For reasons of economy, this document is pr inted in a limited number. Delegates are kindly asked to bring their copies to mee tings and not to request additional copies.

I:\MEPC\59\2-7.doc

INTERNATIONAL MARITIME ORGANIZATION

IMO 

# E

MARINE ENVIRONMENT PROTECTION
COMMITTEE
59th session Agenda item 2 MEPC 59/2/7
16 December 2008 Original: ENGLISH

HARMFUL AQUATIC ORGANI SMS IN BALLAST WATER

Application for Final Approval of the GloEn-Patrol TM Ballast Water Treatment System

Submitted by the Republic of Korea

SUMMARY

Executive summary: This document contains the non-confidential information related to the application for Final Approval of the GloEn-Patrol TM Ballast Water Treatment System under the ìProcedur e of approval of ballast water management systems that make use of Active Substance (G9)î adopted by resolution MEPC.169(57) . The documentation complies with the requirements related to assessments for Final Approval.

Strategic direction: 7.1

High-level action: 7.1.2

Planned output: 7.1.2.4

Action to be taken: Paragraph 6

Related documents: BWM/CONF/36; MEPC 57/2/4; MEPC 58/23 and BWM.2/Circ.15

Introduction

1 Regulation D-3.2 of the International C onvention 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 ìProcedure for approval of ballast wa ter management systems that make use of Active Substances (G9)î stipulates th e required information (MEPC 57/21, annex 1, paragraph 4.2.1) and contains provisions for risk characteri zation and analysis (MEPC 57/21, annex 1, paragraph 5.3). According to sectio n 6 of Procedure (G9), the Organization should evaluate the information provided in the application.

3 According to BWM.2/Circ.15, a document on th e proposal for approval containing all the
non-confidential data related to the respective ballast water mana gement systems that make use
of Active Substances should be submitted to the Committee.MEPC 59/2/7 - 2 -

I:\MEPC\59\2-7.doc 4 The competent authority in the Republic of Korea has verified the application dossier prepared by PANASIA Co., Ltd. and believes it to satisfy the data requirements of Procedure (G9) adopted by resolution MEPC.169(57).

5 The Republic of Korea therefore submits the non-confidential part of the manufacturerís application dossier in the annex of this document to the Organization for evaluation according to Procedure (G9). The complete dossier w ill be made available to the experts of
the GESAMP-BWWG with the understan ding of confidential treatment.

Action requested of the Committee

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

***MEPC 59/2/7

I:\MEPC\59\2-7.doc ANNEX

NON-CONFIDENTIAL INFORMATION ON THE GloEn-Patrolô BALLAST WATER TREATMENT SYSTEM (THE REPUBLIC OF KOREA)

1 INTRODUCTION

1.1 Terms and definitions

1.1.1 ìGloEn-Patrolô Ballast Water Treatment Syst emî is the commercial name of the ballast water treatment system developed by ìPANASIA CO., LTD.î This system is composed of filtration modules configured in a paralle l as a pre-treatment process, followed by a UV irradiation process equipped with a medium-pressure ultraviolet (MPUV) lamp as the main
treatment unit.

1.1.2 ìBallast Waterî means the seawater tr eated by the GloEn-Patrolô Ballast Water Treatment System.

1.1.3 ìTreated Waterî is the seawater treated by the GloEn-Patrolô Ballast Water Treatment System.

1.1.4 ìPre-treated Waterî is the seawater trea ted by only a filtration system, which is a pre-treatment part of the GloEn-Patr olô Ballast Water Treatment System.

1.1.5 ìBallast Water Dischargeî means the ballast water as would be discharged overboard through the GloEn-Patrolô Balla st Water Treatment System.

1.1.6 ìActive Substanceî means a substance or or ganism, including a virus or a fungus that has a general or specific action on or against harmful aquatic micro-organisms and pathogens.

In the GloEn-Patrol TM Ballast Water Treatment System, the MPUV process produces a ìPhotonî as the only ìActive Substanceî, which is comple tely responsible for inactivating all harmful aquatic micro-organisms and pathogens present in the ballast water (de Mora et al. , 2000;
Anderson et al. , 2003).

1.1.7 ìPreparationî means any commercial form ulation containing one or more ìActive Substances,î including any additives.

The GloEn-Patrol TM Ballast Water Treatment System does not intentionally add any ìPreparationî besides UV light.

1.1.8 ìRelevant Chemicalsî means transformati on or reaction products that are produced during the treatment process or in the receivi ng environment and may be of concern to the aquatic environment and human health when discharged.

The GloEn-Patrol TM Ballast Water Treatment System regards only hydroxyl radical (ïOH) as a ìRelevant Chemicalî. However, the amount of ï OH produced in the system is extremely small (de Mora et al. , 2000; Zepp, 1987; Brezonik and Fu lkerson-Brekken, 1998; Vaughan and Blough, 1998) and that was confirme d in the land-based testing.MEPC 59/2/7

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I:\MEPC\59\2-7.doc 1.2 Abbreviations used in the proposal

Table 1.1: List of abbreviations

BWTS Ballast Water Treatment System DOC Dissolved Organic Carbon DOM Dissolved Organic Matter DMPO 5,5í-dimethyl-1-pyrroline-N-oxide

HAAs Haloacetic Acids

H 2 O 2 Hydrogen Peroxide HOBr Hypobromous Acid HOCl Hypochlorous Acid IMO International Maritime Organization ïOH Hydroxyl Radical

OBr - Hypobromite Ion

OCl - Hypochlorite Ion

IUVA International Ultraviolet Association LPUV Low-pressure Ultraviolet MPUV Medium-pressure Ultraviolet NOM Natural Organic Matter

p CBA para -chlorobenzoic Acid PQL Practical Quantification Limit SUVA Specific UV Absorbance TOC Total Organic Carbon

TRO Total Residual Oxidant

THMs Trihalomethanes TSS Total Suspended Solid USEPA United States Environmental Protection Agency

UV dose Ultra Violet dose

mJ/cm 2 Milli Jule per Centimeter Square

mW sec/cm 2 Milli Watt Second per Centimeter Square EPA IRIS EPA Integrated Risk Information System

EPA HEAST EPA Health Effect s Assessment Summary Tables WHO World Health Organization WHO IARC WHO International Agency for Research on Cancer

1.3 Test facilities

The GloEn-Patrol TM Ballast Water Treatment System is installed on a special barge that has been designed and manufactured to meet IMOís require ment for the land-based testing. It has length of 44 metres, a width of 14 metres, a height of 3.3 metres and has four (4) ballast tanks, each of which has a capacity of 237 m 3 . Two of them are used as control tank (No. 4 W.B. TK) and simulated ballast tank (No.1.W.B.TK) during the type approval test according to Guidelines (G8) and the others are used for culture tanks/dosing tanks (No.2 and No.3 W.B.TK).

Internal structures conform to shipís practice. The ballast pumps are centrifugal type, and the piping is galvanized steel pipe.MEPC 59/2/7

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I:\MEPC\59\2-7.doc 1.4 GloEn-Patrol TM Ballast Water Treatment System

The PANASIA Ballast Water Treatment System ( called the ìthe GloEn-Patrolô Ballast Systemî hereinafter) for land-based test consisted of filtration unit, a UV unit, and Monitoring and Control Panel (called the ìcontrol panelî hereinafter) as specified below:

.1 Filtration system as a pre-treatment.
Flow rate: 250 m 3 /h Filtration degree: 50 micron
Material - Filter housing: SS 316L
- Filter screen: SS 316L - Cleaning mechanism: SS 316L

.2 UV disinfection system as a main treatment installed with: UV chamber (SS316L, flow rate 250 m 3 /h) Medium pressure UV lamps
UV monitor Temperature sensor Automatic washing wiper for quartz sleeves.

.3 Control and monitoring panel Power supply: 3-phase 380/440V, 50/60Hz
Controller: Siemens PLC - CPU: CPU 315-2 DP (Memory: 2 MB) - Power Supply: PS 307 5A

- DI: 16 X DC24V
- DO: 16 X Rel. AC120V/230V
- AI: 8 X 12bit

The whole system (the filter unit and the UV un it) is connected in series to the pipeline.

The GloEn-Patrol TM Ballast System operates in-line and so treats the ballast water as it passes through the system during the uptake of the ballast water and at discharge. At discharge the ballast water passes the UV unit onl y and the filter unit is bypa ssed to avoid backflushing water
from the filter unit.

1.5 Advantages and validity for use of the MPUV-based GloEn-Patrol TM

The summary of specific advantages for the MPUV-based GloEn-Patrol TM Ballast System is as
follows:

- UV is the most environmentally friendly way to reduce the number of viable micro-organisms, without causing poll uting the local seawater ecology;

- no biocide chemicals are required;

- no toxic by-products are formed;

- no corrosion problems in ballast tanks;MEPC 59/2/7

ANNEX Page 4

I:\MEPC\59\2-7.doc - the process requires little mainte nance and is easy to handle;

- the use of medium-pressure lamp technology allows small space requirements; and

- minimum operating costs and maximum operating safety.

Also, internationally recognized associations, International UV Association (IUVA) and the USEPA, guarantee water treatment by UV irradiation as a clean process:

The IUVA describes the UV technology as shown below:

Since UV is light, it travels through air and water at the speed of light, and when the UV source is turned off, the UV is gone. There are no residuals, and the water that has been exposed to UV is the same as it was before exposure, and certainly the water is
not radioactive . UV water disinfection units are de signed to provide enough of a UV dose so that any pathogenic micro-organisms in the water are rendered inactive. What happens is
that the UV is absorbed by the DNA in micro-organisms; the DNA is damaged so that the organism cannot reproduce. Cells that cannot reproduce cannot cause disease. The good thing about UV is that it does its job while the water is passing through the unit, but after the water has passed thro ugh, it has been disinfecte d, but its water quality has not changed

. (Quotation source: http://www.iuva.org/public/faqs.php )

Also, the USEPA regards the UV technology as a clean technology that does not form any specific harmful by-products.

Disinfection using a UV system is well-known as a clean process that does not generate disinfection by-products, according to the rule (Stage 2 Disinfectants and Disinfection By-products Proposed Rule (Stage 2 DBPR)) re gulated by the EPA, which addresses risks from microbial pathogens and disinfectants/d isinfection by-products (D/DBPs). The Stage 2 DBPR focuses on public health protection by li miting exposure to DBPs, specifically total trihalomethanes (TTH M) and five haloacetic acids (HAA 5 ), which can form in water through disinfectants used to control microbial pathogens. However, this rule will apply to a ll community water systems (CWSs) and non-transient non-community water systems (NTNCWSs) that add a primary or residual disinfectant other than ultraviolet (UV) light or deliver water that has been disinfected by a primary or resid ual disinfectant other than UV . Quotation source: http://www.epa.gov/safewa ter/stage2/index.html )

1.6 Efficacy test

Test water was prepared in two tanks of 440 m 3 in total (about 220 m 3 per tank) using high salinity seawater at the Busan coast or br ackish water at downstream of the Nakdong River considering the required salinity (>32 PSU or 3-32 PSU, respectively, with a minimum difference of 10 PSU). The 440 m 3 of test water was used for bot h of the testing and control.

The natural seawater as test wa ter was pumped from the sea 2 miles off harbour a day before test in order to meet salinity requirement while brackish water was taken at Nakdong River.MEPC 59/2/7

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I:\MEPC\59\2-7.doc Cultured organisms are poured into test water in No.2 and 3 ballast water tanks to meet target
concentrations.

The ballast tanks were pressure -washed with tap water by ge neral service pump on the barge
after each test.

The treatment sequence is illustra ted in Figures 1.1 and 1.2 below.

The GloEn-Patrolô Ballast System treats the ba llast water both on uptake and at discharge. At discharge the ballast water passes the UV un it and the filter unit is bypassed to avoid filter backflushing.

Figure 1.1: Schematic of the test at ballasting

Sampling point was determined as per Guidelin es (G8). Sampling numb ers are indicated by

SP1-SP8.

- Sampling points: Day 0;

- Sampling point SP 1 represents an untreated water sample;

- Sampling point SP 2 represents treated wate r with the GloEn-Patrolô Ballast System;
and

- Sampling Point SP 3 represents a control water sample.MEPC 59/2/7

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I:\MEPC\59\2-7.doc During ballasting, water passes thro ugh the filter unit to remove any particles and organisms and then continues/flows to the UV unit. Back flushing water is returned to the sea in situ at the ballasting site.

During discharge, the water passes the UV unit agai n to destroy any organisms, bacteria that might have re-grown in the tanks during storage.

Treated ballast water has been tested after a 5-day holding.

The treated water is stored in No.1 W.B.TK and control water is stored in No. 4 W. B. TK for 5 days. After 5 days, the water is transfe rred by ballast pump to be treated and then the control water is pumped for sampling before discharging to the sea.

In order to meet IMO Guidelines (G8), the la nd-based test for the type approval, chemical analysis testing and whole-effluent toxicity (WET) testing were simultaneously performed under
the same conditions.

Figure 1.2: Schematic of the land-based test at discharge

- Sampling points after 3 days storage: Day 3 - Sampling point SP 7 represents a cont rol water sample after 3 days storage - Sampling point SP 2 represents a tr eated water sample 3 days storage

- Sampling points after 5 days storage: Day 5 - Sampling point SP 6 represents an untr eated water sample after 5 days storage - Sampling point SP 4 represents a treated water sample 5 days storage - Sampling point SP 5 represents a cont rol water sample after 5 days storageMEPC 59/2/7

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I:\MEPC\59\2-7.doc 1.6.1 Land-based test

1.6.1.1 Seawater in Busan: test cycles 1, 2 and 6

The organism concentrations of test water for the land-based test sampling were set following Guidelines (G8). The water quality of the loca tion is summarized in Table 1.2. In this test,
after GloEn-Patrol TM treatment, the number of living organisms for all groups in control and treated water met regulation D-2 of the BWM Convention.

Table 1.2: Water quality of seawater (Busan)

Date Sample pH Temp. (°C) Salinity (PSU) DO (mg/L) TSS (mg/L) DOC (mg/L) POC (mg/L)

2008.07.24 Test water 8.4 23.3 32.6 7.5 18.1 2.8 2.7

2008.07.29 Control 7.9 25.3 32.5 5.3 18.6 1.9 0.7

2008.07.29 Treated 7.9 27.0 32.4 4.5 16.0 2.0 1.1

2008.08.08 Test water 8.2 24.7 33.4 8.4 18.9 3.4 2.1

2008.08.13 Control 7.8 28.2 32.0 8.6 11.1 1.8 0.7

2008.08.13 Treated 7.9 29.2 32.3 8.3 12.5 1.7 1.4

2008.10.15 Test water 8.1 23.6 33.1 7.2 19.7 2.4 1.7

2008.10.20 Control 7.8 22.5 33.2 7.1 10.2 2.5 0.4

2008.10.20 Treated 7.9 23.2 33.0 6.9 16.5 2.4 0.3

1.6.1.2 Brackish water in Nakdon g River: test cycles 3 to 5

The organism concentrations of test water for the land-based test sampling were set following Guidelines (G8). The water quality of the location is summarized in Table 1.3. In this test, after
GloEn-Patrol TM treatment, the number of living organisms for all groups in control and treated water met regulation D-2 of the BWM Convention.MEPC 59/2/7

ANNEX Page 8

I:\MEPC\59\2-7.doc Table 1.3: Water quality of brac kish water (Nakdong River)

Date Sample pH Temp. (°C) Salinity (PSU) DO mg/L TSS mg/L DOC mg/L POC mg/L

2008.09.24 Test water 8.0 25.4 21.2 6.7 53.2 5.3 6.3

2008.09.29 Control 7.7 24.2 21.0 7.4 87.1 2.5 4.6

2008.09.29 Treated 7.7 24.3 20.9 6.4 88.7 3.0 11.0

2008.10.01 Test water 7.7 23.1 20.9 8.9 82.4 7.1 5.7

2008.10.06 Control 7.5 24.2 21.1 7.7 49.6 2.5 4.0

2008.10.06 Treated 7.3 25.0 21.1 6.4 51.8 2.6 5.4

2008.10.08 Test water 8.2 23.0 20.6 8.4 66.5 7.2 5.8

2008.10.13 Control 7.4 23.3 21.0 6.9 52.3 3.2 2.5

2008.10.13 Treated 7.3 24.3 21.0 6.3 47.8 2.7 0.8

2 ACTIVE SUBSTANCE AND RELEVANT CHEMICAL

2.1 Identification of the ìActive Subs tanceî and ìRelevant Chemicalsî

2.1.1 ìActive Substanceî (Photon)

.1 The GloEn-Patrol TM Ballast System was designed to disinfect most of harmful aquatic micro-organisms and pathogens pr esent in seawater. The key method of this system to inactivate ha rmful aquatic micro-organisms and pathogens is use of direct photolysis with the MPUV irradi ation process. The MPUV lamp radiates photonic energy of polychromatic wavele ngths (200~300 nm) of UV light which makes it possible to kill all kinds of mari ne microbes that have their specifically sensitive wavelength (Giese and Darby, 2000).

.2 Since the general definition of ìActive Substanceî is a substance or organism, including a virus or a fungus that has a ge neral or specific action on or against harmful aquatic micro-organisms and pa thogens, ìPhotonî is defined as the
ìActive Substanceî in the GloEn-Patrol TM Ballast System.

2.1.2 ìRelevant Chemicalî (ïOH)

.1 Through the sunlight (especially UV light ) exposure of natura l water, ïOH could be formed photochemically by a variety of mechanisms. The absorption of light by DOM (dissolved organic matter) initially results in the formation of a single excited state species (DOM * ) that subsequently decays through a series of photophysical and photochemical pathways producing ïOH (de Mora et al. , 2000).

DOM + hv ! DOM* !! ïOHMEPC 59/2/7

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I:\MEPC\59\2-7.doc .2 Another route of ïOH production is the irradiation of nitrate in its long-wavelength absorption band (maximum 302 nm), resulting in ïO - production as an intermediate. The produced ïO - is rapidly protonated to its conjugate acid, ïOH (Zepp, 1987; Brezonik and Fulker son-Brekken, 1998; Vaughan and Blough, 1998).

NO 3 - + hv ! ! ïOH

.3 As described above, the MPUV system could generate ïOH in theory through the mechanisms as described above. Therefore, ïOH is defined as the ìRelevant
Chemicalî in the GloEn-Patrol TM Ballast System.

2.2 Test strategy of the ìTreated Waterî formed by the ìActive Substanceî and
ìRelevant Chemicalî

2.2.1 Other chemicals residual testing:

.1 HOBr/OBrAccording to the literature, bromide ion (Br - ) can be oxidized by ïOH according to following sequential reactions. (Zehav i and Rabani, 1972; von Gunten, 2003)

Br - + ïOH ↔ BrOH - k + = 1.06×10 8 M -1 s -1

, k

- = 3.3×10 7 s -1

BrOH - + H + ↔ Brï + H 2 O k + = 1.06×10 8 M -1 s -1

, k

- = 1.36 s -1

Brï + Br - ! Br 2 ï- k = 1010 M-1s-1

Br 2 ï- + Br 2 ï- ! Br- + Br 3 ï- k = 2×10 9 M-1s-1

Br 3 ï- + H 2 O ! HOBr + 2Br- + H+

HOBr ↔ H + + OBr -

.2 HOCl/OClChloride ion can also be oxidized by ïOH according to following analogous reactions (Jayson and Parsons, 1973; von Gunten, 2003)

Cl - + ïOH ↔ ClOH ClOH - + H + ↔ Clï + H 2 O
Clï + Cl - !!! HOCl/OCl -

Hypobromous acid/hypobromite ion (HOBr/OBr - ) and hypochlorous acid/hypochlorite ion (HOCl/OCl - ) are relatively stable oxidants in water once formed,. In practice, however, chances of formation of tertiary oxidants (HOCl and
OCl - etc.) are low since oxidation of chlori de ion to Clï by ïOH can be neglected under typical natural pH condition (Buxton et al. , 1988).

To investigate any formation of these oxidants (i.e. HOCl/OCl - ), residual
concentrations of HOCl/OCl - and HOBr/OBr - in the ìTreated Waterî were measured using the Total Residual Oxidant (TRO) analysis method (Perrins et al. , 2006). HOCl/OCl - and HOBr/OBr - were not detected (DL= 0.03 mg/L) in the ìTreated Waterî.MEPC 59/2/7

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I:\MEPC\59\2-7.doc .3 Hydrogen peroxide

In theory, the recombination of ïOH or naturally caused reactions (e.g., natural water exposed to sunlight) can produ ce another oxidant, hydrogen peroxide (H 2 O 2 ) (Buxton et al. , 1988, Cooper et al. , 1988; de Mora et al. , 2000).

ïOH + ïOH ! H 2 O 2 DOM + hv ! H 2 O 2 ( λ > 295 nm)

For H 2 O 2 analysis, the fluorometric method was used with the specifically devised

H 2 O 2 -analyser (Lazrus et al. , 1985; Oh et al. , 2005). A trace of residual H 2 O 2 (18 μg/L ~ 48 μg/L) was detected in the ìTreated Waterî, but was close to the detection limit (PQL= 10 μg/L). It is known that hydrogen peroxide could be naturally produced by many living organisms either within the organism itself or in the surround medium (Anders et al. , 1970, Zepp, 1987). In fact, the concentration level of hydrogen peroxi de formed during photolysis is not considered to be problematic in the marine aquatic environment.

2.2.2 By-products formation testing

Once the oxidants, HOCl/OCl - and HOBr/OBr - are formed, that could react with dissolved organic matters (DOM) in seawater to form se veral harmful halogenated organics such as Thrihalomethanes (THMs), Haloacetic acid (HAAs), and others (Westerhoff et al. , 2004).

ìTreated Waterî was analyzed halogenated organics by USEPA methods (EPA methods No.524.2, 552.2, and 90209). In result, none of hal ogenated by-products was detected in the
Treated Water.

The above results support the fact that both the ìActive Substanceî (Photon) and ìRelevant Chemicalî (ïOH) must not be resi dual in both of ìBallast Waterî and ìBallast Water Dischargeî not affecting the marine aquatic environment, which means that this process is safe in chemical perspective.

Further to that, the toxicity tests of treated wate r were followed to confirm any harmful effects to the marine aquatic environment.

2.3 List of water quality parameters for chemical analysis testing

For this proposal, samples of the ìUntreated Waterî and ìTreated Waterî (defined as ìBallast Waterî) were collected from the GloEn-Patrol TM Ballast System and were analyzed to see any changes in the water characteristics betwee n the samples. All sample analysis was carried out according to standard methods (or equivalent) except ïOH and H 2 O 2 , which requires specific analytical set-up. The testing is accredited by KORDI for the performance efficacy test, Yonsei University for specific analysis of ïOH, H 2 O 2 and TRO, and by the SGS Testing Korea Co., Ltd., for general chemical analysis, and NeoEnbiz for toxicity test, respectively. All experiments (sampling and data analysis) were carefully performe d under the well planned quality assurance project plan (QAPP).MEPC 59/2/7

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I:\MEPC\59\2-7.doc 2.4 Alternatives to testing a nd non-submission of data

Both photon and ïOH defined, as the ìActive Subs tanceî and ìRelevant Chemicalî, respectively, are not residual. Therefore, chemical analysis an d toxicological testing fo r the both could not be conducted. Instead, intrinsic properties with e fficacies for the both (photon and ïOH) were investigated from references.

Also, the literature on the disinfection with UV irradiation demonstrates that the process is effective against most all bacteria, viruses, an d protozoa relevant for the current drinking and waste water practices (Craik et al. , 2001; Oguma et al. , 2004; Hijnen et al. , 2006):

- Several researchers reported that bacter ial and viral fish pathogens including infectious salmon anaemia virus (ISAV) and viral haemorrhagic septicaemia virus (VHSV), and Vibrio species were very sensitive to UV-C irradiation, showing a 2-4 log
inactivation of infectivit y in fresh, brackish and seawater at 100-300 mJ/cm 2 of UV dose (Liltved et al. , 1995; Frerichs et al. , 2000; Liltved et al. 2006).

- Linden et al. (2007) reported that 4-log (99.99%) in activation of adenovirus, the most UV resistant waterborne pathoge n of concern to public hea lth, is achieved at less
than 60 mJ/cm 2 of UV fluence by use of MPUV lamp.

- Ultraviolet (UV) light disinfection systems play an important role in a total water treatment process used in fish hatcheries and rearing facilities. UV disinfection systems have been proven to be the most cost effective systems for destroying pathogenic micro-organisms in hatchery wa ters. Similar UV doses are effective at inactivating a host of bacteria, viruses and pr otozoa which can initiate disease in the hatchery and its rearing facilities.

- Hanovia Ltd., one of UV manufacturing comp anies, has installed over 300 aquaculture sy stems using medium pressure UV disinfection in 14 countries
around the world. Their UV treatment unit s have been widely applied to water treatment in hatcheries, fish farms (sal mon, sea bream and sea bass) shellfish depuration tanks and fry rearin g tanks as well as treati ng recirculation water in marine parks and aquaria ( http://www.water-technolo gy.net/contractors/ disinfection/ha novia/press13.html ).

- Aquafine/Trojan UV systems have been employed extens ively in the aquaculture industry and have, ove r the last 25 years, globally installed in ex cess of 150 UV systems in private a nd public hatcheries. These facilit ies disinfect over 275 million gallons of water per day to rear 1,000ís of tons of commercial and sport fish (http://www.aquafineuv.com/Ma rkets/Aquaculture.aspx).

Also, UV technology is particularly suited to the brewing, beverage , bottled water and food processing industries, where extremely high standard of hygiene are expected (Aquionics Inc. News) (http://h almapr.com/news/aquionics/).

UV irradiation (200-400 nm wavelengths) is a phys ical disinfection process. No chemicals are
added and there is no residual effect once the water leaves the UV react or. UV disinfection does not significantly change the water quality and thus does not produce significan t levels of regulated disinfection by-products (DBP s) (Bolton, J.R, 2008).MEPC 59/2/7

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I:\MEPC\59\2-7.doc 2.5 Procedures and timelines

The procedures and timelines for all tests in th is proposal followed in accordance with QAPP.

3 DATA-SET REQUIRED IN THE APPLICATION

3.1 Identification of the Active Substance or Preparation (G9: 4.1)

3.1.1 Preparations

ìPreparationî means any commercial formulati on containing one or more Active Substances including any additives:

The GloEn-PatrolTM Ballast System does not in tentionally add any ìPreparationî besides UV light.

Not applicable.

3.1.2 Active Substance

3.1.2.1 The MPUV based GloEn-Patrol TM Ballast System pr oduces photons as an only Active Substance that is available to kill a nd inactivate micro-organisms. The definition of the ìPhotonî is a particle of elect romagnetic radiation that travels at the speed of light, used to explain phenomena that require light to behave as particles rather than as waves. Because the photons are only available upon turning on the MPUV lamp, there must be no residual photons in both ìBallast Waterî and ìBallast Water Discharge.î

3.1.2.2 The information required by IMO as listed below is not ap plicable for Photon.

.1 the Trade name (where relevant); .2 the chemical (IUPAC) name; .3 the CAS number; .4 the UN number and proper shipping name (where relevant); .5 the molar mass; .6 the empirical formula; .7 the structural formula; .8 the classification in accordance with the UN GHS system; .9 the purity of the technical material and identification of impurities (chemical name and CAS-numbers, etc.); and .10 the identity of any stabilis ers or necessary additives.

3.1.2.3 It is because a photon is not a chemical substance but a physical matter, a ìParticle.î Thus, the physical properties and the relevant de finitions of a photon are summarized as follows (Bolton, 2001):MEPC 59/2/7

ANNEX Page 13

I:\MEPC\59\2-7.doc .1 Light has both particle and wave properties . It is transmitted in discrete packets of energy (photons) and yet has a freque ncy and a wavelength. The connection between these two properties is embodied in the Planck Law of Radiation:

Where u is the energy (J) of one photon, v is frequency (s -1 ), λ is the wavelength (m), is the wavenumber (m -1 ), c is the speed of light (2.9929 x 10 8 m/s 1 ) in a vacuum, h is the planck constant (6.6261 x 10 -34 J s), N A is the Avogadro number (6.02214 x 1023 mol -1 ), and U is energy per Einstei n. The units here have been given in the standard SI forms; however, for applications in ultraviolet light and photochemistry, λ is usually given in nanometres (nm) and in cm -1 , with appropriate numerical factors to make the le ft-hand side of the equation come out to joules (J).

.2 Fluence (UV dose): Fluence (symbol H, unit J/m 2 ) (also called UV dose) is defined as the total radiant energy of all wavelengt hs passing from all directions through an infinitesimally small sphere of a cross-secti onal area. If the fluenc e rate is constant overtime, the fluence is given by the fluence rate times the exposure time in seconds.
The term UV dose is often used in the UV disinfection literature. UV dose represents the UV exposure of a given or ganism in the germicidal range. Many
authors have used the unit mJ/cm 2 , but the equivalent mJ/cm 2 (=10 J/m 2 ) is preferred. The term ìFluenceî is preferred over that of ìUV dose,î since the term ìDoseî is used to imply total absorbed energy (e.g., the ìUV Doseî required to induce sunburn on the skin). Fluence repres ents the radiant energy ìIncidentî on a micro-organism, and in most cases only a small fraction (about 1%) of the radiant energy is absorbed.

.3 Quantum yield: The quantum yield (unitless), Φ , is a measure of the photon efficiency of a photochemical reaction. Φ is defined as the number of moles of a product formed or a reactant removed (P) per Einstein (one mole of photon) of photons absorbed. If steady-state is achieved, Φ can also be defined in terms of rates

as:

Where the rate of generation of P is in mol s -1 and Na is the absorbed photon flow (einstein s -1 ). Note that Φ P is based on the absorbed and not the incident photon flow.
This is an error often made in the literature.

.4 UV sensors: Certain semiconductors absorb only in the UV region (e.g., diamond, 190-230 nm; SiC, 210-380 nm and GaN, 250-370 nm) and are insensitive to visible light. These semic onductors can be incorporated into an
electronic circuit and thus serve as c onvenient online UV sensors in UV reactors. However, UV sensor circuits based on thes e semiconductors tend to drift with age; hence, they must be calibrated periodically with a radiometer.MEPC 59/2/7

ANNEX Page 14

I:\MEPC\59\2-7.doc 3.1.3 Relevant Chemicals (G9: 2.1.4) :

3.1.3.1 The by-product that the MPUV-based GloEn-Patrol TM system might produce when reacting with ballast water has been determined to be only ïOH.

3.1.3.2 The following information for ïOH (hydroxyl radical) is deemed to be a ìRelevant Chemicalî (NDRL/NIST Solu tion Kinetics Database, 2005):

.1 the Chemical (IUPAC) name: InChI=1/HO/h1H

.2 the CAS number: 3352-57-6

.3 the Molar mass: 17.0073 (g/mol)

.4 the empirical formula: HO

.5 the structural formula: O* H

.6 the classification in accordance with the GHS system.

3.1.3.3 Results of ïOH residual testing

For ïOH residual testing, 100 mM DMPO and 2 μ M p CBA were spiked into the ìUntreated Waterî, ìTreated Waterî (immediately afte r MPUV irradiation, after 10 min, 20, 40, 60 min retention, respectively). There were no residual ïOH in wate r treated with GloEn-patrol TM Ballast System.

3.1.4 Other Chemicals

According to the IMO Procedure (G9), wher e the processes might produce by-products not
deemed to be ìRelevant Chemical sî by the applicant, a justificat ion for such a conclusion should be provided.

3.1.4.1 The MPUV-based GloEn-Patrol TM Ballast System might produce other chemicals such as
HOCl/OCl - , HOBr/OBr - , THMs, HAAs, other halogenated organics, and H 2 O 2 due to the possibility of ïOH production dur ing MPUV irradiation. The in formation on each chemical
defined as ìOther Chemicalî is as follows:

.1 HOCl/OCl -

HOCl is a weak acid (pKa = 7.5 at 25 o C), which partially dissociates to OCl - :

HOCl = H + + OCl The ratio of HOCl to OCl - may be calculated from the expression:

log([HOCl]/[OCl - ] = 7.5 ñ pHMEPC 59/2/7

ANNEX Page 15

I:\MEPC\59\2-7.doc The sum of the three species, Cl 2 , HOCl, and OCl - , is commonly referred to as free available chlorine (FAC), and the con centrations of the individual species and their sum are usually expressed in units of mg/L as Cl 2 . The species of chlorine present in water will depend on the tota l concentration of chlorine, pH, and temperature (Letterman, 1999).

.2 HOBr/OBr - ( http://en.wikipedia.org/wiki/Hypobromite )

Hypobromous acid (HOBr) is a weak, unstable acid. It occurs only in solution and has chemical and physical properties that are very similar to those of HOCl.

In aqueous solution, HOBr partially deco mposes into the hypobromite anion OBr − and the proton H + . The salts of HOBr are also calle d HOBr. Just as the acid, these salts are unstable and when evaporated or boiled to dryness, they undergo a disproportionation reaction, yielding the respective bromate and bromide salts.

When pure bromine is added to water, HOBr and hydrobromic acid (HOBr) form:

Br 2 (l) + H 2 O(l) → HOBr(aq) + HBr (aq)

HOBr dissociates to some degree to form the OBr - , depending upon the pH:

HOBr ↔ OBr - + H+ (pKa = 8.7)

HOBr is used as bleach, an oxidizer, a deodorant, and a disinfectant, due to its ability to kill the cells of many pathogens. The co mpound is generated in warm-blooded vertebrate micro-organi sms especially by eosinophils, which produce HOBr by the action of esoinophil peroxidase, an enzyme that preferentially uses bromide. Br - is also used in hot tubs and spas as a germicidal agent, using the action of an oxidizing agent to generate OBr - in a similar fashion to the peroxidase in eosinophils. It is especially effective when used in combination with its coneger, HOCl.

.3 THMs

Trihalomethanes (THM) are a group of four chemicals that are formed along with other disinfection by-products when chlorine or other disinfecta nts used to control microbial contaminants in drinking wate r react with naturally occurring organic and inorganic matter in water. The trihalomethanes are chloroform, bromodichloromethane, dibromochloromethane, and bromoform. The EPA has published the Stage 1 Disinfectants/Disin fection By-products Rule to regulate total trihalomethanes (TTHM) at a ma ximum allowable annual average level of 80 parts per billion. This standard replaced the standard of a maximum allowable annual average level of 100 part s per billion in December 2001 for large surface water public water systems. The st andard became effective for the first
time in December 2003 for small surf ace water and all ground water systems ( http://www.epa.gov/enviro/html/icr/gloss_dbp.html ).MEPC 59/2/7

ANNEX Page 16

I:\MEPC\59\2-7.doc .4 HAAs

Haloacetic acids (HAA 5 ) are a group of chemicals that are formed along with other disinfection by-products when ch lorine or other disinfectants used to
control microbial contaminants in drinki ng water react with naturally occurring organic and inorganic matter in water. The regulated haloacetic acids, known as

HAA 5 , are: monochloroacetic acid, dich loroacetic acid, trichloroacetic acid, monobromoacetic acid, and dibromoacetic acid. The EPA has published the Stage 1 Disinfectants/Disin fection By-products Rule to regulate

HAA 5 at 60 parts per billion annual averages. This standard became effective for large surface water public water systems in December 2001 and for small surface water and all ground water public water systems in December 2003 ( http://www.epa.gov/enviro/html/icr/gloss_dbp.html ).

. 5 H 2 O 2

Hydrogen peroxide (H 2 O 2 ) solutions are clear, colorless, and water-like in appearance, and can be mixed with water in any propor tion. At high concentrations, H 2 O 2 has a slightly pungent or acidic odor. H 2 O 2 has a molecular weight of 34.02 and is nonflammable at an y concentration. Its Chemical Abstracts Service Registry Number is 7722-84-1 ( www.h2o2.com ).

H 2 O 2 dissociates into th e hydroperoxide ion (HO 2 - ):

H 2 O 2 ↔ H 2 O - + H + (pKa = 11.6)

H 2 O 2 (ORP = 1.8 V) is one of the most powerfu l oxidizers known stronger than chlorine, chlorine dioxide, and potassium permanganate.

Despite its power, H 2 O 2 is a natural metabolite of many micro-organisms, which decompose the H 2 O 2 they produce into oxygen and water. H 2 O 2 is also formed by the action of sunlight on water a natural purification system for our environment. Consequently, H 2 O 2 has none of the problems of gaseous release or chemical
residues that are associated with ot her chemical oxidants. And since H 2 O 2 is totally miscible with water, the issue of safety is one of concentration. Industrial-strength H 2 O 2 is a strong oxidizer and t hus requires special handling precautions.

The fact that H 2 O 2 is used for seemingly conve rse applications proves its versatility. For example, H 2 O 2 can inhibit microbial grow th (as in the biofouling of water circuits) and encourage microbial growth (as in the bioremediation of contaminated groundwaters and soils). Similarly, H 2 O 2 can treat easy-to-oxidize pollutants (iron and sulfides) and diffi cult to oxidize pollutants (solvents, gasolines and pesticides).

The reason why H 2 O 2 can be used for such diverse applications is the different ways in which its power can be directed termed selectivity. By simply adjusting
the conditions of the reac tion (e.g., pH, temperature, dose, reaction time, and/or catalyst addition), H 2 O 2 can often be made to oxidi ze one pollutant over another,
or even to favour different oxidati on products from the same pollutant.MEPC 59/2/7

ANNEX Page 17

I:\MEPC\59\2-7.doc Since H 2 O 2 was first commercialized in the 1800s, H 2 O 2 production has now
grown to over ₤ 1 billion per year (as 100%). In addition to pollution control,

H 2 O 2 is used to bleach textiles and paper products, and to manufacture or process foods, minerals, petrochemicals, and cons umer products (detergents). The use of

H 2 O 2 for pollution control parallels thos e of the movement itself municipal wastewater applications in the 1970s, industrial waste/wa stewater app lications in the 1980s, and more recently, air applications in the 1990s. Today, H 2 O 2 is readily available throughout the United States in drum, tote, mini-bulk, and bulk quantities in concentrations of 35% or 50% by weight.

3.2 Data on effects on aquatic plants, invert ebrates and fish, and other biota, including sensitive and representative organisms for Active Substance and Relevant Chemical (G9: 4.2.1.1)

3.2.1 Acute aquatic toxicity

3.2.2 Chronic aquatic toxicity

3.2.3 Endocrine disruption

3.2.4 Sediment toxicity

3.2.5 Bioavailability/biomagnification/bioconcentration

3.2.6 Food web/population effects

Since the ìActive Substance,î photon, is in the UV chamber onl y when the UV lamp is on and immediately disappears after st opping UV, the above items 3.2.1 to 3.2.6 are not relevant to the
Active Substance.

Regarding Relevant Chemical, ïOH:

.1 Data on effects on aquatic plants, invert ebrates and fish, and other biota, including sensitive and representative organisms is not available even from US EPA IRIS,
EPA HEAST and WHO IAR.

.2 ïOH instantaneously disappears within milli-seconds as soon as the water leaves the UV chamber due to its extremely short life-time (~10 -9 sec) in water and
furthermore no residual ïOH was obser ved in the ìTreated Waterî.

.3 Results of toxicity test show that no significant acute / ch ronic toxicity and sediment toxicity was observed.

Judging from the above, the above items 3.2.1 to 3.2.6 ar e not relevant to the Relevant Chemical.MEPC 59/2/7

ANNEX Page 18

I:\MEPC\59\2-7.doc 3.3 Data on mammalian toxicity for Ac tive Substance and Relevant Chemical

3.3.1 Acute toxicity

3.3.2 Effects on skin and eye

3.3.3 Repeated-dose toxicity

3.3.4 Chronic toxicity

3.3.5 Developmental and reproductive toxicity

3.3.6 Carcinogenicity

3.3.7 Mutagenicity/genotoxicity

3.3.8 Toxicokinetics

As described the ìActive Substanceî, photon, is in the UV chamber only when the UV lamp is on and immediately disappears after stopping UV, the above items 3.3.1 to 3.3.8 are not relevant
to the Active Substance.

Regarding Relevant Chemical, ïOH:

.1 Data on effects on aquatic plants, invert ebrates and fish, and other biota, including sensitive and representative organisms is not available even from US EPA
database.

.2 ïOH instantaneously disappears within milli-seconds as soon as the water leaves the UV chamber due to its extremely short life-time (~10 -9 sec) in water and
furthermore no residual ïOH was obs erved in the ìTreated Waterî.

.3 Results of toxicity test show that no significant acute / ch ronic toxicity and sediment toxicity was observed.

Judging from the above, the above items 3.3.1 to 3.3.8 ar e not relevant to the Relevant Chemical.

3.4 Data on environmental fate and effect under aerobic and anaerobic condition (G9: 4.2.1.3)

3.4.1 Modes of degradation (biotic and abiotic)

According to the Procedure of the approval of ba llast water management systems that make use of Active Substances (G9), tes ting should include a study on hydr olysis at pH 5, 7, and 9 under aerobic conditions according to OECD guideline 111. In addition, studies on ready biodegradability according to OECD guidelines 301 and 306 (or equivalent guidelines) should be conducted, if the Active Substa nces, any other components of preparations, and Relevant Chemicals are discharged into water.MEPC 59/2/7

ANNEX Page 19

I:\MEPC\59\2-7.doc .1 Active Substances (photon)

Photon is available and active only during UV irradiation, but, photon immediately disappears af ter stopping UV irradiati on. (Ref: International UV association (IUVA), http://www.iuva.org/ public/faqs.php ). Consequently, the testing for hydrolysis and biodegradab ility of photon is not available.

.2 Relevant Chemical (ïOH):

In theory, maximum 10 -13 ~10 -15 M of ïOH can be produced during
MPUV irradiation with GloEn-Patrol TM Ballast System. However, ïOH can not remain in seawater due to short-life time (~milliseconds) and the high reactivity (10 9 ~10 10 M -1 s -1 ) with background components presen ce in seawater as described above (1.3.2). The results of ïOH residual te sting support the fact that ïOH is not to remain in treated water (see sect ion 3.1.3). Therefore, the testing for degradation of Relevant Chemical (ïOH) is not available with GloEn-Patrol TM Ballast System.

Required data Active
Substance (Photon) Relevant
Chemicals (ïOH) Treated

Water

3.4.2 Bioaccumulation, Partition Coefficient, Octanol/Water
Partition Coefficient N.A. N.A. -

3.4.3 Persistence and Identification of

the Main Metabolites in the

Relevant Media N.A. Extremely
short half-life a -

3.4.4 Reaction with Organic Matter N.A. b N.A. c

- 3.4.5 Potential Physical Effects on
Wildlife and Benthic Habitats N.A. N.A. None

3.4.6 Potential Residues in Seafood N.A. N.A. - 3.4.7 Any Known Interactive Effects None None -

- Not required N.A Not applicable
A The half-life of ïOH is close to 10 -9 sec in water (Buxton et al. , 1988). b A photon reacts with organics at relatively slow ra tes, and the reaction rate is dependant on the chemical properties of matter, such as quantum yiel d, molar extinction coefficient, and photolysis fraction (Bolton, 2001). For the case of DOC, a si gnificantly high UV dose is required for its reduction (Buchanan et al. , 2004). c ïOH reacts with organics at extremely high rates ranging 10 8 ~10 10 M -1 s -1 (Buxton et al. , 1988). These reactions of ïOH with organics are possible under the continuously ïOH produced condition, which can be provided by advanced oxidation processes (AOPs) such as ozone/high pH, ozone/H 2 O 2 , UV/H 2 O 2 , ozone/UV, UV/TiO 2 , gamma-ray, sonication, (Photo) Fenton, etc. (Arbon et al. , 1994; Rechardson et al. , 1996; Kang and Hoffmann, 1998; Park et al. , 2001;

Moraes et al.

, 2004; Garoma and Gurol, 2005; Oh et al, 2005; Chen et al. , 2006). In general, these AOPs can produce high amounts (10 -9 ~10 -11 M) of ïOH. So, it should be noted that the amount of ïOH produced from the MPUV irradiation of seaw ater is significantly low, at most 10 -13 ~10 -15 M, which is not a significant level to affect any ch ange in background organics present in seawater.MEPC 59/2/7

ANNEX Page 20

I:\MEPC\59\2-7.doc 3.5 Physical and chemical properties for the Active Substances (N.A) and treated ballast water, if applicable (G9: 4.2.1.4)

Required data Active
Substance (Photon) Relevant
Chemicals (ïOH) Treated Water

3.5.1 Melting Point N.A. - - 3.5.2 Boiling Point N.A. - - 3.5.3 Flammability (Flash Point) N.A. N.A. -

3.5.4 Density (Relative Density) N.A. N.A. Brackish water:1.012 Seawater:1.017 g/mL 3.5.5 Vapour Pressure, Vapour Density N.A. N.A. -

3.5.6 Water Solubility/ Dissociation Constant (pKa) N.A. N.A./11.9 a

-

3.5.7 Oxidation/Reduction Potential (ORP) N.A. 2700 mV b Brackish water: 733 mV, c

Seawater: 727 mV c 3.5.8 Corrosivity to the Materials or Equipment of Normal Ship Construction N.A. N.A. -

3.5.9Auto-ignition Temperature N.A. N.A. -

3.5.10 Explosive Properties N.A. N.A. -

3.5.11 Oxidizing Properties N.A. Nonselective d

Various

routes e -

3.5.12 Surface Tension N.A. - - 3.5.13 Viscosity N.A. - - 3.5.14 Thermal Stability and Identity of Relevant

Breakdown Products N.A f

- -

3.5.15 Reactivity towards
Container Material N.A. N.A. None

3.5.16 pH - - 7.3-8.4

3.5.17 Salinity
- - Brackish water:20.9-21.2 PSU

Seawater: 32.0-33.4 PSU

3.5.18 DOC
- - Brackish water:5.3-7.1 mg/L Seawater: 2.4-3.4 mg/L

3.5.19 POC
- - Brackish water:5.7-6.3 mg/L Seawater: 1.7-2.7 mg/L

3.5.20 Other Known Relevant Physical or
Chemical Hazards N.A. N.A. None

- Not required N.A. Not applicable.MEPC 59/2/7

ANNEX Page 21

I:\MEPC\59\2-7.doc a It is of little importance at the pH values that prevail in biological systems, but it must be mentioned that at high pH the ïOH deprotonates as the following equilibrium (Weeks and Rabani, 1996; Poskrebyshev et al. , 2002).

ïOH + OH - ↔ O ï + H 2 O pKa = 11.9 b OH shows the highest ORP value compared to the other oxidants summarized in the table below.

Oxidants ORP (V)

ïOH 2.70

Ozone 2.07

H 2 O 2 1.77

KMnO 4 1.67

ClO 2 1.50

HOCl 1.36

c The ORP value of ìTreated Waterî is almost same as that (727~733 mV) of ìPre-treated Waterî. d The ïOH (hydroxyl radical) is one of the most powerful oxidizing agents known (E  ̊ = +2.7 V in acid solution) and reacts with most organic compounds at almost diffusion-controlled rates (Letterman, 1999; Bolton, 2001). e The following are possible reaction types (Bolton, 2001):

- Abstraction of a hydrogen atom ñ usually w ith aliphatic hydrocarbon groups; for example:

CH 3 OH + ïOH ! ïCH 2 OH + H 2 O

- Insertion ñ usually with unsaturated or aromatic hydrocarbon groups; for example:
CHCl=CCl 2 (TCE) + ïOH ! ïCHCl-C(OH)Cl 2

- Electron transfer ñ usually with inorganics; for example:

I- + ïOH ! ïI + OH -

- Radical-radical reactions ñ for example:

HO 2 ï + ïOH ! O 2 + H 2 O

- The ïOH radical absorbs UV weakly ( ε 230 = 530 M -1 cm -1 ; ε 260 = 370 M -1 cm -1 ).

3.5.21 Corrosivity to the materials or equi pment of normal ship construction

The influential factors on corrosion in seawater are salt content, solute gases such as oxygen, carbon dioxide, and pH level. Of the several fact ors, the solute oxygen content is of primary importance as a component influencing the corrosi on behaviour of most metals in seawater.
The GloEn-Patrol TM Ballast System does not cause oxygen gas evolution. There was no change of pH in the effluent water (ìTreated Waterî) as compared to influent water (ìUntreated Waterî).

The GloEn-Patrol TM Ballast System does not produce any corrosive by-products, such as TRO (Total Residual Oxydants) and acidic compounds . It should be also noted that the ORP (Oxidation-Reduction Potential) va lue of ìTreated Waterî is almost the same as that (727~733 mV) of ìPre-treated Wate r.î In addition, the TRO was not detected after treatment, the above support the fact that the GloEn-Patrol TM Ballast System is free of corrosion risk.MEPC 59/2/7

ANNEX Page 22

I:\MEPC\59\2-7.doc 3.6 Analytical methods at environmentally relevant concentrations (G9: 4.2.1.5)

3.6.1 Other chemical analysis

All analyses of backgrounds and by-products we re conducted in accordance with the standard operation procedures (SOPs) and quality manua l (KS A ISO/IEC 10275) of SGS Testing Korea. Quality assurance and control were preformed based on the separated study plan as outlined in QAPP.

4 USE OF THE ACTIVE SUBSTANC E (PHOTON) OR THE RELEVANT CHEMICAL (ïOH)

4.1 Handling of Active Substances (Photon) and hydroxyl radicals

The Photon and ïOH s are produced from a specified number of UV lamps which is designed at specified flow rate for specified application.

Furthermore the UV dose is continuously mon itored by a sensor equipped on the UV chamber and limited on fixed power by control panel.

Since the control system adju sts the lamp power to limit the required UV dose 350 mJ/cm 2 , the maximum dosage (or maximum allowable discharge concentration) is not exceeded at any time.

5 MATERIAL SAFETY DAT A SHEETS (G9: 4.2.7)

Not available.

6 RISK CHARACTERIZATION

6.1 Screening for persistence, bioaccu mulation and toxicity (G9: 5.1)

The half-life of the ìActive S ubstanceî (photon) and the ìRel evant Chemicalî (ïOH) is so extremely short (about 10 -9 sec) and the ïOH have no residual property. As refer to the Criteria for identification of PBT substances, th e ìActive Substanceî (photon) and the ìRelevant Chemicalî (ïOH) produced from th e GloEn-Patrolô are not regarded as the PBT substance. Therefore, the assessment of PBT does not seem to be necessary.

6.2 Evaluation of the treated ballast water (G9: 5.2)

6.2.1 Chemical analysis of treated ballast water

Results of chemical analysis

The analysed backgrounds (anions, organic) co mpounds and potential by-products that might be
formed after GloEn-Patrol TM Ballast System in the brackish water and the seawater were
summarized in Tables 6.1 and 6.2.

Tables 6.1(1) and (2) (Report No. G280-1), and Tables 6.1(3) and (4) (R eport No. G280-2) list the results of seawater (>32 PSU) samples take n during the biological efficacy test cycles 1 and 2, respectively. Tables 6.2(1) and (2) (Report No. G280-3) show the results obtained using the brackish water (3~32PSU) for biological efficacy test cycle 4.MEPC 59/2/7

ANNEX Page 23

I:\MEPC\59\2-7.doc - Background (anions): There were no signi ficant changes on bromide, sulfate, fluoride, and nitrate concentrations in ì UV treated waterî compared to ìuntreated water (control water)î and ìcontrol waterî for both in the seawater and brackish

water.

- Bromide: 62 ~64 mg/L (control 63 mg/L ), 63 ~ 62 mg/L (control 65 mg/L) in seawater treated, 40 ~ 40 mg/L (cont rol 40 mg/L) in brackish water.

- Sulfate: 2410 ~ 2530 mg/L (contro l 2310 mg/L), 2690 ~ 2680 mg/L (control 2680 mg/L) in treated seawater (Data shown in Table 6.1(1), (2)), 1490 ~ 1480 mg/L, 1540 ~ 1520 mg/L in brackish water (1450 ~ 1550 mg/L in brackish control) (Data shown in Tables 6.2(1) and (2))

- Fluoride: Fluoride concentr ation seemed to be slight ly decreased both in the seawater and in the brackish water, but the concentrations were low (< 2.2 mg/L).

- Nitrate: Background nitrate is regarded as important source compound that can produce ïOH as described in previous (see section 2.1.2). However, nitrate was not detected in seawater samples. In brackish water, nitrate was detected
in both of control wate r (0.27~0.37 mg/L) and treate d water (0.27~0.53 mg/L), which were significantly low level and existed in raw water itself.

- Bromate (BrO 3 - ) is known to be the most to xic health rela ted inorganic by-products but was not detected (PQL = 0.25 mg/L, MDL = 4.3 μ g/L) in all of

the test conditions.

- TOC: TOC concentrations in the test wa ter were added with soluble lignin, starch (or seaweed powder) and kaolin (or prepar ed mud) to adjust the initial level of <1 mg/L in seawater (> 32 PSU) a nd >5 mg/L in brackis h water (3-32 PSU) according to IMO Guidelines (G8). Samp le TOCs were slightly increased (3.35 to 4.2, 3.05 to 3.61, 4.09 to 5.45, and 2.2 to 2.55 mg/L in seawater, and 8.14 mg/L to 8.2 mg/L in the brackish water) but some TOC data were fluctuated. This is because, the PQL and MDL values of TOC in seawater were determined to be 1~3 mg/L and 0.3~1 mg /L, respectively, due to the interference
of seawater constituents.

- Potential by-products (THMs, HAAs, TC E, PCE, and TOX): In seawater tests, any halogenated organic by-products such as THMs, HAAs, TCE, and PCE were
not detected in both of untreated and tr eated water samples. In brackish water, however, low level of HAAs were dete cted both in control (0.89 ~ 29.6 μ g/L) and in ìTreated Waterî (0.74 ~ 26.5 μg/L). The detected levels of HAAs were less than US EPA drinking water standard (60 μg/L). The raw water contamination
with trace level of HAAs is understandabl e since the river is the most polluted river contaminated with synthetic organic ch emicals in the Republic of Korea. It is
worthwhile to note that the HAAs decrease as the increase of storage time, but not
because of the treatment.MEPC 59/2/7

ANNEX Page 24

I:\MEPC\59\2-7.doc - TRO: Possible formation of HOCl/OCl - and HOBr/OBr - in the ìTreated Waterî was determined by directly meas uring Total Residual Oxidant (TRO)
concentration in situ . TRO was not detected (PQL = 0.03 mg/L) both in untreated and treated water samples, which implies that the GloEn-Patrol TM Ballast System does not produce any secondary stable oxidants such as HOCl/OCl - and
HOBr/OBr -

.

- Hydrogen peroxide: A tr ace level of residual H 2 O 2 (18 μg/L ~ 48 μg/L for seawater and 21 μg/L for blackish water) was detected in the ìTreated Waterî after MPUV irradiation, but concentration level was close to the detection limit (PQL= 10 μg/L). Knowing that hydrogen pe roxide could be naturally produced by many living organisms either within the or ganism itself or in the surround medium (Anders et al. , 1970, Zepp, 1987), the concentrati on level of hydrogen peroxide formed during photolysis is not considered to be problematic in the marine aquatic
environment.

In summary, no significant change on the conc entration of backgrounds was observed and the
other chemicals mentioned above were found not to be produced or detected at trace (insignificant) level during the GloEn-Patrol TM system. Consequently, these results confirm

that the GloEn-Patrol TM Ballast System employing MPUV physical process does not alter
the seawater chemical characteristics

.MEPC 59/2/7

ANNEX Page 25

I:\MEPC\59\2-7.doc Table 6.1: List of backgrounds (anions, organic compounds) and potential by-products in the seawater (>32 PSU) of Busan port after GloEn-Patrol TM Ballast System

(1) Treated water Test dates: 24-29 July 2008 (Report No.: G280-1) Test period Day 0 Day 3 Day 5

Procedure Ballasting Storage Discharge

Parameter Unit Untr

eated

wate

r (SP1

) Treat

ed

wate

r (SP2) Treated
water 3

days storage

(SP8) Untreate

d water
after 5

days storage

(SP6) Treated

water
after 5

days storage

(SP4) MDL

Bromide ion (Br
- ) mg/L 62 64 60 63 62 <25 c Fluoride ion (F
- ) mg/L 1.91 2.13 1.84 1.40 0.513 <0.0390 Bromate ion (BrO 3 - ) mg/L N.D b N.D N.D N.D N.D <0.250 c

Nitrate ion (NO 3 - ) mg/L

as N N.D N.D N.D N.D N.D <0.0760

Sulfate ion (SO 4 2- ) mg/L 2410 2530 2720 2690 2680 <0.0574 TOC mg/L 3.35 4.20 3.40 3.05 3.61 <1

COD a mg/L 96 128 168 128 136 <3.07 TCE μg/L N.D N.D N.D N.D N.D <0.76 PCE μg/L N.D N.D N.D N.D N.D <0.78 Chloroform μg/L N.D N.D N.D N.D N.D <0.73 Bromodichloromethane μg/L N.D N.D N.D N.D N.D <0.68 Dibromochloromethane μg/L N.D N.D N.D N.D N.D <0.76 Bromoform μg/L N.D N.D N.D N.D N.D <0.63 Total THMs μg/L N.D N.D N.D N.D N.D - Dibromoacetic acid μg/L N.D N.D N.D N.D N.D <0.02 Dichloroacetic acid μg/L N.D N.D N.D N.D N.D <0.14 Monobromoacetic acid μg/L N.D N.D N.D N.D N.D <0.10 Monochloroacetic acid μg/L N.D N.D N.D N.D N.D <0.07 Trichloroacetic acid μg/L N.D N.D N.D N.D N.D <0.04 Total HAAs μg/L N.D N.D N.D N.D N.D -

TOX μg/L 120 61 93 67 66 <20 c TRO mg/L N.D N.D N.D N.D N.D <0.03 Hydrogen peroxide mg/L N.D 0.048 N.D N.D 0.018 <0.0006

a Chloride ion contained in seawater is th e primary interference when determining COD
concentration. To reduce interference from chlo ride ion, all samples were diluted by 4-hold and added 0.5g HgSO4. In additio n, suspended solids (SS) were formed during COD analysis test. Sample dilution and suspended solids ( SS) might cause the measured COD values to be too high. b N.D: Not detected with the analytical method tested, < detection limit.

c Detection limit: PQL (Practical Quantification Li mit (reporting limit)), The PQL is the lowest level that can be reliably measured within speci fied limits of precision and accuracy during routine laboratory operating conditions. The SG S reporting limits are PQLs. This laboratory strives to establish PQLs at or near 3.18 times that of the maximum MDL. SP1: Untreated water (Ballasting, untreated water) SP2: Treated water (Ballasting, treated water) SP3: Control water (Ballasting, Control water) SP4: Treated water after 5 days storage (Discharge procedure, treated water) SP5: Control water after 5 days storage (Discharge procedure, Control) SP6: Untreated water after 5 days storage (Discharge, untreated water)MEPC 59/2/7

ANNEX Page 26

I:\MEPC\59\2-7.doc SP7: Control water for 3 days storage SP8: Treated water 3 days storage

(2) Control water Test dates: 24-29 July 2008 (Report No.: G280-1)

Test period Day 0 Day 3 Day 5

Procedure Ballasting Storage Discharge

Parameter Unit Control

water (SP3) Control
water after 3days storage

(SP7) Control
water after 5 days storage

(SP5) MDL

Bromide ion (Br - ) mg/L 63 64 65 <25 c Fluoride ion (F - ) mg/L 1.24 1.92 3.41 <0.0390 Bromate ion (BrO 3 - ) mg/L N.D N.D N.D <0.250 c

Nitrate ion (NO 3 - ) mg/L

as N N.D N.D N.D <0.0760

Sulfate ion (SO 4 2- ) mg/L 2310 2510 2680 <0.0574 TOC mg/L F b F F <1

COD a mg/L 156 92 128 <3.07 TCE μg/L N.D N.D N.D <0.76 PCE μg/L N.D N.D N.D <0.78 Chloroform μg/L N.D N.D N.D <0.73 Bromodichloromethane μg/L N.D N.D N.D <0.68 Dibromochloromethane μg/L N.D N.D N.D <0.76 Bromoform μg/L N.D N.D N.D <0.63 Total THMs μg/L N.D N.D N.D - Dibromoacetic acid μg/L N.D N.D N.D <0.02 Dichloroacetic acid μg/L N.D N.D N.D <0.14 Monobromoacetic acid μg/L N.D N.D N.D <0.10 Monochloroacetic acid μg/L N.D N.D N.D <0.07 Trichloroacetic acid μg/L N.D N.D N.D <0.04 Total HAAs μg/L N.D N.D N.D -

TOX μg/L 85 100 260 <20 c TRO mg/L N.D N.D N.D <0.03 Hydrogen peroxide mg/L N.D N.D N.D <0.0006

a The same as above(table 6.1(1)). b F: the analyte was positively identified but the associated numerical values were between MDL(Method detection limit, 1 mg/L) and the PQ L (Practical quantification limit, 3 mg/L). c The same as above(table 6.1(1)).MEPC 59/2/7

ANNEX Page 27

I:\MEPC\59\2-7.doc (3) Treated water Test dates: 8-13 August 2008 (Report No.: G280-2)

Test period Day 0 Day 3 Day 5

Procedure Ballasting Storage Discharge

Parameter Unit Untreated

Water (SP1) Treated

water (SP2) Treated
water 3

days storage (SP8) Untreated
water after 5 days storage (SP6) Treated

water
after 5

days storage (SP4) MDL

Bromide ion (Br
- ) mg/L - b - - - - <0.50 d
Fluoride ion (F
- ) mg/L 0.693 0.41 1.18 1.10 0.317 <0.0390 Bromate ion (BrO 3 - ) mg/L N.D N.D N.D N.D N.D <0.10 d

Nitrate ion (NO 3 - ) mg/L

as N N.D N.D N.D N.D N.D <0.0760

Sulfate ion (SO 4 2- ) mg/L 3070 3240 2840 2770 2780 <0.0574 TOC mg/L 4.09 5.45 1.75 2.20 2.55 <0.30

COD a mg/L 344 360 360 316 360 <3.07 TCE μg/L N.D N.D N.D N.D N.D <0.76 PCE μg/L N.D N.D N.D N.D N.D <0.78 Chloroform μg/L N.D N.D N.D N.D N.D <0.73 Bromodichloromethane μg/L N.D N.D N.D N.D N.D <0.68 Dibromochloromethane μg/L N.D N.D N.D N.D N.D <0.76 Bromoform μg/L N.D N.D N.D N.D N.D <0.63 Total THMs μg/L N.D N.D N.D N.D N.D - Dibromoacetic acid μg/L N.D N.D N.D N.D N.D <0.02 Dichloroacetic acid μg/L N.D N.D N.D N.D N.D <0.14 Monobromoacetic acid μg/L N.D N.D N.D N.D N.D <0.10 Monochloroacetic acid μg/L N.D N.D N.D N.D N.D <0.07 Trichloroacetic acid μg/L N.D N.D N.D N.D N.D <0.04 Total HAAs μg/L N.D N.D N.D N.D N.D -

TOX μg/L 12000 c 97 260 170 N.D <20 d
TRO mg/L N.D N.D N.D N.D N.D <0.03 Hydrogen peroxide mg/L N.D 0.047 N.D N.D N.D <0.0006

a The same as above (Table 6.1 (1)). b Samples for anions analysis were filtered with the OnGuard II Ag cartridges (P/N 057090) to remove chloride ion before anal ysis. Bromide ions in test sample were also removed by the pre-treatment. c It might be contamination with unknown hal ogenated organic during sampling. However, it
was from raw water not in treated water. d The same as above (Table 6.1 (1)).MEPC 59/2/7

ANNEX Page 28

I:\MEPC\59\2-7.doc (4) Control water Test dates: 8-13 August 2008 (Report No.: G280-2)

Test period Day 0 Day 3 Day 5

Procedure Ballasting Storage Discharge

Parameter Unit Control water (SP3) Control
water after 3 days storage

(SP7) Control
water after 5 days storage

(SP5) MDL

Bromide ion (Br - ) mg/L - b - - <0.50 c Fluoride ion (F - ) mg/L 1.39 1.17 1.17 <0.0390 Bromate ion (BrO 3 - ) mg/L N.D N.D N.D <0.10 c

Nitrate ion (NO 3 - ) mg/L

as N N.D N.D N.D <0.0760

Sulfate ion (SO 4 2- ) mg/L 3050 2870 2770 <0.0574 TOC mg/L 3.36 3.25 1.94 <0.30

COD a mg/L 392 584 308 <3.07 TCE μg/L N.D N.D N.D <0.76 PCE μg/L N.D N.D N.D <0.78 Chloroform μg/L N.D N.D N.D <0.73 Bromodichloromethane μg/L N.D N.D N.D <0.68 Dibromochloromethane μg/L N.D N.D N.D <0.76 Bromoform μg/L N.D N.D N.D <0.63 Total THMs μg/L N.D N.D N.D - Dibromoacetic acid μg/L N.D N.D N.D <0.02 Dichloroacetic acid μg/L N.D N.D N.D <0.14 Monobromoacetic acid μg/L N.D N.D N.D <0.10 Monochloroacetic acid μg/L N.D N.D N.D <0.07 Trichloroacetic acid μg/L N.D N.D N.D <0.04 Total HAAs μg/L N.D N.D N.D -

TOX μg/L 160 77 97 <20 c TRO mg/L N.D N.D N.D <0.03 Hydrogen peroxide mg/L N.D N.D N.D <0.0006

a The same as above (Table 6.1 (1)). b The same as above (Table 6.1 (3)). c The same as above (Table 6.1 (1)).MEPC 59/2/7

ANNEX Page 29

I:\MEPC\59\2-7.doc Table 6.2 List of backgrounds (anions, organ ic compounds) and potential by-products in the brackish water (3-32 PSU) of Nakdong River after GloEn-Patrol TM Ballast System

(1) Treated water
Test dates: 1-6 October 2008 (Report No.: G280-3)

Test period Day 0 Day 3 Day 5

Procedure Ballasting Storag

e Discharge

Parameter Unit Untreated

water (SP1) Treated

water (SP2) Treated
water 3

days storage (SP8) Untreated

water
after 5

days storage (SP6) Treated

water
after 5

days storage (SP4) MDL

Bromide ion (Br
- ) mg/L 40.0 40.0 40.0 40.0 40.0 <0.0563 Fluoride ion (F
- ) mg/L 0.555 0.60 0.423 0.477 0.402 <0.0390 Bromate ion (BrO 3 - ) mg/L N.D N.D N.D N.D N.D <0.0043

Nitrate ion (NO 3 - ) mg/L

as N 0.366 0.528 0.268 N.D N.D <0.0517

Sulfate ion (SO 4 2- ) mg/L 1490 1480 1480 1540 1520 <0.0574 TOC mg/L 8.14 8.20 3.25 2.95 8.13 <0.30

COD a mg/L 194 238 278 290 288 <3.07 TCE μg/L N.D N.D N.D N.D N.D <0.76 PCE μg/L N.D N.D N.D N.D N.D <0.78 Chloroform μg/L N.D N.D N.D N.D N.D <0.73

Bromodichlorometh

ane μg/L N.D N.D N.D N.D N.D <0.68

Dibromochlorometh

ane μg/L N.D N.D N.D N.D N.D <0.76

Bromoform μg/L N.D N.D N.D N.D N.D <0.63 Total THMs μg/L N.D N.D N.D N.D N.D - Dibromoacetic acid μg/L 4.64 3.87 3.61 N.D N.D <0.02 Dichloroacetic acid μg/L N.D N.D N.D N.D N.D <0.14

Monobromoacetic
acid μg/L N.D N.D 0.72 0.60 0.74 <0.10

Monochloroacetic
acid μg/L 4.93 3.06 N.D N.D N.D <0.07

Trichloroacetic acid μg/L 16.9 19.6 N.D N.D N.D <0.04 Total HAAs μg/L 26.5 26.5 4.33 0.60 0.74 -

TOX μg/L 4.78 6.99 2.14 2.14 2.21 <2 b
TRO mg/L N.D N.D N.D N.D N.D <0.03 Hydrogen peroxide mg/L N.D 0.021 N.D N.D N.D <0.0006

a, b The same as above (Table 6. 1 (1)).MEPC 59/2/7

ANNEX Page 30

I:\MEPC\59\2-7.doc (2) Control water
Test dates: 1-6 October 2008 (Report No.: G280-3)

Test period Day 0 Day 3 Day 5

Procedure Ballasting Storage Discharge

Parameter Unit Control

water (SP3) Control

water after 3days storage

(SP7) Control

water after 5 days storage

(SP5) MDL

Bromide ion (Br - ) mg/L 40 40 40 <0.0563 Fluoride ion (F - ) mg/L 0.725 0.442 0.399 <0.0390 Bromate ion (BrO 3 - ) mg/L N.D N.D N.D <0.0043

Nitrate ion (NO 3 - ) mg/L

as N 0.345 0.274 0.37 <0.0517

Sulfate ion (SO 4 2- ) mg/L 1450 1490 1550 <0.0574

TOC a mg/L 4.18 3.65 3.06 <0.3

COD b mg/L 232 170 264 <3.07 TCE μg/L N.D N.D N.D <0.76 PCE μg/L N.D N.D N.D <0.78 Chloroform μg/L N.D N.D N.D <0.73 Bromodichloromethane μg/L N.D N.D N.D <0.68 Dibromochloromethane μg/L N.D N.D N.D <0.76 Bromoform μg/L N.D N.D N.D <0.63 Total THMs μg/L N.D N.D N.D - Dibromoacetic acid μg/L 4.36 N.D N.D <0.02 Dichloroacetic acid μg/L N.D N.D N.D <0.14 Monobromoacetic acid μg/L N.D 0.89 1.00 <0.1 Monochloroacetic acid μg/L 5.62 N.D N.D <0.07 Trichloroacetic acid μg/L 19.6 N.D N.D <0.04 Total HAAs μg/L 29.6 0.89 1.00 -

TOX μg/L 4.18 4.05 3.68 <2 c TRO mg/L N.D N.D N.D <0.03 Hydrogen peroxide mg/L N.D N.D N.D <0.0006

a Control limit for TOC analysis was 70~130 %. b,c The same as above (Table 6. 1 (1)).

6.2.2 Assessment of treated ballast water

As outlined above, these tests were conducted on the whole-effluent from the GloEn-Patrol TM Ballast System of PANASIA CO., LTD.

Field water samples were collected at three appropriate time intervals after treatment (immediately after treatment, after 72 hrs (hou rs) interval, and final ballast water discharge after 5 days interval). Test substances for WET tests were prepared from the field water samples immediately on delivering to the laboratory. The water samples were passed through the filtering system (pore size 0.45 μ m) by using peristaltic pump, and then water parameters ñ pH, temperature, salinity and dissolved oxygen (DO) ñ were measured.MEPC 59/2/7

ANNEX Page 31

I:\MEPC\59\2-7.doc 6.2.2.1 Acute aquatic toxicity

.1 Acute toxicity test with the Rotifer , Brachionus

This study was performed to the effect of whole effluent (WET) by GloEn-Patrol TM Ballast System on the acute aquatic toxicity with Rotifer,
Brachionus . We evaluated the ability to kill 50% (LC 50 ) of Brachionus plicatilis

, marine water rotifer for 24 hrs of treated ba llast water (seawater or brackish water) and this compared to control water (seawater or brackish water).

The assay was performed in basic accorda nce with ìASTM E1440 Standard Guide for Acute Toxicity Test with the Rotifer, Brachionus .î

Using 24 hrs old rotifers (< 24 hrs neonate) hatched from the resting eggs, acute toxicity tests were carried out for treated ballast water (seawater or brackish water) and control water (seawater or brackish wa ter). Five rotifers were transferred to individual wells of a 48 well polystyrene plate, each containing 1 ml of test substances. The plates were incubated at 25oC in darkness. After 24 hrs, the
rotifers were observed under the stereomicr oscope. Rotifers were considered dead if no movement of the cilia and mastax was observed over a period of 30s. The dead and alive rotifers were counted. Statistical evaluation was performed according to methods for lethal and sub- lethal tests. A nominal error rate of 0.05 was applied when testing hypothesis to determine the test results. The results of the tests were reported as table showing survival at each experimental condition. The value of LC 50 was the concentrations (expressed as % treated ballast water) that cause d the mortality 50% of rotifers.

These results showed that there was no mortality to Brachionus plicatilis at all at any experimental condition. When treate d ballast water (seaw ater or brackish water; SP2, SP8, SP4) was compared to cont rol water (seawater or brackish water; SP3, SP7, SP5), there was no significant di fference in the survival rate. The LC 50 and actual NOEC could not be determined because these data was 100% over
concentration.

Therefore, the treated ballast wate r (seawater or brackish water) by GloEn-Patrol TM Ballast System did not indu ce the aquatic acute toxicity
in 24 hrs for Brachionus plicatilis

.

.2 Growth inhibition test with Microalgae

This study was performed to the effect of whole effluent (WET) by GloEn Patrol TM Ballast System on the aquatic acute toxicity of microalgae. We evaluated the ability to 50% growth inhibition (EC 50 ) of Dunaliella tertiolecta
and Skeletonema costatum or Phaeodactylum tricornutum, marine water microalgae for 96 hrs of treated ballast wate r (seawater or brackish water) and this compared to control water (seawater or brackish water).

The assay was performed in basic acco rdance with ìASTM E1218-97a Standard Guide for Conducting Static 96-h T oxicity Tests with Microalgaeî.MEPC 59/2/7

ANNEX Page 32

I:\MEPC\59\2-7.doc Three strains of microalgae, Dunaliella tertiolecta and Skeletonema costatum or Phaeodactylum tricornutum were used. They were inoculated at 25T flask and cultured for 96 hrs in shaking incubator. Cell number was counted by using of hemocytometer.

Statistical evaluation was performed accord ing to methods for growth inhibition
test. A nominal error rate of 0.05 was applied when test ing hypothesis to
determine the test results. The results of the tests were repor ted as table showing the progress of growth in the cultures at each experimental condition. The value
of EC 50 were the concentrations (expressed as % treated ballast water) that caused 50% reduction of the growth of the algae.

In these results, test substances did not induce growth inhibition to Dunaliella
tertiolecta and Skeletonema costatum or Phaeodactylum tricornutum at any concentrations. When treated ballast water (seawater or brackish water; SP2, SP8, SP4) was compared to control water (seawater or brackish water; SP3, SP7, SP5), there was no significa nt difference in the growth rate. The EC 50 and actual NOEC
could not be determined because these data was 100% over concentration.

Therefore, the treated ballast water by GloEn-Patrol TM Ballast System did not induce growth inhibition in 96 hrs for Dunaliella te rtiolecta and Skeletonema

costatum or Phaeodactylum tricornutum , marine waters microalgae.

.3 Survival toxicity test with the fish, Cyprinodon variegatus (larvae)

This study was performed to the e ffect of whole effluent (WET) by
GloEn-Patrol TM Ballast System on the survival test with sheepshead minnow. We evaluated the ability to kill 50% (LC 50 ) of Cyprinodon variegatus (larvae)

, marine water fish for 96 hrs of treated ballast water (seawater or brackish water) and this compared to control water (seawater or brackish water).

The assay was performed in basic accordance with ìUSEPA 821/R-02/014 Standard Guide for Short-term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Marine and Estuarine Organismsî.

Using 24 hrs old fish hatched from the resting eggs, acute toxicity test was carried out for a treated ballast water (s eawater or brackish wa ter), or a control water (seawater or brackish water). Ten of fish larvae were transferred to
individual chambers of 1L beakers of glass, each containing 500 ml of test substances. The chambers were incubated at 20oC for 96 hrs. Daily, the fish were
observed the survival. The dead and alive fi sh were counted. After 96 hrs, the test was end, and calculated the survival (%).

Statistical evaluation was performed according to methods for lethal and
sub-lethal tests. A nominal error rate of 0.05 was applied when testing hypothesis to determine the test results. The results of the tests were reported as table showing survival at each experimental condition. The value of LC 50 was the concentrations (expressed as % treat ed ballast water) that caused the mortality 50% of Cyprinodon variegatus (larvae).MEPC 59/2/7

ANNEX Page 33

I:\MEPC\59\2-7.doc These results showed that there was no mortality to Cyprinodon variegatus (larvae) at all at any experimental cond ition. When treated ballast water (seawater or brackish water; SP2, SP8, SP4) was comp ared to control water (seawater or brackish water; SP3, SP7, SP5), there was no significant difference in the
survival rate. The LC 50 and actual NOEC could not be determined because these
data was 100% over concentration.

Therefore, the treated ballast water by GloEn-Patrol TM Ballast System did not induce the aquatic acute toxicity in 96 hrs for sheepshead minnow, Cyprinodon variegatus (larvae).

6.2.2.2 Chronic aquatic toxicity

.1 Reproduction (or population growth) toxicity test with the Rotifer,
Brachionus

This study was performed to the e ffect of whole effluent (WET) by
GloEn-Patrol TM Ballast System on reproduction (or population growth) toxicity with Rotifer, Brachionus . We evaluated the ability to 50% popula tion growth inhibition (EC 50 ) of Brachionus plicatilis, marine water rotifer for 96 hrs of treated ballast water (seawater or brackish water) and this compared to control water (seawater or brackish water).

The assay was performed in basic accordan ce with ìCyst-based toxicity tests (Janssen et al. , 1994) Standard Guide for Short-ch ronic toxicity tests with the
freshwater rotifer Brachionus calyciflorus î.

Using 24 hrs old rotifers (<24 hrs neonate ) hatched from the resting eggs, the short chronic toxicity tests were carried out for treated ballast water (seawater or brackish water) and control water (seawater or brackish water). Five rotifers were
transferred to individual wells of a 48 we ll polystyrene plate, each containing 1 ml of test substances. The plates were incubated at 25 o C in darkness for 96 hrs. The
medium which contained 1 x 10 6 cells per ml of N. oculata, was not renew throughout the exposure period. After 96 hrs, the rotifers were observed under the stereomicroscope. Rotifers were considered dead if no movement of the cilia and mastax was observed over a period of 30 s. The dead and alive rotifers were
counted.

Statistical evaluation was performed accord ing to methods for growth inhibition tests. A nominal error rate of 0.05 was applied when testing hypothesis to determine the test results. The results of the tests were reported as table showing the progress of growth in the cultures at each experimental condition. The value of

EC 50 were the concentrations (expressed as % treated ballast water) that caused 50% reduction of the populat ion growth of the rotifers.

In these results, all test substances di d not induce population growth inhibition to Brachionus plicatilis at any concentrations. When treated ballast water (seawater or brackish water; SP2, SP8, SP4) was comp ared to control water (seawater or brackish water; SP3, SP7, SP5), there was no significant difference in the growth
rate. The EC 50 and actual NOEC could not be determined because these data
was 100% over concentration.MEPC 59/2/7

ANNEX Page 34

I:\MEPC\59\2-7.doc Therefore, the treated ballast water by GloEn-Patrol TM Ballast System did not induce reproduction (or population gr owth) inhibition in 96 hrs for Brachionus plicatilis , marine waters rotifers.

.2 Growth toxicity test with the larval fish, Cyprinidon variegatus (larvae)

This study was performed to the e ffects of whole effluent (WET) by
GloEn-Patrol TM Ballast System on population grow th toxicity with sheepshead minnow. We evaluated the ability to 50% growth inhibition (EC 50 ) of Cyprinodon variegatus (larvae)

, marine water fish for 96 hrs of treated ballast water (seawater or brackish water) and this compared to control water (seawater or brackish water).

The assay was performed in basic acc ordance with ìUSEPA 821/R-02/014 Standard Guide for Short-term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Marine and Estuarine Organismsî.

Using 24 hrs old fish hatched from the rest ing eggs, the short chronic toxicity test
was carried out for a treated ballast wa ter (seawater or brackish water), or a control water (seawater or brackish water). Ten fish larvae were transferred to
individual chambers of 1L beakers of glass, each containing 500 ml of test
substances. The chambers were incubated at 20oC for 7 days. The test substances (treated ballast water or control water) we re renewed daily usi ng freshly prepared solution. Sheepshead minnow larvae were fe d newly-hatched (less than 24-h old)

Artemia nauplii once a day from hatch day 0 through day 6; larvae were not fed on day 7. Daily, the fish were observed the survival. At test termination on day 7, dead larvae were recorded and fish larvae were removed measured for weight determinations (towel dried) to 10 fish larvae per treatment replicate and calculated the growth rate.

Statistical evaluation was performed accord ing to methods for growth inhibition
test. A nominal error rate of 0.05 was applied when test ing hypothesis to determine the test results. The results of the tests were reported as table showing the progress of growth in the cultures at each experimental condition. The value
of EC 50 was the concentrations (expressed as % treated ballast water) that caused 50% reduction of the population growth rate of Cyprinodon variegatus (larvae).

In these results, all test substances di d not induce population growth inhibition to Cyprinodon variegatus (larvae) at any concentrations . When treated ballast water (seawater or brackish water; SP2, SP8, SP4) was compared to control water (seawater or brackish water; SP3, SP7, SP5), there was no significant difference in the growth rate. The EC 50 and actual NOEC could not be determined because
these data was 100% over concentration.

Therefore, the treated ballast water by GloEn-Patrol TM Ballast System did not induce population growth inhibition in 7 days for Cyprinodon variegatus (larvae),
marine water fish.MEPC 59/2/7

ANNEX Page 35

I:\MEPC\59\2-7.doc 6.2.2.3 Sediment toxicity

.1 Sediment toxicity test with amphipod

This study was performed to the e ffect of whole effluent (WET) by
GloEn-Patrol TM Ballast System on sediment toxicity with amphipod. We evaluated the ability to kill 50% (LC 50 ) of Monocorophium acherusicum, marine water amphipod for 10 days of treated ballast water (seawater or brackish water) and this compared to control water (seawater or brackish water).

The assay was performed in basic accordance with ìUSEPA 600/R-94/025 Standard Guide for Short-term Methods for Assessing the Toxicity of Sediment-associated Contaminants with Estuarine and Marine Amphipodsî.

Benthic amphipods Monocorophium acherusicum were reared in the laboratory (NeoEnBiz Co.) which the initial strain had been collected from a mudflat in Daebudo (37 ○ 17'N; 126 ○ 34'E), located in the Western coast of Korea. They were
reared in the 20-L containers with cl ean sediment and overlying water with
continuous aeration under static renewa l condition with a biological filtering system, and fed ground fish meal (Tetra-M in) and diatoms. Salinity, temperature and dissolved oxygen were maintained at 30 PSU, 20 o C and over 80%. The treated ballast water (seawater or brackish water) or control water (seawater or brackish water) were spiked with sediment for 7 days. Individuals of
M. acherusicum were exposed to aging test substa nces. Indeed, ten individuals of
M. acherusicum allocated into each replicate 1 L beakers were exposed to test substances spiked sediment for 10 da ys. During the test substances exposure period, dead individuals were counted and removed on 10 days.

Statistical evaluation was performed according to methods for lethal and
sub-lethal tests. A nominal error rate of 0.05 was applied when testing hypothesis to determine the test results. The results of the tests were reported as table showing survival at each experi mental condition. The value of LC 50 was the concentrations (expressed as % treated ballast water) that caused the mortality 50% of M. acherusicum

.

These results showed that there was no mortality to M. acherusicum at all at any experimental condition. When treated ballast water (SP2, SP8, SP4) was compared to control water (SP3, SP7, SP5 ), there was no significant difference in
the survival rate. The LC 50 and actual NOEC could not be determined because
these data was 100% over concentration.

Therefore, the treated ballast water by GloEn-Patrol TM Ballast System did not induce the sediment toxicity in 10 days for amphipod, M. acherusicum.

6.2.3 Determination of holding time

This system is operated only during ballas ting and discharge and does not produce any significant level of residual oxidants and by-pro ducts to be required for holding. Some trace level of hydrogen peroxide (approx. 18~48 μg/L) was de tected in the ìTreated Water,î but theMEPC 59/2/7

ANNEX Page 36

I:\MEPC\59\2-7.doc detected concentration is not c onsidered to be problematic in the marine aquatic environment. Hydrogen peroxide is commonly considered as a ìgreenî chemical and is non-persistent in the
environment and does not accumulate in biota. In addition, hydrogen peroxide is naturally produced by living organisms either within the organism itself or in the surrounding medium. For blue-green algae pr oduce hydrogen peroxide under the light irradiation at a rate

of 1-50 μ g/L per hour (Zepp et al. , 1987). Therefore, consideration of the holding time of the treated ballast water is not necessary. Not limited.

6.3 Risk Characterization and analysis

6.3.1 Reaction with organic matter (see G9 : 4.2.1.3 and section 3.4.4 of this document)

ìActive Substanceî (Photon) and ìRelevant Chemi calî (ïOH) can react with organic matters, but it is possible just in the UV chamber not in the ballast water and the ballast water discharge due to their non-residual property. Therefore, the eval uation on the reaction w ith organic matter in seawater is not appli cable (see section 3.4.4).

6.3.2 Characterization of Degradat ion Route and Rate (G9: 5.3.5)

ïOH could be formed during the UV process: however, the formed ïOH is instantaneously scavenged by several specific chemical reactions with basic components present in seawater as described below (Jayson and Parsons, 1973; Zehavi and Rabani, 1972; Buxton et al. , 1988; Hoigne and Bader, 1979):

ïOH + Cl - ! k = 4.3×10 9 M -1 s -1 (Overall rate constant)

ïOH + Br - ! k = 1.1×10 9 M -1 s -1

ïOH + ïOH ! k = 10 9 M -1 s -1

ïOH + NOM ! k = 2×10 4 M -1 s -1

ïOH + HCO 3 - ! k = 8×10 6 M -1 s -1

ïOH + CO 3 2- ! k = 4×10 8 M -1 s -1

The above reactions show that how rapidly ïOH c ould be dissipated. In fact, no risk associated with ïOH is expected due to non-residuality

6.3.3 Prediction of discharge and environmental concentrations

As described above, all ïOH instantaneously disappear within milli-seconds once the water leaves the UV reactor due to its extremely short life-time (~10 -9 sec) in water and high reactivity with the background components pr esent in seawater. In this proposal , to confirm the non-residuality of ïOH in treated water, ïOH in untreated and treated water was monitored with spin trapping-ESR spectroscopy (quantification: 5×10 -8 M) and competition kinetic method using ïOH probe compound, p CBA (Quantification: less than 10 -12 M), which were the currently available representative detection methods for th e detecting and quantifying ïOH. As a result, there were no residual ïOH in water treated with GloEn-patrol TM Ballast System.

From the obtained information, it is concluded that a 100% concentration of ïOH in treated water during ballasting and discharge is close to zero, which is th eoretically acceptable under any
situation.MEPC 59/2/7

ANNEX Page 37

I:\MEPC\59\2-7.doc In this application, the toxic ity tests were conducted on the whole-effluent water from the
GloEn Patrol TM Ballast System. The results of WET te sting support that the tested water (both of seawater and brackish water) does not induce any toxicity in aquatic environment.

6.3.4 Assessment of Potential for Bioaccumulation

Not applicable (see description under the section 3.4 ìD ata on environmental fate and effect under aerobic and anaerobic conditionsî)

6.3.5 Effects on aquatic organisms

No aquatic toxicity of the treated ballast wa ter at discharge was found through WET testing of
the treated ballast water.

6.3.6 PEC/PNEC ratio for the Active Substance and Relevant Chemical

As described above, both of photon (Active Subs tance) and ïOH (Relevant Chemical) does not
remain in treated water once the water l eave a UV reactor. Consequently, modelling for
calculation of the PEC with program is not applicable.

7 RISK ASSESSMENT

7.1 Risk to safety of ship

7.1.1 Increased Corrosion

The influential factors on corrosion in seawater are salt content, solute gases such as oxygen, carbon dioxide, and pH level. Of the several fact ors, the solute oxygen content is of primary importance as a component influencing the corrosi on behaviour of most metals in seawater.
The GloEn-Patrol TM Ballast System does not cause oxygen gas evolution. There was no change of pH in the effluent water (ìTreated Waterî) as compared to influent water (ìUntreated Waterî).

The GloEn-Patrol TM system does not produce any corros ive by-products, such as TRO (Total Residual Oxydants) and acidic compounds . It should be also noted that the ORP (Oxidation-Reduction Potential) va lue of ìTreated Waterî is almost the same as that (727~733 mV) of ìPre-treated Waterî. In addi tion, the value of TRO was not observed after treatment, which support that the GloEn-Patrol TM Ballast System is free of corrosion risk.

7.1.2 Fire and explosion (formation of gases)

In theory, hydrogen gas can be produced by water phot olysis in the absence of other constituents (i.e. only at ultra pure water) radiating only ex tremely short wavelength (120-190 nm) from a VUV (vacuum UV) system or excimer UV lamp system;

H 2 O +h ν→ ïOH + ïH (reaction 1)

ïOH + ïH → H 2 O (reaction 2)

ïH + ïH → H 2 (reaction 3)MEPC 59/2/7

ANNEX Page 38

I:\MEPC\59\2-7.doc However, in the presence of other constituent, reaction 3 would not take place due to the presence of ïOH scavenger. For example, hydroge n radicals can react with dissolved oxygen to produce a perhydroxyl radical which is very unstable in aqueous system (reaction 4).

ïH + O 2 → ïHO 2 (reaction 4)

In GloEn-Patrol TM Ballast System, the main UV spectra are 200 ñ 400 nm, whic h are longer than that of VUV (much lower energy flux is expect ed). As a matter of fact, hydrogen or any gas formation is not expected in the GloEn-Patrol TM Ballast System.

7.1.3 Storage and handling of the substances

Since the Photon and ïOH are produced during ope ration and not residual in ballast water, storage and handling is not issue.

Any substances are not added in the process. A ny chemical are not required to be stored on
board.

7.1.4 Contact with, or inhalation of, process products

Since the Photon and ïOH are produced during operat ion and not residual in ballast water out of the UV chamber, an operator doesnít have any chance to contact with the Photon and ïOHs.

7.1.5 Noise

Assumed to be negligible.

7.2 Risks to human health

Important information on risks to human health is as follows:

- electrical safety; - overheating of UV chamber; - burns from UV chamber; and - UV light exposure.

To reduce the risk of electrical shock, the main electrical supply to th e UV chamber should be disconnected and the operator should wait at l east 5 minutes for the lamps to cool down and energy to dissipate before any maintenance is performed.

The UV lamps produce a considerable amount of heat that is removed if the flow-rate of the liquid passing through the system is high enough. In order to monitor the temperature of the liquid, a temperature detector is fitted on the UV chamber so that unsafe situations caused by possible breakdowns can be prevented.

As soon as the liquid temperature exceeds the pre-set value (default value: 45oC), an alarm is given and the system shuts down at the same time.MEPC 59/2/7

ANNEX Page 39

I:\MEPC\59\2-7.doc The chamber can also become hot during opera tion under abnormal. The temperature of the chamber should be assessed prior to contact.

WARNING

This chamber can produce ho t temperature at abnormal. The temperature should be assessed prior to contact.

UV lamps are housed within lamp sleeves to help keep the lamp at optim al operating temperature and to protect the lamp from breaking. Lamp sl eeves are tubes of quart z. The sleeve length is sufficient to include the lamp and associated electrical connections.

There is no risk to human h ealth unless the UV light is dire ctly exposed on the human under emergency, which is almost impossible in actual situation.

To prevent eye and skin injuries, sources of UV light must be conspicuously labelled with a warning attached to the UV chamber. The warning sign states the following:

WARNING

DO NOT EXPOSE EYES AND SK IN TO ULTRAVIOLET LIGHT
RAYS MAY BE HARMFUL TO UNPROTECTED EYES AND
SKIN

7.2.1 Health effects in humans

There is no risk to human health and so informati on on health effects in humans is not available.

7.2.2 Risks to the environment

No aquatic toxicity of the treated ballast wa ter at discharge was found through WET testing of the treated ballast water. From the results of WET testing and ïOH residual testing, it could be concluded that the treated water of ballasting a nd discharge in this syst em would not induce any
adverse effect towards a quatic organisms and human.

7.2.3 Human Exposure Scenario

The ìActive Substance,î photon, is in the UV chamber only when the UV lamp is on and immediately disappears after stopping UV, there is no chance of operator exposure to the UV light. In the worst case, operator can open a flange on the chamber when water flows and
switch is on. However this is almo st impossible in actual situation.MEPC 59/2/7

ANNEX Page 40

I:\MEPC\59\2-7.doc The Relevant Chemical, ïOH, is also produced only when the UV lamp is on and immediately disappears after the ballast water leaves out of the UV chamber.

In the worst case, the ballast water flows in case that operator opens a flange of the chamber, at this time the liquid temperature rises and then an alarm is given and the system shuts down at the
same time.

Any hazard from the GloEn-Patrolô Ballast System can not be identified.

8 ASSESSMENT REPORT (G9: 4.3)

8.1 From the chemical analysis, no significan t change on the concen tration of backgrounds
was observed and the other chemicals mentione d above were found not to be produced or detected at trace (insignificant) level during the GloEn-Patrol TM system. Consequently, these
results confirm that the GloEn-Patrol TM Ballast System employing UV physical process does not
alter the seawater chemical characteristics.

8.2 ïOH instantaneously disappears within milli-seconds as soon as the water leaves the UV chamber due to its extremely short life-time (~10 -9 sec) in water and furthermore no residual ïOH
was observed in the ìTreated Waterî.

8.3 Results of toxicity testing show that no si gnificant acute/chronic to xicity and sediment toxicity was observed.

The results of above show the evidence that humans, ships and environment ar e not at risk at all.
Therefore risk assessment is not considered necessary.

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