I:\MEPC\57\2-7.doc 

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INTERNATIONAL MARITIME ORGANIZATION

IMO 

E

MARINE ENVIRONMENT PROTECTION 

COMMITTEE 

57th session 

Agenda item 2 

MEPC 57/2/7

 20 December 2007

 Original: ENGLISH

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER 

Application for Basic Approval of a combined ballast water management system consisting of 

sediment removal and an electrolytic process using seawater to produce Active Substances 

(Greenship Ltd) 

Submitted by the Netherlands 

SUMMARY

Executive summary: This document contains non-confidential information for Basic 

Approval of a combined system consisting of sediment removal and 

an electrolytic process using seawater to produce Active Substances, 

as required by the Procedure for approval of ballast water 

management systems that make use of Active Substances (G9). 

Relevant documents together with the application dossier will be 

submitted to the Marine Environment Division of the Organization for 

review by the GESAMP-Ballast Water Working Group in accordance 

with Procedure (G9). 

Action to be taken: Paragraph 6 

Related documents: BWM/CONF/36; MEPC 53/24/Add.1; MEPC 55/2/16; MEPC 56/2/2 

and BWM.2/Circ.10 

Introduction 

1 Regulation D-3.2 of the International Convention for the Control and Management of 

Shipsí Ballast Water and Sediments stipulates that ballast water management systems that make 

use of Active Substances to comply with the Convention shall be approved by the Organization. 

2 The Procedure for approval of ballast water management systems that make use of 

Active Substances (G9), as adopted by resolution MEPC.126(53), defines the principal aspects to 

be documented by data or testing (MEPC 53/24/Add.1, annex 4, paragraph 4.2.1) and some basic 

principles for risk evaluation (MEPC 53/24/Add.1, annex 4, paragraph 5.3). According to 

section 6 of Procedure (G9) the Organization should evaluate the information provided in the 

application. 
MEPC 57/2/7 - 2 - 

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3 According to circular BWM.2/Circ.10, proposals for approval of ballast water 

management systems that make use of Active Substances are to be submitted to the Marine 

Environment Division of the Organization to be reviewed by the GESAMP-Ballast Water 

Working Group. In the meantime, a document on the proposal for approval containing all the 

non-confidential data related to the respective ballast water management system that makes use 

of Active Substances needs to be submitted to the MEPC.

4 The competent authority in the Netherlands has verified the application dossier prepared 

by Greenship Ltd. and believes it to satisfy the data requirements of Procedure (G9). 

5 The Netherlands therefore submits the non-confidential part of the applicantís dossier in 

the annex to this document to the Organization for evaluation according to Procedure (G9). 

The complete dossier will be made available to the experts of the GESAMP-Ballast Water 

Working Group. 

Action requested of the Committee 

6 The Committee is invited to consider the proposal for approval and decide as appropriate. 

*** 
MEPC 57/2/7 

I:\MEPC\57\2-7.doc 

ANNEX 

NON-CONFIDENTIAL INFORMATION ON THE COMBINED BALLAST WATER 

MANAGEMENT SYSTEM CONSISTING OF SEDIMENT REMOVAL AND AN 

ELECTROLYTIC PROCESS USING SEAWATER TO PRODUCE ACTIVE 

SUBSTANCES DEVELOPED BY GREENSHIP LTD (THE NETHERLANDS) 

This annex follows the requirements for application as presented in the Methodology for 

information gathering and the conduct of work of GESAMP-BWWG (the Methodology, 

MEPC 56/2/2, annex 4) and has the following content:

Chapter 1: Introduction 

Chapter 2: Description of the system and the production of Active Substance and Relevant 

Chemicals 

Chapter 3: Data sets and risk characterization of Active Substance and Relevant Chemicals 

(Methodology, sections 3 and 6) 

Chapter 4: Toxicity evaluation of treated ballast water 

Chapter 5: Risk assessment (Methodology, section 7) 

Chapter 6: Assessment report (Methodology, section 8) 

References 

NB: The applicant has not reported on sections 4 and 5 of the Methodology (MEPC 56/2/2, 

annex 4). Since no chemicals are added a material data safety sheet seems redundant. 

The information requirements as described in chapter 4 are either redundant or will be provided 

in the application for Final Approval (e.g., technical manual). 

1 INTRODUCTION 

The applicant proposes a ballast water management system (BWMS) that combines removal of 

sediment at ballasting with disinfection, using seawater in an electrolytic process to produce 

Active Substances for the deactivation of biota, at ballasting and de-ballasting. This application is 

based on the Procedure for approval of ballast water management systems that make use of 

Active Substances (G9). 

The BWMS is capable of removing sediment-particles > 20 μm with an efficiency of 100% and 

sediment-particles of > 10 μm with an efficiency of > 80%. The treated water is subsequently 

disinfected by Active Substances generated in an electrolytic cell with a killing efficiency of 

over 99.99%. Upon completion of treatment, the ballast water complies with the D-2 standard of 

the BWM Convention. The capacity of the BWMS is modular: it can handle ballast water flows 

ranging from 50 m3

/hr up to 5.000 m3/hr and even more. 

The seawater electrolytic process produces Free Active Chlorine (FAC) from natural seawater 

taken on board. The applicantís in-line disinfecting technique can be successfully implemented 

in a wide range of applications. Using the salt present in the water, the electrolytic cell 

produces 0.5 ñ 3 ppm FAC. FAC is widely applied for the disinfection of water. The major 
MEPC 57/2/7 

ANNEX 

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advantage of this type of electrolytic cell is the long-lasting coating. The electrolytic cells can 

disinfect with a minimum of maintenance (a once a year cleaning is all that is required) for the 

duration of approximately three to five years. 

The applicant believes that the BWMS is a safe and economical system for ships and crews 

applicable without the storage of chemicals on board. Water chlorination is a safe and reliable 

disinfection procedure used worldwide for drinking water production. 

After FAC has deactivated micro-organisms in ballast water, it will decompose rapidly into 

harmless chloride ions, a natural component of seawater, through spontaneous decomposition by 

reactions with organic matter in natural seawater. FAC has no persistence or bioaccumulation in 

water. 

The applicant evaluated the toxicity of seawater treated with electrolytically generated FAC by 

toxicity tests and using literature data. The results of these evaluations indicate that the influence 

on the environment of the discharges after treatment by the BWMS is negligible. 

2 DESCRIPTION OF THE SYSTEM AND THE PRODUCTION OF ACTIVE 

SUBSTANCE AND RELEVANT CHEMICALS 

Greenshipís Ballast Water Management System (BWMS) 

Greenshipís BWMS consists of a multi-hydrocyclone system for removal of larger particles and 

organisms, followed by disinfection with an electrolytic cell. The electrolytic cell produces FAC 

from chloride in seawater, which is extremely potent in breaking down micro-organisms and 

bacteria. No substances are added to the process. 

2.1 General description of the system

2.1.1 System Components 

The BWMS consists of the following two modular components: 

- the Sedimentor: The sediment removal system removes sediment and biota 

during intake; resulting in 100% removal for particles of 20 micron and bigger 

and 80% removal for particles of ≥10 micron. The remaining sediment particles 

stay in suspension and will leave the ballast tanks during de-ballasting; and 

- the Termanox: The electrolytic cell decimates all bacteria and organisms. 

Together with the Sedimentor the electrolytic cell achieves a killing rate 

of 99.99%. 
MEPC 57/2/7 

ANNEX 

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Figure 2.1: Picture of the 50m3/hr laboratory-based test unit for ballast water treatment 

with a Sedimentor and an Electrolytic cell 

The sediment removal system ìSedimentorî 

Greenship developed a revolutionary system preventing sedimentation of suspended solids in 

ballast tanks: not only does the system fight the pollution of the ballast water; it even prevents the 

cause of the consolidating mud problem. With tons of sediment in the ballast tanks, a ship 

consumes more fuel and transports less cargo. In recent calculations, it appears that there is an 

economic profit on fuel consumption up to 3% and even more through separation of sediment 

from ballast water (source: Chemgas, the Netherlands) which provides a very attractive pay back. 

2.1.2 The electrolyse system: Termanox

The electrolytic cell kills effectively bacteria and organisms. Together with the Sedimentor, the 

electrolytic cell achieves a killing rate of 99.99%. This secondary stage of the BWMS consists of 

a dedicated electrolytic cell, which was especially engineered for this specific application. 

The ìkilling efficiencyî of this electrolytic process is based on the electrolysis of chloride from 

seawater. Greenshipís disinfecting technique can be successfully implemented in a wide range of 

applications. Using the chloride in the water, the electrolytic cell produces hypochlorite. 

The Termanox is like the Sedimentor engineered from modular components. The system enables 

the construction of any capacity required in m3

/hour, and can be tailored to the same volume 

requirements as the Sedimentor. 
MEPC 57/2/7 

ANNEX 

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For the optimum performance of the electrolytic cell, it is of great importance to reduce the 

amount and size of sediment particles. Fouled seawater may lead to deposits building up on the 

anodic and cathodic electrodes effectively reducing their efficiency. By using the Sedimentor in 

combination with the electrolytic cell, a trouble-free operation can be guaranteed. 

The Electrolysis of Aqueous NaCl 

Figure 2.2: An idealized drawing of a cell in which an aqueous solution of 

sodium chloride is electrolysed

NaCl (s) + H2O (l) ! Na+ (aq)+ Cl- (aq) 

The Na+ ions migrate toward the negative electrode and the Cl- ions migrate toward the positive 

electrode. There are two substances that can be reduced at the cathode: Na+ ions and water 

molecules. 

Cathode (-): 

 Na+ + e- Na Eo

red = -2.71 V 

 2 H2O + 2 e- H2 + 2 OH- Eo

red = -0.83 V 

Because it is much easier to reduce water than Na+ ions, the only product formed at the cathode is 

hydrogen gas. 

Cathode (-): 2 H2O(l) + 2 e- H2(g) + 2 OH-

(aq) 

There are also two substances that can be oxidized at the anode: Cl- ions and water molecules. 

Anode (+): 

 2 Cl- Cl2 + 2 e- Eo

ox = -1.36 V 

 2 H2O O2 + 4 H+ + 4 e- Eo

ox = -1.23 V 

The standard-state potentials for these half-reactions are so close to each other that we might 

expect to see a mixture of Cl2 and O2 gas collect at the anode. In practice, the only product of this 

reaction is Cl2. 

Anode (+): 2 Cl- Cl2 + 2 eIn summary, electrolysis of aqueous NaCl solutions gives a mixture of hydrogen and chlorine gas 

and an aqueous sodium hydroxide solution. 

 

2 NaCl(aq) + 2 H2O(l) 2 Na+

(aq) + 2 OH-(aq) + H2(g) + Cl2(g) 
MEPC 57/2/7 

ANNEX 

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The products of the electrolysis of aqueous sodium chloride react with water to form sodium 

hypo-chlorite. 

 Cl2(g) + H2O(l) HOCl(aq) + H+ (aq)+ Cl- (aq) 

 HOCl (aq) H+ (aq) + ClO- (aq) 

2.2 Results of laboratory tests 

2.2.1 Test unit 

For determining the performance of the BWTS, a test was executed with a laboratory test unit 

with a capacity of 50 m3

/h. The experiments took place at the NHL University for Professional 

Education, Leeuwarden, The Netherlands on 22 June 2005 and were witnessed by 

Mr. T. Henstra of Lloydís Register EMEA. 

The feed was technical seawater which consisted of a suspension of sediment collected from 

ballast water tanks from several ships. The feed is separated with the Sedimentor in a 

concentrated underflow with the bigger suspended solids which is returned to the sea (in the test 

this is a buffer tank) and an overflow with the smaller suspended solids which was treated with 

the electrolytic cell for disinfection of the water and transported to the ballast tank/sea (in the test 

this is a buffer tank or sewer). 

2.2.2 Purpose of the experiments 

The test is divided in two experiments, namely: 

Sedimentor test: In this test the separating efficiency of the Sedimentor is determined 

with the following conditions: 

- pressure difference of 2 bar and a reflux of 0,3 (the fraction which is returned to 

the sea = underflow divided by the sum of the overflow) 

- sediment suspended in feed in a concentration between 1-5 wt% 

- salt concentration of 35 PSU 

Killing test: In this test the killing efficiency of the electrolytic cell is determined on 

heterotrophic bacteria in a minimum concentration of 104 colony forming units per 

millilitre (cfu/ml). The conditions of the Sedimentor and the technical seawater are equal 

to the conditions in the Sedimentor test. The electrolytic cell is used with a maximum 

current output (=25 Ampere). 

2.2.3 Results and discussion 

Based on the results of the Sedimentor test, it can be concluded that 100% removal is achieved 

for particles of 20 μm and bigger. For particles of 10 μm, 80% removal is achieved. This means 

that the particles that pass the electrolytic cell vary from 0 ñ 20 μm. But the biggest load is 

smaller than 10 μm, namely, 80%. Viable organisms include thereby mostly plankton, algae, 

bacteria and viruses. These organisms can be effectively treated with the electrolytic cell 

(see table 2.1). 
MEPC 57/2/7 

ANNEX 

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Figure 2.3: Separation curve for the Sedimentor

According to the Guidelines for approval of ballast water management systems (G8), test 

organisms may be either naturally occurring in the test water, or cultured species that may be 

added to the test water (paragraph 2.3.18 of Guidelines (G8)). For influent water, heterotrophic 

bacteria should be present in a density of at least 104

 living bacteria per millilitre 

(paragraph 2.3.19.3 of Guidelines (G8)). Samples during the test should be taken at the 

following times and locations: immediately before the treatment equipment, immediately 

after the treatment equipment and upon discharge (paragraph 2.3.25 of Guidelines (G8)). 

In order to be sure to obtain a final concentration of 104 cfu/ml indicator bacteria in the buffer 

tank of the test unit, 300 ml of E. coli in a concentration of 108

 cfu/ml has been added. After 

determining the total amount of bacteria in the buffer tank the concentration turned out to 

be 105

 cfu/ml. Sampling took place simultaneously before and after the electrolytic at three 

points in time, namely, after 1, 2 and 3 minutes. Samples were immediately processed in the 

laboratory. 

Results of this test of the electrolytic cell unit show a killing efficiency of 99.99% (or log 4). 

The influent test water contained a representative amount of bacteria (105

 cfu/ml) and at a setting 

of 25 Ampere, the colony count, after passing the electrolytic unit, showed 

after 1 minute 30 colonies and after 2 and 3 minutes less than 10 colonies per milliliter 

(see table 2.1). According to regulation D-2 of the Convention, Vibrio cholerea should be less 

than 1 cfu per 100 ml ballast water, whereas E.coli must be less than 250 cfu/ml and intestinal 

Enterococci must be less than 100 cfu/ml. 

Separation curve

0

20

40

60

80

100

120

0 20 40 60 80 100

diameter (μm)

percentage

∆P = 2bar;

reflux = 0,3;

salt content =

35 PSU;

Temperature

= free
MEPC 57/2/7 

ANNEX 

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Table 2.1: Killing efficiency of electrolytic cell

Concentration 

sodium hypochlorite 

produced with 25 A[ppm] 

Colony Count [CFU/ml] 

10,8 Before electrolytic cell After 

electrolytic cell Killing efficiency (%) 

 sample 1 

 sample 2 

 sample 3

 1,80E+05 30 

 2,10E+05 < 10 

 2,60E+05 <10

99.983 

99.995 

99.996 

Medium control 

Blank 

 No growth 

 1,20E+05 

conclusion: log 4-5 (99.99%) 

killing efficiency 

 Legend Medium control: Non-inoculated plates

 Blank: Total count on sample from buffer tank before addition of test organism

From this result it can be concluded that the killing efficiency of the electrolytic cell is sufficient 

for the IMO regulated organisms smaller than 10 μm. Minimum load to be tested is, 

namely, 104

 cfu/ml. With a log 4 killing efficiency and a load of 104 cfu/ml, the concentration 

bacteria after the electrolytic cell would theoretically be 1 cfu per 100 ml. In practice the average 

will be less than 1 cfu/ml so it meets also the standard for Vibrio cholerea. After all lab-tests 

showed that Vibrio cholerea is more sensitive for hypochlorite than other bacteria. 

2.2.4 Final remarks 

Sediment layers that precipitate in ballast tanks form a substrate suitable for the survival of many 

benthic species and dormant stages of plank tonic species, while they decrease the effective 

volume of ballast tanks. The results prove that chlorination treatment is effective in killing 

bacteria in seawater. Results of earlier laboratory tests show that Greenshipís electrolytic cell 

needs 2 ñ 3 ppm sodium hypochlorite to achieve a satisfying killing efficiency in tap water 

with 35 PSU salt. The test with Greenshipís BWTS was performed with 10 ppm sodium 

hypochlorite on test water with 105

 cfu/ml of test organism (E. coli) and 35 PSU salt and 3.5 wt% 

of suspended solids of which 1% consists of Organic Carbon. This proves that sediment 

concentration is a significant contributor to sodium hypochlorite demand. Concentration of 

sediment in the test water is determined on 3.5 wt% (Total Suspended Solids), which is quite a 

heavy load of sediment. The concentration sediment is three times more concentrated than the 

Humber, a river known for its high concentration of sediment. 

The most important factor to ensure that sodium hypochlorite is effectively and conservatively 

applied as a biocide is to ensure that sediment loads are minimized as much as possible. The 

Sedimentor minimizes the loads of sediment significantly, which decreases the concentration of 

sodium hypochlorite needed, to achieve the killing efficiency on IMO regulated organisms. This 

ensures that not more then 10 ppm of sodium hypochlorite is needed. To ensure that enough 

sodium hypochlorite is used, one could monitor the residual concentration and keep the 

concentration between 0.5 and 2.0 ppm. 
MEPC 57/2/7 

ANNEX 

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In the test, no residue of sodium hypochlorite has been found in the ballast water. Residual 

measurements on sodium hypochlorite were performed within half an hour after sampling 

(see table 2.2). These measurements were performed with the ìFree Chlorine Checkî of 

SenSafeô with a minimal sensitivity of 0.05 ppm. Free chlorine refers to hypochlorite which is 

responsible for water disinfection and which has not reacted yet with the compounds in the water. 

 Table 2.2: Residual measurements on sodium hypochlorite in laboratory test samples 

Concentration 

sodium 

hypochlorite 

produced with 

25 A [ppm] 

Residual measurement on sodium hypochlorite within half an hour 

after sampling, using Free Chlorine Check of SenSafeô with 

minimal sensitivity of 0,05 ppm 

10,8 Before electrolytic cell After electrolytic cell 

sample 1 Negative negative 

sample 2 Negative negative 

sample 3 Negative negative 

Blank Negative 

 Blank: Sample from buffer tank before addition of test organism

These tests have been witnessed and the analyses have been reviewed and found in accordance 

with the test results by Lloydís Register. 

The above-mentioned tests were done in the summer of 2005. Later test programmes in 2006 

and 2007 showed that FAC is effective in the range of 0.5 ñ 3.0 ppm. Further tests for 

optimization of FAC concentration will be done during full-scale tests to prepare the application 

for Final Approval. 
MEPC 57/2/7 

ANNEX 

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2.3 Results of land-based tests 

2.3.1 Production of Active Substance and Relevant Chemicals 

It is common knowledge, that the production of Free Active Chlorine (FAC) in natural waters 

leads to the formation of halogenated by-products, like halogenated methanes and halogenated 

acetic acids. The applicant has tested the formation of such by-products during land-based tests 

of a complete BWMS with natural seawater. The results are the basis for the selection of 

Relevant Chemicals to provide data sets and risk characterization according the requirements of 

sections 4 and 5 of Procedure (G9). 

A BWMS with a capacity of 100m3/hr was installed on board of a moored ship in the harbour of 

Harlingen, the Netherlands, at the border of the Waddensea in August and September 2007. The 

BWMS was operated under normal harbour conditions. The 100m3/hr is representative for a 

normal complete system of Greenship. Greenship, as the manufacturer of the equipment, can 

demonstrate by using mathematical modelling and/or calculations, that any up scaling will not 

affect the ultimate functioning and effectiveness on board a ship of type and size for which the 

equipment will be certified. 

Samples for chemical analysis were taken and distributed to different specialized laboratories 

with full accreditation. Control samples for chemical analysis consisted of seawater treated with 

the Sedimentor only. 

Active Substance 

FAC and Total Residual Chlorine (TRC) were analysed by Omegam-Water, Wognum, the 

Netherlands. The analyses were performed according to NEN/EN/ISO 7393-2. Results are 

reported for control samples (TB), samples taken immediately after treatment with FAC (T0) 

and 30 (T30) resp. 120 (T120) minutes after treatment. Table 2.3 presents the results. 

 Table 2.3: Concentrations (mg/l) of FAC and TRC in natural seawater samples 

 Code: TB Code: T0 Code: T30 Code: T120 

TRC mg/l <0.01 2.38 1.83 1.15 

FAC mg/l <0.01 1.67 1.25 0.51 

Relevant Chemicals 

Halomethanes were analysed by Omegam-Laboratoria, Amsterdam, the Netherlands. The 

analyses of halomethanes were performed according to NEN/EN/ISO 15680. Results are 

reported for control samples (3473925), samples taken immediately after treatment with Active 

Substances (3473926), 30 minutes after treatment (3473927), 12 hours after treatment (3473928) 

and 24 hours after treatment (3473929). Table 2.4 presents the results. 
MEPC 57/2/7 

ANNEX 

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Table 2.4: Concentrations (μg/l) of chloro- and bromomethanes in 

treated natural seawater samples 

Reference number : 3473925 3473926 3473927 3473928 3473929

Organic compounds ñ chlorinated

Volatile chlorinated aliphates: 

Q dichloromethane μg/l < 1,0 < 1,0 < 1,0 < 1,0 < 1,0 

Q 1,1-dichloroethane μg/l < 0,5 < 0,5 < 0,5 < 0,5 < 0,5 

Q 1,2-dichloroethane μg/l < 0,5 < 0,5 < 0,5 < 0,5 < 0,5 

Q trans-1,2-dichloroethene μg/l < 0,5 < 0,5 < 0,5 < 0,5 < 0,5 

Q cis-1,2-dichloroethene μg/l < 0,5 < 0,5 < 0,5 < 0,5 < 0,5 

Q 1,2-dichloropropane μg/l < 0,5 < 0,5 < 0,5 < 0,5 < 0,5 

Q trichloromethane μg/l < 0,1 < 0,1 < 0,1 < 0,1 < 0,1 

Q tetrachloromethane μg/l < 0,1 < 0,1 < 0,1 < 0,1 < 0,1 

Q 1,1,1-trichloroethane μg/l < 0,1 < 0,1 < 0,1 < 0,1 < 0,1 

Q 1,1,2-trichloroethane μg/l < 0,1 < 0,1 < 0,1 < 0,1 < 0,1 

Q trichloroethene μg/l < 0,1 < 0,1 < 0,1 < 0,1 < 0,1 

Q tetrachloroethene μg/l < 0,1 < 0,1 < 0,1 < 0,1 < 0,1 

 sum C/T dichloroethene μg/l < 0,5 < 0,5 < 0,5 < 0,5 < 0,5 

 sum chloroalifates μg/l < 2,1 < 2,1 < 2,1 < 2,1 < 2,1 

Volatile chlorinated aliphates ñ remainder: 

 dibromomethane μg/l < 0,5 < 0,5 < 0,5 < 0,5 < 1,2 

 tribromomethane μg/l < 0,5 200 200 280 290 

 bromodichloromethane μg/l < 0,5 1,3 < 0,5 < 0,5 < 0,5 

 dibromochloromethane μg/l < 0,5 9,5 9,1 12 13

Haloacetic acids and chloroamines were analysed by RPS Analyse BV, Breda, the Netherlands. 

The analyses of haloacetic acids were performed by GC-MS. Results are reported for control 

samples (3973470), samples taken immediately after treatment with Active Substances 

(3973471), 30 minutes after treatment (3973472), 12 hrs after treatment (3973473) and 24 hrs 

after treatment (3973474). Table 2.5 presents the results for haloacetic acids (see also annex 3). 

The chloroamines were analysed in another programme of NHL University for disinfection of 

fresh surface water. Salt was added to fresh surface water in a concentration of 24 g/l and 10 ppm 

FAC was produced by the electrolytic cell. The analyses were performed by titration. In the 

treated surface water no chloroamines were detected with a detection limit of 0.5 mg/l. 

Table 2.5: Concentrations (μg/l) of haloacetic acids in treated 

natural seawater samples

Reference number: 3973470 39734701 3973472 3973473

 3973474 

Haloacetic acids (Method: GC-MS) 

Chloroacetic Acid μg/l < 1 < 1 < 1 < 1 < 1 

Dichloroacetic acid μg/l < 1 < 1 < 1 < 1 < 1 

Trichloorazijnzuur μg/l < 1 < 1 < 1 < 1 < 1 

Bromoacetic Acid μg/l < 1 < 1 < 1 < 1 < 1 

Dibromoacetic acid μg/l < 1 62 50 64 < 1 

tribromoacetic acid μg/l < 1 < 1 < 1 < 1 < 1 

Bromochloroacetic acid μg/l < 1 1,3 1,6 2,1 < 1 

Dibromochloroacetic acid μg/l < 1 < 1 < 1 < 1 < 1 

Bromodichloroacetic acid μg/l < 1 < 1 < 1 < 1 < 1 
MEPC 57/2/7 

ANNEX 

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Conclusion 

The results show, that Active Substance (FAC) and Relevant Chemicals are produced during the 

disinfection step in the electrolytic cell. The results are very much in line with the results of other 

applicants (Japan, Sweden). A typical FAC concentration during standard operation of the 

BWMS is 1.5 ñ 2 ppm immediately after treatment, which rapidly decreases to 0.5 ppm 

(after 2 hours). Additional measurements, including longer aging of the ballast water will be done 

during land-based tests for Final Approval with a full-scale BWMS. Only 2 halogenated 

methanes were detected: tribromomethane and dibromochloromethane. Tribromomethane 

represents more then 96% of the total of the halomethanes and is therefore considered as a 

Relevant Chemical. Only 2 haloacetic acids were detected: dibromoacetic acid and 

bromochloroacetic acid. After 24 hours of aging of the treated ballast water these compounds 

were not detected anymore. Dibromoacetic acid, representing 97% of the haloacetic acids, is 

considered a Relevant Chemical. Chapter 3 presents the data sets and risk characterization for 

these compounds. 

The formation of hydroxyl radicals by the electrolytic process in the cell, is not considered 

environmentally relevant, since these radicals have an extremely short half-life in the electrolytic 

cell and therefore will never reach the environment. 

The formation of small amounts of hydrogen gas (H2) in the electrolytic cell is considered a 

safety issue and will be dealt with in chapter 5. 

2.3.2 Results of land-based disinfection tests with seawater 

Although the results of laboratory tests on the efficiency of the disinfection process during 

electrolysis were very convincing, it was decided to do supplemental land-based tests with 

natural seawater. In the period between 1 May 2007 and 25 June 2007, five valid replicate test 

cycles were performed. Each test cycle took place over a period of at least five days. A BWMS 

with a capacity of 100m3

/hr was used, which was installed on deck of a moored barge, which was 

moored to a tanker, at the quay of the harbour of the city of Harlingen, the Netherlands, at the 

border of the Waddensea. The BWMS was operated under standard conditions. The tanker had 

several tanks with normal internal structures and a total capacity of 842 m3, resembling ballast 

water tanks, in which untreated and treated seawater could be stored. 

Biological and microbiological tests were performed by the Institute f ̧r Umwelttechnik 

Fachhochschule EUTEC, University of Applied Sciences in Oldenburg, Germany. The results of 

the five valid replicate test cycles are summarized in table 2.6. 
MEPC 57/2/7 

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Table 2.6: Summarized results for the land-based test (cycle 1 ñcycle 5, results for 

untreated uptake water and treated discharge water; the untreated 

uptake water resembles the harbour water) 

Run 1 Run 2 Run 3 Run 4 Run 5 

Sizeclass/ 

IMO 

regulation

untreated 

uptake 

treated, 

effluent 

untreated 

uptake 

treated, 

effluent

untreated 

uptake 

treated, 

effluent

untreated 

uptake 

treated, 

effluent

untreated 

uptake 

treated, 

effluent

1 

(plankton 

≥50 μm/m3) 

IMO: less 

than 1 /m3 

637000 0 228000 0 706000 0 660000 0 4240000 0 

2 

(plankton 

10-50 μm/ 

ml) 

IMO: less 

than 10/ml 

400 0 370 0 600 0 300 7 500 7 

3 

aerobic 

heretotrophic 

bacteria 

cfu/100 ml 

NO IMO 

no test 6000 867000 3500 53000 700 66000 1000 126000 0 

3 

E. coli 

(cfu/100 ml) 

IMO: less 

than 

250 

cfu/100ml 

no test 0 73 0 7 0 2 1 9 0 

3 

Enterococcae 

cfu/100 ml 

IMO: less 

than 100 

cfu/100 ml 

no test 0 0 0 6 0 1 0 8 0 

Conclusion 

The present results show that the Greenship ballast water treatment system removes plankton 

organisms and bacteria from treated ballast water, so that the discharged water complies with the 

BWM Convention. 

The system was tested in step with the actual practice. Harbour water of the port of Harlingen 

was used as test water, and the test tanker ìAquariusî was moored at a place where much 

shipping traffic took place, so the test conditions come close to reality. Within the five cycles, 

different free chlorine concentrations were reached with the electrolysis cell. For best results, a 

free chlorine production, resulting in a concentration of at least 2.6 ppm of free chlorine during 

uptake should be achieved. Run 4 has shown that even smaller free chlorine concentrations lead 

to sufficient killing rates (see detailed report of run 4), but to be on the safe side, about 2.6 ppm 

of free chlorine production is recommended. Higher free chlorine concentrations lead to higher 

killing rates, but should not be used if not necessary to preserve the environment. 
MEPC 57/2/7 

ANNEX 

Page 13 

I:\MEPC\57\2-7.doc 

3 DATA SETS AND RISK CHARACTERIZATION (SEE THE METHODOLOGY, 

SECTIONS 3 AND 6) 

In the previous chapter the performance of the BWTS and the results of the chemical and 

(micro)biological analyses in treated ballast water have been reported. The chemical analyses 

demonstrated the presence of a number of compounds: FAC and Relevant Chemicals 

(see paragraph 2.3.1) for which an assessment for potential environmental risks has to be 

presented. This chapter presents data for the Active Substance and environmentally Relevant 

Chemicals: FAC (in the form of hypochlorite), tribromomethane and dibromoacetic acid.

The findings of the chemical analyses will be validated against the literature data on toxicity of 

these compounds. The conclusions per individual compound can never exclude adverse 

environmental effects of discharged treated ballast water. Therefore whole effluent toxicity 

testing was performed as well and is reported in chapter 4. 

The applicant has used the key data summary form as presented in the Methodology, for the 

content in this chapter, the applicant has used the following main sources of information: 

Risk assessment report for sodium hypochlorite, version January 2007, including 

annexes 2, 3 and 4, provided by: Dipartimento di Ambiente e Connessa Prevenzione 

Primaria, Istituto Superiori di Sanita, Rome, Italy (reference 33). 

This document is a final draft to become a full EU Risk Assessment Report (RAR) and is 

produced by Member State Italy with support of the European chlorine industry. Annex 3 in this 

reference gives a full summary of literature data on eco-toxicology study results for fish, 

invertebrates and algae in brackish and seawater: 

- MEPC 56/2: Application by Japan for Basic Approval of Active Substances 

- Annex 7 to MEPC 56/2/2: Review by the GESAMP-BWWG of the application 

by Japan (MEPC56/2), appendices 1, 3 and 5 

- MEPC 55/2/4: Application by Sweden for Basic Approval of Active Substances 

- Annex 7 to MEPC 55/2/16: Review by the GESAMP-BWWG of the application 

by Sweden (MEPC 55/2/4) 

Chemical identification 

For three compounds, a complete data set and risk characterization will be presented. Chapter 2, 

paragraph 2.3.1, presents the list of all possible by-products. In the conclusion, it is motivated 

why data sets and risk assessments for three compounds will be presented in this application for 

Basic Approval. The Active Substance (FAC), the Relevant Chemicals and all other possible 

byproducts, including bromate, will be analysed in the land-based tests, necessary for application 

for Final Approval. 

Composition of Preparation 

Component Chemical Name CAS Number Concentration (%) AS, RC or Other 

Sodium-hypochlorite 7681-52-9 Max 1,67 ppm AS 

Tribromomethane 75-25-2 Max 290 ppb RC 

2,2 Dibromoacetic acid 631-64-1 Max 64 ppb RC 
MEPC 57/2/7 

ANNEX 

Page 14 

I:\MEPC\57\2-7.doc 

3.1 Free active chlorine (hypochlorite) 

Since FAC is present as hypochlorite in seawater (pH = 8 to 8.2), the data set and risk 

characterization will be presented for hypochlorite. The FAC is interpreted as Total Residual 

Oxidants (TRO). 

3.1.1 Effects on aquatic organisms 

Acute aquatic toxicity 

Species Effect Value 

(mg/L)

References 

F Oncorhynchus kisutch 96 h LC50 0.032 

C Ceriodaphnia dubia 24 h LC50 0.005 

A Thalassiosira pseudonana 24 h IC50 0.075 

M Crassostrea virginica 96 h EC50 0.023 

RAR Hypochlorite (Ref. 33); Thatcher, 

1978; Taylor, 1993; Gentile et al., 1979; 

Robertd and Gleeson, 1978 

 F = Fish, C = Crustacea, A = Algae, M = Mollusc 

Chronic aquatic toxicity 

 Species Effect Value 

(mg/L) 

References 

F Menidia peninsulae 28d NOEC 0.04 

Chlorineproduced 

oxidant 

C Pandalus danae 28d NOEC 0.05 mg/l Free 

Active Chlorine 

A Unknown species 7d NOEC 0.0027 mg/l 

TRO 

M Crassostrea virginica 15d NOEC 0.007 mg/l 

TRO 

RAR Hypochlorite 

(Ref. 33); Goodman, 

1983; Gibson, 1976; 

Cairns, 1990; Liden, 

1980.

 F = Fish, C = Crustacea, A = Algae, M = Mollusc 

Information on Endocrine Disruption 

No reports were found, indicating that FAC might have any endocrine effects on aquatic 

organisms. 

Sediment toxicity/bioavailability/biomagnification/bioconcentration/foodweb-population effects 

The Log Pow value of hypochlorous acid is -0.87 (estimated) and that of sodium hypochlorite ñ 3.42 

(estimated), which is smaller than the criteria of Log Pow=3. The Koc value of sodium 

hypochlorite is 14.3 l/kg (estimated by EPI Suite TM), which is smaller than 500 l/kg. 

Therefore, FAC is not considered to absorb to sediment or to accumulate in the food web 

(see also results of MAM-PEC). 
MEPC 57/2/7 

ANNEX 

Page 15 

I:\MEPC\57\2-7.doc 

3.1.2 Mammalian toxicity

Acute mammalian toxicity 

 

Exposure Route Value Species References 

Oral LD50 (mg/kg) 850 rat WHO 2000 (Calcium 

hypochlorite 

Dermal LD50 (mg/kg) > 10000 rabbit MEPC 57/2/1 

Inhalation LC50 (mg/l/4h) > 10.5 rat MEPC 57/2/1

Corrosion/irritation 

 Species Method Results 

(including scores 

where available) 

References 

Skin Rabbit OECD 404 2% slight (1.2) 

20% severe (5.2) 

IUCLID 2000 

Eye Rabbit 5.25% irritant 

0.5% slight irritant 

0.05% NOEC 

Pashley, 1985 

Sensitization 

A 2.8% solution of sodium hypochlorite solution was not found to be a skin sensitizer in 

guinea pigs (IUCLID 2000). 

Repeated dose toxicity 

Exposure Route Oral 

Exposure Duration 90 days 

Exposure dose 200 mg/l TRO in drinking water 

Species Mouse 

Method 

Results 

NOAEL 50 mg/l (10-12 mg/kg/day) 

NOEL 

Reference Daniel et al. (1991) 
MEPC 57/2/7 

ANNEX 

Page 16 

I:\MEPC\57\2-7.doc 

Chronic and long-term toxicity 

Exposure Route Oral 

Exposure Duration 2 years 

Exposure dose Up to 24.2 mg/kg/day (14.4 in rats, 24.2 in Mouse) 

Species Rat and Mouse 

Method 

Results 

NOAEL 14.4 mg/kg/day 

NOEL 

Reference NTP, 1992 

Development and reproductive toxicity 

Exposure Route Oral 

Exposure Duration 7 generations 

Exposure dose 100 mg TRO/l (drinking water treated with sodium 

hypochlorite) 

Species Rat 

Method 

Results 

NOAEL 14.4 mg/kg/day 

NOEL 

Reference Druckrey, 1968 

Carcinogenicity/mutagenicity 

 Species Method 

Details 

Results Reference 

Carcinogenicity Not 

carcinogenic

NTP, 1992 

Mutagenicity Not 

mutagenic

Hayashi, 1988; Meier et al., 

1985 

3.1.3 Environmental fate 

Environmental fate 

Taylor (1993) measured the decay rate of hypochlorous acid and hypochlorite ions in an acute 

aquatic toxicity test. The decay rate was reported as follows: the half-life at pH 7.0 (main formula 

is HClO) is about 0.8 hour and the half-life at pH 8.0 (main formula is ClO-

) is about 1.4 hour. 

The A.I.S.E. document (ref.1) reports a half-life of 45-60 minutes. 

In the presence of organic material, FAC disappears very quickly, due to its oxidizing property. 

Therefore, the resulting TRO in the receiving water will be very low (see also annex 2 to RAR, 

reference 33). 
MEPC 57/2/7 

ANNEX 

Page 17 

I:\MEPC\57\2-7.doc 

Partition coefficients 

 Method Results Reference 

Log Pow estimated - 3.42 EPI Suite TM

Koc estimated 14.3 l/kg EPI Suite TM 

Reaction with organic matter 

It is known that when FAC reacts with organic material in water, by-products such as 

halomethanes and halogenated acetic acids are formed. Four substances (tribromomethane, 

dibromochloromethane, 2,2-dibromoacetic acid and bromochloroacetic acid) were detected by 

preliminary experiments as by-products in treated ballast water (see chapter 2). 

Potential physical effects on wildlife and benthic habitats 

FAC is highly soluble in water (IUCLID, 2000) and does not float on the surface or sediment to 

the bottom. So, the compound is not subject to evaluation of potential physical effects on wildlife 

and benthic habitants under the GESAMP hazard evaluation (GESAMP, 2002). 

Potential residuals in seafood 

No report concerning persistence of FAC in seafood is available. As FAC has a low 

bioaccumulation potential, its persistence in seafood is assumed to be low. 

Any known interactive effects 

Free active chlorine may generate corrosive gas including gaseous chlorine under high 

temperature or low pH condition (<pH 4). These conditions will not occur in the environment or 

in the ballast water tanks. 

3.1.4 Physical and chemical properties 

Physical property Sodium hypochlorite 

CAS number 7681-52-9 

Molecule weight 74.44 

Melting point (°C) - 25 

Boiling point (°C) 107 

Flash point (°C) 

Density (kg/dm3) at 25 °C 1.23*103

Vapour pressure @ 20°C (Pa) 1740-2000 

Water solubility (g/L) miscible(293) 

pH in solution 14 

Octanol/water partition coefficient 

(log Pow) 

-0.87 

Dissociation constant (pKa) 7.63 

Oxidation reduction potential 1.7 

Oxidizing properties Strong oxidizing agent 

Viscosity (mPa.s) 2.6 
MEPC 57/2/7 

ANNEX 

Page 18 

I:\MEPC\57\2-7.doc 

PH, salinity, TSS, POC, DOC 

The pH and salinity of the treated ballast water is the same as the natural values of the uptake 

water. The pH varies from 7.4 to 8.0. Salinity varies from 22 ñ 34 PSU. TSS, DOC and POC 

were analysed in samples taken during the test on killing rates in the summer of 2007. All 

parameters vary highly due to conditions in the harbour through tidal movements and ship 

movements. TSS varied between 20 and 100 mg/l. POC values were in the range 0.5 ñ 29 mg/l 

and DOC values were in the range of 1.0 ñ 52 mg/l. 

3.1.5 Other information 

 Analytical Methods for Measuring the Concentration at environmentally Relevant 

 Concentrations 

Method Fotometric (DPD-1) 

Applicability salt water 

Sensitivity < 0.01 mg/l 

Reference NEN/EN/ISO 7393-2 

Material Safety Data Sheet provided: no

GHS Classification: no

3.1.6 Risk characterization 

Persistent 

(y/n) 

Bioaccumulative 

(y/n) 

Toxic (y/n) Reference 

 No no yes reference 31 and this document 

Evaluation of the treated ballast water 

See chapter 2 ñ for the chemical evaluation of the treated ballast water and chapter 4 ñ for the 

preliminary ecotoxicological evaluation. 

Prediction of discharge and environmental concentrations: MAM-PEC 

For the calculation of the Predicted Environmental Concentration (PEC), the model MAM-PEC, 

version 2.0, was applied. This model is freely available and can be downloaded. The model has 

been developed by Delft Hydraulics (now DELTARES) and the Free University, Amsterdam. 

The model was developed to calculate leaching of anti-fouling paints from ships. It is based on 

the assumption that a permanent source of the pollutant is present in the harbour and calculates a 

steady state concentration of the pollutant. Calculations can be done for different harbours with 

different dimensions and ìsurroundingsî, which in practice means the channel to which the 

harbour is connected. It also has the possibility for calculations in a shipping lane of 200 km2

. 

In this application, a standard OECD-EU harbour has been used with an exchange volume 

of 51,117,000 m3

 per tidal period of 12.1 hours. The daily volume of discharged treated ballast 

water and the concentration of the Active Substance and Relevant Chemicals are critical input 

data. Reliable data on daily discharge of ballast water is difficult to obtain. Other applicants have 

used volumes varying between 396,000m3

/day (Korea) and 50,000 m3/day (Sweden). 
MEPC 57/2/7 

ANNEX 

Page 19 

I:\MEPC\57\2-7.doc 

According to the authorities of the Port of Rotterdam, the real value will be closer to 50,000 than 

to 396,000. It depends on the type of harbour: in Rotterdam the intake of ballast water is higher 

than the discharge, since ships are coming loaded. A port that handles mainly tankers that arrive 

unloaded, may have a higher daily discharge than the Port of Rotterdam. This applicant has used 

the figure of 200,000 m3/day. The most important input data is mentioned as follows: 

Main input data for FAC is: 

Load: 334 kg/day (based on 200,000m3/day and maximum of 1.67 mg/l)

Half-life: 0.041 days in water

The MAM-PEC model calculates for FAC a steady state situation (= PEC) in the harbour 

of 0.34 μg/l and of 0.017 μg/l in the surroundings. The model calculates a steady state 

situation in the shipping lane of 0.014 μg/l. 

Effects on aquatic organisms: predicted-no-effect concentrations (PNEC) 

In various documents, the predicted no effect concentrations of FAC (PNEC) have been 

calculated with different outcomes. Annex 7 to MEPC 56/2/2 (review by the GESAMP-BWWG 

of the application by Japan, MEPC 56/2), reports a value of 0.07 μg/l. Reference 33 reports a 

value of 0.04 μg/l. Document MEPC 57/2/1 (application by Korea) reports 8 μg/l. 

3.1 Tribromomethane 

3.2.1 Effects on aquatic organisms 

Acute aquatic toxicity 

Species Effect Value 

(mg/L) 

Calculated 

NOEC 

(mg/L) 

References 

F Cyprinodon variegates 96 h LC50 7.1 2.9 

C Daphnia magna 24-48 h LC50 46 <7.8 

A Skeletonema costatum 96 h EC50 12.3 

Ward et al., 1981; 

Heitmuller et al., 1981; 

Ecotox, 2005; 

LeBlanc, 1980

 F = Fish, C = Crustacea, A = Algae 

Chronic aquatic toxicity 

 Species Effect Value Reference 

F Cyprinodon variegatus 28d NOEC 4.8 mg/l 

C 

A

Ward et al., 1981

Information on endocrine disruption 

No reports were found, indicating that tribromomethane might have any endocrine effects on 

aquatic organisms. 
MEPC 57/2/7 

ANNEX 

Page 20 

I:\MEPC\57\2-7.doc 

Sediment toxicity/bioavailability/biomagnification/bioconcentration/food web-population effects 

The Log Pow value of tribromomethane is 2.4 (ATDSR, 2005), which is smaller than the criteria 

of Log Pow = 3. The Koc value of tribromomethane is 114.8 l/kg (annex 7 to MEPC 56/2/2), 

which is smaller than 500 l/kg. Therefore, tribromomethane is not considered to absorb to 

sediment or to accumulate in the food web. 

3.2.2 Mammalian toxicity 

Acute mammalian toxicity 

 

Exposure Route Value Species References 

Oral LD50 (mg/kg) 1147 Rat Chu et al., 1980 

Dermal LD50

(mg/kg) 

 

Inhalation LC50

(mg/l/4h) 

>7000 ppm/1 h Dog MEPC 56/2, 

paragraph 2.3.2.2 

 Sub-acute toxicity 

NOAEL oral (mg/kg 

bw/day) 2 weeks 

 

Corrosion/irritation 

 Species Method Results 

(including 

scores 

where 

available) 

Reference 

Skin Rabbit Moderately 

irritating

Eye Rabbit Moderately 

irritating 

Respiratory 

system 

 Moderately 

irritating 

Torkelson et al., 1994 

Sensitization 

No sensitization data are reported for tribromomethane. 
MEPC 57/2/7 

ANNEX 

Page 21 

I:\MEPC\57\2-7.doc 

Repeated dose toxicity 

Exposure Route Oral 

Exposure Duration 13 weeks 

Exposure dose 50 mg/kg/day 

Species Rat 

Method 

Results 

NOAEL 25 mg/kg/d 

NOEL 

Reference NTP, 1989 

Chronic and long-term toxicity 

Exposure Route 1 year 

Exposure Duration 

Exposure dose 6.2-57 mg/kg/d (Rat) 

8.3-73 mg/kg/d (Mouse) 

Species Rat and Mouse 

Method 

Results 

NOAEL <6.2 mg/kg/d 

NOEL <6.2 mg/kg/d

Reference Moore et al., 1994 

Development and reproductive toxicity 

Exposure Route 

Exposure Duration Not given for rat study 

105 d for Mouse study 

Exposure dose 50-200 mg/kg 

Species Rat and Mouse 

Method 

Results foetotoxicity observed in rats 

No fertility effects seen in Mouse study 

NOAEL 

NOEL 

Reference WHO, 2000 
MEPC 57/2/7 

ANNEX 

Page 22 

I:\MEPC\57\2-7.doc 

Carcinogenicity/mutagenicity 

 Species Method 

Details 

Results References 

Carcinogenicity Human Probable 

Human 

Carcinogen 

U.S. EPA (IRIS) 

Mutagenicity Salmonella. 

Mammalian

cells 

Ames test Mixed 

Mixed 

Simmon et al., 1978; 

Simmon et al., 1979 ; 

NTP, 1989 ; Rapson 

et al., 1980 ; Varma 

et al., 1988 ; Morimoto, 

1983 ; Fuji et al., 1993 ; 

Galloways et al., 1985 

3.2.3 Environmental fate 

Modes of degradation (abiotic) and persistence 

The rate constant of hydrolysis for tribromomethane is estimated at 3.2x10-11/sec 

(Mabey, W. et al.,1978). It thus is a stable compound in water with an estimated half-life 

of 686 years. 

Partition coefficients 

 Method Results Reference 

Log Pow observed 2.4 CITI, 1992; Sangster, 1994 

Koc observed 114.8 l/kg Annex 7 to MEPC 56/2/2 

Reaction with organic matter 

No reports on the reaction of tribromomethane with organic matter were found. 

Potential physical effects on wildlife and benthic habitats 

Tribromomethane has a higher specific gravity than seawater (2.890 at 20°C) and a low solubility 

(3.1 g/l (20°C)). Therefore, according to an evaluation based on the GESAMP hazard evaluation 

(GESAMP, 2002), the compound is classified as Rating S (substances having a potential effect 

on benthic habitats). 

Potential residues in seafood 

Tribromomethane has a low bioaccumulation potential and therefore it is unlikely that residues 

will be found in seafood (see paragraph 3.2.1). 
MEPC 57/2/7 

ANNEX 

Page 23 

I:\MEPC\57\2-7.doc 

3.2.4 Physical and chemical properties 

Molecular formula CHBr3 

Molecular weight 252.73 

CAS-number 75-25-2 

Flammability Non-flammable

Vapour pressure (Pa) at 20 oC 534 

Water Solubility (mg/L) Slightly soluble

3.2.5 Other information 

Analytical method for measuring the concentration at environmentally relevant 

concentrations 

Method GC-MS 

Applicability salt water 

Sensitivity < 0.5 ñ 0.1 μg/l 

Reference NEN/EN/ISO 15680 

Material Safety Data Sheet provided: no

GHS Classification: no

3.2.6 Risk characterization 

Persistent (y/n) Bioacumulative (y/n) Toxic (y/n) Reference 

 Yes no no this document 

Evaluation of the treated ballast water 

See chapter 2 ñ for the chemical evaluation of the treated ballast water and chapter 4 ñ for the 

preliminary ecotoxicological evaluation. 

Prediction of discharge and environmental concentrations: MAM-PEC 

For the calculation of the Predicted Environmental Concentration (PEC), the model MAM-PEC, 

version 2.0, was applied. This model is freely available and can be downloaded. The model has 

been developed by Delft Hydraulics (now DELTARES) and the Free University, Amsterdam. 

The model was developed to calculate leaching of anti-fouling paints from ships. It is based on 

the assumption that a permanent source of the pollutant is present in the harbour and calculates a 

steady state concentration of the pollutant. Calculations can be done for different harbours with 

different dimensions and ìsurroundingsî, which in practice means the channel to which the 

harbour is connected. It also has the possibility for calculations in a shipping lane of 200 km2

. 

In this application, a standard OECD-EU harbour has been used with an exchange volume 

of 51,117,000 m3 per tidal period of 12.1 hours. The daily volume of discharged treated ballast 

water and the concentration of the Active Substance and Relevant Chemicals are critical input 

data. Reliable data on daily discharge of ballast water is difficult to obtain. Other applicants have 

used volumes varying between 396,000 m3

/day (Korea) and 50,000 m3/day (Sweden). According 

to the authorities of the Port of Rotterdam, the real value will be closer to 50,000 than to 396,000. 

It depends on the type of harbour: in Rotterdam the intake of ballast water is higher than the 
MEPC 57/2/7 

ANNEX 

Page 24 

I:\MEPC\57\2-7.doc 

discharge, since ships are coming loaded. A port that handles mainly tankers that arrive 

unloaded, may have a higher daily discharge than the Port of Rotterdam. This applicant has used 

the figure of 200,000 m3

/day. The most important input data is mentioned as follows: 

Load: 58 kg/day (based on 200.000 m3/day and maximum of 0.290 mg/l)

Half-life: 340 days in sediment

The MAM-PEC model calculates for tribromomethane a steady state situation (= PEC) in the 

harbour of 1.28 μg/l and of 0.036 μg/l in the surroundings. The model calculates a steady state 

situation in the shipping lane of 0.005 μg/l. 

Effects on aquatic organisms: predicted-no-effect concentrations (PNEC) 

In various documents, the predicted no effect concentrations of tribromomethane (PNEC) have 

been calculated with different outcomes. Annex 7 to MEPC 56/2/2 (review by the 

GESAMP-BWWG of the application by Japan, MEPC 56/2), reports a value of 7.1 μg/l. 

Reference 33 reports a value of 146 μg/l. RIVM (2005) reports a value of 1. 5 μg/l. 

3.2 2,2 Dibromoacetic Acid 

3.3.1 Effects on aquatic organisms 

Acute aquatic toxicity data 

Species Effect Value Reference 

F Pimephales promelas 96 h LC50 6.9 mg/l Mayes et al, 1985 

C 

A

 F = Fish, C = Crustacea, A = Algae 

Chronic aquatic toxicity 

No data is available on the chronic aquatic toxicity of 2,2-dibromoacetic acid. 

Information on endocrine disruption 

No reports were found, indicating that 2,2 dibromoacetic acid might have any endocrine effects 

on aquatic organisms. 

Sediment toxicity/bioavailability/biomagnification/bioconcentration/food web-population effects 

The Log Pow value of 2,2 dibromoacetic acid is 1.22 (observed), which is smaller than the 

criteria of Log Pow = 3. The Koc value of 2,2 dibromoacetic is 1.90 l/kg (), which is smaller 

than 500 l/kg. 

Therefore, 2,2 dibromoacetic acid is not considered to absorb to sediment or to accumulate in the 

food web. 
MEPC 57/2/7 

ANNEX 

Page 25 

I:\MEPC\57\2-7.doc 

3.3.2 Mammalian toxicity 

Acute mammalian toxicity 

 

Exposure Route Value Species Reference 

Oral LD50 (mg/kg) 1737 Rat Linder et al., 1994 

Dermal LD50 (mg/kg) 

Inhalation LC50

(mg/l/4h) 

 

Corrosion/irritation 

 Species Method Results 

(including scores 

where available) 

Reference 

Skin Corrosive 

Eye Severe 

Lung Severe 

Assumed as a strong acid

Sensitization 

No sensitization data are reported for 2,2 dibromoacetic acid. 

Repeated dose toxicity 

Exposure Route Oral Oral

Exposure Duration 28d 3 months 

Exposure dose 0-2000 mg/l 

Species Mouse Mouse

Method 

Results No deaths but various effects seen at >500 mg/l 

NOAEL 38 mg/kg/d Not reported 

NOEL Not reported 

Reference WHO, 2004 

Chronic and long-term toxicity 

Exposure Route Oral Oral

Exposure Duration 2 years 2 years

Exposure dose 0-1000 mg/l 

Species Mouse Rat 

Method 

Results Increased body weights at 50 

and 500 mg/l in males only 

Decrease body weights at 500 

and 1000 mg/l 

NOAEL Not reported Not reported

NOEL Not reported Not reported

Reference NTP, 2005 
MEPC 57/2/7 

ANNEX 

Page 26 

I:\MEPC\57\2-7.doc 

Development and reproductive toxicity 

Exposure Route Oral 

Exposure Duration 

Exposure dose 0-250 mg/kg/d 

Species Rat 

Method 

Results Increased E2 at 250 mg/kg/d 

NOAEL 125 mg/kg/d 

NOEL 

Reference Cummings et al. (1998) 

Carcinogenicity/mutagenicity 

 Species Method 

Details 

Results Reference 

Carcinogenicity Mouse and 

Rat 

Carcinogenic 

(tumours/cancers 

observed) 

NTP, 2007 

Mutagenicity Salmonella 

typhimurium 

Ames 

test 

Positive at 10 mg/l NTP, 2007; Giller 

et al., 1997 

3.3.3 Environmental fate 

Environmental fate 

Holmes et al. (2001) measured the decay rate of 2,2 dibromoacetic acid with in vivo and vitro 

toxicity tests. They report a half-life of 1.5 hours. 

Partition coefficients 

 Method Results Reference 

Log Pow estimated 1.22 EPI Suite TM

Koc estimated 1.90 l/kg EPI Suite TM

Reaction with organic matter/Potential physical effects on wildlife and benthic habitats/Potential 

residuals in seafood

The 2,2 Dibromoacetic acid is highly soluble in water; actually it is highly hygroscopic. 

It therefore will not react substantially with organic matter nor will it precipitate in wildlife or 

benthic habitats or accumulate in seafood. 

3.3.4 Physical and chemical properties 

Molecular formula CHBr2COOH 

Molecular weight 217.860 

CAS-number 631-64-1 

Flammability Non-flammable

Vapour pressure (Pa) at 25 oC 0.023 

Water Solubility (mg/L) Highly soluble 
MEPC 57/2/7 

ANNEX 

Page 27 

I:\MEPC\57\2-7.doc 

3.3.5 Other information 

Analytical methods for measuring the concentration at environmentally relevant concentrations

Method GC-MS 

Applicability salt water 

Sensitivity < 1 μg/l

Reference RPS Laboratories: Halacet_V1 methodology 

Material Safety Data Sheet provided: no 

GHS Classification: no

3.3.6 Risk characterization 

Persistent 

(y/n) 

Bioacumulative 

(y/n) 

Toxic 

(y/n) 

Reference 

No no no this document 

Evaluation of the treated ballast water 

See chapter 2 ñ for the chemical evaluation of the treated ballast water and chapter 4 ñ for the 

preliminary ecotoxicological evaluation. 

Prediction of discharge and environmental concentrations: MAM-PEC 

For the calculation of the Predicted Environmental Concentration (PEC), the model MAM-PEC, 

version 2.0, was applied. This model is freely available and can be downloaded. The model has 

been developed by Delft Hydraulics (now DELTARES) and the Free University, Amsterdam. 

The model was developed to calculate leaching of anti-fouling paints from ships. It is based on 

the assumption that a permanent source of the pollutant is present in the harbour and calculates a 

steady state concentration of the pollutant. Calculations can be done for different harbours with 

different dimensions and ìsurroundingsî, which in practice means the channel to which the 

harbour is connected. It also has the possibility for calculations in a shipping lane of 200 km2

. In 

this application, a standard OECD-EU harbour has been used with an exchange volume 

of 51,117,000 m3

 per tidal period of 12.1 hours. The daily volume of discharged treated ballast 

water and the concentration of the Active Substance and Relevant Chemicals are critical input 

data. Reliable data on daily discharge of ballast water is difficult to obtain. Other applicants have 

used volumes varying between 396,000 m3

/day (Korea) and 50,000 m3/day (Sweden). According 

to the authorities of the Port of Rotterdam, the real value will be closer to 50,000 than to 396,000. 

It depends on the type of harbour: in Rotterdam the intake of ballast water is higher then the 

discharge, since ships are coming loaded. A port that handles mainly tankers that arrive 

unloaded, may have a higher daily discharge than the Port of Rotterdam. This applicant has used 

the figure of 200,000 m3/day. The most important input data is mentioned as follows: 

Load: 13 kg/day (based on 200.000 m3

/day and maximum of 0.064 mg/l) 

Half-life: 0.0625 day in water
MEPC 57/2/7 

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The MAM-PEC model calculates for 2,2 dibromoacetic acid a steady state situation (= PEC) in 

the harbour of 0.019 μg/l and of 0.001 μg/l in the surroundings. The model calculates a steady 

state situation in the shipping lane of 0.0007 μg/l. 

Effects on aquatic organisms: predicted-no-effect concentrations (PNEC) 

In various documents, the predicted no effect concentrations of 2,2 dibromoacetic acid (PNEC) 

have been derived with different outcomes. Annex 7 to MEPC 56/2/2 (review by the 

GESAMP-BWWG of the application by Japan, MEPC 56/2), reports a value of 6.9 μg/l. 

Reference 33 reports a value of 0.72 μg/l. 

4 TOXICITY EVALUATION OF THE TREATED BALLAST WATER 

In order to comply with paragraph 5.2 of Procedure (G9) regarding toxicity testing of the treated 

ballast water, the applicant has commissioned the Institute for Marine Resources ands Ecosystem 

Studies of Wageningen IMARES, Den Helder, The Netherlands, to perform the prescribed 

toxicity tests on whole effluent of the BWTS (treated ballast water). The samples were taken 

under the same technical conditions as samples taken for chemical analysis (see paragraph 2.3 of 

this document). This chapter presents the full report on the results of the tests. 

Summary 

Greenship B.V. has developed a ballast water management system consisting of a Sedimentor 

(multi-hydrocyclone system) and an electrolytic cell, producing hypochlorite for killing 

organisms. The residual effects of seawater treated with the electrolytic cell was investigated 

with bioassays, using three marine organisms: an algae (Skeletonema costatum) a crustacean 

(Artemia franciscana) and a fish (Solea solea). 

The tests were performed at the laboratory of IMARES in Den Helder, using treated ballast water 

aged for 24 h, 48 h, 72 h and 96 h. Each test day dilutions of 10% 18%, 33%, 56% and 100% 

treated ballast water were made, using untreated ballast water (only hydrocyclone treated) as 

dilution medium and blank. The salinity of the test water was adjusted to approximately 30% by 

adding NaCl. 

Treated ballast water showed no negative effects in the tests with the crustacean and the fish. 

In the algal growth inhibition test, significant negative effects of treated ballast water were found. 

The algae did not survive exposure to 100% treated ballast water in any of the test runs. Exposure 

to a dilution of 56% treated ballast water resulted in complete mortality in the test run 

with 24 h aged ballast water, but recovery was observed in older ballast water. In 96 h aged 

ballast water, full recovery was observed during the course of the test (3 days). 

4.1 Introduction 

Ballast water is used by ships to compensate for differences in cargo load. With the ballast water, 

non-indigenous organisms are transported worldwide from ships transporting cargo between 

regions, which may result in disturbances of regional ecosystems. IMO has set out a mandatory 

framework for treatment of ballast water on board of ships, in order to minimize the risk of 

ballast water discharges. Bioassays have to be conducted to assess the effects of treated ballast 

water on the receiving ecosystems. 
MEPC 57/2/7 

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Greenship B.V. has developed a Ballast Water Management System consisting of a Sedimentor 

(multi-hydrocyclone system) and an electrolytic cell, producing hypochlorite for killing 

organisms. The residual effects of seawater treated with the electrolytic cell was investigated 

with bioassays, using three marine organisms: an algae (Skeletonema costatum), a crustacean 

(Artemia franciscana), and a fish (Solea solea) ñ one to four days after the treatment. 

4.2 Materials and methods 

4.2.1 General 

On Tuesday, 21 August 2007, a treatment run was performed in Harlingen Harbour, 

The Netherlands. From IMARES, A.C. Sneekes and J. Cuperus were present to collect the water 

samples. The Treated Ballast Water (TBW) was seawater from Harlingen Harbour, treated with 

the hydrocyclone and the electrolytic cell. It was collected in four 25 L PE jerry cans, coded 

TBW1 to TBW4. A 5th jerry can was taken as back-up. The Untreated Ballast Water (UBW), 

was taken at the same location in Harlingen Harbour, but was only treated with the hydrocyclone. 

The UBW was collected in four 25 L PE jerry cans, coded UBW1 to UBW4 and a 5th as back-up. 

After filling the last jerry can, the water samples were directly transported to the laboratory of 

IMARES in Den Helder and stored in the dark at approx. 16°C. 

4.2.2 Bioassays 

Bioassays were initiated approximately 24 h (22 August), 48 h (23 August), 72 h (24 August) 

and 96 h (25 August) after the water was collected and treated in Harlingen Harbour. As the 

oxygen content of the water was too low for the tests, before test initiation, the water used for the 

tests was aerated overnight. Before use, water quality parameters were measured in the jerrycans. 

As the salinity of the water in Harlingen Harbour was too low for the test organisms 

(approximately 19%), 10 L was tapped into a large bottle and the salinity was adjusted with NaCl 

(p.a.-grade) to approximately 29%. After mixing for at least 30 minutes water quality parameters 

were measured again. 

Each test day, dilution series were made by mixing TBW with UBW in the following proportions 

(see table 4.1): 

Table 4.1: Dilutions of treated ballast water (TBW) with untreated ballast water (UBW) 

Code TBW UBW 

BW0 0% 100% 

BW1 10% 90% 

BW2 17.8% 82.2% 

BW3 32.6% 67.4% 

BW4 56.2% 43.8% 

BW5 100% 0% 

The dilution series were made directly from stored water (approximately 16°C) and was then set 

away at the conditions of different bioassays for acclimatization. Water parameters were 

measured in the dilution series for Skeletonema costatum and Solea solea at start and termination 

of the test. The test water for Artemia franciscana was taken from the dilution series of the fish 

test. 
MEPC 57/2/7 

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4.2.2.1 Skeletonema costatum 

The test protocol is based upon OECD 201 (1984) and ISO10253 (2006). The test species used was 

the marine diatom Skeletonema costatum. An active growing culture was obtained from TNO 

Industry (J. Klijnstra). With this inoculum, cultures were started in F2-medium, incubated under 

the conditions of the test. In the temperature-controlled shaking-cabinet normally used for 

algal-growth tests, only one test series (including reference test) could be placed. Therefore, part of 

the tests was performed in a climate chamber. In this location, the test flasks had to be shaken by 

hand several times a day to facilitate gas exchange. The control growth rate on this location was 

actually too slow (less than 16x multiplication in 72 h), due to a slightly lower temperature (18°C vs 20°C), 

a different light source (cool white vs fluoro) and the lack of continuous shaking. 

Therefore, test series I (24 h after treatment) and IV (96 h after treatment) were performed in the 

shaking cabinet, while only test series II (24 h) and III (72 h) were performed in the climate 

chamber. 

The tests were performed in 250 mL Erlenmeyer flask, filled with approximately 150 mL test 

medium. For the algal growth test, the TBW was diluted with UBW. The UBW was 0.2μm 

filtered in order to remove the natural phytoplankton. Each concentration was tested in 3-fold. 

To each concentration, the same amount of F2-growth medium was added. 

Each test concentration was inoculated with algae from a log-phase growing culture. The start 

concentration was approximately 20 μg/L chlorophyll-a, as measured with a fluorometer before 

filling the replicate flasks. The flasks were incubated in continuous light at 18°C or 20°C. 

The development of the algal biomass, measured as chlorophyll-a concentration, was measured 

each 24 h. 

With each test series, a reference test was conducted, using potassiumdichromate (K2Cr2O7) as 

toxicant. 
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Summary of test conditions for the algal growth inhibition test 

with the marine diatom Skeletonema costatum 

Test organism Skeletonema costatum 

Test organism 

source 

TNO Industry, continuous culture 

Test organism life 

stage 

Log-phase growth, ca. 4 day old culture 

Test duration 72 h 

Test chamber 250 mL Erlenmeyer 

Test solution 

volume 

200 mL per replicate 

Initial 

concentration 

Approx. 20 μg/L chlorophyll-a 

Replicates 3 

Method Fluorescence measurements 

Endpoint Growth (as concentration chlorophyll-a) 

Test temperature 20°C (series I and IV) 

18°C (series II and III) 

Dilution water UBW, 0.2 μm filtered/autoclaved 

Media stock 

solutions 

F2-medium 

Photoperiod Permanent light 

Type of light Fluoro (series I and IV) 

Cool white (series II and III) 

Shaking 130 rpm (series I and IV) 

by hand, several times a day (series II and III) 

Test protocol OECD 201 (1984) and ISO10253 (2006) 

Control 

acceptability 

criteria 

Minimum chlorophyll-a increase by factor 16 

after 72 h 

Reference test K2Cr2O7

Statistics 

Growth rates were calculated by fitting an exponential growth curve through the individual 

samples (replicates). The curve was fitted with the statistical program GraphPad Prism 

(v 4.03, Jan. 2005), using the following formula: 

0

0 ln( ) ln( )

t t

N N

μ

L

L

−

− =

Wherein: 

μ = specific growth rate (day-1) 

NL = chlorophyll-a concentration at tL (at 24, 48, or 72 h). 

N0 = chlorophyll-a concentration at t0 (initial concentration) 

tL = time of measurements (days) 

t0 = start of measurements (0 days). 
MEPC 57/2/7 

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EC50s were calculated as being the concentration/dilution that causes 50% growth inhibition, 

using the formula for a dose-response curve with variable slope built-in in GraphPad Prism. 

GraphPad Prism uses the following formula: 

EC x Hillslope

Top Bottom

y Bottom (log 50 )* 1 10 − +

− = +

Wherein: 

x = Concentration or dilution 

y = Specific growth rate μ 

Top = Maximum growth rate 

Bottom = Minimum growth rate (0) 

Bottom was set at a fixed value of 0, to correct for negative growth (mortality). 

The NOEC was determined as the highest test concentration in which the growth rate was not 

significantly reduced compared to the control (UBW). This was assessed by means of a one-way 

ANOVA followed by Dunnettís multiple comparison post-test. 

4.2.2.2 Artemia franciscana 

The test was performed in a multiwell testplate using instar II-III larvae of the brine shrimp 

Artemia franciscana, obtained as dried cysts from Microlan B.V., The Netherlands, conform the 

Standard Operational Procedure for ARTOXKIT Mô (MicroBioTests Inc. V100603). 

The cysts were incubated in artificial seawater (salinity 35%) 30 h prior to the start of the tests 

at 25°C with continuous illumination. After 30 h, most cysts were hatched and the larvae 

developed into instar II-III stages. 

Approximately 50 larvae were transferred to a rinsing well containing test medium. From the 

rinsing well, 10 larvae were transferred to the three test wells per concentration/dilution for the 

test. The well plate was incubated at 25°C in the dark. After 24 h living and dead larvae in the 

test wells were counted. 

With each test series, a reference test was conducted, using potassiumdichromate (K2Cr2O7) as 

toxicant. 
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Summary of test conditions for the ARTOXKIT M with the 

brine shrimp Artemia franciscana 

Test organism Artemia franciscana 

Test organism source ARTOXKIT M, MicroBioTests Inc. 

Test organism life stage Larvae <24 h old 

Test duration 24 h 

Test chamber 24-well plate 

Test solution volume 1 mL per replicate 

Number of organisms/chamber 10 

Replicates 3 

Endpoints Survival 

Test temperature 25±2°C 

Dilution water UBW 

Photoperiod Permanent dark 

Test protocol Standard Operating Procedure MicroBioTests

Control acceptability criteria <10% mortality 

Reference test K2Cr2O7

Statistics 

EC50s were calculated as being the concentration/dilution that causes 50% mortality, using the 

formula for a dose-response curve with variable slope built-in in GraphPad Prism. GraphPad 

Prism uses the following formula: 

EC x Hillslope

Top Bottom

y Bottom (log 50 )* 1 10 − +

− = +

Wherein: 

x = Concentration or dilution 

y = Mortality (as %) 

Top = Maximum mortality (100) 

Bottom = Minimum mortality (0) 

The NOEC was determined as the highest test concentration in which the growth rate was not 

significantly reduced compared to the control (UBW). This was assessed by means of a one-way 

ANOVA followed by Dunnettís multiple comparison post-test. 

4.2.2.3 Solea solea

The protocol is based upon OECD 203 (1992). Freshly fertilized eggs of the sole (Solea solea) 

were obtained from SOLEA/IMARES, IJmuiden, from a batch produced 19 August 2007. 

The eggs were stored at 12-13°C and slight aeration until use in the tests. 

The test was performed in 100 mL glass beakers, containing approx. 80 mL of the test 

concentration. Each concentration was replicated 4-fold. To prevent dilution of the test 

concentrations, first 40 fertilized eggs, or yolk-sac larvae (depending on availability) were 

transferred to a rinsing beaker containing the test concentration. From there, 10 organisms were 

transferred to each replicate. The test beakers were covered with perforated microwave foil to 

prevent evaporation, and put away at 12-13°C with a 16 h light ñ 8 h dark regime. After 4 days 

exposure, surviving organisms were counted in each beaker. 
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With each test series, a reference test was conducted, using hydrogenperoxide (H2O2) as toxicant. 

Summary of test conditions for the acute fish test with eggs/larvae of the sole Solea solea 

Test organism Solea solea 

Test organism source Commercial hatchery SOLEA/IMARES, Netherlands

Test organism life stage Egg ñ yolk-sac larvae 

Test duration 96 h 

Test chamber 100 mL glass beakers 

Test solution volume 80 mL 

Number of organisms/chamber 10 

Replicates 4 

Endpoint Survival 

Test temperature 12-15 °C 

Dilution water UBW 

Photoperiod 16 hours light/8 hours dark 

Aeration None 

Test protocol OECD 203 (1992) 

Control acceptability criteria <10% mortality 

Reference test H2O2

Statistics 

EC50s were calculated as being the concentration/dilution that causes 50% mortality, using the 

formula for a dose-response curve with variable slope built-in in GraphPad Prism. GraphPad 

Prism uses the following formula: 

EC x Hillslope

Top Bottom

y Bottom (log 50 )* 1 10 − +

− = +

Wherein: 

x = Concentration or dilution 

y = Mortality (as %) 

Top = Maximum mortality (100) 

Bottom = Minimum mortality (0) 

The NOEC was determined as the highest test concentration in which the growth rate was not 

significantly reduced compared to the control (UBW). This was assessed by means of a one-way 

ANOVA followed by Dunnettís multiple comparison post-test. 

4.3 Quality assurance 

As a control on the viability of the test organisms, reference tests were performed simultaneously 

with the ballast water tests. For Skeletonema costatum and Artemia franciscana,

potassiumdichromate (K2Cr2O7) was used as reference toxicant. The results were compared with 

standard values: ISO for S. costatum and manufacturer specifications of the batches for 

A. franciscana. 
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For the sole early life stage test, no standards were available. Therefore, H2O2 was used as 

reference toxicant and the results were compared with previous tests with sole larvae conducted 

at the IMARES laboratory. 

4.4 Results 

4.4.1 Reference tests 

The results of the reference tests are summarized in table 4.2. Skeletonema costatum appears to 

be rather insensitive, with 72 h EC50 values two to four times higher than is indicated in the ISO 

guidelines. K2Cr2O7 is a yellow solution causing some disturbance in the fluorometric 

measurements. This probably resulted in chlorophyll-a measurements that were too high for the 

treatments with 3.2 and 5.6 mg/L, as measurements of cell activity did not support the relatively 

high levels of chlorophyll-a in these. It was the intention to verify the fluorometirc measurements 

by performing cellcounts after the final measurements. However, the cells of S. costatum tended 

to form aggregates during the test which made cell counting impossible. 

Table 4.2: Results of reference tests as EC50 in mg/L 

Test initiation 

date 

S. costatum 

EC50 K2Cr2O7

A. franciscana 

EC50 K2Cr2O7

S. solea 

EC50 H2O2

Expected EC50 2.5±1.1 26.7-35.6 84-150 

22-08-2007 5.6 28.4 87.4 

23-08-2007 9.2 54.0 87.6 

24-08-2007 8.7 37.8 145.6 

25-08-2007 5.6 46.9 - 

The EC50 values obtained in the reference tests with Artemia franciscana were close to or within 

the indicated range specified for the batch of cysts used at 22-08 and 24-08, but were higher for 

the other two tests. The latter were initiated by a less experienced analyst, who probably 

introduced too much hatching medium into the rinsing wells, causing dilution of the test 

solutions. 

The EC50 values for H2O2 in the reference tests with sole eggs and larvae, were within the range 

established in previous tests with this species (Sneekes et al., 2007). In the test initiated 

on 25 August the concentrations were accidentally only 10% of those intended. Therefore, the 

highest concentration was well below no-effect level and effects were not observed. 

Ballast water tests 

Skeletonema costatum 

S. costatum responded directly to exposure to treated ballast water. Each test day, a clear dose 

response relationship was obvious at the initial measurements that were performed within half an 

hour after the algae were introduced into the test medium (see table 4.3).
MEPC 57/2/7 

ANNEX 

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Table 4.3: Measurements of chlorophyll-a (chl-a) and cell activity (% act) 

at initiation of the tests

Start 

day 

24 h 48 h 72 h 96 h 

% TBW chl-a % act chl-a % act chl-a % act chl-a % act 

0 20.83 31.53 23.22 30.89 21.50 24.24 29.04 27.75 

10 19.69 32.11 20.80 38.16 18.80 26.02 29.79 28.74 

18 19.51 32.16 21.69 34.74 14.82 23.88 28.91 28.89 

33 19.97 30.79 21.23 33.43 13.74 19.58 28.53 30.13 

56 16.38 13.56 21.77 35.43 12.16 10.43 25.98 24.09 

100 14.31 12.03 20.87 26.00 11.55 10.37 18.86 11.57 

In the tests with 24 h and 48 h old ballast water, the algae seemed affected in all ballast water 

dilutions, but recovered during the test in the most diluted treatments (Figure 1). Algae in 33% 

TBW grew a little less than in 10% and 18% TBW, but the growth rate was only significantly 

different from UBW in the test with 48 h old ballast water. 

In 56% TBW the same pattern was observed, but more severe. In the test with 24 h old ballast 

water, the algae died and chlorophyll-a concentrations decreased to levels below the detection 

limit. In the other tests, however, the algae recovered after an initial decrease in density, resulting 

in a complete recovery after 3 days in the test with 96 h old ballast water. 

In 100% TBW, the algae died within 24 h exposure and no recovery was observed in any of the 

four tests. 

0 24 48 72

0

100

200

300

400

0% TBW

10% TBW

18% TBW

33% TBW

56% TBW

100% TBW

hours

algal biomass (μg chl-a / L)

Figure 1: Growth of S. costatum introduced into ballast water dilutions 24 h after treatment
MEPC 57/2/7 

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From the obtained growth rates, the following EC50 and NOEC values (as % TBW) were 

calculated (table 4.4): 

Table 4.4: EC50 values based upon algal growth rate

 

Time after BW treatment 72 h EC50 72 h NOEC 

24 h 34.8% 32.6% 

48 h 59.4% 17.8% 

72 h 56.7% 32.6% 

96 h 67.6% 56.2% 

The first and last test (24 h and 96 h old ballast water) were incubated in a temperature-controlled 

shaking cabinet with fluoro-type lights at 20°C. The second and third test were incubated in a 

temporary location with cool-white lights at ca. 18°C and had to be shaken manually. Under 

these circumstances, the algae grew slower and did not reach the minimum growth rate of 0.9/d. 

However, the response to TBW (and the reference toxicant) was similar in all tests, indicating 

that the lower growth was not due to a lower viability of the algae, but to less than optimal 

culture conditions. 

Artemia franciscana 

The brine shrimp A. franciscana was not affected by treated ballast water. Survival was at 

least 90% in all treatments, with two exceptions: UBW in the 48 h test (87%) and 10% TBW in 

the 72 h test (77%). 

Solea solea 

Survival of sole larvae was good (87.5% to 100%) throughout all tests. No effects of ballast 

water treatment were observed. 

4.5 Conclusions 

At 24 h after treatment of the ballast water with the electrolytic cell, no effects were observed of 

the treatment on larvae of the brine shrimp (Artemia franciscana) and eggs and yolk-sac larvae of 

the sole (Solea solea). 

The diatom Skeletonema costatum was severely affected by the treated ballast water, resulting in 

complete mortality of the algae in undiluted treated ballast water even in the tests initiated 96 h 

after treatment. In time, however, the effects were gradually alleviated, resulting in complete 

recovery of the algae in 56% TBW during the 3 day exposure in the test initiated with ballast 

water 96 h after treatment. 
MEPC 57/2/7 

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5 RISK ASSESSMENT (THE METHODOLOGY, SECTION 7) 

5.1 Risk to safety of the ship 

Corrosion 

The electrolytic cell itself, including connecting pipes, is fully protected by special coatings 

against corrosion. The ballast water tanks in principle are subject to corrosion, especially 

immediately after treatment. FAC, however, disappears rapidly. Ballast water tanks normally are 

coated against corrosion. This regular practice is expected to be sufficient for treated ballast 

water. Corrosion is at present monitored and will be reported in the application for 

Final Approval. 

Generation of hydrogen gas 

During electrolysis hydrogen gas (H2) is produced (see chapter 2). Theoretically, the cell 

produces 0.0186 mol H2 gas per ampere (A) per hour, which equals 7.5 g H2 per hour under 

standard operating with 200 A. With a flow in the cell of 100 m3/hour, this results in a H2 gas 

concentration of less then 0,1 ppm. This is far below any dangerous concentration. During 

full-scale testing for the Final Approval application, H2 will be monitored. 

Other issues 

Storage and handling of substances is not an issue, since FAC is produced in situ. Neither is 

contact with, inhalation or noise an issue. The BWMS will operate in the machine room of the 

ships using standard pumps. Neither the Sedimentor nor the electrolytic cell produces any noise. 

5.2 Risks to human health 

FAC 

FAC was detected in treated ballast water at a maximum concentration of 1.67 mg/l immediately 

after treatment. It decreased to 0.5 mg/l within 2 hours. Ref. 31 states that, in general, regulations 

for FAC concentration in swimming pools require a minimum of 0.4 mg/l. Sometimes maximum 

concentrations are set, e.g., in France. The figure is 1.4 mg/l. WHO (2004) recommends a 

drinking water standard for chlorine of 5 mg/l. The PEC in a standard OECD-EU harbour for 

FAC was calculated at 0.34 μg/l with MAM-PEC (see chapter 3.1). It is concluded that FAC in 

treated ballast water in the tanks nor in the environment poses a risk to human health. 

Tribromomethane 

Tribromomethane was detected in treated ballast water at a maximum concentration of 290 μg/l. 

WHO (2004) recommends a drinking water standard for tribromomethane of 100 μg/l. The PEC 

in a standard OECD-EU harbour for tribromomethane was calculated at 1.28 μg/l with 

MAM-PEC (see chapter 3.2). It is concluded that tribromomethane in treated ballast water in the 

tanks nor in the environment poses a risk to human health. 
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2,2 Dibromoacetic acid 

The 2,2 Dibromoacetic acid was detected in treated ballast water at a maximum concentration 

of 64 μg/l. It was below detection (1 μg/l) after 24 hours aging of the ballast water. WHO (2004) 

recommends a drinking water standard for 2,2 dibromoacetic acid of 100 μg/l. The PEC in a 

standard OECD-EU harbour for 2,2 dibromoacetic acid was calculated at 0.019 μg/l with 

MAM-PEC (see chapter 3.3). It is concluded that 2,2 dibromoacetic acid in treated ballast water 

in the tanks nor in the environment poses a risk to human health. 

5.3 Risks to the aquatic environment 

FAC 

The MAM-PEC model calculates for FAC a steady state situation (= PEC) in the harbour 

of 0.34 μg/l and of 0.017 μg/l in the surroundings. The model calculates a steady state situation in 

the shipping lane of 0.014 μg/l. 

In various documents, the predicted no effect concentrations of FAC (PNEC) have been 

calculated with different outcomes. Annex 7 to MEPC 56/2/2 (review by the GESAMP-BWWG 

of the application by Japan, MEPC56/2), reports a value of 0.07 μg/l. Reference 31 reports a 

value of 0.04 μg/l. MEPC 57/2/1 (application by Korea) reports 8 μg/l. 

When using the lowest figure of 0.04 μg/l the PEC/PNEC ratio for a standard OECD-EU harbour 

is 0.34/0.04 = 8.5 and for its surroundings 0.017/0.04 = 0.42. For the shipping lane it 

is 0.014/0.04 = 0.35. The applicant concludes, that using these input data, the PEC/PNEC ratio 

for the harbour is > 1. In the other compartments it is lower than 1. 

Tribromomethane 

The MAM-PEC model calculates for tribromomethane a steady state situation (= PEC) in the 

harbour of 1.28 μg/l and of 0.036 μg/l in the surroundings. The model calculates a steady state 

situation in the shipping lane of 0.005 μg/l. 

In various documents, the predicted no effect concentrations of tribromomethane (PNEC) have 

been calculated with different outcomes. Annex 7 to MEPC 56/2/2 (review by the 

GESAMP-BWWG of the application by Japan, MEPC 56/2), reports a value of 7.1 μg/l. 

Reference 31 reports a value of 146 μg/l. RIVM (2005, ref. 30) reports a PNEC of 1.5 μg/l. 

When using the lowest figure of 1.5 μg/l, the PEC/PNEC ratio for a standard OECD-EU harbour 

is 1.28/1.5 = 0.85 and for its surroundings 0.036/1.5 = 0.024. For the shipping lane it 

is 0.005/1.5 = 0.003. The applicant concludes, that the PEC/PNEC ratio for tribromomethane is 

much less than 1 for all compartments. 

2,2 Dibromoacetic acid 

The MAM-PEC model calculates for 2,2 dibromoacetic acid a steady state situation (= PEC) in 

the harbour of 0.019 μg/l and of 0.001 μg/l in the surroundings. The model calculates a steady 

state situation in the shipping lane of 0.0007 μg/l. 
MEPC 57/2/7 

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In various documents, the predicted no effect concentrations of 2,2 dibromoacetic acid (PNEC) 

have been derived with different outcomes. Annex 7 to MEPC 56/2/2 (review by the 

GESAMP-BWWG of the application by Japan, MEPC 56/2), reports a value of 6.9 μg/l. 

Reference 31 reports a value of 0.72 μg/l. 

When using the lowest figure of 0.72 μg/l, the PEC/PNEC ratio for a standard OECD-EU 

harbour is 0.019/0.72 = 0.03 and for its surroundings 0.001/0.72 = 0.001. For the shipping lane 

it is 0.0007/0.72 = 0.001. The applicant concludes, that the PEC/PNEC ratio for 

2,2 dibromoacetic acid is much less than 1 for all compartments. 

5.4 Conclusion 

The main concern of this BWMS is the risk to algae by the PEC of FAC in a harbour of limited 

dimensions (0.34 μg/l ) and the tribromomethane concentration (approximately 0.300 mg/l) for 

the crew in the ballast water tanks after intake. The toxicity for algae was confirmed by the 

ecotoxicological tests commissioned by the applicant (see chapter 4). The applicant will further 

investigate and assess these risks during full scale land-based tests for the Final Approval 

application. 

6 ASSESSMENT REPORT (THE METHODOLOGY, SECTION 8) 

6.1 Overview of data and endpoints 

Chapter 5 presents an overview of all critical data and endpoints used for the risk assessment. 

All data is science based and literature references are given. Monographs on individual 

compounds have been used among which a draft RAR for the Active Substance. The applicant 

has commissioned research on the Active Substance and Relevant Chemicals by accredited 

commercial laboratories and University institutions in the Netherlands and Germany. Quality 

control protocols were at all times strictly followed: see annexes 1-4. Representatives of Lloydís 

register have consequently witnessed critical tests in the laboratory and on land and have 

approved these. The applicant considers the quality of test reports ìstate of the artî. 

6.2 Assessment of risks, input data for modeling and uncertainty 

From chapter 5 it can be concluded, that the main risk of this BWMS is the PEC of FAC for 

algae in the harbour of discharge of treated ballast water. The PEC/PNEC ratio is clearly too 

high, when calculated with MAM-PEC and the input data used. Some of these input data has a 

considerable uncertainty: 

The volume of discharge per day of ballast water: At present no reliable data is available. 

Figures are used that differ orders of magnitudes (50,000 ñ 397,000 m3

). The figure used in this 

application (200,000 m3) is considered too high, according to information of the Rotterdam Port 

Authority. It implies that each day 3-4 big bulk carriers and/or oil tankers with this BWMS 

discharge in the same harbour. A more realistic figure is 5 such ships each week. It should be 

kept in mind that MAM-PEC is a ìsteady stateî model, that assumes that there is a permanent 

source of a pollutant, in this case 334 kg hypochlorite each day in the same place, the year round. 

It is highly questionable, whether this is a realistic assumption. It probably is a considerable 

overestimation. 
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Different half-lives: In the literature, varying values for the half-life of hypochlorite can be 

found: minimum 45 minutes and maximum 90 minutes. This is the half-life based on hydrolysis. 

FAC, however, reacts very quickly with organic material and will disappear very fast in an 

environment with organic material (see annex 2 in ref. 31). It is difficult to quantify this figure, 

but even in the ballast tank it reduces from 1.67 to 0.5 mg/l in 2 hours. Further analysis will be 

done during full-scale land-based tests. 

Different concentrations: The T=0 concentration during the tests for this application 

was 1.67 mg/l. The applicant will optimize the electrolytic cell to produce the minimum 

concentration of FAC for effective killing the organisms, which is 0.5 mg/l. 

Different PNECS: A critical value for risk assessment is the PNEC value. In this application, 

the lowest value found in literature (0.04 μg/l) has been used to calculate the PEC/PNEC ratio. 

Further research will be done to decide on the most realistic value of PNEC for hypochlorite, 

including temperature effects. 

6.3 Compliance with the Convention 

The results of the laboratory and land-based tests clearly demonstrate that the applicant is 

complying with the Convention. The BWMS is achieving the minimum killing rates required for 

all relevant organisms easily through the combination of sediment removal and subsequent 

disinfecting. 

Preliminary ship-board tests have shown that the BWMS is effective in water with a salt content 

of > 3 PSU. So, the BWMS can operate in 96% of all situations worldwide. The BWMS can 

operate in fresh water conditions, but salt has to be added during ballast water intake to a 

minimum concentration of 3 PSU. 

6.4 Risk management 

The applicant considers risks under normal operational conditions of this BWMS within the 

limits of the normal daily operation of any ship. The BWMS is a very robust device with little 

risk of failure. When switched of, e.g., under SOLAS, the BWMS immediately stops producing 

Active Substance. 

The concentration of the Active Substance and Relevant Chemicals will be controlled through 

the functioning of the electrolytic cell. The BWMS is controlled on line through sensors for flow, 

pressure and electrical conductivity, which has direct relation with chloride concentration in the 

ballast water. During full-scale land-based testing, optimization will be investigated in order to 

minimize the production of FAC and Relevant Chemicals. During these tests FAC, Relevant 

Chemicals, H2 and other required parameters will be monitored (TSS, DOC, POC, pH, salinity 

and temperature). Bromate analysis will be included in the program. Corrosion in ballast water 

tanks is monitored at present in detail and results will be reported in the application for 

Final Approval. Reliable statistics on the average daily discharge of treated ballast water in 

harbours will be collected to estimate more precise the input data for MAM-PEC to calculate the 

PEC. Further research will be done to clarify existing discrepancies with regard to the value of 

the PNEC, in particular for hypochlorite. New eco-toxicological tests will be done with treated 

ballast water, starting these tests immediately after treatment (T=0) and after 5 days of aging. 

All tests will be done under supervision of Lloydís Register. 
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