Lakes fleets and trades? Special

operational considerations include:

o Salty and Canadian laker fleet: Voyage durations of days to weeks for ships in the salty

fleet; andApril 28, 2010

o U.S. laker fleet: Voyage duration of hours to days; no anticorrosion coatings on interiors

of U.S. laker ballast tanks; entirely fresh water voyages; possibility of multiple ballast

pumps and very high ballast flow rates.

 What adaptations might be necessary to enhance applicability?

 What is the general cost of this system?

This preamble addresses these Great Lakes

‐ relevant questions. The factual information on

treatment performance in terms of biological effectiveness and environmental soundness provided here

is derived entirely from the GSI 2009 test outcomes. Opinions provided regarding readiness for

adaptation to operational parameters of Great Lakes relevant fleets are those of the Siemens Water

Technologies.

Great Lakes Relevant Biological Performance Considerations

All information derived from 2009 GSI land

‐ based tests

1. Great Lakes Special Consideration 1: “Below the Radar” Zooplankton

The GSI land

‐ based tests showed the Siemens SiCURETM system to be capable of consistently meeting

International Maritime Organization (IMO) standards for biological performance

. The IMO standards

related to plankton are rooted in size classes (e.g., 10

– 50 μ m in minimum dimension, >50 μ m in

minimum dimension) rather than taxonomic categories (e.g., zooplankton, phytoplankton). These size

delineations relate well to the taxonomic delineations in brackish and salt water assemblages. In the

freshwater assemblages, however, the zooplankton can run smaller than in saltier environments, and

some segment of the population will be below 50 μm in minimum dimension. Though this undersized

segment of the overall zooplankton population can be small, it can also be most adept at withstanding

filtration, depending upon filter pore size. Consequently, a treatment system which technically meets

the IMO standard for the >50 μ m size category in salt water may or may not deliver the same

performance relative to zooplankton generally in the natural freshwater context.

During these tests, the generally undersized (<50 μm in minimum dimension) Lecanid rotifer was rarely

detected in intake or control discharge samples in which live zooplankton numbered in the hundreds of

thousands. However, in treated discharge where most if not all of the larger zooplankton were been

removed by the 50 μm filtration component of the treatment system, from 1 to 5 live Lecanid rotifer

individuals per cubic meter were detected. Table 1 contrasts performance relative to the size class

regulated under the IMO standard (greater than 50 μ m) versus zooplankton generally.April 28, 2010

Table 1: Average Density (per m 3 ) of Live Zooplankton in Treatment Discharge

during the Trials of the SiCURETM System.

Test Trials: Trial A Trial B Trial C Trial D Trial E

Total Vol. Treatment Discharge Analyzed, m 3 : 3.84 3.96 6.11 5.97 6.05

Greater than 50 μ m (min. dimension)

Taxa Group Species Avg.

Density

(per m 3 ) Avg.

Density

(per m 3 ) Avg.

Density

(per m 3 ) Avg.

Density

(per m 3 ) Avg.

Density

(per m 3 )

Arachnida Mite 0.17

Cladocerans Bosmina 0.17

Daphnia 0.17

Copepods Copepod 0.79 0.17

Diptera Chironomid 2.08 4.03 2.79 2.36 0.66

Nematoda Nematode 0.33

Ostracoda Ostracod 0.17

Dreissena Dreissenid (Zebra Mussel) 0.50

Nauplii Copepod Nauplii 1.56 2.52 1.32 0.34 0.66

Tardigrade Tardigrade 0.49

Rotifers Bdelloid 0.52 0.33

Keratella 0.33

Greater than 50 μ m (min. dimension) Total: 4.95 7.54 4.44 4.04 1.49

Less than 50 μ m (min. dimension)

Taxa Group Species Avg.

Density

(per m 3 ) Avg.

Density

(per m 3 ) Avg.

Density

(per m 3 ) Avg.

Density

(per m 3 ) Avg.

Density

(per m 3 )

Rotifers Lecanidae 5.21 12.57 7.52 3.02 0.99

Less than 50 μ m (min. dimension) Total: 5.21 12.57 7.52 3.02 0.99

Live Zooplankton Total: 10.16 20.11 11.96 7.06 2.48

2. Great Lakes Special Consideration 2: State Level Performance Standards Stricter than IMO

The States of Wisconsin and New York have issued ballast discharge standards that are 100 to 1000

times stricter than those contained in the IMO Convention. Based on the GSI tests, it is clear that the

version of the treatment system evaluated at GSI, though it may meet the IMO standards, would not

also meet the stricter state standards. Live zooplankton concentrations in the discharge from the GSI

test facility samples would have had to have been far fewer than 1 per cubic meter, essentially a “non

‐

detect”, across all five trials, for it to be considered possible that the treatment could meet a standard

even just 10 times higher than the IMO benchmark. In such a case, retesting with greater volumes of

water or a greater number of replicates would be warranted to estimate to what extent theApril 28, 2010

performance may exceed the IMO standard. But in these tests, densities of organisms in treated

discharge in the regulated size class were always above 1 per cubic meter, and so no additional testing

was needed. It is worth noting however, that the treatment was nonetheless highly effective, with

densities encountered in the treated discharge 5 to 6 orders of magnitude lower than control

(untreated) discharge.

3. Great Lakes Special Consideration 3 : Total Residual Chlorine and State Discharge Standards

The undiluted discharge from this treatment process during the GSI land

‐ based tests was consistently

within U.S. EPA discharge limits for residual chlorine (0.1 mg/L, total residual chlorine or TRC). Upon

reaching a receiving system with dissolved organic compounds in it, this TRC level can be expected to

further decrease rapidly. However, there are special circumstances that limit prospective applicability of

this version of the SiCURETM system to ships in the Great Lakes trade. First, the discharge level of TRC

achieved in the GSI tests followed a five day tank retention period (required for IMO

‐ consistent tests); a

shorter retention period likely would have resulted in discharge concentrations exceeding this level. As

noted in table 2, U.S. lakers and Canadian laker voyages are hours to days, as opposed to five days or

more. It is possible that the retention period requirement could be met in certain voyages of some salt

water vessels that visit the Great Lakes, but not consistently.

In addition, under the Clean Water Act, some states like Wisconsin have established water quality

standards which prohibit the discharge of chlorine above the established final acute value (FAV) of 0.04

mg/L Cl 2, less than one half the national U.S. EPA criterion (table 3). In Wisconsin, an acute daily

maximum of38 ug/l (0.038 mg/l) also is a water quality based limit, applicable at the end of the pipe (no

mixing zone). Therefore, to comply with the Wisconsin state standard, the discharge would have to be

actively neutralized or held even longer than 5 days for the chlorine to dissipate, prior to discharge.

In conclusion, as a practical matter, the SiCURETM system would require a modification, specifically the

addition of a neutralization step with another chemical such as sodium bisulfate, for it to have wide

applicability to Great Lakes fleets. Fortunately, in recent weeks, Siemens has designed and

implemented this modification such that neutralization occurs on an “as needed” basis, and is

conducting land

‐ based testing of the revised system in brackish water. They have not yet trialed the

modification in freshwater.April 28, 2010

Table 2. Physical Characteristics of Relevant Fleets/Trades of the

Great Lakes-St. Lawrence Seaway System.

Type of vessel Approx.

number of

vessels in

global fleet Average

Length (m) Average

Beam (m) Ballast

capacity (m 3 ) Typical 1

number of

ballast

pumps (#) Typical

ballast pump

rate per

pump

(m 3 /hour) Typical 1

voyage

duration

(range)

Seaway-sized

bulk carrier 1,028 2 180 23 12,000 2 690 Days to

weeks

Seaway-sized tanker 5,495 2 135 23 5,000 2 300 Days to

weeks

Seaway-sized

general cargo carrier 12,048 2 178 23 8,000 2 900 Days to

weeks

United States Laker 41 230 24 20,000 2 2,400 Hours to

days

United States

1000 ft Laker 11 303 32 50,000 4 2,900 Hours to

days

Canadian Laker 80 190 21 15,000 2 1,000 – 2,000 Hours to

days

1 There are exceptions.

2 Information from a 2001 vessel fleet analysis con ducted by Lloyd’s Maritime Information Services of

London for the St. Lawrence Seaway Development Corporation. Analysis determined that 41,909

vessels, representing 69.7 percent of the world’s fleet, are small enough to enter the St. Lawrence

Seaway.

Table 3. State Residual Chlorine Discharge Standards.

State Chlorine Discharge

Standard (mg/L)

Indiana 0.02 (daily max.)

Illinois 0.05

Michigan 0.038

Minnesota 0.038

New York 0.005*

Ohio 0.038

Wisconsin 0.038

*Allowances incorporating dilution criteria when permitting can result in a range of

0.05-2.0 mg/L depending on the water classification for the discharge location.April 28, 2010

Great Lakes Relevant Operational Performance Considerations

All information supplied by the Siemens Water Technologies

1. In what ways is the system currently operationally compatible to Great Lakes fleets and trades?

What adaptations may be necessary?

The standard design for the Siemens SiCURETM Ballast Water Management System uses sea water as a

source of supply to produce sodium hypochlorite. However, the electrolytic cells in the SiCURETM system

are installed in a side stream of the main ballast intake, and just a fraction of the ballast water flow is

required to produce sufficient sodium hyplochlorite to treat the main ballast flow. This opens

opportunities for the adaptation of the Siemens’ SiCURETM system for the range of Great Lakes

‐ relevant

fleets. Canadian laker and salty vessels have access to salt water over the course of their voyage pattern

to serve this purpose. Siemens has designed a system that allows ships to take salt water onboard while

operating in salt water, store it in a designated ballast tank and use this water to feed the electrolytic

generator during the ballast operation.

U.S. lakers never ply salt water. However, the SiCURETM design can be customized to use salt water from

an alternative source, not the incoming or stored onboard ballast water. For the vessels with trade

routes limited to the Great Lakes boundaries, the applicability of the SiCURETM will be subject to

availability of this alternative source of salt for the side stream.

While Siemens does not expect the SiCURETM system to raise corrosion issues, Siemens will be

completing its corrosion testing program under the supervision of Germanischer Lloyds and in

cooperation with ThyssenKrupp and International Paint in the second half of 2010. A circumstance of no

interior coating on the ballast tank will be taken into consideration in this evaluation.

The SiCURETM system can be used for medium to high ballast water flow ranges. With respect to the

shorter voyage durations, the system may be modified for this application.

2. What is the general cost of the SiCURETM system?

SiCURETM Ballast Water Management System will be offered at a list price range from about U.S.

$500,000 to U.S. $1.000.000 depending on size and configuration (prices given for 200 m 3 /h and 2000

m 3 /h systems).