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\2-6.doc

INTERNATIONAL MARITIME ORGANIZATION

IMO 

# E

MARINE ENVIRONMENT PROTECTION

COMMITTEE

59th session Agenda item 2 MEPC 59/2/6

12 December 2008 Original: ENGLISH

HARMFUL AQUATIC ORGANI SMS IN BALLAST WATER

Application for Final Approval of the Greensh ip Sedinox Ballast Water Management System

Submitted by the Netherlands

SUMMARY

Executive summary: This document contains the non-conf idential information related to the application for Final Approval of the Greenship Sedinox Ballast Water Management System (the system re ceived Basic Approval at MEPC 58 under the name of ìGreenshipís Ba llast Water Management Systemî), as required by the ìPro cedure for approval of ballast water management systems that make use of Active Su bstances (G9)î adopted by resolution MEPC.169(57) and in accordance with the ìMethodology for information gathering and the conduct of wo rk of the GESAMP-BWWGî. The system consists of particle removal system followed by an electrolytic process using chloride ions in surface water. Relevant documents together with the application dossier have been submitted to the

Marine Environment Division of th e Organization for review by the GESAMP-Ballast Water Working Group in accordance with the above-mentioned procedure.

Strategic direction: 7.1

High-level action: 7.1.2

Planned output: 7.1.2.4

Action to be taken: Paragraph 7

Related documents: MEPC 53/24/Add.1, MEPC 55/2/16, MEPC 56/2/2, MEPC 57/2/7,

MEPC 57/21 and MEPC 58/2/7

Introduction

1 Regulation D-3.2 of the Inte rnational Convention for the Control and Management of Shipsí Ballast Water and Sediments stipulates th at ballast water management systems that make use of Active Substances to comply with the Convention shall be appr oved by the Organization.MEPC 59/2/6 - 2 -

I:\MEPC\59\2-6.doc 2 The ìProcedure for approval of ballast wate r management systems that make use of Active Substances (G9)î adopted by resolution MEPC.169(57) identi fies the information to be documented by data or testing and basic principles for risk evaluation, which is further elaborated in the ìMethodology for information gather ing and the conduct of work of the GESAMP-BWWGî (MEPC 58/2/7, annex 4). Accord ing to section 6 of Procedure (G9), the Organization should evaluate the info rmation provided in the application.

3 According to BWM.2/Circ.15, applications 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 cont aining all the non-confidential data related to the respective Active Subs tances needs to be submitted to the MEPC.

4 The applicantís responses and actions to address the recommendations of the GESAMP-BWWG as presented in document MEPC 58/2/7, annex 6, are provided in this dossier and are summarized in chapter 1.2 of the annex.

5 The competent authority in the Netherlands ha s verified the application dossier prepared by the applicant and believes it satisfies th e requirements of Procedure (G9) and the Methodology.

6 The Netherlands therefore submits the appli cantís dossier in the annex to this document for evaluation according to Procedure (G9). The co mplete dossier will be made available to the experts of the GESAMP-Ballast Water Working Group.

Action requested of the Committee

7 The Committee is invited to consider the pr oposal for approval and decide as appropriate.

***MEPC 59/2/6

I:\MEPC\59\2-6.doc ANNEX

NON-CONFIDENTIAL INFORMATION ON THE GREENSHIP SEDINOX BALLAST WATER MANAGEMENT SYSTEM (THE NETHERLANDS)

This annex follows the requirements for app lication as presented in the Methodology for information gathering and the conduct of wo rk of GESAMP-BWWG (MEPC 58/2/7, annex 4) and has the following content:

Annex: Non-confidential report

Chapter 1: Introduction

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

Chapter 3: Identification of Active Substance a nd relevant by-products, in cluding application

data sets and measurements of salinity, pH, TSS, DOC and POC

Chapter 4: Material safety data sheets (MSDS)

Chapter 5: Risk characterization

Chapter 6: Risk assessment

Chapter 7: Assessment report

References

Confidential appendices

I. Operation and technical manua ls of the ìSedinoxî BWMS

II. Efficacy testing of the ìSedinoxî BWMS

III. Analysis of Active Substance, rele vant by-products, hydrogen and general

parameters

IV. Key data summary of Activ e Substance and relevant by-products (MEPC 58/2/7, annex 4, appendix 1)

V. MSDSs of Active Substance and relevant by-products

VI. Toxicity tests

VII. Corrosion tests

VIII. Data sheets on MAM-PEC results and Haskoning report, 2008 : Ballast water quantities Port of Rotterdam

IX. Human risk assessment by EUSES 2.1, (MEPC 58/2/7, annex 4, appendix 2)

X. Quality assurance project plan (QAPP)MEPC 59/2/6

ANNEX Page 2

I:\MEPC\59\2-6.doc 1 INTRODUCTION

1.1 General

The applicant proposes a ballast water management system (BWMS) that combines destruction and removal of biota, and removal of sediment at uptake of ballast water using a patented multi hydrocyclone technology followed by a mild disinf ection step, using chloride ions in surface water in an electrolytic process to produce Active Substance for the killing of remaining micro-organisms (smaller then 20 mμ). This ap plication is based on the Procedure for approval of ballast water management systems that make use of Active Substances (G9).

The GESAMP-BWWG recommended Basic Approval for this system (MEPC 58/2/7, annex 6) and it was granted by the MEPC in October 2008. The applican t presents its responses to the GESAMP-BWWG review in chapter 1.2 of this document. One of the main comments of the GESAMP-BWWG was that the system n eeded refinement (MEPC 58/2/7, annex 6, paragraph 2.1.9). The applican t has significantly refined the system without changing the principles of the treatment. The refinement cons ists of three main adjustments: (1), lowering the

maximum dose concentration of Active Substance at uptake, (2) abolishm ent of the disinfection at ballast water discharge and (3) installing on -line continuous monitori ng of Active Substance during uptake with conti nuous feed back to the electrolytic cells to maintain a maximum subs.

minimum dose concentration of Active Substance.

The BWMS is capable of removing biota and particles of > 20 μm fr om water with an efficiency of 100 % and particles of > 10 μm with an effi ciency of > 80 %. This treated water is subsequently disinfected by Active Substance generated in an elect rolytic cell. Upon completion of treatment the ballast water complies with the discharge standard of regulation D-2 of the

International Convention for th e Control and Management of Shipsí Ballast Water and Sediments. The capacity of the BWMS is mo dular: it can handle ballast water flows ranging

from 100 m 3 /hr up to 5,000 m 3 /hr and even more.

The electrolytic process produces Free Active Chlorine (FAC) from chloride ions present in natural surface water on board. FAC is widely a pplied for the disinfection of water. The major advantage of this type of electro lytic cell is the long la sting coating. The el ectrolytic cells can disinfect with a minimum of maintenance (a once a year cleaning is all that is required) for the duration of approximately 5 years.

This applicant believes that the BWMS is a safe and economical system for ships and crews applicable without the storage of chemicals on board. Water chlo rination is a safe and reliable disinfection procedure used worldwide for dri nking water production, in i ndustry and as biocide in cooling water systems to prevent bio-f ouling, e.g., in electrical power generation.

This document presents all required information according to the revised Procedure (G9) adopted by resolution MEPC.169(57). It contains all scie ntific data on Active Substance and relevant byproducts and reports all results of chemical and ecotoxicological tests. A quality assurance project plan (QAPP) was in place from the start of the tests. It is presented in appendix X.MEPC 59/2/6

ANNEX

Page 3

I:\MEPC\59\2-6.doc 1.2 The applicantís response to the GE SAMP-BWWG review of the application for Basic Approval (MEPC 58/2/7, annex 6)

Summary (all paragraph numbers referred in this section are those of document MEPC 58/2/7, annex 6)

0.1 This BWMS does not use a filtration system; it uses multi hydrocyclone technology to destruct and remove biota and remove suspended so lids with a size of > 20 μm with an efficiency of 100% and with a size of > 10 μm with an efficiency of > 80%.

0.5 This application contains a quantified ri sk characterization for human health using EUSES 2.1 (see chapter 6.2 and appendix IX).

0.6.2 See 0.5.

0.6.3 The organic content of the wa ter of tests for Final Approval is reported in chapter 3.2 and appendix III.

0.6.4 The level of quantification (L OQ) for haloacetic acids during the tests for Final Approval was 1 μg/l in natural surface water. In the Ne therlands no laboratory coul d be found with better performance (see chapter 3.3 and appe ndix III). See also chapter 7.4.

Completeness of dossier

2.1 (See MEPC 58/2/7, annex 6)

2.1.1.1 The applicant has provided the comp lete system lay-out in appendix I.

2.1.1.2 Protection devices and failsaf e controls: see appendix I.

2.1.1.3 Details of the treatment: s ee chapter 2 and appendix I.

2.1.1.4 Maximum dose concentration: the proposed maximum dose concentration is 1 ppm (see for details chapters 2 a nd 3.2 and appendices I and III).

2.1.1.5 Maximum allowable discharge concentra tion: the proposed maximum allowable discharge concentration is < 0.01 ppm (see for details chapters 2 and 3.3 and appendix III).

2.1.1.6 Means of determining and controlling dose rates: see chapter 2 and appendix I.

2.1.2 The concentrations of Activ e Substance and by-products at the point of discharge is reported in chapter 3.3.

Note: It should be noted, that Green ship has abolished the second di sinfection step at discharge, since treatment at uptake results in full compliance to the efficacy criteria of the Convention.MEPC 59/2/6

ANNEX Page 4

I:\MEPC\59\2-6.doc 2.1.3 See for the quantification of THMs and HAAs in natural surface water chapter 3.3.

2.1.4 See for a complete description of mon itoring and control systems chapter 2 and appendix I.

2.1.5 See for hydrogen measurements chapter 6.1 and appendix III.

2.1.6 See for a complete description of the corrosive effects chapter 6.1 and appendix VII.

2.1.7 Risks associated with by-pr oducts are reported in chapters 5 and 6 and appendices IV, V,

VIII and IX.

2.1.8 The BWMS has been significantly refined. The maximum dose concentration of FAC has been reduced and the treatment at discharge abolished. A system fo r on-line dose control and

failsafe controls has been installed. See for deta ils in chapter 2 and appe ndix I. Outcomes on

PEC/PNEC ratio calculations ar e reported in chapter 6.3 and appendix VIII; measurements of FAC in the plume of the discharge of treated ballast water, immediately after uptake and treatment, are reported in chapter 6.3 and appendi x III to illustrate the ab sence of the risk of short-term exposure. Under normal operating c onditions, ballast water will not be discharged immediately after uptake and treatment.

2 DESCRIPTION OF THE SYSTEM AND THE PRODUCTION OF ACTIVE

SUBSTANCE

2.1 The principles of the ìSedinoxî BWMS

The ìSedinoxî BWMS is a total solution to the pr evention of the distribution of aquatic species from one ecosystem to another ecosystem el sewhere on the globe a nd thus prevents the introduction of alien species into an environment that cannot cope with it . It not only prevents such distribution, but it also prev ents the settlement of significan t amounts of susp ended solids in

ballast water tanks duri ng the journey and will thus cont ribute to a better economy of cargo transport over seas by increasing load capacity and decreasing ballast water tank cleaning costs and corrosion damage (see letter of Holwerda Ship management BV, appendix VII and chapter 6.1).

The ìSedinoxî BWMS consists of two consecutive steps:

2.1.1 Destruction and removal of biot a and removal of suspended solids

The ìSedimentorî, a patented multi hydrocyclone technology, destructs and removes biota and bigger particles during ballast water uptake. The Sedimentor works through a combination of pressure built-up and high G-forces. It removes 100% of the biota and particles of a size of > 20 μm and bigger and 80% of the particles of ≥ 10 μm (see figure 1). An underflow, enriched with bigger particles, is pumped over board at the locatio n of ballast water uptake. The overflow is pumped via disi nfecting electrolytic cells to the ballast water tanks.MEPC 59/2/6

ANNEX

Page 5

I:\MEPC\59\2-6.doc Figure 1: Separation curve for the Sedimentor (7 experiments)

A schematic drawing of the Sedime ntor is presented in figure 2.

Figure 2: Schematic drawing of the Sedimentor (one unit)

2.1.2 Disinfection with Active Substance

Active Substance for disinfection is produced from chloride in surface water with the ìTermanoxî electrolytic cell. The cell produces Free Active Chlorine (FAC), that is highly efficient in killing remaining micr o-organisms, in particular alg ae and bacteria. Since biota and suspended solids with adsorbed organic carbon ma terial are removed to a great extent by the multi hydrocyclone, a very mild disinfection step suffices to reach the efficacy criteria of the Convention (see paragraph 2.3). The FAC pr oduction inside a cell depends on chloride

concentrations in the surface wate r and the settings of the cell. In practice, brackish and salt water is pumped via two cells at uptake; in fresh water a third cell needs to be added in order to produce the needed dose for disinfection (see for deta ils in Appendix 1). The range of values that

can be measured with the online sensor in treat ed natural surface water, situated at a distance of 10 x D (pipe diameter) after the cells (figure 3), is 0.01 ñ 2.0 ppm. This online sensor adjusts FAC production at a continuous consta nt level of ma ximum 1.00 ppm.MEPC 59/2/6

ANNEX Page 6

I:\MEPC\59\2-6.doc Figure 3: Appendage Pipe for measuring & cont rol FAC (fit for sampling purpose as well), refer to Guidelines (G2).

Figures 4 and 5 show the external and internal features of the Term anox (see details in appendix I).

Figure 4: Outside view of the ìTermanoxî

Figure 5: Inside view of the ìTermanoxîMEPC 59/2/6

ANNEX

Page 7

I:\MEPC\59\2-6.doc 2.1.3 Modular build-up of the ìSedinoxî

The capacity of the ìSedinoxî BWMS is modular. One unit can handle 100 m 3 /hr but capacity can be enlarged by installing in parallel the number of units needed to achieve the desired capacity up to volumes of 5000 m3/hr (basically unlimited). Figure 6 shows a schematic drawing

of a 300 m 3 /hr system.

Figure 6: Modular build-up of the ìSedinoxî

2.1.4 Monitoring and control equipment

The applicant BWMS is equipped with a number of measuring points to measure a variety of parameters like pressure, flow, NaCl, FAC, temperature, etc. The data coming from these measuring points are entered into the M&C unit (Figure 8) of the system that manages and controls the power uni t and the valves in order to have a sa ve and correct operati on of the system. And if needed, in case of malfunc tion to close the system or part s thereof down. The system also incorporates control equipment, which automa tically and continuously monitors and adjusts necessary electrolytic Amperages of the Termanox units during operation. One visual alarm is for the operation of the electrolytic cells. Th e maximum allowable dose concentration of the ìSedinoxî BWMS is regulated through continuous monitoring of the FAC concentration in the system itself during uptake of ballast water. A FAC monitoring unit is registering FAC and pH concentration and water temperature. The sensor is able to measure FAC in the range of 0.01 ñ 2.00 ppm. In practice a minimum of 0 .1 ppm and a maximum value of 1 ppm for FAC will be preset in the control unit for alarm purposes. The control equipment stores data for at least 24 months and can display or print record s for official inspection. The control equipment is MED approved. Figure 7 shows the touch sc reen (mimic) of the monitoring and control equipment.MEPC 59/2/6

ANNEX Page 8

I:\MEPC\59\2-6.doc Figure 7: Touch screen (mimic) of the control and monitoring equipment

2.2 Operation of the ìSedinoxî BWMS

Appendix I presents all de tails of the system layout and the operation of the Sedinox as required in the review for Basic Approval by the GESA MP-BWWG. The protection devices and failsafe controls are described in appendi x I, technical manual at pages 49 to 54. The two components of the Sedinox have no moving parts. Safety controls are incorporated for a number of parameters: pressure, flow and maximum-minimum allowabl e dose concentration of FAC (see technical manual in Appendix I). This is all proven and sta ndard technology used in all kinds of industries and in the public domain (e.g., on board of ships).

2.3 Efficacy testing of the ìSedinoxî BWMS

In the application for Basic Approval, efficacy testing was reported for five tests (see chapter 2.3.2 of MEPC 57/2/7). The original report is pres ented again in appendix II -1. FAC concentrations of 1.5 ppm were reported to produc e the required killing rates. In October and November 2007, three ship board efficacy test runs were performe d. Initially more specifically to get a good view on the influence of the amount of total organi c content (TOC.) on the production of FAC these tests were done with a fixed power setting on the Termanox. The results are presented in appendices II-2, II-3 and II-4. The average FAC concen tration during sampling in test 1 was 1.1 ppm; in test 2 it was 0.6 ppm and in test 3 it was 2.9 ppm. An additional test was done, this time maintaining a low fixed FAC level by automatica lly varying the power level on the Termanox, on 26 June 2008 with a very low FAC concentration: 0.1 ppm. This test showed th at even with such low concentrations the efficacy criteria are met (see appendix II-5).

3 IDENTIFICATION OF ACTIVE SUBS TANCE AND RELEVANT BY-PRODUCTS, INCUDING DATA SETS, AND MEASUREMENTS OF SALINITY, pH, TSS, TOC,

DOC AND POC

3.1 General

The production of FAC by electrolysis from chlorides in natural waters leads to the formation of halogenated by-products, like haloge nated alifates, chloroamines and halogenated acetic acids. The applicant has tested the formation of such by-products during land-based tests of a full-scale

BWMS with natural surface water. The results are the basis fo r the selection of relevant chemicals to provide data sets and risk charac terization according the requirements of sections 4 and 5 of Procedure (G9).MEPC 59/2/6

ANNEX

Page 9

I:\MEPC\59\2-6.doc A BWMS with a capacity of 100 m 3 /hr was installed on board of a moored ship. This equipment had been tested already for 2 years on board of MV ìElizabethî (see also par. 6.1 and appendices II and VII). It was the same equi pment as used in 2007 for G8 land-based efficacy tests and the tests for the Basic Approval appl ication (see MEPC 57/2/7). Figure 8 shows the unit for the ship board tests in th e engine room of MV ìElizabethî.MEPC 59/2/6

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I:\MEPC\59\2-6.doc The BWMS treated two types of surface water and the treated ba llast water was stored in a storage tank during 2 days. In August 2008 br ackish water from the harbour of Harlingen, the Netherlands, at the border of the Waddensea (test location 1), was treated and stored. In September 2008 fresh water from the ìvan Harinxma Channelî, just after the sea-locks of Harlingen harbour (test location 2), was treated and stored. Samples for chemical analysis and toxicity evaluation (see paragraph 5.2) were taken at different time intervals after treatment and distributed to different speciali zed laboratories with full accreditation. Control samples consisted of untreated natural surface water. Figure 9 shows test locations 1 and 2 in Harlingen,

the Netherlands.

3.2 Two types of water: brackish and fresh

The tests for Final Approval were done in two different types of natural surface water: brackish and fresh as prescribed in the Methodology (see MEPC 58/2/7, annex 4, paragraph 10.2.5). These types of water are not specified in Procedure (G9), neither is referred to Guidelines (G8) in which two types of water are defined with rega rd to salinity, TSS and TOC/POC/DOC content.

Tables 1 and 2 present the character istics of type I and type II water. Samples were taken from

the harbour and the ch annel (source water).

Table 1: Characteristics of type I water (brackish)

Oxygen

% Temperature,

Co Salinity

â pH TSS, mg/l DOC, mg/l POC, mg/l TOC, mg/l

91.7 19.3 18.8 7.93 15 8.5 - 7.5

N.B.: TOC is lower then DOC. Theoretically this is not possible, because DOC is part of TOC. Explanation of the minor difference is a m easurement inaccuracy (see also appendix III).

Table 2: Characteristics of type II water (fresh)

Oxygen

% Temperature,

Co Salinity

â pH TSS, mg/l DOC, mg/l POC, mg/l TOC, mg/l

94.3 16.2 2.8 7.84 9.9 14 1.0 15

See for details of the analytical methodology and results: appendix III

3.3 Identification of Active Substance and relevant by-products

3.3.1 Free Active Chlorine (FAC)

FAC was analyzed by Omegam-Water, Wognum, the Netherlands. The analyses were performed

with the same sensor as used for the on-line measurements during treatme nt of ballast water (see chapter 2). The sensor was calibrated by Omegam-Water using the method according to

NEN/EN/ISO 7393-2. Results are reported for control samples (s ource water) and samples taken from the stored treated ballast water at different time intervals: immediately after treatment (T=0), after 30 min (T=0.5), 1 hrs (T=1), 2 hours (T=2), 4 hrs (T =4), 12 hrs (T=12) and 48 hrs (T=48). Tables 3 and 4 present the results for th e two types of water. The dose rates of FAC, measured on line immediately after the cells, we re 1.0 ppm for brackis h water and 0.38 ppm for

fresh water.MEPC 59/2/6

ANNEX Page 11

I:\MEPC\59\2-6.doc Table 3: Concentrations of FAC in mg /l in type I treated water (brackish)

Control T=0 T=0.5 T=2 T=4 T=12 T=48

<0.01 1.0 0.4 0.1 <0.01 < 0.01 < 0.01

Table 4: Concentrations of FAC in mg/l in type II treated water (fresh)

Control T=0 T=0.5 T=2 T=4 T=12 T=48

<0.01 0.38 0.2 < 0.01 <0.01 < 0.01 < 0.01

See for details of the analytical methodology and results: chapter 2, appendix III and for the FAC data set: appendix IV.

3.3.2 Halogenated organic compounds

Halogenated organic compounds were analyzed by Omegam-Laboratoria, Amsterdam, the Netherlands. The analyses were performe d according to NEN/EN/ISO 15680. Results are reported for control samples (sou rce water) and samples taken fr om the stored treated ballast

water at different time interval s: immediately after treatment (T =0), after 30 min (T=0.5), 2 hrs (T=2), 4 hours (T=4), 12 hrs (T=1 2) and 48 hrs (T=48). Tables 3 and 4 present the results for the two types of water.

Table 5: Concentrations in μg/l of halogena ted organic compounds in type I treated water (brackish)

Control T=0 T=0.5 T=2 T=4 T=12 T=48

dichloromethane <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0

1,1-dichloroethane <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

1,2-dichloroethane <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

trans-1,2-dichloroethene <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

cis-1,2-dichloroethene <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5
1,2-dichloropropane <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

trichloromethane <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

tetrachloromethane <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

1,1,1-trichloroethane <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

1,1,2-trichloroethane <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

trichloroethene <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

tetrachloroethene <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

tribromomethane <0.5 47 70 80 73 82 84

sum C/T dichloroethene 0.7 0.7 0.7 0.7 0.7 0.7 0.7

sum chloroaliates 2.9 2.9 2.9 2.9 2.9 2.9 2.9
Volatile chlorinated aliphates - remainder:

dibromomethane <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

bromodichloromethane <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

dibromochloromethane <0.5 3.8 5.2 5.9 5.4 6 6.3MEPC 59/2/6

ANNEX Page 12

I:\MEPC\59\2-6.doc Table 6: Concentrations in μg/l of halogena ted organic compounds in type II treated water (fresh)

Control T=0 T=0.5 T=2 T=4 T=12 T=48

dichloromethane <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0

1,1-dichloroethane <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

1,2-dichloroethane <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

trans-1,2-dichloroethene <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

cis-1,2-dichloroethene <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5
1,2-dichloropropane <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

trichloromethane <0.1 0.3 0.4 0.5 0.6 0.8 0.9

tetrachloromethane <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

1,1,1-trichloroethane <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

1,1,2-trichloroethane <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

trichloroethene <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

tetrachloroethene <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

tribromomethane <0.5 11 14 15 15 16 16

sum C/T dichloroethene 0.7 0.7 0.7 0.7 0.7 0.7 0.7

sum chloroaliates 2.9 3.1 3.2 3.3 3.4 3.6 3.7
Volatile chlorinated aliphates - remainder:

dibromomethane <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5

bromodichloromethane <0.5 2.6 3.6 4.0 4.3 4.7 4.9

dibromochloromethane <0.5 9.9 13 13 14 15 16

See for details of the analytical methodology and re sults: appendix III. For the data sets of tribromomethane (bromoform), dibromochl oromethane and dichlorobromomethane: appendix IV.

3.3.3 Haloacetic acids and chloroamines

Haloacetic acids and chloroamines were analyzed by RPS Analyse BV, Breda, the Netherlands. The analyses of haloacetic aci ds were performed by GC-MS. Results are reported for control samples (source water) and samples taken from the st ored treated ballast water at different time intervals: immediately after trea tment (T=0), after 30 min (T=0.5) , 2 hrs (T=2), 4 hours (T=4), 12 hrs (T=12) and 48 hrs (T=48). Tables 7 and 8 present the results for the two types of water. The analyses for chloroamines were performed by titration. Chloroamines were not detected in both types of treated surface water (detection limit: 0.1 mg/l).MEPC 59/2/6

ANNEX Page 13

I:\MEPC\59\2-6.doc

Table 7: Concentrations in mg/l of chloroamin es and in μg/l of halogenated acetic acids in type I treated water (brackish)

Control T=0 T=0.5 T=2 T=4 T=12 T=48

monochloroamine <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

dichloroamine <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

trichloroamine <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

chloroacetic acid <1 <1 <1 <1 <1 <1 <1

dichloroacetic acid <1 <1 <1 <1 <1 <1 <1

bromoacetic acid <1 24 72 77 59 86 5.8

trichloroacetic acid <1 <1 <1 <1 <1 <1 <1

dibromoacetic acid <1 40 76 64 47 69 3.6

bromochloroacetic acid <1 4.1 6.7 5.8 4.5 6.2 <1

bromodichloroacetic acid <1 2.2 3,2 2.3 2.4 3.1 2.8

dibromochloroacetic acid <1 <1 <1 <1 <1 <1 <1

tribromoacetic acid <1 9.9 14 12 12 13 12

Table 8: Concentrations in mg/l of chloroamin es and in μg/l of halogenated acetic acids in type II treated water (fresh)

Control T=0 T=0.5 T=2 T=4 T=12 T=48

monochloroamine <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

dichloroamine <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

trichloroamine <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1

chloroacetic acid <1 7 5.3 7.1 4.5 4.1 1.3

dichloroacetic acid <1 5.1 5.5 5.4 3.8 3.6 6.4

trichloroacetic acid <1 <1 <1 <1 <1 <1 <1

bromoacetic acid <1 17 16 15 12 9.9 12

dibromoacetic acid <1 39 40 40 31 32 30

tribromoacetic acid <1 <1 <1 <1 <1 <1 <1

bromochloroacetic acid <1 24 23 22 18 17 17

dibromochloroacetic acid <1 <1 <1 <1 <1 <1 <1

bromodichloroacetic acid <1 <1 <1 <1 <1 <1 <1

See for details of the analytical methodology and re sults: appendix III. For the data sets of chloroacetic acid, bromoacetic ac id, dichloroacetic acid, dibromoacetic acid, bromochloroacetic acid, bromodichloroacetic acid and tribromoacetic acid: appendix IV.

4 MATERIAL SAFETY DAT A SHEETS (MSDS)

The MSDSs of FAC and all relevant by- products are presented in appendix V.MEPC 59/2/6

ANNEX Page 14

I:\MEPC\59\2-6.doc 5 RISK CHARACTERIZATION

5.1 Screening for persistence, bioaccumulation and toxicity

The criteria for evaluating long term persisten ce, bioaccumulation and toxicity are given in section 6.1.4 of the Methodology. These criteria were applied on the Active Substance and the by-products found in the treated ballast water (s ee chapter 3). The results are presented in table 9. A similar table was presented in docum ent MEPC 58/2/7, annex 6, page 21. Some data is different, but references are gi ven for verification. For 3 haloace tic acids toxicity data was not

available. Data of dibromoacetic acid was used.

Table 9: PBT evaluation

Chemical Persistent (y/n) Bioaccumulative (y/n) Toxic (y/n) Hypochlorous acid No 1/2-Life: 0.058 days in water (Taylor, 1993) No Log Pow=-3.42 No 7d NOEC for unknown species, 0.0027 mg/l (MEPC 58/2/7, annex 6)

Bromodichloromethane No 1⁄2-Life: 0.08 days in water (EU-RAR Hypochlorite, par. 3.1.2) No LogPow= 1.88 No Oryzias latipes NOEC= 0.78 mg/l/21days (MEPC 58/2/7, annex 7)

Dibromochloromethane No 1⁄2-Life: 0.11 days in water (EU-RAR Hypochlorite, par. 3.1.2) No Log Pow = 2.08 No Daphnia magna NOEC = 0.063 mg/l/21days (GLP) (MEPC 58/2/7, annex 7)

Tribromomethane No 1⁄2-Life: 0.30 days in water (EU-RAR Hypochlorite, par. 3.1.2) No Log Pow = 0.38 No Cyprinodon variegates NOEC= 4.8 mg/l/28 days (MEPC 58/2/7, annex 6)

Dichloroacetic acid No 1⁄2-Life: 5.4 days in water (Hashimoto et al, 1998) No Log Pow = 0.92 No Nitocra spinipes LC50= 23 mg/l/96 h (MEPC 58/2/7, annex 7, original reference unknown)

Bromochloroacetic acid No 1⁄2-Life: 2.7 days in water (Hashimoto et al, 1998) No Log Pow = 0.61 No Pimephales promelas LC50= 6.9 mg/l/96 h (Dibromoacetic acid)

Dibromoacetic acid No 1⁄2-Life: 3.1 days in water (Hashimoto et al, 1998) No Log Pow = 1.22 No Pimephales promelas LC50= 6.9 mg/l/96 h (Mayes et al, 1985)

Tribromoacetic acid No 1⁄2-Life: 0.04 days in water (Yuefeng Xie, 2004) Spontaneous decomposition in water (EU-RAR Hypochlorite, par. 3.1.2) No Log Pow = 1.71 No Pimephales promelas LC50= 6.9 (mg/l/96 h) (Dibromoacetic acid)

Chloroacetic acid No 1⁄2-Life: 3.9 days in water (Hanson et al, 2002) No Log Pow = 0.22 No Daphnia Magnia, 48 hr EC50= 77 mg/l (US-EPA Ecotoxicology database, 2008)

Bromoacetic acid No 1⁄2-Life:3.2 days in water (Hashimoto et al, 1998) No Log Pow = 0.295 No Daphnia magna NOEC= 1.6 mg/l/21days (Kuhn, R. et al. , 1989)

Bromodichloroacetic

acid No 1⁄2-Life: 3.6 days in water (Hashimoto et al, 1998) No Log Pow =1.71 (tribromoacetic acid) No Pimephales promelas LC50= 6.9 (mg/l/96 h) (Dibromoacetic acid)

Conclusion: None of the compounds shoul d be classified as a PBT substance

.MEPC 59/2/6

ANNEX Page 15

I:\MEPC\59\2-6.doc 5.2 Toxicity evaluation of the treated ballast water

In order to comply with the re quirement in section 5.2 ìtoxicity testing of the treated ballast waterî of Procedure (G9), the applicant has co mmissioned the Institute for Marine Resources and Ecosystem Studies of Wageningen IMARES, Den Helder, the Netherlands, to perform the prescribed toxicity tests on whole effluent of the treated ballast water. Samples of two types of

treated water were taken under the same techni cal conditions as samples taken for chemical analysis (see chapter 3 of this document). In this paragraph a summary of t oxicity tests is given. The full report is presented in appendix VI.

The residual effects of (brackish) sea water and freshwater treated with the Sedimentor and the electrolytic cell were investigated with bioassays, using three organisms: two algae ( Phaeodactylum tricornutum and Pseudokirchneriella subcapitata ) and a crustacean (the brine shrimp Artemia franciscana ).

Two water types were tested: fr eshwater (salinity <5â) and brackish water (salinity <20â). The test species were adapted to the de sired salinity regime prior to testing.

Tests were performed directly after treatment and 48 hours after treatment and storage in a

container. For each test dilutions of 10% 18% , 33%, 56% and 100% treated ballast water were made, using untreated ballast water (only hydrocyc lone treated) as dilu tion medium and blank.

Treated ballast water showed no negative effects in the tests with the brine shrimp. Treated ballast water caused a significant effect on both algal species. The freshwater species P. subcapitata appeared to be the most sensitive. Ta ble 10 gives an overview of results for the algae tests (see for explanation of sample codes and sample characteristics: page 29, appendix A of appendix VI). In July tests in duplicate were done w ith treated ballast wa ter immediately after uptake (sample codes 200807). In August and September tests were done immediately after uptake and after 48 hrs storage (sample codes 200808 and 200809).

Table 10: Summary results of the algae tests

Phaeodactylum tricornutum Sample code NOEC (m/m%) LOEC (m/m%) EC50 (m/m%)

2008070853b

2008070853b

2008082553

2008082700 Intake intake (duplo)

intake discharge 17.0

17.0

17.2

30.2 30.2

30.2

30.2

53.7 48.7 (47.6 - 49.7) 44.0 (42.5 - 45.6) 32.8 (30.3 - 35.4)

>95.6

Pseudokirchneriella subcapitata Sample code NOEC (m/m%) LOEC (m/m%) EC50 (m/m%)

2008070853f

2008070853f

2008091553

2008091700 Intake Intake (duplo)

Intake discharge <9.3

<9.3

9.4

29.6 9.3

9.3

16.6

52.7 16.9 (16.3 - 17.1) 15.3 (13.3 - 17.5) 20.3 (19.1 - 21.7) 58.7 (51.0 - 67.6)

As can be concluded from the table on average a 6ñfold ( P. tricormutum ) to 20-fold dilution ( P. subcapitata ) is needed to reach NOEC. In some balla st water tests, a clear effect of volatile

substances was observed in the bl ank wells that were added as co ntrol for volatile substances.

This effect was observed in all tests with the freshwater algae P. subcapitata and in the Aug 26th test with the marine algae P. tricornutum . The effect was limited and did not affect the performance of the test.MEPC 59/2/6

ANNEX Page 16

I:\MEPC\59\2-6.doc 5.3 Risk characterization and analysis

Prediction of discharge and envir onmental concentrations: MAM-PEC

For the calculation of the Pr edicted Environmental Concentr ation (PEC) the model MAM-PEC (version 2.0) was applied. This model is freely available and can be dow nloaded. The model has been developed by Delft Hydrau lics (now DELTARES) and the Free University, Amsterdam. The model was developed to calculate leaching of anti-fouling from ships. It is based on the assumption that a permanent source of the polluta nt is present in the harbour and calculates a steady state concentration of the pollutant. Calc ulations can be done for different harbours with different dimensions and ìsurroundingsî, whic h in practice mean the channel to which the harbour is connected. In this application a stan dard commercial harbour has been used with an exchange volume of 259,000,000 m 3 per tidal period of 12.4 hours. The daily volume of discharged treated ballast water and the concen tration of the Active S ubstance and relevant chemicals are critical input data. Accordi ng to an investigati on by Haskoning, commissioned in 2008 by the authorities of the Port of Rotterd am, a realistic average value of ballast water discharge is 50,000 m 3 per day.

For all MAM-PEC calculations the highest concentration from the time series of measurements, either brackish or fresh water, was used. See tabl es 3, 4, 5, 6, 7 and 8 in chapter 3. This implies the worst case scenario, e.g., for FAC the maximu m allowable dose concentration of 1 ppm was used, instead of the allowable disc harge concentration (< 0.01 ppm).

All input data and results of the MAM-PEC calcu lations and the Haskoning report are presented in appendix VIII.

5.3.1 FAC

Main input data for FAC is:

Load: 50 kg/day (based on 50.000 m 3 /day and maximum of 1.00 mg/l); Half life: 0.058 days in water.

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

of 0.013 μ g/l and of 0.002 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

In various documents, predicted no effect concen trations of FAC (PNEC) have been calculated

with different outcomes. Annex 7 to docum ent MEPC 56/2/2 (review by the GESAMP-BWWG of the application by Japan, MEPC 56/2), reports a value of 0.07 μ g/l. Document MEPC 57/2/1 (application by Korea) reports 8 μ g/l. The GESAMP-BWWG used 0.27 μ g/l in document MEPC 58/2/7, annex 6.MEPC 59/2/6

ANNEX Page 17

I:\MEPC\59\2-6.doc 5.3.2 Tribromomethane (bromoform)

Main input data for tribromomethane is:

Load: 4.2 kg/day (based on 50.000 m 3 /day and maximum of 84 μ g/l); Half life: 0.30 days in water.

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

harbour of 0.004 μ g/l and of 0.0009 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

In various documents, predicted no effect concen trations of tribromomethane (PNEC) have been

calculated with different outcomes. Anne x 7 to document MEPC 56/2/2 (review by the GESAMP-BWWG of the application by Ja pan, MEPC 56/2), repo rts a value of 7.1 μ g/l. RIVM (2005) reports a value of 1.5 μ g/l. The GESAMP-BWWG used 48 μ g/l in document MEPC 58/2/7, annex 6.

5.3.3 Dibromochloromethane

Main input data for dibromochloromethane is:

Load: 0.8 kg/day (based on 50, 000 m 3 /day and maximum of 16 μ g/l); Half life: 0.11 days in water.

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

the harbour of 0.00036 μ g/l and of 0.00008 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

In various documents, predicted no effect concen trations of dibromochloromethane (PNEC) have

been calculated with different outcomes. An nex 7 to document MEPC 56/2/2 (review by the GESAMP-BWWG of the application by Ja pan, MEPC 56/2) reports a value of 27 μ g/l. Document MEPC 57/2/6 presents 5.2 μ g/l and document MEPC 58/2 presents 3 μ g/l.

5.3.4 Tribromoacetic acid

Main input data for tribromoacetic acid is:

Load: 0.7 kg/day (based on 50, 000 m 3 /day and maximum of 14 μ g/l); Half life: 0.04 days in water.

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

harbour of 0.0001 μ g/l and of 0.00002 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

Document MEPC 58/2 reports a value of 10 μ g/l. Document MEPC 58/2/7, annex 7 reports 6.9 μ g/l.MEPC 59/2/6

ANNEX Page 18

I:\MEPC\59\2-6.doc 5.3.5 Dibromoacetic acid

Main input data for 2, 2 dibromoacetic acid is:

Load: 3.8 kg/day (based on 50,000 m 3 /day and maximum of 76 μ g/l); Half life: 3.1 days in water (calculated).

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

the harbour of 0.020 μ g/l and of 0.0016 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

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

have been derived with different outcomes. Annex 7 to document MEPC 56/2/2 (review by the GESAMP-BWWG of the application by Japan, MEPC56/2), reports a value of 6.9 μ g/l. Document MEPC 58/2/7, annex 7 reports 6.9 μ g/l and document MEC 58/2 6.5 μ g/l.

5.3.6 Bromodichloromethane

Main input data for bromodichloromethane is:

Load: 0.245 kg/day (based on 50,000 m 3 /day and maximum of 4.9 μ g/l); Half life: 0.08 day in water.

The MAM-PEC model calculates fo r bromodichloromethane a steady state situation (= PEC) in

the harbour of 0.0008 μ g/l and of 0.00017 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

The predicted no effect concentration of bromodichloromethane (PNEC) is 1.58 μ g/l (MEPC 58/2/7, annex 7).

5.3.7 Bromoacetic acid

Main input data for bromoacetic acid is:

Load: 4.3 kg/day (based on 50,000 m 3 /day and maximum of 86 μ g/l); Half life: 3.2 days in water (calculated).

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

harbour of 0.023 μ g/l and of 0.0018 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

In various documents, predicted no effect concen trations of bromoacetic acid (PNEC) have been

derived with different outcomes. Docu ment MEPC 58/2 reports a value of 3.4 μ g/l and document MEPC 57/2/6 reports even 2 different values: 1.6 μ g/l and 0.12 μ g/l. Document MEPC 58/2/7, annex 7 reports 2.8 μ g/l.MEPC 59/2/6

ANNEX Page 19

I:\MEPC\59\2-6.doc 5.3.8 Chloroacetic acid

Main input data for chloromoacetic acid is:

Load: 0.355 kg/day (based on 50,000 m 3 /day and maximum of 7.1 μ g/l). Half life: 3.9 day in water.

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

harbour of 0.002 μ g/l and of 0.00015 in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

Document MEPC 58/2 reports a PNEC of 7.7 μ g/l and 0.066 in MEPC 58/2/7, annex 7.

5.3.9 Dichloroacetic acid

Main input data for dichloroacetic acid is:

Load: 0.320 kg/day (based on 50,000 m 3 /day and maximum of 6.4 μ g/l) Half life: 5.4 days in water (calculated)

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

harbour of 0.0023 μ g/l and of 0.0001 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

Document MEPC 58/2 reports a PNEC of 8.2 μ g/l and the review of this application reports 23 μ g/l (MEPC 58/2/7, annex 7).

5.3.10 Bromodichloroacetic acid

Main input data for brom odichloroacetic acid is:

Load: 0.160 kg/day (based on 50,000 m 3 /day and maximum of 3.2 μ g/l); Half life: 3.6 days in water (calculated).

The MAM-PEC model calculates for bromodichloroac etic acid a steady state situation (= PEC)

in the harbour of 0.0006 μ g/l and of 0.00006 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

No PNEC values were found for bromodichl oroacetic acid or coul d be derived from toxicological data. Therefore, the PNEC values for tribromoacetic acid will be used. Document MEPC 58/2 reports a value of 10 μ g/l. Document MEPC 58/2/7, annex 7 reports 6.9 μ g/l.MEPC 59/2/6

ANNEX Page 20

I:\MEPC\59\2-6.doc 5.3.11 Bromochloroacetic acid

Main input data for br omochloroacetic acid is:

Load: 1.2 kg/day (based on 50,000 m 3 /day and maximum of 24 μ g/l); Half life: 2.7 days in water (calculated).

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

the harbour of 0.005 μ g/l and of 0.0005 μ g/l in the surroundings.

Effects on aquatic organi sms: predicted no effect concentrations (PNEC)

Document MEPC 58/2 reports a PNEC of 7.7 μ g/l. Document MEPC 58/2/7, annex 7, reports a

value of 0.07 μ g/l.

6 RISK ASSESSMENT

6.1 Risk to safety of ship, in cluding corrosion evaluation

Corrosion

The Sedimentor is made of a synthetic materi al, resulting in a lightweight construction and preventing corrosion within the system. The electroly tic cell itself, including connecting pipes, is fully protected by special coatings against corros ion. The ballast water tanks in principle are subject to corrosion, especially immediately after treatment. Ballast water tanks normally are coated against corrosion. This regular practice is expected to be sufficient for treated ballast water. The FAC produced by the BWMS will be present in low concentrations and disappears quickly (see chapter 3). The Sedinox BWMS has been used fo r two years on MV ìElizabethî

and corrosion of ballast water tanks was mon itored and inspected by Germanischer Lloyd. According to the shipowner no sign of any corros ion could be observed af ter two years (see for details appendix VII).

Hydrogen measurements

During electrolysis hydrogen gas (H 2 ) is produced. Theoretically, the cell produces 0.0186

mol H 2 gas per ampere (A) per hour, which equals 7.5 g H 2 per hour under standard operating

with 200 A. With a flow in the cell of 100 m 3 /hour, this results in a H 2 gas concentration of less then 0.1 ppm. This is far below any dangerous concentration. This was confirmed by H 2 measurements in the head space of the ballast wa ter storage tank immediately after treatment. All results (brackish and fresh water treatment) we re below detection (< 0.05 %v/v). For details: see appendix III.

Other issues

Storage and handling of the Active Substances a nd Preparations (Procedure (G9), paragraph 7.1) is not an issue since FAC is produced in-situ . Personal Protective Equipment (PPE) specifically

used in order to avoid contact with the FAC is therefore not necessary. Neither is contact with or inhalation an issue. The BWMS will operate in the machine room of the ships using standard pumps. Neither the Sedimentor nor th e Electrolytic cell produces any noise.MEPC 59/2/6

ANNEX Page 21

I:\MEPC\59\2-6.doc 6.2 Risk to human health

Human Risk Assessment for potential risks to system operators, shipís crew and, at de-ballasting, the general public belongs to the application for Final Approval. Appendix IX presents the full report on calculations carried ou t with the model EUSES (version 2.1) to quantify these risks in terms of Margin of Safety (MOS) values compared with reference MOS values (MOS ref ). In this chapter the main re sults are presented.

EUSES calculated MOS values and MOS/MOS ref (MRR) values. These MRR values are

tabulated in Table 11. If the MRR value is ≥ 1 a safety margin of at least 100 is obtained and the risk is considered acceptable.

EUSES gives MRR values for each toxicological endpoint, if available, e.g., acute inhalation, acute dermal, acute total, repetitive dose inhala tion, repetitive dose total, development inhalation, development total, etc. Only the lowest values (i.e. maximum risk values) are given in Table 11.

Table 11: MRR (MOS/MOS ref ) values

MRR (MOS/MOS ref ) lowest value Substance Operators and crew a General public b

FAC 502 6.31E+4

Tribromomethane 36.1 4.71E+3

Dibromochloromethane 6.49E+3 3.07E+5

Bromodichloromethane 1.39E+4 2.94E+4

Bromoacetic acid 3.22E+3 1.54E+5

Chloroacetic acid 2.76E+5 4.70E+6

Dibromoacetic acid 2.45E+6 6.49E+6

Dichloroacetic acid 1.30E+5 2.92E+6

Bromochloroacetic acid 2.57E+4 2.86E+6

Bromodichloroacetic acid 3.58E+4 4.74E+5

Tribromoacetic acid 1.06E+2 7.66E+4

a Based on acute toxicity data

b Based on repetitive dose and/or development toxicity data

From the EUSES calculations (Table 11) it is cl ear that MRR values for operators, crew and the general public of all substances produced by the BWMS are much larg er than 1. Th e highest risk (under unrealistic worst-case assu mptions) is observed for tribro momethane, which still has a margin of safety of 3610 for operators and cr ew and a margin of safety of 4.71 x 105 for the general public after de -ballasting. Therefore, the results show that the BWMS of Greenship B.V. poses no risk to engine room/system operators, no r to the shipís crew or to the general public.

6.3 Risk to the aquatic environment

In order to assess the risk to th e aquatic environment the PEC/PNEC ratio has been calculated for all compounds in table 12. PEC values have been calculated with MAM-PE C (see chapter 5.3). PNEC values have been derived from toxicity data (see table 9). Va rious PNEC values are reported by other applicants and GESAMP-BWWG (see chapter 5.3).MEPC 59/2/6

ANNEX Page 22

I:\MEPC\59\2-6.doc Table 12: PEC/PNEC ratios

Chemical PEC (Max) (mg/L) Toxicity (mg/L) Factor Applied PNEC (mg/L) PEC/PNEC (Max)

Hypochlorite 1.33E-05 2.7E-03 10 2.7E-04 4.9E-02

Bromodichloromethane 8.47E-07 0.78 500 1.56E-03 5.4E-04

Dibromochloromethane 3.62E-07 0.063 500 1.26E-04 2.9E-03

Tribromomethane 4.04E-06 4.8 100 4.8E-02 0.8E-04

Chloroacetic acid 2.03E-06 77 10,000 77E-04 2.6E-04

Bromoacetic acid 2.30E-05 1.6 500 3.2E-03 0.7E-02

Dichloroacetic acid 2.33E-06 23 1,000 23E-03 0.1E-03

Bromochloroacetic acid 5.71E-06 6.9 1000 6.9E-03 0.8E-03

Dibromoacetic acid 2.00E-05 6.9 1,000 6.9E-03 0.3E-02

Tribromoacetic acid 1.32E-07 6.9 1,000 6.9E-03 0.2E-04

Bromodichloroacetic acid 6.53E-07 6.9 1,000 6.9E-03 0.9E-04

Conclusion: the PEC/PNEC ratios for Active Subs tance and all by-products are far below 1, even though a worst case scenario has been used: maximum allowable dose (FAC) and maximum concentration of by-products found in tr eated ballast wate r (see chapter 3).

FAC measurements in the ballast water discharge plume

In order to address the concern of th e GESAMP-BWWG on short term exposure (see MEPC 58/2/7, annex 6, paragraph 2.1.9), extra measurements were done in the discharge plume of treated ballast water. The Sedi nox equipment was operated for two hours at 100 m 3 /hr and regulated to produce the maximum allowabl e dosage concentration. The treated ballast water was discharged during trea tment in the Harlinge n harbour, subs. Van Ha rinxma Channel. FAC was measured in samples at various distances from the discha rge point. Samples of surface water were taken at the depth of 1 m. FAC never exceeded background levels in any surface water sample. These results confirm the expectati on that FAC is very rapidly degraded in surface water, like is the case in the discharge plum es of cooling systems of power stations (see RAR Hypochlorite, chapter 3.1.2.9). For details: see appendix III.

7 ASSESSMENT REPORT

7.1 Overview of data and endpoints

Chapter 6 presents an overview of all critical da ta and endpoints used for the risk assessment (see also appendices IV, VI, VIII and IX). 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 by-products by accredited commercial laboratories and University institutions in the Netherlands and Germany. Quality control pr otocols were at all times strictly followed (see appendix X: Quality Assurance Project Plan ). Representatives of Lloydís Register have consequently witnessed critical tests in the la boratory and on land and have approved these. The applicant considers the quality of test reports ìstate of the artî.MEPC 59/2/6

ANNEX Page 23

I:\MEPC\59\2-6.doc 7.2 Risk assessment of ship, crew and the general public

Ship

Corrosion: see chapter 6.1

Hydrogen: see chapter 6.1

Crew and general public

From the EUSES calculations (table 11) it is clear that MRR values for operators, crew and the general public of all substances produced by the BWMS are much larg er than 1. Th e highest risk (under unrealistic worst-case assu mptions) is observed for tribro momethane, which still has a margin of safety of 3610 for operators and crew and a margin of safety of 4.71 x 10 5 for the general public after de -ballasting. Therefore, the results show that the BWMS of Greenship B.V. poses no risk to engine room/system operators, no r to the shipís crew or to the general public.

7.3 Risk assessment of the aquatic environment

From table 12, it can be concluded, that all PEC/ PNEC ratios are orders of magnitude below 1, using the highest concentrations of FAC and by -products found during treat ment and/or storage during 2 days of treated ballast water. The highe st PEC/PNEC ratio was fo und for FAC: 4.9E-02. Even this value will not occur during normal op eration since no FAC coul d be detected in the treated, stored ballast water 4 hour s after treatment (see table 3, chapter 3). The risk for the aquatic environment of this BWMS is negligible. Th is is the result of a nu mber of steps to refine this BWMS. These included: (1 ) continuous on line regulation of the maximum allowable dose of FAC and continuous adjustment to various cond itions of surface water with regard to chloride concentrations, TSS and organic carbon content; (2) decrease of the maximum allowable dose to 1 ppm; and (3) abolishment of treatment at di scharge (as is the case in other systems: see documents MEPC 58/2 and MEPC 57/2/6).

7.4 Uncertainties

Different PNECs

In various documents of other applicants an d the reviews by the GESAMP-BWWG , almost for every compound more then 1 PNEC value is reporte d. This applicant has used the PNEC values for FAC, bromoform and dibromoacetic acid from the review of its Basic Approval application (MEPC 58/2/7, annex 6). For the other by-products PNECs were derived from the data sets (see appendix IV) as reported also in document MEPC 58/2/7, annex 7 and in document MEPC 57/2/6.

Half lifes

In the literature varying values for the half life of FAC and the by- products can be found. In this application half lifes in water have been used and the references are given. Moreover, the application of half life data from literature seems rather theoretical or at least very much ìworst caseî, since no residual FAC could be detected in the discharge plumes of treated ballast water,

even with treatment sti ll ongoing (see paragraph 6.3).MEPC 59/2/6

ANNEX Page 24

I:\MEPC\59\2-6.doc Volume of discharge water

In the various applications diffe rent values for the volumes of discharges of ballast water are used. The figure used in th is application for the MAM-PEC calcula tions is 50, 000 m 3 , according to a recent report of the Rotterdam Port Authority (see appendix VIII). 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 50 kg hypochlorite each day in the same place, the year round. This is a worst case assumption any way, since the maximu m allowable dose concentration was used for

the risk calculations in the HES and for the aquatic environment.

Types of water: TSS a nd DOC/POC/TOC content

The tests for Final Approval were done in two different types of natural surface water: brackish and fresh (see chapter 3) as prescribed in the Methodology (see MEPC 58/2/7, annex 4, paragraph 10.2.5). These types of water are not specified in Pro cedure (G9), neither is referred to Guidelines (G8) in which two types of wate r are defined with rega rd to salinity, TSS and

TOC/POC/DOC content. Since te sts were performed in natural conditions, the TSS and organic

carbon contents of the surface wate r are beyond control of the applicant, while salinity was not. Given the design of the ìSedinoxî BWMS, results will not be different with regard to the risk to the aquatic environment since the TSS and TOC are always low after multihydrocyclone treatment and hence there will be no difference. FAC concentrations are regulated on line and the maximum dose concentration will be kept at a constant level, regardless of TSS or TOC/DOC/POC content. Moreover, the margin of safety of the PEC/PNEC ratio for by-products is such, that also for these compounds no advers e effects will occur if higher concentrations will be produced as a result of higher concen trations of organic carbon content.

Level of detection of haloacetic acids

In the review of the Basic Approval applic ation of this applicant, the GESAMP-BWWG expressed concern about the level of detection of the haloacetic acids: (MEPC 58/2/7, annex 6, paragraph 0.6.4). Unfortunately, the applicant could not find a laboratory with a better performance then 1 μg/l. Given the MRR: the app licant considers, that th e application of Best Available Technique (BAT) in th e Netherlands is satisfactory.

Combination of Guidelines (G8) an d Procedure (G9) for ecotoxicology

Samples for the ecotoxicological tests as prescrib ed for Procedure (G9) for Final Approval were taken during full scale land-base d tests in the summer of 2008 with the same equipment as used on board a ship for 2 years (see appendix VII) and as used for Guidelines (G8) test cycles performed in the summer of 2007 (see appendix II). The a pplicant considers this procedure in compliance with the Methodology as prescribed in document MEPC 58/2/7, annex 4, pa ragraph 6.2.2.1 and in compliance with Procedure (G9) as prescribed in document MEPC 57/21, anne x 1, paragraph 5.2.3. However, paragraph 5.2.1.2 of Procedure (G9) pres cribes that discharge testing should be done as part of the land-based type approval process, which seems not fully consistent with the other prescriptions. Since samples were taken from ba llast water, treated by the same equipment used for all tests, the applicant considers that the methodology was followed properly.MEPC 59/2/6

ANNEX Page 25

I:\MEPC\59\2-6.doc 7.5 Compliance with the Convention

The ìSedinoxî BWMS using FAC as Active Subs tance, is indeed in compliance with the Convention since all requirements of Procedure (G9) have been met. MSDSs are available for all

relevant chemicals and no PBT substances are used or being produced during operation. All risks to the environment, the crew, and the general public are acceptable during normal operation as well as in case of emergency deballasting im mediately after treatment since for all risk

calculations the maximum allowabl e dose concentration was used.

7.6 Risk management

The applicant considers risks under normal operationa l conditions of this BW MS within the limits of the normal daily operation of any ship. The BW MS is a very robust devi ce with little risk of failure. When switched off, e.g., under SOLAS, the BWMS immediately stops producing Active

Substance. The BWMS ha s been in operation now already for 2 years on a ship a nd many tests have been performed. The performance of the BWMS has been fully satisfactory (see appendix VII).

The concentration of the Ac tive Substance is now co ntrolled through the functioning of a FAC sensor (as used in swimming pools as well) built in the system for continuous on line measurements (see chapter 2 and appendix I) and continuous adjustme nt of the maximum allowable dose of 1 ppm during operation. The applicant is of the opinion that no further specific precautionary measures are needed (e.g., protective clothes, hand gloves, etc. etc.), other than are in place during normal operations on ships. In case treated ballast water will be discharged for emergency reasons immediately after or even during treatment, the risk s will be as presented in this document, since calculations, e.g., for human risk are based on ma ximum dose concentration at uptake anyway.

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