For reasons of economy, this document is printed in a limited number. Delegates are 

kindly asked to bring their copies to meetings and not to request additional copies.

I:\MEPC\60\2-11.doc 

INTERNATIONAL MARITIME ORGANIZATION

IMO 

E

MARINE ENVIRONMENT PROTECTION 

COMMITTEE 

60th session 

Agenda item 2 

MEPC 60/2/11

 30 October 2009

 Original: ENGLISH

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER 

Report of the tenth meeting of the GESAMP-Ballast Water Working Group 

Note by the Secretariat 

SUMMARY

Executive summary: This document contains the report of the tenth meeting of 

the GESAMP-Ballast Water Working Group (GESAMP-BWWG) 

and includes the evaluation of proposals submitted for approval 

by Germany, the Republic of Korea and South Africa. Following the 

decision of MEPC 58, only the main body of the GESAMP-BWWG’s 

reports is translated in all the three working languages with the 

annexes in English only. 

Strategic direction: 7.1 

High-level action: 7.1.2 

Planned output: 7.1.2.4 

Action to be taken: Paragraph 5 

Related document: GESAMP-BWWG 10/6 (attached) 

Introduction

1 The tenth meeting of the GESAMP-Ballast Water Working Group (GESAMP-BWWG) 

was held at IMO Headquarters from 14 to 18 September 2009 and its report is attached to this 

document as GESAMP-BWWG 10/6. 

2 The main purpose of this meeting was to evaluate the remaining four proposals for 

approval of ballast water management systems that make use of Active Substances, submitted 

before the deadline of 19 December 2008 established for MEPC 59. The findings of the Group are 

contained in annexes 4 to 7 of the attached report. 
MEPC 60/2/11 - 2 - 

I:\MEPC\60\2-11.doc 

3 Noting that nine new proposals for approval of ballast water management systems had 

been submitted for consideration by MEPC 60 in accordance with the agreed deadline 

of 28 August 2009, the Group agreed that another two meetings will be needed before MEPC 60 

to evaluate all the new submissions. It was further agreed to hold the GESAMP-BWWG 11 

from Monday, 19 October to Saturday, 24 October 2009 and the GESAMP-BWWG 12 

from 7 to 11 December 2009. 

4 Since MEPC 61 will be held in October 2010, the Group agreed to tentatively schedule its 

next regular meeting (GESAMP-BWWG 13) from 24 to 28 May 2010, subject to submission of 

relevant documents and application dossiers by the interested Administrations. In accordance 

with the approved timetable for activities related to the GESAMP-BWWG meetings, the deadline 

for submission of proposals to be considered by MEPC 61 is 1 April 2010. 

Action requested of the Committee

5 The Committee is invited to: 

 .1 agree that Final Approval be granted to GloEn-PatrolTM Ballast Water Management 

System submitted by the Republic of Korea in document MEPC 59/2/7 

(see annex 4); 

 .2 agree that Final Approval not be granted to Ecochlor® Ballast Water Management 

System submitted by Germany in document MEPC 59/2/9 (see annex 5); 

 .3 agree that Basic Approval be granted to SiCURETM Ballast Water Management 

System submitted by Germany in document MEPC 59/2/11(see annex 6); 

 .4 agree that Final Approval be granted to Resource Ballast Technologies System 

submitted by South Africa in document MEPC 59/2/10 (see annex 7); 

 .5 note the suggested time schedule for the thirteenth meeting of the 

GESAMP-BWWG (24 to 28 May 2010) and invite Members to submit their 

proposals for approval and the non-confidential description of their ballast 

water management systems to MEPC 61, as soon as possible but not later 

than 1 April 2010; and 

 .6 approve the report in general. 

***
I:\MEPC\60\2-11.doc 

GESAMP-BALLAST WATER WORKING 

GROUP (GESAMP-BWWG) 

Agenda item 6 

GESAMP-BWWG 10/6

 18 September 2009

 Original: ENGLISH

REPORT OF THE TENTH MEETING OF THE GESAMP-BALLAST WATER 

WORKING GROUP (GESAMP-BWWG) 

Table of Contents 

Section Page Nos. 

 

1 INTRODUCTION ................................................................................. 3 

2 ISSUES OF CONFIDENTIALITY ..................................................... 3 

3 TERMS OF REFERENCE AND TIME FRAME .............................. 4 

4 REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER 

MANAGEMENT SYSTEMS THAT MAKE USE OF ACTIVE 

SUBSTANCES ..................................................................... 

5 

5 ANY OTHER BUSINESS......................................................... 9 

6 CONSIDERATION AND ADOPTION OF THE REPORT ................. 10 
GESAMP-BWWG 10/6 - 2 - 

I:\MEPC\60\2-11.doc 

ANNEXES 

Annex 1 List of members who attended the Tenth Meeting of the GESAMP-BWWG 

Annex 2 Agenda for the Tenth Meeting of the GESAMP-BWWG 

Annex 3 Terms of reference for the Technical Group 

Annex 4 Review of proposals for approval of ballast water management systems that make 

use of Active Substances – GloEn-PatrolTM Ballast Water Management System 

– Submitted by the Republic of Korea for Final Approval 

Annex 5 Review of proposals for approval of ballast water management systems that make 

use of Active Substances – Ecochlor® Ballast Water Management System 

– Submitted by Germany for Final Approval 

Annex 6 Review of proposals for approval of ballast water management systems that make 

use of Active Substances – SiCURETM Ballast Water Management System 

– Submitted by Germany for Basic Approval 

Annex 7 Review of proposals for approval of ballast water management systems that make 

use of Active Substances – Resource Ballast Technologies System 

– Submitted by South Africa for Final Approval 
 - 3 - GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

1 INTRODUCTION 

1.1 The tenth meeting of the GESAMP-Ballast Water Working Group (GESAMP-BWWG) 

was held at IMO Headquarters, London, from 14 to 18 September 2009, under the chairmanship 

of Mr. Jan Linders. A list of members who attended this meeting is shown in annex 1 and the 

agenda, as adopted by the Group, is set out in annex 2. 

1.2 The meeting was opened by Mr. Dandu Pughiuc, Head, Marine Biosafety Section, who 

conveyed the appreciation of the Director of Marine Environment Division for the effort made by 

the members of the GESAMP-BWWG to have this extraordinary meeting to evaluate the 

remaining four proposals submitted before the deadline of 19 December 2008 established 

for MEPC 59. 

1.3 The Group was informed that nine new proposals for approval had been submitted for 

consideration by MEPC 60 in accordance with the agreed deadline of 28 August 2009 and 

advised that another two meetings will be needed before MEPC 60 to evaluate all the new 

submissions. It was proposed to hold the GESAMP-BWWG 11 from 19 to 23 October 2009 

and GESAMP-BWWG 12 from 7 to 11 December 2009. 

1.4 The Group was briefed on the outcome of MEPC 59, in particular, that the Committee 

agreed with the recommendation of the Group to hold a Second Stocktaking Workshop, 

back-to-back to the GESAMP-BWWG 11 in October 2009, with a view to expediting the 

development of the new tools identified to increase the effectiveness and efficiency of the Group. 

It was emphasized that, in view of the rapidly increasing workload and the need for timely 

review of the proposals for approval, IMO is prepared to take all the possible actions to 

maximize the effectiveness and efficiency of the Group in the common effort to respond to the 

expectations of the proponent Administrations. In this regard, Mr. Pughiuc stressed the need to 

finalize the work on the much needed Human Exposure Scenario (HES) and on adapting 

the MAMPEC model to the specificity of ballast water discharges and invited the members of the 

Group to make every effort to achieve these objectives as a matter of urgency. 

1.5 Mr. Pughiuc expressed his appreciation for the effort made by the IMO consultant, 

Dr. Andrew Craven, for his hard work in preparing this meeting and reviewing a large amount of 

documentation in a relatively short period of time. 

1.6 Finally, Mr. Pughiuc reported on the contractual arrangements and informed the Group on 

the logistics of the meeting. 

2 ISSUES OF CONFIDENTIALITY 

2.1 One proposal for Basic Approval of ballast water management systems that make use 

of Active Substances had been submitted by Germany (MEPC 59/2/11) and three proposals 

for Final Approval had been submitted by Germany (MEPC 59/2/9), the Republic of Korea 

(MEPC 59/2/7) and South Africa (MEPC 59/2/10). All four submissions contained confidential 

supporting data. 

2.2 The confidential nature of the information was recognized by the Group and was treated 

as such in order to protect the commercial interests of the manufacturers concerned. In order to 

ensure that the report did not contain any confidential information, the Group noted that 

the Secretariat would liaise with the relevant Administrations prior to submitting the report 

to MEPC. 
GESAMP-BWWG 10/6 - 4 - 

I:\MEPC\60\2-11.doc 

2.3 Pursuant to paragraphs 4.2.2, 8.1.1 and 8.1.2.7 of the “Procedure for approval of ballast 

water management systems that make use of Active Substances (G9)”, all information gathered, 

materials, notes and reports obtained or made out during the work of the GESAMP-BWWG, 

were, and will be, treated as confidential. In this respect, all the members of the Group and 

the Consultant signed the Statements of Acceptance related to confidentiality. 

2.4 The original copies of these Statements, duly signed and dated by all involved, were filed 

with the Technical Secretary of the Group and will be kept together with the submissions. 

2.5 The submissions (dossiers) were deposited in a safe place in the IMO Headquarters and 

made available to the Consultant, at his request, during the working hours. They were available 

for consultation by the members of the Group for the duration of the meeting in the meeting 

room and returned to the Organization’s designated room after the working hours. 

2.6 On completion of the work, the Chairman of the GESAMP-BWWG obtained from the 

other members all the documents, drafts and any other associated records and reports, which 

were transmitted to the Technical Secretary of the GESAMP-BWWG for retention in confidence. 

All electronic records and data held on personal computers/laptops were destroyed when they 

were no longer necessary for the work of the GESAMP-BWWG. 

3 TERMS OF REFERENCE AND TIME FRAME 

3.1 The Group continued to conduct its work in accordance with the Terms of Reference 

approved by the MEPC as contained in annex 3 of this report. 

3.2 The Group used the table below to determine the timetable for activities related to its 

regular meetings and agreed to decide, on a case-by-case basis, on the timing of additional 

meetings as appropriate. 

TIMETABLE FOR ACTIVITIES RELATED TO GESAMP-BWWG MEETINGS 

Timeline Activity 

28 weeks before MEPC Deadline for submission of application dossiers and related 

documents to be reviewed by the GESAMP-BWWG 

(8 weeks) Preparation of the meeting, including circulation of any relevant 

information provided by other delegations 

20 weeks before MEPC GESAMP-BWWG Meeting 

(1 week) Editing and completion of the draft report of the meeting 

(3 weeks) Review and approval of the report by the GESAMP including 

response/clarification by the working group 

(1 week) Administrations confirm that no confidential data are contained in 

the report 

(1 week) Produce the final report addressing the comments by the GESAMP 

13 weeks before MEPC Submission of the report of the meeting of the GESAMP-BWWG in 

accordance with the 13-week deadline (bulk documents) for MEPC 
 - 5 - GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

3.3 The Group confirmed that the next regular meeting of the GESAMP-BWWG, i.e. the 

eleventh meeting, will take place from 19 to 23 October 2009 and agreed to have an additional 

meeting, from 7 to 11 December 2009, in an attempt to evaluate all the nine submissions received 

before the deadline of 28 August 2009. 

3.4 Bearing in mind that MEPC 61 was tentatively scheduled from 11 to 15 October 2010 

and considering the activities contained in the table above, the Group agreed to tentatively 

schedule its thirteenth meeting from 24 to 28 May 2010 with a deadline for submission of 

documents on Thursday, 1 April 2010. 

4 REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER 

MANAGEMENT SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES

4.1 General review of the submissions 

4.1.1 The Group noted that three proposals for Final Approval had been submitted 

by Germany, the Republic of Korea and South Africa and one submission for Basic Approval 

had been received from Germany. 

4.1.2 Having reviewed all of the submissions, the Group agreed that there are a number of 

points arising, which it wished to bring to the attention of the MEPC. These are addressed in the 

rest of this section. 

4.1.3 The Group recommended that Administrations, before submitting a proposal for 

Final Approval to the Organization, should check and confirm whether or not the ecotoxicity testing 

required by Procedure (G9) has been performed as part of the Type Approval testing in accordance 

with the requirements for the whole effluent tests, as this has implications for the evaluation 

required under Procedure (G9). 

4.1.4 The Group re-iterated the need for each Applicant to make a clear reference to 

the Methodology version being followed in the preparation of their submission. 

4.1.5 The Group noted that, during this meeting, it was necessary to request additional 

information or clarification from all the Applicants, as the dossiers were either incomplete or, 

more commonly, the information provided was unclear, so slowing down the evaluation process. 

4.2 Detailed review of the submissions

4.2.1 Details of the submissions reviewed by the Group can be seen in: 

Annex Ballast Water Management System (BWMS) Administration 

4 GloEn-PatrolTM Ballast Water Management System The Republic of Korea 

5 Ecochlor® Ballast Water Management System Germany 

6 SiCURETM Ballast Water Management System Germany 

7 Resource Ballast Technologies System South Africa 
GESAMP-BWWG 10/6 - 6 - 

I:\MEPC\60\2-11.doc 

4.2.2 Bearing in mind the criteria related to Procedure (G9) and having reviewed all of the 

information associated with these submissions, the Group recommended that: 

 .1 Final Approval be granted to GloEn-PatrolTM Ballast Water Management System 

(Republic of Korea); 

 .2 Final Approval should not be granted to Ecochlor® Ballast Water Management 

System (Germany); 

 .3 Basic Approval be granted to SiCURETM Ballast Water Management System 

(Germany); and 

 .4 Final Approval be granted to Resource Ballast Technologies System (South Africa). 

4.3 Specific comments related to GloEn-PatrolTM Ballast Water Management System 

4.3.1 The Group noted that the Panasia Co. Ltd. GloEn-PatrolTM Ballast Water Management 

System (BWMS) consists of filtration combined with Medium Pressure UltraViolet (MPUV) 

irradiation to treat the ballast water. The Group noted that the system did not use a catalyst. 

4.3.2 Having reviewed all the data and information submitted by the Republic of Korea with 

the application for Final Approval, the Group was satisfied with the completeness of the dossier 

and recommended to MEPC that Final Approval be granted to the GloEn-PatrolTM Ballast Water 

Management System. 

4.3.3 The Group accepted the view of the Applicant that there should be no unacceptable risks 

to the ship, to human health or to the environment posed by the use of this BWMS when operated 

in accordance with the specified instructions. 

4.4 Specific comments related to Ecochlor® Ballast Water Management System 

4.4.1 The Group noted that the Ecochlor® Ballast Water Management System (BWMS) consists 

of filtration and treatment of the ballast water with the Active Substance chlorine dioxide by 

oxidation and disinfection. It was submitted for Final Approval by Germany. 

4.4.2 The Group agreed that the information provided in the proposal submitted by Germany 

for Final Approval, supplemented by that provided by the Applicant in response to questions, 

was sufficient to enable an appropriate evaluation to be made. 

4.4.3 Having reviewed all the data and information received, the Group could not recommend 

to MEPC that Final Approval be granted to the Ecochlor® BWMS and the Group recommended 

that the following points should be given attention by the Applicant in support of any further 

application for Final Approval in the future: 

.1 The proposed discharge concentrations for chlorine dioxide, chlorite ion and 

chlorate ion significantly exceed the discharge concentration of 0.1 mg/L 

to 0.2 mg/L TRO (as Cl2) previously recommended by the Group. 

 .2 To maintain environmental safety, the group recommends that monitoring and 

control of the discharge should be incorporated. 

.3 Given that this BWMS is provided with chemicals supplied externally which react 

on board to produce the Active Substances, the provisions of the IMDG Code 

should be followed as far as is practical and the guidance provided in the IMO 

“Guidance to ensure safe handling and storage of chemicals and preparations used 
 - 7 - GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

to treat ballast water and the development of safety procedures for risks to the ship 

and crew resulting from the treatment process” should also be fully taken into 

account. 

.4 Further attention to procedures and risk mitigation measures applying to BWMS 

maintenance or chemical replenishment operations on board the ship. 

.5 Additional corrosion testing should be conducted in accordance with the guidance 

provided in Section 5.1 of MEPC 59/2/16. 

 .6 A more detailed description of arrangements to be put in place for fire mitigation 

measures is required. 

4.5 Specific comments related to SiCURETM Ballast Water Management System

4.5.1 Siemens SiCURETM Ballast Water Management System consists of filtration and treatment 

of the ballast water with Active Substance sodium hypochlorite, formed by on-demand in situ

electrolysis of seawater, without the addition of any other chemicals. It was submitted 

for Basic Approval by Germany. 

4.5.2 Having reviewed all the data and information submitted by Germany in the proposal for 

Basic Approval and the information supplied by the Applicant in response to questions posed by 

the Group, the Group agreed to recommend to the MEPC that Basic Approval be granted to 

the Siemens SiCURE TM BWMS. 

4.5.3 The Group noted that the Applicant did not provide any information on ecotoxicity 

testing of the treated ballast water that is a stipulated requirement for Basic Approval. However, 

after deliberation, the Group considered that the treated ballast water discharge ecotoxicity 

results were not likely to be substantially different from those obtained from electrolytic systems 

previously considered by the Group and granted Final Approval by MEPC. Hence, the Group 

agreed to make an exception in this case and further agreed that the lack of submitted data could 

be overlooked in this particular Basic Approval assessment. The Applicant should provide the 

results of acute and chronic aquatic ecotoxicity testing of treated ballast water, in accordance 

with the full requirements of Procedure (G9), to be reviewed for Final Approval. 

4.5.4 The Group made the following recommendations, if this system is to be reviewed 

for Final Approval in the future: 

.1 The Group recommended that comprehensive corrosion testing be conducted, 

taking into account the guidance in section 5.1 of the “Report of the eighth 

meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16. 

 .2 The Group recommended that confirmation should be obtained from analytical 

results for the Active Substance, Relevant Chemicals and Other Chemicals in 

treated ballast water, that there will be no unacceptable risks (to ship safety, 

human health or the environment) in the chemical composition of treated ballast 

water caused by the use of this BWMS. 

.3 In accordance with the requirements of Procedure (G9), the Group recommended 

that acute and chronic aquatic ecotoxicity testing of treated ballast water should be 

performed. 
GESAMP-BWWG 10/6 - 8 - 

I:\MEPC\60\2-11.doc 

.4 The Group recommended that the maximum treatment dosage of 6 mg/L stated by 

the Applicant should be further clarified and confirmed, particularly when ballast 

waters with different properties are treated by the system. This may include 

control system logic to verify the Applicant’s claims. 

.5 The Group recommended that an environmentally safe minimum holding time for 

treated ballast water is determined and justified. 

.6 The Group noted that the proposed system does not include either a discharge 

control point for TRO to ensure that the MADC is not exceeded, or a 

neutralization step. The Group recommended that such measures be fully 

considered, regardless of any proposed minimum holding time for the treated 

ballast water. 

.7 The Group recommended that the lower limit of salinity for operation of the 

system should be defined by the Applicant. 

.8 The Group recommended that inhalation and dermal routes of exposure should be 

considered by the Applicant as the Group believes these to be more appropriate in 

assessing the exposure and occupational risk of crew and BWMS operators. 

 .9 The Group recommended that a more realistic estimation of the decay rate 

(half-life time) of Active Substance in treated ballast water should be defined by 

the Applicant. 

.10 The Group recommended that a revised submission of MAMPEC modelling 

for PEC values should be produced, with all the relevant points addressed and 

mistakes corrected. 

4.6 Specific comments related to Resource Ballast Technologies System 

4.6.1 The Group noted that the Resource Ballast Technologies System uses a combination of 

cavitation, as a primary treatment of the ballast water, with small amounts of Active Substances 

(ozone and sodium hypochlorite) to assist the cavitation process, together with ballast water 

filtration. The Group also noted that this BWMS generates the two Active Substances on board 

ship, employing ambient air to form ozone in a generator unit and electrolysis of seawater in 

an electrochemical unit to produce hypochlorite. It was submitted for Final Approval 

by South Africa. 

4.6.2 Having reviewed all the data and information submitted by South Africa with the 

application for Final Approval and the information received from the Applicant, the Group was 

satisfied with the completeness of the dossier and recommended to MEPC that Final Approval be 

granted to the Resource Ballast Technologies System, subject to the Administration verifying 

that all recommendations have been fully addressed prior to the issuance of a Type Approval 

Certificate. 

4.6.3 The Group accepted the view of the Applicant that there should be no unacceptable risks 

to the ship, to human health or to the environment posed by the use of this BWMS when operated 

in accordance with the specified instructions. 
 - 9 - GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

5 ANY OTHER BUSINESS 

5.1 The Group noted and appreciated the decision of MEPC 59 with regard to the 

appropriateness for the evaluation of BWMS that utilize UV irradiation as a disinfection under 

Procedure (G9). Recognizing that the decision was taken that it is for the National 

Administration to determine if a BWMS that uses UV light produces Active Substances and to 

decide if it needs to make a proposal for approval of the Committee or not, the Group wishes to 

offer further comment that may be of assistance to the Administration in its consideration of such 

systems. 

5.2 The Group has noted during its evaluation of BWMSs using UV light irradiation that, 

dependent upon the type of UV light used (LP, MP or HP), analysis of the treated water has 

shown levels of THM produced. They may pose a potential risk to both the environment and 

human health. The Group noted that any risk posed could not be attributed to any particular level 

of irradiation and should be assessed on a case-by-case basis. It is, therefore, recommended that 

Administrations review the chemical analysis results for the treated ballast water, with particular 

emphasis on the level of THM found, in their preliminary screening of such systems. The Group 

wishes to remind that BWMSs using UV irradiation together with a catalyst accelerating the 

reaction, commonly produce free radicals that are normally considered as Active Substance. 

5.3 For information and convenience, the Group offers the following literature references for 

further information to the Administrations: 

 .1 Bukhari, Z. LeChevalier, M. (2003). Assessing performance for treatment 

of finished water. Water Science and Technology 47 (3), pp 179-184. 

 .2 Cooper, W.J. (1989). Sunlight – induced photochemistry of humic 

substances in natural waters: major reactive species. In: Suffet, I.H., 

MacCarthy, P,. Aquatic humic substances – Influence on fate and treatment 

of pollutants. Advances in Chemistry series 219, American Chemical 

society, Washington DC, 1989. 

 .3 Cooper, W.J., Adam, C.J., Whitehead, R.F., Zika, R.G. (2007). 

Sunlight-induced photochemical decay of oxidants in natural waters: 

implications in ballast water treatment. Environmental science and 

Technology 41, pp 3728-3733. 

 .4 Jayson, G.G., Parsons, B.J. (1973). Some simple, highly reactive, inorganic 

chlorine derivatives in aqueous solution. Journal of the Chemical Society, 

Faraday Trans. 1, pp 1597-1607. 

 .5 Kano, I., Darbouret, D., Mabic, S. (2003). UV technologies in water 

purification systems. RD009, The R&D Notebook, Millipore Corporation. 

 .6 De Mora, S., Demers, S., Vernet, M. (2000). The effects of UV radiation in 

the marine environment. Cambridge University Press, 324 S, 

ISBN 052163218. 

 .7 Lia,W., Cheung, L-M., Yang, X and Shang, C., 2006. THM, HAA and 

CNCI formation from UV irradiation and chlor(am)ination of selected 

organic waters. Water Research, 40 (10), 2033-2043. 
GESAMP-BWWG 10/6 - 10 - 

I:\MEPC\60\2-11.doc 

5.4 In preparation for the Second Stocktaking Workshop, the Group held a planning session 

regarding the objectives and the agenda of the Workshop. The Group agreed on the need to 

finalize the development of the “new tools” identified during the First Stocktaking Workshop as 

a matter of urgency and allocated specific tasks regarding the further work needed for the HES 

and the MAMPEC Model to the members concerned. 

5.5 After considering a number of methods to conduct human risk assessments, 

including BEAT, EUSES, Fugacity, etc., the Group agreed to focus on a simple but robust 

standard tool easy to achieve, which could be offered to the Applicants and their respective 

Administrations to be used in future proposals. The Group decided to continue its consultations 

with the US EPA experts through teleconference and to invite Dr. A. Philips, Health and Safety 

Executive, Chemicals Regulation Directorate (United Kingdom) to share the experience of his 

Organization with regard to occupational exposure. 

5.6 With regard to MAMPEC, the Group decided to explore the possibility of adapting 

version 2.5 of the Model with a new default for the agreed ballast water standard port. 

The Group also decided to allocate time to develop a checklist for Basic Approval and Final 

Approval to assist Applicants/Administrations in preparing their proposals. 

5.7 The Group agreed to prepare, in advance for the meeting, working by correspondence and 

recommended that informal Questions and Answers sessions with interested parties could be 

organized during MEPC 60 to provide clarification on the new tools that would be included in 

the Methodology for information gathering and the conduct of work of the GESAMP-BWWG. 

6 CONSIDERATION AND ADOPTION OF THE REPORT 

6.1 A draft report of the tenth meeting of the GESAMP-BWWG was produced 

on 18 September 2009 and, after a paragraph-by-paragraph review, the Group agreed on the final 

text and requested the Secretariat to make the necessary editorial changes to ensure consistency 

with IMO documents’ format and style. 

6.2 The Chairman expressed his appreciation for the long hours and substantial efforts made 

by the members of the Group throughout the week and closed the meeting at 17 h 30. 

*** 
GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

ANNEX 1 

LIST OF MEMBERS WHO ATTENDED THE TENTH MEETING 

OF THE GESAMP-BWWG 

Mr. Jan Linders (Chairman) 

Senior Risk Assessor 

National Institute for Public Health and 

 Environment – Expert Centre on Substances 

Anthonie van Leeuwenhoeklaan 9 

RIVM-SEC 

P.O. Box 1 

NL-3720 BA Bilthoven 

The Netherlands 

E-mail: 

Tel: 

Fax: 

jan.linders@rivm.nl 

+31 30 274 3164 

+31 30 274 4401 

Ms. Teresa Borges 

Senior Technical Officer 

General-Directorate of Health 

(Environmental Health Division) 

Avenida Rio de Janeiro, no 58, 3o dto 

1700-338 Lisbon 

Portugal 

E-mail: 

Tel: 

Mobile: 

tborges@dgs.pt

+351 2 1843 0599 

+351 9 1779 8048 

Mrs. Annette Dock 

Director, Adalia Toxicology Consultants 

Runslingan 3E 

SE-187 72 TÄBY 

Sweden 

E-mail: 

Tel: 

Fax: 

Mobile: 

“Adalia AB” <info@adalia.se>

+46 8 510 149 36 

+46 8 510 126 02 

+46 70 483 11 23 

Mr. Shinichi Hanayama 

Senior Research Fellow 

Maritime Technology Department 

Ocean Policy Research Foundation 

1-15-16 Toranomon 

Minatoku-ku, Tokyo 105-0001 

Japan 

E-mail: 

Tel: 

Fax: 

s-hanayama@sof.or.jp 

+81 3 3502 1886 

+81 3 3502 2033 

Mr. Edward Lemieux 

Director 

Center for Corrosion Science and Engineering 

Naval Research Laboratory, Code 6130 

4555 Overlook Avenue, SW 

Washington, DC 20375 

USA 

E-mail: 

Tel: 

Fax: 

Mobile: 

edward.lemieux@nrl.navy.mil

(202)-404-2123 (Office) 

305-293-4213 

240-475-6918 
GESAMP-BWWG 10/6 

ANNEX 1 

Page 2 

I:\MEPC\60\2-11.doc 

Dr. Kitae RHIE 

Professor of Biology Department 

Kyung Hee University 

#1 Hoe-ki Dong 

Dong-dae-moon Ku 

Seoul 130-701 

Republic of Korea 

Current postal address: 

Dr. Kitae RHIE 

c/o Chesapeake Biology Laboratory-UMCES 

P. O. Box 38 

One Williams Street 

Solomons, MD 20688 

USA 

E-mail: 

Tel: 

Fax: 

Mobile: 

Tel: 

Mobile: 

rhiekt@khu.ac.kr 

+82 (2) 961-0603 

+82 (2) 961 0244 

+82 16-9343-3860 

410-326-7218 

310-626-7621 

Mr. David Tongue 

Marine Manager 

International Chamber of Shipping 

12 Carthusian Street 

London EC1M 6EZ 

United Kingdom 

E-mail: 

Tel: 

Fax: 

Mobile: 

david.tongue@marisec.org

+44 20 7417 2860 

+44 20 7417 8877 

+44 78 5539 1258 

IMO-GESAMP CONSULTANT 

 

Dr. Andrew Craven 

23 Wenlock Drive 

Escrick 

York YO19 6JB 

United Kingdom 

E-mail: 

Tel: 

Fax: 

andrew.craven7@btinternet.com 

+44 (0) 7849 070 668 (Mobile) 

+44 (0) 1904 728 428 (H) 

GESAMP 

 

Mr. Martin Soderberg 

GESAMP Officer 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment, London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax 

Mobile: 

msoderbe@imo.org 

+44 (0)20 7463 4139 (Direct) 

+44 (0)20 7587 3210 

0755 269 9604 
GESAMP-BWWG 10/6 

ANNEX 1 

Page 3 

I:\MEPC\60\2-11.doc 

IMO SECRETARIAT

 

Mr. Miguel Palomares 

Director 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment 

London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax: 

mpalomares@imo.org 

+44 (0)20 7587 3218 

+44 (0)20 7587 3210 

Mr. René Coenen 

IMO Technical Secretary to GESAMP 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment 

London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax: 

rcoenen@imo.org

+44 (0)20 7587 3239 

+44 (0)20 7587 3261 

Mr. Dandu Pughiuc 

IMO Technical Secretary to GESAMP-BWWG 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment 

London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax: 

dpughiuc@imo.org 

+44 (0)20 7587 3247 (Direct) 

+44 (0)20 7587 3261 

Mr. HUANG Tianbing 

Technical Officer, Marine Biosafety Section 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment 

London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax: 

thuang@imo.org

+44 (0)20 7463 4198 (Direct) 

+44 (0)20 7587 3261 

***

GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

ANNEX 2 

AGENDA FOR 

THE TENTH MEETING OF THE GESAMP-BWWG 

1 Introduction 

2 Issues of confidentiality 

3 Terms of reference and time frame 

4 Review of proposals for approval of ballast water management systems that make use of 

Active Substances 

.1 Republic of Korea – GloEn-PatrolTM Ballast Water Management System for Final 

Approval 

 .2 Germany – Ecochlor® Ballast Water Management System for Final Approval

 .3 Germany – SiCURETM Ballast Water Management System for Basic Approval 

.4 South Africa – Resource Ballast Technologies System for Final Approval

5 Any other business 

6 Consideration and adoption of the report 

***

GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

ANNEX 3 

TERMS OF REFERENCE FOR THE TECHNICAL GROUP 

1 Consideration of development of necessary methodologies and information requirements 

in accordance with the “Procedure for approval of ballast water management systems that make 

use of Active Substances (G9)” (adopted by resolution MEPC.169(57)) for consideration 

by MEPC 60. 

2 For Basic Approval, the Group should review the comprehensive proposal submitted by 

the Member of the Organization along with any additional data submitted as well as other 

relevant information available to the Group and report to the Organization. 

 In particular, the Group should undertake: 

.1 scientific evaluation of the data set in the proposal for approval 

(see paragraphs 4.2, 6.1, 8.1.2.3, 8.1.2.4 of Procedure (G9)); 

.2 scientific evaluation of the assessment report contained in the proposal for 

approval (see paragraph 4.3.1 of Procedure (G9)); 

.3 scientific evaluation of the risks to the ship and personnel to include consideration 

of the storage, handling and application of the Active Substance 

(see paragraph 6.3 of Procedure (G9)); 

.4 scientific evaluation of any further information submitted (see paragraph 8.1.2.6 

of Procedure (G9)); 

.5 scientific review of the risk characterization and analysis contained in the proposal 

for approval (see paragraph 5.3 of Procedure (G9)); 

.6 scientific recommendations on whether the proposal has demonstrated a potential 

for unreasonable risk to the environment, human health, property or resources 

(see paragraph 8.1.2.8 of Procedure (G9)); and 

.7 preparation of a report addressing the above-mentioned aspects for consideration 

by MEPC (see paragraph 8.1.2.10 of Procedure (G9)). 

3 For Final Approval, the Group should review the discharge testing (field) data and 

confirm that the residual toxicity of the discharge conforms to the evaluation undertaken 

for Basic Approval and that the previous evaluation of the risks to the ship and personnel 

including consideration of the storage, handling and application of the Active Substance remains 

valid. The evaluation will be reported to the MEPC (see paragraph 8.2 of Procedure (G9)). 

4 The Group should keep confidential all data, the disclosure of which would undermine 

protection of the commercial interests of the Applicant, including intellectual property. 

***

GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

ANNEX 4 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

GloEn-PatrolTM Ballast Water Management System 

Submitted by the Republic of Korea for Final Approval 

0 SUMMARY 

0.1 Having reviewed all the data and information submitted by the Republic of Korea with 

the application for Final Approval and the information received from the Applicant during 

the GESAMP-BWWG meeting, the Group recommended to MEPC that Final Approval be 

granted to the Panasia Co. Ltd. GloEn-PatrolTM Ballast Water Management System (BWMS). 

0.2 The Group recalled that Basic Approval of the BWMS was granted by MEPC 57 and the 

report is available at document MEPC 57/2/10 (BWWG 5/9, annex 6, Review of Proposal 

for Basic Approval of Active Substance). 

0.3 In view of the responses from the Applicant to questions posed by the Group in the 

Basic Approval report, together with the information received from the Applicant during 

the GESAMP-BWWG meeting, the Group was satisfied with the completeness of the dossier 

received from the Applicant. 

0.4 The Group noted that the Panasia Co. Ltd. GloEn-PatrolTM Ballast Water Management 

System uses a combination of filtration with Medium Pressure UltraViolet (MPUV) irradiation to 

treat the ballast water. 

0.5 As the BWMS does not require the storage of chemicals on board ship, the Group 

recognized that there will not be any associated chemical storage related safety problems. 

0.6 The Group recognized that the BWMS has potential safety and environmental concerns 

and the Group has reviewed the hazards and risks associated with the use of the system. 

0.7 The Group recognized that the Applicant has provided information on system controls 

and operational risk mitigation measures that have been incorporated together with safety 

considerations for the installation of the BWMS on board ship. As such, the Group considered 

that the GloEn-PatrolTM BWMS, when installed and operated as described in the submission, 

should present no unacceptable risks to the safety of the ship. 

0.8 In addition, the Group noted the provision by the Applicant of analytical results for chemicals 

in treated ballast water. The Group accepted the view of the Applicant that there are no unacceptable 

risks in the chemical composition of treated ballast water caused by the use of this BWMS. 

0.9 The Group noted the human health assessment provided by the Applicant that includes 

occupational exposure to ships’ crew and BWMS operators. The Group accepted the view of 

the Applicant that there should be no unacceptable risks to human health posed by the use of 

this BWMS when operated in accordance with the specified instructions. 
GESAMP-BWWG 10/6 

ANNEX 4 

Page 2 

I:\MEPC\60\2-11.doc 

0.10 Moreover, the Group recognized that the Applicant has provided detailed information on 

ecotoxicity testing of treated ballast water. The Group accepted the view of the Applicant that 

there should be no unacceptable risks to the environment posed by the use of this BWMS. 

0.11 The Group identified a concern that the filtration cycle commences when the system is 

switched on and stops when switched off and in this scenario it appeared possible that the filter 

could be switched off just prior to a backflow cycle and that the backflush matter may then be 

discharged at commencement of ballasting at the next ballast uptake port. Following a question 

posed to the Applicant during the BWWG meeting, the Group noted that the Applicant is to 

incorporate procedures to address the concern identified. The Group recommended that such 

procedures form part of the requirements for this system for Type Approval. 

0.12 The Group noted that a quality assurance project plan (QAPP) was in place from the start 

of the tests performed for this application for Final Approval. 

0.13 In conclusion, having reviewed all the information provided by the Applicant, the Group 

agreed to recommend to the MEPC that Final Approval be granted to the Panasia Co. Ltd. 

GloEn-PatrolTM Ballast Water Management System. 

1 INTRODUCTION

1.1 The data used to evaluate this system were extracted from that supplied by the Republic 

of Korea in document MEPC 59/2/7 and in the associated confidential dossier, which was 

supplemented by additional information provided by the Applicant after requests for further 

information by the Group during its meeting. 

2 COMPLETENESS OF DOSSIER AND APPLICANT’S RESPONSES TO DATA 

REQUESTS FROM THE GROUP

2.1 The Group recalled that it had already provided the following questions and concerns 

during its evaluation of the application for Basic Approval of the system (see MEPC 57/2/10, 

BWWG 5/9, annex 6, Review of Proposal for Basic Approval of Active Substance), which it 

considered should be addressed by the Applicant for Final Approval. The Applicant’s responses 

received, and the Group’s reaction to these responses are shown in Table 1: 
I:\MEPC\60\2-11.doc 

Table 1: Applicant’s Responses to Data Requests set by the Group during evaluation fo

Section No. 

Group’s Question Applicant’s Response and Section No. 

this Report 

2.1.1 The Group strongly recommended that whole 

effluent ecotoxicity testing and related chemical analysis with QA be carried out for Final Approval. Samples should be taken during efficacy tests to 

meet Guidelines (G8) (Ref. Procedure (G9), 5.2.1). The purpose is to demonstrate conclusively both the lack of any ecotoxicity and the lack of any disinfection by-products.

Whole effluent ecotoxicity testing:Applicant has provided full set of ecotoxicstudies on treated ballast water – acute, chroand sediment, see section 6.2. Chemical analysis with QA: Applicant has provided full analytical data Other Chemicals in treated ballast water – section 3.3. Samples should be taken during efficacy teto meet Guidelines (G8): Applicant has provided full informaton this aspect of the sampling regime – sections 3.3.3 – 3.3.5. Demonstrate conclusively both the lack of aecotoxicity and the lack of any disinfectby-products: Applicant has confirmed these two aspects in results of the testing – see sections 6.2.5 3.3.7, respectively. 

2.1.2 The Group noted that a QAPP had been submitted, but 

the exact procedures for sampling and handling of the samples for chemical analysis, the ballast water treatment conditions applied in the test, and the water quality parameters were not included. The Group was therefore not able to evaluate the reliability of the low detection limits reported by the Applicant.

Procedures for sampling and handling of 

samples for chemical analysis: See sections 3.3.3 – 3.3.5. The ballast water treatment conditiapplied in the test: See sections 3.3.3 – 3.3.5.

The water quality parameters: See appendix. 
GESAMP-BWWG 10/6 

ANNEX 

Page 4 

I:\MEPC\60\2-11.doc 

2.2 During the GESAMP-BWWG meeting, the Group posed three questions to the Applicant. 

The Group’s questions (in bold text), the Applicant’s responses (in plain text) and the reactions 

of the Group (in italic text) are noted below, in numerical order of the individual questions. 

Question 1: 

1 The Group notes that, in the instruction manual (1.3.3 control panel), there appears 

a possibility for manual control of the three-stage power level namely minimum, 

medium and maximum, and that a power control option is available. However, 

there is neither instruction on how to select the appropriate power level nor any 

indication that the power level is to be automatically adjusted. Please further explain 

how power level to arc lamps is to be selected. 

Response 1: 

.1 Power level to arc lamps is fixed. Manual control is wrong expression. Very sorry 

for confusion caused. Why description is not detailed is that automatic power 

control is an option which is available on request . 

.2 Power levels can be changed automatically by the control panel (plc) designed to 

dose control. 

.3 The UV lamp(s) can operate at three power levels. Each power level will increase 

or decrease the UV output of the lamp. Power level min. will give the minimum 

power to the lamp, power level max. will give the maximum power to the lamp. 

.4 The lamp power is controlled from relay contacts, which in turn are controlled 

from PLC output for three level power switching. 

.5 Our all relevant tests have been made with automatic control panel. 

.6 The logic of how to control power level is as follows: 

– UV dose can be set to (data deemed to be confidential and removed at the 

request of the submitting Administration) by an operator. 

– If for example dose is set (data deemed to be confidential and removed at the 

request of the submitting Administration), and change in flow rate or water 

quality during operation causes change in UV intensity and then causes 

change in UV dose. 

– At this moment, current dose is compared to the setting value. In case the 

current dose is higher than the setting value, the power level is step down by 

PLC. This is a complex algorithm. 

– Judging from your question, we think our specification might need to be 

changed and so auto power control is not option. Automatic power control 

was option, however, we think that auto power control is not an option any more 

judging from your question. Our specification remains the same as before. 

The Group was satisfied with this response. The Group noted that automatic power control is to 

be incorporated in this system.
GESAMP-BWWG 10/6 

ANNEX 4 

Page 5 

I:\MEPC\60\2-11.doc 

Question 2: 

2 The Group noted that the proposal is based upon the evaluation of ecotoxicity of the 

treated water where the flow rate is 250 m3/hour with a UV dose of (data deemed to 

be confidential and removed at the request of the submitting Administration) at 

wavelength of 200nm – 400 nm. Should the flow rate reduce, or the UV dose 

increase, what would be the effect of higher UV exposure on the data provided? 

Response 2: 

.1 In GloEn-PatrolTM Ballast Water Management System, photon is an 

“Active Substance” and •OH is defined “relevant chemical”. Because photons have 

no residuality in water, photon does not induce any ecotoxicity in treated water. 

Possible chemicals related to ecotoxicity would be •OH and other oxidants such as 

total residual oxidants (TRO). 

.2 As mentioned in the main proposal, the concentration of •OH naturally produced 

by sunlight irradiation ranges from 10-17 to 10-19 M (de Mora et al., 2000). Since 

the MPUV lamp can emit about 17,500 times higher photonic energy 

(data deemed to be confidential and removed at the request of the submitting 

Administration) than that of sunlight (~ 0.02 mJ/cm2

), the maximum concentration 

of •OH during MPUV irradiation in this system is approximated to be 

about 10-13~10-15 M. Even if the operational UV dose (data deemed to be 

confidential and removed at the request of the submitting Administration) increase 

several fold times higher than (data deemed to be confidential and removed at the 

request of the submitting Administration) (the setting value), the maximum 

concentration of •OH in photo-reactor would be in the same range (~10-13~10-15 M). 

•OH production in seawater UV photolysis is not linearly increased with respect 

to UV dose, since •OH is immediately scavenged by the background constitutes 

present in seawater. In fact, even the higher UV exposure, no significant amount 

of •OH would be expected to remain in the treated water. 

.3 The key method of GloEn-PatrolTM system to inactivate harmful aquatic 

micro-organisms and pathogens is use of direct photolysis with the MPUV 

irradiation. Even though •OH could be produced in theory by the process, the 

concentration is negligibly small compared with other radiation processes such as 

electron-beam or γ-ray radiation which generate significant amount of •OH by 

water radiolysis. 

.4 Other chemicals such as total organic oxidants (TRO) such as HOCl/OCl- and 

HOBr/OBr- can be formed through •OH. Since no significant amount of •OH would be 

expected to remain in the treated water even with high UV exposure, other chemicals 

and corresponding harmful halogenated by-products can not be formed. 

.5 We normally use and tell maximum power level between our customer when the 

specification is described. This means power level is always under safety level of ships. 

The Group accepted this response in this case. The Group is aware that with increasing dose 

and change in wavelength with UV, increasing amounts of THMs have been experienced. 
GESAMP-BWWG 10/6 

ANNEX 4 

Page 6 

I:\MEPC\60\2-11.doc 

Question 3: 

3 The Group notes that the filtration cycle commences when the system is switched on and 

stops when switched off. In this scenario it appears possible that the filter is switched off 

just prior to a backflow cycle and that the backflush matter could then be discharged at 

commencement of ballasting at the next ballast uptake port. How is this addressed? 

Response 3: 

.1 In that case, manual cleaning/backflush process is required. The filter will enter the 

cleaning process by manually pressing the “cycle run (for cleaning )” button on the main 

screen then the suction pump on the backflushing line will remove the backflush matter. 

.2 Manual cleaning/backflush process which removes the backflush matter is 

required every time when ballast pump stops at each ballasting port. We will 

reflect and put this procedure in our instruction manual. 

The Group noted that the Applicant is to incorporate procedures to address the concern 

identified. The Group recommended that such procedures form part of the requirements for this 

system for Type Approval. 

2.3 In view of the above responses from the Applicant to questions posed by the Group, and 

considering all the data and information submitted by the Applicant in this dossier, the Group is 

satisfied with the completeness of the dossier received from the Applicant. 

3 DESCRIPTION OF THE SYSTEM

3.1 Overview 

3.1.1 The Group recalled that this Ballast Water Management System (BWMS) had already 

been described and reviewed in the report for Basic Approval and the Group noted that Figure 1 

schematically shows the BWMS being reviewed for Final Approval. 

3.1.2 The Group recalled that the Applicant proposes a BWMS that combines 50-micron 

filtration with irradiation by Medium Pressure UltraViolet (MPUV) lamps to treat the ballast 

water at uptake, with re-treatment by MPUV at discharge. 

 Ballasting 

Î Î Î 

 De-ballasting Í Í Í 

Figure 1: Schematic process diagram of ballast water management system 

Filtration MPUV 

Ballast 

Water 

Tanks 

MPUV 
GESAMP-BWWG 10/6 

ANNEX 4 

Page 7 

I:\MEPC\60\2-11.doc 

3.1.3 As the BWMS does not require the storage of chemicals on board ship, the Group 

recognized that there will not be any associated storage safety problems. 

3.1.4 Therefore, the Group recognized that this application for Final Approval focuses on the 

system components and operations for ballast water treatment during uptake and discharge. The 

Group noted that for this Final Approval application, the system is installed on a special barge 

that has been designed and manufactured to meet IMO’s requirement for the land-based testing, 

with four ballast tanks, each of which has a capacity of 237 m3

. 

3.1.5 The Group noted that the system consists of a specified number of UV lamps that are 

designed at specified ballast water flow rate for a specified application. The UV lamps have 

automatic wipers for the quartz sleeves and furthermore the UV dose is continuously monitored 

by a sensor on the UV chamber to ensure that the minimum acceptable UV dose is maintained. 

3.1.6 The Group emphasized that the ballast water management system presented 

for Final Approval was evaluated on the basis (data deemed to be confidential and removed at 

the request of the submitting Administration) wavelengths of 200 nm – 400 nm. 

3.2 Safety and control 

3.2.1 The Group accepted the view of the Applicant that no substances or preparations are 

added in the process and no chemicals are required to be stored on board. In addition, no 

significant gas formation is expected as a result of use of this BWMS. 

3.2.2 The Group noted that safety considerations for human health had been identified by 

the Applicant as follows: 

- electrical safety; 

- overheating of UV chamber; 

- burns from UV chamber; and 

- UV light exposure. 

The Group noted that the Applicant has produced various relevant guidance notes and suggested 

warning notices for use on board ship. The Group considered that the guidance provided was 

sufficient to address the specific risks that had been identified. 

3.2.3 The Group noted that to reduce the risk of electrical shock and burns, the main electrical 

supply to the UV chamber should be disconnected and personnel should wait at least 5 minutes 

for the lamps to cool down and energy to dissipate before any maintenance is performed. The 

Group noted that according to the Applicant, the UV lamps produce a considerable amount of 

heat that is removed if the flow-rate of the liquid passing through the system is sufficient. 

In order to monitor correct operation, a temperature detector is fitted to the UV chamber so that 

unsafe situations caused by possible breakdowns are 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. In addition, the control system adjusts the lamp power to ensure the maximum 

dosage (data deemed to be confidential and removed at the request of the submitting 

Administration) is not exceeded at any time. 
GESAMP-BWWG 10/6 

ANNEX 4 

Page 8 

I:\MEPC\60\2-11.doc 

3.2.4 The Group noted that according to the Applicant, UV lamps are housed within lamp 

sleeves to help keep the lamp at optimal operating temperature and to protect the lamp from 

breaking. There is no risk to human health unless personnel are directly exposed to the UV light 

under emergency or abnormal conditions, and according to the Applicant, this risk is minimized 

due to the lamp design. The Group further noted that the Applicant is to post appropriate 

warning notices of the risk of eye and skin injuries from exposure to UV light. 

3.3 Active Substances (AS), Relevant Chemicals (RC) and Other Chemicals (OC)

3.3.1 The Group agreed with the view of the Applicant that in this system, the MPUV irradiation 

process produces photons as the only Active Substance, which are completely responsible for 

inactivating all harmful aquatic micro-organisms and pathogens present in the ballast water. The Group 

therefore defined photons as the Active Substance in the GloEn-PatrolTM BWMS. 

3.3.2 The Group agreed with the view of the Applicant that in this system, the MPUV 

irradiation process produces hydroxyl radical (•OH) as a Relevant Chemical. The Group 

therefore defined hydroxyl radical (•OH) as a Relevant Chemical in the GloEn-PatrolTM BWMS. 

The Group noted that •OH instantaneously disappears within milli-seconds as soon as the water 

leaves the UV chamber due to its extreme reactivity and hence extremely short half-life time 

(~10-9 sec) in water and furthermore no residual •OH was observed in the treated ballast water 

from this system, as confirmed by the Applicant in the land-based testing. 

3.3.3 The Group noted that the hydroxyl radical (•OH) can react with natural constituents 

present in seawater to produce so-called Other Chemicals and the Applicant has provided 

analyses of treated ballast water for these Other Chemicals as part of this application for 

Final Approval. The Group noted that test water was prepared in two tanks of 440 m3

 in total 

(about 220 m3 per tank) using high salinity natural seawater which was pumped from the 

sea 2 miles off Busan coastal harbour or brackish water at the Nakdong River, with due 

consideration for the required salinities (>32 PSU or 3-32 PSU, respectively, with a minimum 

difference of 10 PSU). The 440 m3

 of water was used for both the test and control samples, with 

treated ballast water being tested after a 3 or 5-day holding period. 

3.3.4 The Group noted that according to the Applicant, in order to meet Guidelines (G8), the 

land-based test for the Type Approval, analytical chemistry testing and whole-effluent ecotoxicity 

testing (WET) were simultaneously performed under the same conditions. The testing was accredited 

by KORDI for the performance efficacy test, Yonsei University for specific analysis of •OH, H2O2 and 

TRO, by the SGS Testing Korea Co. Ltd. for general chemical analysis, and NeoEnbiz for the 

ecotoxicity testing, respectively. The Group noted that all experiments (sampling and data analysis) 

were performed under the Applicant’s quality assurance project plan (QAPP). The Group also noted 

that all analyses of Other Chemicals were conducted in accordance with the standard operating 

procedures (SOPs) and quality manual (KS A ISO/IEC 10275) of SGS Testing Korea. Quality 

assurance and control were performed based on the study plan as outlined in the Applicant’s QAPP. 

3.3.5 The Group noted that the potential Other Chemicals that might be formed during use of 

the BWMS in the seawater and the brackish water are summarized in Tables 2 and 3, 

respectively. 

3.3.6 The Group noted the results in Tables 2 and 3 of the analysis of potential Other 

Chemicals (THMs, HAAs, TCE, PCE and TOX). In the seawater tests, any halogenated organic 

compounds such as THMs, HAAs, TCE and PCE were not detected in both the untreated and 

treated water samples. In brackish water, however, low levels of HAAs (MDL = 0.02-0.14 μg/L) 
GESAMP-BWWG 10/6 

ANNEX 4 

Page 9 

I:\MEPC\60\2-11.doc 

were detected both in control (0.89-29.6 μg/L) and in treated water (0.74-26.5 μg/L). The Group 

agreed with the Applicant that detected levels of HAAs were less than the US EPA drinking 

water standard (60 μg/L). The Group also noted the statement from the Applicant that raw 

brackish water contamination with trace level of HAAs is understandable since the Nakdong 

River is the most polluted river contaminated with synthetic organic chemicals in the Republic of 

Korea. 

3.3.7 The Group summarized the results of analysis of potential Other Chemicals in seawater and in 

brackish water following use of this BWMS, as no significant change in the concentration of the 

measured Other Chemicals. Consequently, in the view of the Group, these results confirm that the 

GloEn-PatrolTM BWMS does not significantly alter the seawater or brackish water chemical 

characteristics. 

Table 2: Analysis of potential Other Chemicals in seawater (>32 PSU) of Busan port 

after GloEn-PatrolTM Ballast Water Management 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 

Untreated 

water 

Treated 

water 

Treated 

water 

3 days 

storage 

Untreated 

water 

after 5 

days 

storage 

Treated 

water 

after 5 

days 

storage 

MDL b 

Trichloroethylene μg/L N.D a N.D N.D N.D N.D <0.76 

Perchloroethylene 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 - 

Total organic halides μg/L 120 61 93 67 66 <20

Total residual oxidant 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 N.D: Not detected with the analytical method used, < detection limit. 

b MDL: Method detection limit. The PQL (Practical Quantification Limit) is the reporting limit. 

The PQL is the lowest level that can be reliably measured within specified limits of precision 

and accuracy during routine laboratory operating conditions. The SGS reporting limits are 

PQLs. This laboratory strives to establish PQLs at or near 3.18 times that of the maximum 

MDL. 
GESAMP-BWWG 10/6 

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(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 

Control 

water after 

3 days 

storage 

Control 

water after 

5 days 

storage 

MDL b 

Trichloroethylene μg/L N.D a N.D N.D <0.76 

Perchloroethylene 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 - 

Total organic halides μg/L 85 100 260 <20 

Total residual oxidant 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 – see Table 2(1).

b The same as above – see Table 2(1). 
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ANNEX 4 

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(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 Treated 

water 

Treated 

water 3 

days 

storage 

Untreated 

water after 

5 days 

storage 

Treated 

water 

after 5 

days 

storage 

MDL b

Trichloroethylene μg/L N.D a N.D N.D N.D N.D <0.76 

Perchloroethylene 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 - 

Total organic halides μg/L 12000c 97 260 170 N.D <20 

Total residual oxidant 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 – see Table 2(1). 

b The same as above – see Table 2(1).

c It might be contamination with unknown halogenated organic during sampling. However, it 

was from raw water not in treated water. 
GESAMP-BWWG 10/6 

ANNEX 4 

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I:\MEPC\60\2-11.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 

Control 

water after 

3 days 

storage 

Control 

water after 

5 days 

storage 

MDL b

Trichloroethylene μg/L N.D a N.D N.D <0.76 

Perchloroethylene 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 - 

Total organic halides μg/L 160 77 97 <20

Total residual oxidant 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 – see Table 2(1). 

b The same as above – see Table 2(1). 
GESAMP-BWWG 10/6 

ANNEX 4 

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I:\MEPC\60\2-11.doc 

Table 3: Analysis of potential Other Chemicals in brackish water (3-32 PSU)of Nakdong 

River after GloEn-PatrolTM Ballast Water Management System 

(1) Treated 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 Untreated 

water 

Treated 

water 

Treated 

water 3 

days 

storage 

Untreated 

water 

after 5 

days 

storage 

Treated 

water 

after 5 

days 

storage 

MDL b

Trichloroethylene μg/L N.D a N.D N.D N.D N.D <0.76 

Perchloroethylene 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 - 

Total organic 

halides μg/L 4.78 6.99 2.14 2.14 2.21 <2 

Total residual 

oxidant 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 – see Table 2(1). 
GESAMP-BWWG 10/6 

ANNEX 4 

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I:\MEPC\60\2-11.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 

Control 

water after 

3 days 

storage 

Control 

water after 

5 days 

storage 

MDL b

Trichloroethylene μg/L N.D a N.D N.D <0.76 

Perchloroethylene 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 - 

Total organic halides μg/L 4.18 4.05 3.68 <2 

Total residual oxidant mg/L N.D N.D N.D <0.03 

Hydrogen peroxide mg/L N.D N.D N.D <0.0006 

a, b The same as above – see Table 2(1). 

4 HUMAN HEALTH ASSESSMENT

4.1 The Group noted that the potential hazards for human health related to overheating of UV 

lamps and exposure to UV irradiation resulting from operating this system were sufficiently 

addressed by the Applicant by engineering control measures put in place and training of 

operators. Therefore the Group concluded that the risk of crew exposure was sufficiently 

mitigated by the measures put in place. 

4.2 The Group also noted that measures adopted in the BWMS for installation on board ship 

for Final Approval mitigate the risk of human exposure to Active Substance or Other Chemicals 

through the exposure routes of concern assessed (dermal and inhalation). A summary of the 

various safety measures developed by the Applicant is given above in section 3.2. 

4.3 In addition the Group noted that all the disinfection by-products measured in the 

discharged ballast water were under LOD with exception of HAAs (MDL = 0.02-0.14 μg/L) in 

brackish water (table 3) that were detected both in control (0.89-29.6 μg/L) and in treated water 

(0.74-26.5 μg/L). The Group agreed with the Applicant that detected levels of HAAs were below 

the US EPA drinking water standard, 1998 (60 μg/L) and therefore presents no unacceptable risk 

for the ships’ crew and general public. 
GESAMP-BWWG 10/6 

ANNEX 4 

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I:\MEPC\60\2-11.doc 

4.4 The Group considered that there is no unacceptable risk for occupational exposure based 

on the low value of Henry’s constant of the HAA present in the highest concentration in the 

treated ballast water (trichloroacetic acid). 

4.5 The Group was satisfied that these results show that the BWMS does not present an 

unacceptable risk to ships’ crew (BWMS operators included) and to the general public. 

5 RISKS TO SAFETY OF THE SHIP, ITS CREW AND THE GENERAL PUBLIC

5.1 Safety of the ship 

5.1.1 The Group noted that specific risk control measures are to be employed in this system to 

deal with envisaged emergency and safety problems during the ballast water treatment as 

summarized above. A summary of various system safety measures incorporated by the Applicant 

is given above in section 3.2. 

5.1.2 The Group concurred with the Applicant that use of this BWMS should not adversely 

affect corrosion rates of the ships’ ballast water system and ballast water tanks. 

5.2 Safety of the crew 

5.2.1 The Group considered that risk to safety of the ships’ crew (BWMS operators included) 

by exposure to chemicals and treated ballast water is judged to be acceptable based on the 

measures developed by the Applicant for installation on board ship. A summary of the various 

safety measures developed by the Applicant is given above in section 3.2. The Group considered 

that in this system, the risk to ships’ crew is judged to be appropriately managed. 

5.3 Safety of the general public 

5.3.1 It was reasonably considered by the Group that the system has no unacceptable risk to the 

health of the general public in light of the conclusions noted above. 

6 ENVIRONMENTAL RISK ASSESSMENT 

6.1 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T) 

6.1.1 The Group recalled that it was decided at the Basic Approval, neither the 

Active Substance (photons) nor the Other Chemicals are classified as PBT substances and that 

further assessment of PBT is not necessary. 

6.2 Ecotoxicity testing of treated ballast water 

6.2.1 The Group noted that in this section, the results of aquatic ecotoxicity studies performed 

by the Applicant with 100% treated ballast water as a test substance are presented in accordance 

with the “Procedure for approval of ballast water management systems that make use of 

Active Substances (G9)”. The Group noted the provision above (see section 3.3) of basic 

information on water sampling and data analysis for the ecotoxicity testing of treated ballast 

water, both seawater and brackish water. Field water samples were collected at three appropriate 

time intervals after treatment (immediately after treatment, after 72 hours interval, and final 

ballast water discharge after 5 days interval). Samples for WET tests were prepared from the 

field water samples immediately on delivering to the laboratory. The water samples were passed 
GESAMP-BWWG 10/6 

ANNEX 4 

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I:\MEPC\60\2-11.doc 

through the filtering system (pore size 0.45 μm) by using peristaltic pump, and then water 

parameters – pH, temperature, salinity and dissolved oxygen (DO) – were measured. 

6.2.1 Acute aquatic ecotoxicity 

6.2.1.1 Acute toxicity test with the Rotifer, Brachionus plicatilis

The Group noted that this study evaluated the ability to kill 50% (LC50) of Brachionus plicatilis, 

marine water rotifer for 24 hours using treated ballast water (seawater or brackish water) and this 

was compared to control water (seawater or brackish water). 

The assay was performed in basic accordance with ASTM E1440 Standard Guide for 

Acute Toxicity Test with the Rotifer, Brachionus plicatilis, using 24 hours old rotifers hatched 

from the resting eggs, with incubation at 25oC in darkness. After 24 hours, the rotifers were 

observed and considered dead if no movement of the cilia and mastax was observed over a period 

of 30 seconds. The dead and alive rotifers were counted. 

These results showed that there was no mortality to Brachionus plicatilis at all at any 

experimental condition. When treated ballast water (seawater or brackish water) was compared to 

control water (seawater or brackish water), there was no significant difference in the survival 

rate. The LC50 and NOEC could not be determined. 

Therefore, the treated ballast water (seawater or brackish water) did not induce any acute toxicity 

in 24 hours for Brachionus plicatilis. 

6.2.1.2 Growth inhibition test with Microalgae 

The Group noted that this study evaluated the ability to produce 50% growth inhibition (EC50) of 

Dunaliella tertiolecta and Skeletonema costatum or Phaeodactylum tricornutum, marine water 

microalgae for 96 hours using treated ballast water (seawater or brackish water) and this was 

compared to control water (seawater or brackish water). 

The assay was performed in basic accordance with ASTM E1218-97a Standard Guide 

for Conducting Static 96-h Toxicity Tests with Microalgae. 

In this study, none of the test samples induced growth inhibition to the 3 microalgae at any 

concentrations. When treated ballast water (seawater or brackish water) was compared to control 

water (seawater or brackish water), there was no significant difference in the growth rate. 

The EC50 and NOEC could not be determined. 

Therefore, the treated ballast water did not induce growth inhibition in 96 hours for Dunaliella 

tertiolecta and Skeletonema costatum or Phaeodactylum tricornutum, marine waters microalgae. 

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

The Group noted that this study consisted of a survival test with sheepshead minnow, and 

evaluated the ability to kill 50% (LC50) of Cyprinodon variegatus (larvae), marine water fish 

for 96 hours using treated ballast water (seawater or brackish water) and this was compared to 

control water (seawater or brackish water). 
GESAMP-BWWG 10/6 

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The assay was performed in basic accordance with US EPA 821/R-02/014 Standard Guide for 

Short-term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to 

Marine and Estuarine Organisms. The study used 24 hours old fish hatched from the resting 

eggs, which were incubated at 20oC for 96 hours. 

These results showed that there was no mortality to Cyprinodon variegatus (larvae) at all at any 

experimental condition. When treated ballast water (seawater or brackish water) was compared to 

control water (seawater or brackish water), there was no significant difference in the survival 

rate. The LC50 and NOEC could not be determined. 

Therefore, the treated ballast water did not induce acute toxicity in 96 hours for sheepshead 

minnow, Cyprinodon variegatus (larvae).

6.2.2 Chronic aquatic ecotoxicity 

6.2.2.1 Reproduction (or population growth) toxicity test with the Rotifer, Brachionus plicatilis

The Group noted that this study evaluated the ability to produce 50% population growth 

inhibition (EC50) of Brachionus plicatilis, marine water rotifer for 96 hours using treated ballast 

water (seawater or brackish water) and this was compared to control water (seawater or brackish 

water). 

The assay was performed in basic accordance with Cyst-based toxicity tests (Janssen et al., 1994) 

Standard Guide for Short-chronic toxicity tests with the freshwater rotifer Brachionus

calyciflorus. The study used 24 hours old rotifers hatched from the resting eggs, with incubation 

at 25oC in darkness for 96 hours. Assessment was performed as noted above (section 6.2.2.1). 

None of the test samples induced population growth inhibition to Brachionus plicatilis at any 

concentrations. When treated ballast water (seawater or brackish water) was compared to control 

water (seawater or brackish water), there was no significant difference in the growth rate. 

The EC50 and NOEC could not be determined. 

Therefore, the treated ballast water did not induce reproduction (or population growth) inhibition 

in 96 hours for Brachionus plicatilis, marine water rotifer. 

6.2.2.2 Growth toxicity test with the fish, Cyprinidon variegatus (larvae) 

The Group noted that this study evaluated population growth toxicity with sheepshead minnow, 

using the ability to produce 50% growth inhibition (EC50) of Cyprinodon variegatus (larvae),

marine water fish, for 7 days with treated ballast water (seawater or brackish water) and this was 

compared to control water (seawater or brackish water). 

The assay was performed in basic accordance with US EPA 821/R-02/014 Standard Guide 

for Short-term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters 

to Marine and Estuarine Organisms, using 24 hours’ old fish hatched from the resting eggs, with 

incubations at 20oC for 7 days. 

In this study, the test samples did not induce any population growth inhibition to Cyprinodon 

variegatus (larvae) at any concentrations. When treated ballast water (seawater or brackish 

water) was compared to control water (seawater or brackish water), there was no significant 

difference in the growth rate. The EC50 and NOEC could not be determined. 
GESAMP-BWWG 10/6 

ANNEX 4 

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I:\MEPC\60\2-11.doc 

Therefore, the treated ballast water did not induce population growth inhibition in 7 days for 

Cyprinodon variegatus (larvae), marine water fish. 

6.2.3 Sediment ecotoxicity 

6.2.3.1 Sediment toxicity test with amphipod Monocorophium acherusicum

The Group noted that this study evaluated the ability to kill 50% (LC50) of Monocorophium 

acherusicum, marine water amphipod, for 10 days using treated ballast water (seawater or 

brackish water) and this was compared to control water (seawater or brackish water). 

The assay was performed in basic accordance with US EPA 600/R-94/025 Standard Guide for 

Short-term Methods for Assessing the Toxicity of Sediment-associated Contaminants with 

Estuarine and Marine Amphipods. 

Benthic amphipods Monocorophium acherusicum were reared in the laboratory (NeoEnBiz Co.) 

of which the initial strain had been collected from a mudflat in Daebudo (37○

17'N; 126○34'E), 

located on the Western coast of Korea. Salinity, temperature and dissolved oxygen were 

maintained at 30 PSU, 20o

C and over 80%, respectively. The treated ballast water or control 

water samples were spiked with sediment for 7 days. Individuals of M. acherusicum were then 

exposed to aged test samples for 10 days. 

These results showed that there was no mortality to M. acherusicum at all at any experimental 

condition. When treated ballast water was compared to control water, there was no significant 

difference in the survival rate. The LC50 and NOEC could not be determined. 

Therefore, the treated ballast water did not induce any sediment toxicity in 10 days for amphipod, 

M. acherusicum. 

6.2.4 Conclusion on aquatic ecotoxicity testing of treated ballast water 

The Group concurred with the Applicant that the results of the aquatic ecotoxicity testing show 

that no significant acute or chronic toxicity and sediment toxicity was observed in any of the 

studies with both seawater and brackish water. 

6.3 Risk assessments of chemicals for aquatic organisms 

6.3.1 The Group recalled that in the report of the application for Basic Approval of this system, 

it was stated that the calculation of PEC/PNEC ratios is not appropriate. The Group confirmed 

this view for Final Approval of the BWMS and considered that further work is not required in 

this area. 

6.3.2 Also, according to the chemical analyses performed during the combined testing with 

Guidelines (G8) and Procedure (G9), the Group reconfirmed that there is a low probability of 

Relevant Chemical production by this BWMS, if the dose and exposure time are maintained as 

specified in the application. 
GESAMP-BWWG 10/6 

ANNEX 4 

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I:\MEPC\60\2-11.doc 

6.4 Conclusion for environmental risk assessment 

6.4.1 The Group concluded that there is no unacceptable risk to the aquatic environment from 

use of this BWMS. 

7 CONCLUSIONS AND RECOMMENDATIONS

7.1 Risks to safety of the ship 

7.1.1 The Group noted that the specific risk control measures to be employed in this system to 

deal with envisaged emergency and safety problems during this ballast water treatment process 

have been well described and discussed above, and as such the Group considered that the Panasia 

Co. Ltd. GloEn-PatrolTM BWMS should present no unacceptable risks to the safety of the ship. 

7.2 Risks to the crew and general public 

7.2.1 The Group considered that the use of the GloEn-PatrolTM BWMS raises no unacceptable 

risks to the health of the crew and the general public, regarding the exposure to chemicals and 

treated ballast water. 

7.3 Risks to the environment 

7.3.1 Having reviewed all of the information submitted with this application, the Group agreed 

that use of this system will not pose any unacceptable risks for the environment. 

7.4 Recommendation 

7.4.1 In conclusion, having reviewed all the information provided by the Applicant, the Group 

agreed to recommend to the MEPC that Final Approval be granted to the Panasia Co. Ltd. 

GloEn-PatrolTM Ballast Water Management System. 

* * * 
GESAMP-BWWG 10/6 

ANNEX 4 

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I:\MEPC\60\2-11.doc 

Appendix 

WATER QUALITY ASSESSMENTS 

1 Water Quality Assessments for Land-based Test of BWMS 

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 location is summarized in the following table. In this 

test, after GloEn-PatrolTM treatment, the number of living organisms for all groups in control and 

treated water met regulation D-2 of the BWM Convention. 

Table : 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 

1.2 Brackish water in Nakdong 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 the following table. In this 

test, after GloEn-PatrolTM treatment, the number of living organisms for all groups in control and 

treated water met regulation D-2 of the BWM Convention. 
GESAMP-BWWG 10/6 

ANNEX 4 

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I:\MEPC\60\2-11.doc 

Table: Water quality of brackish 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 

***

GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

ANNEX 5 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

Ecochlor® Ballast Water Management System 

Submitted by Germany for Final Approval 

0 SUMMARY 

0.1 Having reviewed all the data and information submitted by Germany with the application 

for Final Approval and the information received from the Applicant during the 

GESAMP-BWWG meeting, the Group could not recommend to MEPC that Final Approval 

be granted to the Ecochlor® Ballast Water Management System (BWMS). 

0.2 The Group recalled that Basic Approval of the BWMS was granted by MEPC 58 and the 

report is available at document MEPC 58/2/8 (BWWG 7/9, annex 5, Review of Proposals 

for Approval of Ballast Water Management Systems that make use of Active Substances). 

0.3 In view of the responses from the Applicant to questions posed by the Group in the Basic 

Approval Report, together with the information received from the Applicant during the 

GESAMP-BWWG meeting, the Group could accept that the information provided in the dossier 

supplemented by that provided by the Applicant in response to questions was sufficient to enable 

an appropriate evaluation to be made. 

0.4 The Group noted that the Ecochlor® BWMS uses a combination of filtration and 

oxidation. The oxidation is performed by the reaction on board ship between Purate® 

(a proprietary Preparation from Eka Chemicals containing 40% by weight sodium chlorate 

(NaClO3) and 8% by weight hydrogen peroxide (H2O2) in water) and sulphuric acid (H2SO4) to 

generate chlorine dioxide as Active Substance at a maximum allowable concentration of 5 mg/L 

to treat the ballast water by oxidation and disinfection. 

0.5 The Group noted that the Applicant has provided information on ecotoxicity testing of 

treated ballast water, environmental risk assessment for aquatic organisms, and a proposal for 

maximum allowable discharge concentrations for the Active Substance and Relevant Chemicals, 

together with a proposal for minimum holding time for treated ballast water. The Group noted the 

discharge concentrations, with a treated ballast water holding time of 24 h, were as follows: 

Chlorine dioxide – 0.85 mg/L (= 0.44 mg/L TRO as Cl2); 

Chlorite ion – 3.8 mg/L (= 1.98 mg/L TRO as Cl2); 

Chlorate ion – 2.4 mg/L (= 1.01 mg/L TRO as Cl2); and 

Dibromoacetic acid (DBAA) – 0.036 mg/L. 

0.6 The Group noted that the Applicant indicated in its dossier for Final Approval that all the 

discharge concentrations mentioned above were higher than had been reported in the application 

for Basic Approval. The Group recognized that the degradation half-life of chlorine dioxide in 

natural seawater is about 3 minutes. However, the chlorite and chlorate ions, which are primary 
GESAMP-BWWG 10/6 

ANNEX 5 

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I:\MEPC\60\2-11.doc 

by-products when chlorine dioxide degrades, are toxic to aquatic organisms. The Group 

considered that the discharge concentrations of chlorite and chlorate ions, which can be measured 

as part of the TRO, are significant in the evaluation of risks to the environment. 

0.7 The Group noted that the discharged ballast water contains 3.8 mg chlorite/L 

(= 1.98 mg/L TRO as Cl2) after 24 hours holding time. The Group had concerns with this 

discharge concentration as very similar levels of TRO have been used as the maximum allowable 

dosage in other systems that have been evaluated. The Group previously recommended to other 

systems that a discharge concentration in the range of 0.1 mg/L to 0.2 mg/L TRO (as Cl2) should 

be set as the maximum allowable discharge concentration (MADC). The chlorite discharge 

concentration exceeds the above recommendations for TRO by a factor of 19 to 38 and is 

therefore unacceptable. The Group recalled that in the evaluation of the Ecochlor® BWMS 

at Basic Approval that local risks for aquatic organisms had been anticipated as a potential 

problem. Based on these concentrations, the Group is not able to recommend Final Approval for 

the Ecochlor® BWMS as presented. 

0.8 Based on additional calculations using chlorite as representative, the Group concluded 

that the systems proposed discharge concentrations would lead to concentrations in the 

environment that would not exclude unacceptable risks to the aquatic organisms in the receiving 

waters. 

0.9 The Group noted that the results of the Whole Effluent Tests (WET) clearly indicated that 

even with a 5 day tank holding time, the discharged water has both acute and chronic toxicity, so 

that more mitigation would be needed for this BWMS. 

0.10 As the BWMS requires the storage of chemicals on board ship, the Group recognized that 

there will be a potential risk associated with storage safety problems. The submission states that 

as the chemicals used are ship’s stores, then the provisions of the IMDG Code are not applicable. 

The Group recognized that this is the case, however strongly recommended that the provisions of 

the IMDG Code are followed as far as is practical and that the guidance provided in the IMO 

“Guidance to ensure safe handling and storage of chemicals and preparations used to treat ballast 

water and the development of safety procedures for risks to the ship and crew resulting from the 

treatment process” is also fully taken into account. 

0.11 The Group recognized that the system utilizes an Active Substance with potential safety 

and environmental concerns and the Group has reviewed the hazards and risks associated with 

the Active Substance. 

0.12 The Group recognized that the Applicant has provided some information on system 

controls and safety considerations for installation of the BWMS on board ship, together with 

provisions for maintenance and chemical replenishments to the system which will be performed 

by the manufacturer. The Group considered that the Applicant did not provide sufficient 

information to permit a full evaluation of these safety matters, particularly with regard to 

procedures and risk mitigation measures applying to BWMS maintenance or chemical 

replenishment operations on board the ship. 

0.13 The Group noted that while additional corrosion tests had been conducted they were 

insufficient and additional testing was recommended by the Applicant’s corrosion testing 

laboratory. The Group concurred and recommended that additional testing should be conducted 

in accordance with the guidance provided in section 5.1 of MEPC 59/2/16. 
GESAMP-BWWG 10/6 

ANNEX 5 

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0.14 The Group noted the human health assessment provided by the Applicant and the Group 

accepted the view of the Applicant that there should be no unacceptable risks to human health 

posed by the use of this BWMS if operated correctly. 

0.15 In conclusion, having reviewed all the information provided by the Applicant, the Group 

could not recommend to the MEPC that Final Approval be granted to the Ecochlor® BWMS. 

1 INTRODUCTION

1.1 The data used to evaluate this system were extracted from that supplied by Germany in 

document MEPC 59/2/9, which was supplemented by additional information in the confidential 

dossier and by that provided by the Applicant after a request for further information by the Group 

during its meeting. 

2 COMPLETENESS OF DOSSIER AND APPLICANT’S RESPONSES TO 

DATA REQUESTS FROM THE GROUP

2.1 The Group recalled that it had already provided the following questions and 

concerns during its evaluation of the application for Basic Approval of the system 

(see MEPC 58/2/8 – BWWG 7/9, annex 5, Review of Proposals for approval of Ballast Water 

Management Systems that make use of Active Substances), which it considered should be 

addressed by the Applicant for Final Approval. The Applicant’s responses received, and 

the Group’s reaction to these responses are shown in Table 1: 
GESAMP-BWWG 10/6 

ANNEX 5 Page 4 I:\MEPC\60\2-11.doc 

Table 1 : Applicant Responses to Data Requests set by the Group during Evaluation fo

Section No. (BA Report section) 

Group’s Question Applicant’s Response and Section No. in 

this Report 

Gr

2.1.1 (0.3) 

After the injection of chlorine dioxide to the ballast water, chlorite ion is produced as a reaction between seawater and chlorine dioxide and is considered by the Group to be an Active Substance (in addition to the chlorine dioxide) in need of full evaluation in the application for Final Approval. 

Information from the Applicant has been added in response to the GESAMP-BWWG comment indicating that chlorite ion is considered an Active Substance. In Ecochlor’s Basic Approval dossier chlorite ion was classified as a Relevant Chemical based on the definition provided in Procedure (G9). This definition accurately describes chlorite ion, which is formed after employment of the Ecochlor BWMS. Chlorite ion is not produced due to the reaction between seawater and chlorine dioxide. Rather, chlorite ion is the primary by-product when chlorine dioxide degrades, regardless of the matrix (fresh or seawater). Known chlorine dioxide disinfection chemistry clearly indicates that chlorite is the primary reaction by-product of chlorine dioxide oxidation rather than an Active Substance. Ecochlor agrees with the GESAMP-BWWG that the content of chlorite ion in treated ballast water must be considered in regards to potential aquatic toxicity. However, based on Procedure (G9) definition, evaluation of chlorite ion remains under the Relevant Chemicals section in this dossier. The Basic Approval dossier included full information for chlorite ion. In response to the GESAMP-BWWG request, additional information to supplement the evaluation of chlorite ion has been included in section 3.3.3.

The resp

2.1.2 (0.3) 

Purate® containing 40% by weight sodium chlorate (NaClO3) 

and 8% by weight hydrogen peroxide (H2O2) is considered to 

be a Preparation. 

No Response Required.
I:\MEPC\60\2-11.doc 

Section No. (BA Report section) 

Group’s Question Applicant’s Response and Section No. in 

this Report 

Gr

2.1.3 (0.3) 

Sulfuric acid is considered to be a Relevant Chemical. In Ecochlor’s Basic Approval dossier sulfuric acid was 

classified as a Preparation, and also discussed as a Relevant Chemical because of the small excess that is combined with Purate® to generate chlorine dioxide. Comments from the GESAMP-BWWG suggest that sulfuric acid is considered a Relevant Chemical. Ecochlor would like to further emphasize that in water, sulfuric acid will be completely dissociated into hydrogen ions (H+) and sulfate ions (SO42-). Therefore, 

the slight excess of acid can only be present in treated ballast water as the ions, not as sulfuric acid. The interchangeable use of sulfuric acid and sulfate ions in the discussion of these constituents in treated ballast water unintentionally confused the evaluation of sulfate ion in treated ballast water. Because sulfuric acid completely ionizes in water, the only potential impacts of the small amount of acid that may remain after the generation of chlorine dioxide are: 1) an addition of sulfate ions to treated ballast water, or 2) lowering the pH of treated ballast water. Section 2.0.3.1 in the Basic Approval dossier (MEPC 58/2/2) provided sulfate ion concentration and pH data for treated ballast water, which demonstrated that neither are present in treated ballast water at levels that could present aquatic or human health concerns. Further, the GESAMP-BWWG agreed that sulfate ion is not considered a Relevant Chemical (MEPC 58/2/8, annex 5, section 3.2.3). Therefore, no additional evaluation of sulfate ions is presented in this application for Final Approval.

The resp
GESAMP-BWWG 10/6 

ANNEX 5 Page 6 I:\MEPC\60\2-11.doc 

Section No. (BA Report section) 

Group’s Question Applicant’s Response and Section No. in 

this Report 

Gr

2.1.4 (0.4) 

The maximum allowable discharge level of the Active Substances (chlorine dioxide and chlorite) needs to be defined in the application for Final Approval. 

The Applicant has provided full information on proposed definition of maximum allowable discharge concentrations. (See section 6.4). 

The resp

2.1.5 (0.5) 

The Group considers the Level of Quantification (LOQ) for the THMs and HAAs used in the analyses of treated ballast water too high. It is common to determine these contaminants in surface waters at levels of 0.01 – 0.05 μg/L. It remains to be confirmed that the potential amount of by-products produced by the system is sufficiently low and meets the international standards on these substances. This uncertainty should be <0.1 μg/L. 

The GESAMP-BWWG commented that the Level of Quantification (LOQ) associated with the analytical 

data provided in the Basic Approval dossier was too high to confirm that THMs and HAAs in treated water discharge are at sufficiently low levels to ensure that international discharge standards are not exceeded. Clarification on the LOQ comment was requested from the GESAMP-BWWG because the LOQ suggested was very low (0.01 – 0.05 μg/L). The response provided to the German Administration on 4 November 2008 explained that the detection limits noted by the GESAMP-BWWG “...were taken from information provided in previous applications.” Due to the variation in detection limits and terminology that is discussed in this Final Approval, using other applications as “guidance documents” can lead to incorrect data comparisons. Other Applicants may have used detection limit terms differently, produced data by varying methods or in differing matrices (fresh vs. seawater), or had possible errors. As noted by other Applicants, and acknowledged by GESAMP-BWWG, chemical analysis in seawater presents challenges due to potential interferences with the analytical methods. The information herein demonstrates that the THM and HAA data presented has sufficient detection limits and shows that regulatory standards for these constituents are not exceeded in treated ballast discharge. See sections 3.3.6 to 3.3.10. 

The resp
I:\MEPC\60\2-11.doc 

Section No. (BA Report section) 

Group’s Question Applicant’s Response and Section No. in 

this Report 

Gr

2.1.6 (0.6) 

The Group noted that whole effluent ecotoxicity testing still has to be carried out for Final Approval. Samples should be taken during the land-based efficacy tests to meet Guidelines (G8) (Ref. Procedure (G9), 5.2.1) and should include samples taken at day 0, 2 and 5 after treatment to demonstrate conclusively eventual remaining ecotoxicity at discharge after varying holding time in ballast tanks. Chemical analyses with a sufficient low LOQ should be carried out on the samples in order to identify substances responsible for any toxic effects encountered. 

Whole effluent ecotoxicity testing has been performed on samples taken during the land-based efficacy tests to meet Guidelines (G8) (Ref. Procedure (G9), 5.2.1). See section 6.2. Comments received from the GESAMP-BWWG suggested that samples be taken at day 0, 2 and 5 after treatment to demonstrate ecotoxicity at various holding times. Ecochlor would like to note that chlorine dioxide would still be present in treated ballast water at day 0 (i.e. immediately after treatment), conducting ecotoxicity testing at this time point would more accurately reflect efficacy testing. This is due to the fact that the Active Substance, chlorine dioxide, is injected during ballast uptake and decays over time in the ballast tank(s). Therefore, sampling treated ballast water immediately after chlorine dioxide injection would only be expected to produce mortality of aquatic organisms. Testing a broader range of taxonomic groups at time points that represent more realistic onboard situations (days 1 and 5) demonstrates that treated water is safe to discharge within 24 hours of treatment and provides more useful information than confirming the efficacy of chlorine dioxide by 

ecotoxicity testing on samples collected immediately after injection.

The insuclarecoGroAdmthe accPro

2.1.7 (0.7) 

A full environmental risk assessment is required for the application for Final Approval. This should apply model calculations of environmental concentrations using defined emissions scenarios and include the use of the maximum allowable discharge level of both Active Substances and the Relevant Chemicals in the treated ballast water as well as the eventual toxicity of the whole effluent sample. 

The Applicant has provided full information for all these points concerning the environmental risk assessment. See section 6.3. 

The resp
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ANNEX 5 Page 8 I:\MEPC\60\2-11.doc 

Section No. (BA Report section) 

Group’s Question Applicant’s Response and Section No. in 

this Report 

Gr

2.1.8 (0.8) 

For Final Approval the Group recommends additional longterm (at least three months duration) corrosion tests with the treated ballast water to be carried out and also to confirm that epoxy ballast tank coatings commonly in use will not be adversely affected by the use of this BWMS. 

Information has been provided by the Applicant on corrosion testing. See section 5.1. 

The addconand recoCorGrorecotestutilsect

2.1.9 (0.9) 

The Group recommends the provision of appropriate chemical resistant save-all protection by way of the storage tanks and any other locations considered necessary to provide protection to the ship in the event of leakage or spillage of the chemicals used. 

Detailed information was provided in the Basic Approval dossier (MEPC 58/2/2). Additional clarification based on GESAMP-BWWG comments is provided here below. The use of the terms “secondary containment” to describe additional measures to ensure protection to the ship in the unlikely event of a chemical leak is 

equivalent to the terminology “save-all protection” used by the GESAMP-BWWG. This is an engineered aspect of the BWMS to ensure safe installation. Preparing for BWMS installation onboard a ship requires detailed reviews by Ecochlor’s marine engineers, the vessel engineers, as well as the ship’s classification society. Additional mitigation measures that may be identified for safe BWMS installation on a specific ship during these reviews will be implemented as needed.

The that Codpracproenschetreadevfor resuproacc
I:\MEPC\60\2-11.doc 

Section No. (BA Report section) 

Group’s Question Applicant’s Response and Section No. in 

this Report 

Gr

2.1.10 (5.6-5.7) 

Further information should be provided on fire mitigation measures. 

Ecochlor provides information in response to the GESAMP-BWWG comment regarding fire mitigation measures. See section 3.2. 

The with prorathundspebasdetaarrawou

2.1.11 (7.6+ 9.3) 

Full information is required on chemical analysis and water quality data for treated ballast water discharge from the land based test set up. German Administration requested that Ecochlor discuss and present information on dibromoacetic acid (DBAA) as a Relevant Chemical. 

In addition to ecotoxicity data, this Final Approval dossier presents chemical analysis and water quality data for treated ballast water discharge from the land based test set up. (See section 3.3) Based on this new 

data from Guidelines (G8) land-based testing, the German Administration requested that Ecochlor discuss and present information on dibromoacetic acid (DBAA) as a Relevant Chemical (see section 3.3.4). Also, based 

on chemical analysis of treated water discharge from land-based testing, chlorate ion has been added to the list of Relevant Chemicals by the Applicant. (See relevant parts of section 3.3.)

The respthe the to bthe and assenec
GESAMP-BWWG 10/6 

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2.2 During the GESAMP-BWWG meeting, the Group posed four questions to the Applicant. 

The Group’s questions (in bold text), the Applicant’s responses (in plain text) and the reactions 

of the Group (in italic text) are noted below, in numerical order of the individual questions. 

Question 1: 

1 The Group notes that an Installation and Operations Manuals was not submitted, 

can you please provide an electronic copy or a clarification as to its location within 

the submitted dossier. 

Response 1: 

.1 Because the technical details of each BWMS installation will be specific to each 

vessel, the dossier provides general technical and operational information 

pertaining to the subjects in Procedure (G9), section 4.1.2. 

.2 The sections, where the requested information is located, are: 

 Section 3.0.1 – Manner of Application 

 Section 3.0.2 – Operational Overview and Process Description 

 Section 3.0.3 – System Monitoring and Control, Crew Interaction 

Section 3.0.4 – System Requirements (i.e. Technical Installation 

 Specifications; – Maintenance Requirements) 

 Section 3.0.6 – System Locations, Considerations and Limitations 

 Section 3.0.7 – BWTS Operational Safety Features and Alarms 

 Section 3.0.8 – Precursor Chemical Storage, Handling and Delivery 

 Appendix D – BWTS Drawings (General Arrangement) 

.3 The complete BWTS Operational Manual is a voluminous document 

(~1,000 pages), contributing to the reason the dossier provides only general 

information to address the information requested under Procedure (G9). 

Additionally, submittal of the Operations Manual to the German Administration is 

clearly required by Guidelines (G8) for Type Approval. Ecochlor will provide 

this as required to obtain Type Approval from Germany. 

The Group considered the information that had been made available to be very generic and 

lacking the necessary detail to enable a complete safety evaluation to be made. The safety 

procedures to be followed by the manufacturer’s personnel should also be made available. 

Question 2: 

2 Can the applicant clarify that the treatment dosage is controlled on the basis of flow 

rate only and whether any control is provided to accommodate for variations in 

effluent organic content? 

Response 2: 

.1 Regarding the basis for treatment dosage control: 

– The Ecochlor® BWMS includes a flow meter(s) installed in the ballast water 

piping to determine the instantaneous ballast water flow rate. This flow rate 
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information is used by the Ecochlor® BWMS PLC to determine the speed of 

the precursor chemical pumps needed to maintain the 5.0 mg/L chlorine 

dioxide dosage. The ballast water flow rate can fluctuate greatly from the 

beginning of the ballasting operations to the end and this flow pacing is 

necessary to ensure proper treatment over the entire ballast uptake. 

– A chlorine dioxide optical sensor provides verification that the treatment 

dosage has in fact been achieved and maintained throughout the ballasting 

operation. 

– Please also refer to sections 3.0.2 and 3.0.3 of the dossier. 

.2 Regarding the need for controlling to account for organic content variations: 

– As presented in section 3.0.1 of the Final Approval dossier, Ecochlor 

recognizes that the organic content of a water source can affect to some extent 

the demand of the Active Substance. However, in the significant number of 

studies performed during development of the technology, the target dosage 

of 5 mg/L was determined to be the most suitable dose to ensure effective 

removal of AIS and maintain the desired residual within the ballast tank(s), 

over a wide range of organic matter concentrations, while also ensuring the 

least amount of DBP formation. 

– Please see reference 9 of the dossier in section 3.0.6, page 67. 

.3 The following excerpt can be found on pages 4 and 5 within the reference 

document, “A Focus on Chlorine Dioxide: The “Ideal” Biocide”: 

“Selectivity 

In potable and waste treatment applications, a number of researchers have commented 

on the significantly lower demand of the water for chlorine dioxide than for 

chlorine.11,13,98 An example is shown in Figure 3.11 

Figure 3: Comparison of the Measured Residual vs. Dosage of ClO2 with Cl2 for 

a Heavily Contaminated Water.” 
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ANNEX 5 

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.4 The reference highlights the differences between chlorine dioxide demand and 

chlorine demand, which are quite dramatic in high organic waters. Chlorine 

dioxide will exhibit a predictable linear relationship between dosage and residual 

while chlorine exhibits a non-linear relationship. 

.5 Therefore, regardless of the organic loading, the 5.0 mg/L dosage is sufficient to 

ensure proper control of aquatic invasive species to meet any current or proposed 

standard. 

The Group recommended that, to provide certainty for environmental safety, monitoring and 

control of the discharge is incorporated to ensure that the finally agreed MADCs for all 

Active Substances and Relevant Chemicals are not exceeded. 

Question 3: 

3 The Applicant performed only acute toxicity tests. However, we cannot find out the 

evidence that these tests are performed as part of the land-based type approval 

process (described in paragraph 5.2.1 in Procedure (G9)). Could you provide more 

specific description of the treated water? What was the water criteria (salinity, TSS, 

POC and DOC) when the treatment was performed? And were those matched 

to Guidelines (G8) test soup conditions (Guidelines (G8), Part 1, paragraph 2.3.16)? 

And what are the exact tank holding time in ballast tank and the time for 

transportation? 

Response 3: 

.1 Land-based testing of the Ecochlor® BWMS was performed at the 

Royal Netherlands Institute for Sea Research (NIOZ) from April through 

July 2008 according to Guideline 8. In conjunction with the land-based testing, 

ecotoxicity testing was performed on treated ballast water discharge samples. Data 

from land-based testing at NIOZ is identified within the dossier. The ecotoxicity data 

from land-based treated ballast water discharge is presented in Tables T-2.9a 

and T-2.10a. Additionally, further evidence is found in reference 29 

(Grontmij | AquaSense, Report of Ecotoxicological Studies, October 2008), which 

verifies that the samples were obtained during the testing of the Ecochlor® BWMS 

at NIOZ. 

.2 The aquatic toxicity approach used during land-based testing was developed based 

on discussions with the German Authorities, expert ecotoxicologists, and Ecochlor 

before initiation of ecotoxicity testing. Discussion relating to ecotoxicity testing 

performed on treated ballast water discharge samples from the land-based test 

set-up is located in section 2.1, paragraphs 9 – 12. Briefly, the agreed approach 

was to test a broader range of organisms for acute toxicity, while chronic testing 

would only be performed on the most sensitive taxonomic group identified during 

the acute testing series. 

.3 Consequently, the acute aquatic testing series demonstrated that Crassostrea gigas

was the most sensitive group. For this species, the chronic testing method 

evaluates a sublethal endpoint (development), which requires only a short term 

exposure period. So, although it appears that only acute ecotoxicity testing was 

performed, the test method is evaluating a sublethal endpoint on whole effluent, 
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which meets the requirements of section 3.3.3.2. of Procedure (G9). Had a 

different taxonomic group been identified as the most sensitive during the acute 

testing series, then the appropriate chronic test method would have been employed 

for that species. It is simply a matter of using the most appropriate industry 

standard chronic testing method as determined by the ecotoxicologists for a 

particular species. 

.4 Water quality data from the NIOZ land-based testing can be found in Tables T2.8e 

and T2.8f and is as reported by NIOZ. These tables include water quality data for 

the intake harbour water and discharge water after 5 days holding time as required 

by Guideline 8, and are the averages over the number of test cycles performed by 

NIOZ for each salinity. At the time of dossier submittal, Ecochlor had received 

the water quality data from NIOZ but the final NIOZ report had not yet been 

submitted/approved by the German Authorities. An electronic copy 

(in PDF format only, as provided to Ecochlor from NIOZ) can be provided 

to GESAMP-BWWG if requested. 

.5 The NIOZ water quality data meets the Guideline 8 water quality parameters, with 

the exception of DOC for the low salinity test cycles. Testing at NIOZ is done on 

natural harbour water that is not amended for DOC. Therefore, the water quality 

conditions fluctuate with the tidal cycles. 

.6 Section 2.1.1.6 describes that samples evaluated for acute aquatic testing were 

collected one (1) day after treatment. Section 2.1.2.4 describes that samples 

evaluated for chronic (sublethal) ecotoxicity testing were collected one (1) day 

and also five (5) days after treatment. In all cases, samples were then immediately 

placed in coolers with ice, or within a cooler maintained at 4°C prior to 

transportation to the laboratory. Section 2 of the Grontmij | AquaSense report 

(reference No. 29) also presents sample handling procedures. 

The Group considered that acute toxicity testing, semi-chronic testing on the most sensitive 

species, and chemical analyses are sufficient to evaluate risks by ballast water discharge. 

The Group reviewed the land based testing results and was unable to identify neither which test 

runs the ecotoxicity testing samples were obtained from, nor the exact water quality data for 

each test run, hence the test cycle validity could not be established. The Group noted that the 

expectation is that the ecotoxicity tests with samples acquired from the discharge of land based 

tests as required by Procedure (G9) should be conducted using valid test cycles. The Group 

sought the view of the Administration and it indicated that the test cycles employed may be 

accepted for the purpose of Procedure (G9) ecotoxicity testing. 
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ANNEX 5 

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Question 4: 

4 The Group notes the statement in the submission – “The BWMS also determines 

when ballasting has stopped and conducts a pre-determined shut down procedure to 

flush the residual chlorine dioxide from the reactor column and injector piping.”

The dossier does not describe how this flushing is accomplished or where the 

residual chlorine dioxide is flushed to. Please explain further. 

Response 4: 

.1 The flushing process is briefly described in sections 3.03 and 3.04, but Ecochlor 

appreciates the opportunity to elaborate the specifics of this process here. 

To clarify, the term “flushing” was used in the dossier but in actuality the reactor 

column is “evacuated” and the injection piping is “flushed”. To aid in this 

response, it is first important to recall that “motive water” is passed by a venturi 

eductor and used to create a vacuum on the reactor column, and that the motive 

water becomes the dilute solution of chlorine dioxide which is injected into the 

ballast water piping. 

.2 The pre-determined shut-down procedure is triggered by the PLC when the flow 

meter signal reaches a low flow set point. This set point is pre-determined 

specifically for each vessel and corresponds to the ballast water flow rate that is 

expected at the end of a ballasting operation. 

.3 When the set point is reached, the PLC shuts off the chemical pumps and thus, the 

generation of chlorine dioxide stops. Motive water continues to be pumped past 

the venturi maintaining the vacuum on the reactor column. Since no additional 

chlorine dioxide is being generated, the motive water evacuates the remaining 

chlorine dioxide from the column in ≤3 minutes. 

.4 In this way, the remaining chlorine dioxide is removed from the column and the 

motive water continues to pump chlorine-dioxide free water for the time required 

to flush the injector piping of chlorine dioxide solution. The flush time required is 

controlled by the PLC through a pre-determined calculation of the required 

volume of water needed to flush the line. 

.5 All water from this shut-down process flows through the same chemical injection 

piping and directly into the ballast water line. 

The Group accepted the information provided by the Applicant, however, the procedures to be 

used for a manually controlled system, or when topping off tanks, remain unclear. 

2.3 In view of the above responses from the Applicant to questions posed by the Group, and 

considering all the data and information submitted by the Applicant in this dossier, the Group 

was in a position to evaluate the proposed BWMS. 
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ANNEX 5 

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3 DESCRIPTION OF THE SYSTEM

3.1 Overview 

3.1.1 The Group recalled that this Ballast Water Management System (BWMS) had already 

been described and reviewed in detail in the report for Basic Approval and the Group noted that 

Figure 1 schematically shows the BWMS being reviewed for Final Approval. 

3.1.2 The Group recalled that the Applicant proposes a BWMS that combines removal of 

sediment by filtration (40 micron steel mesh) with destruction of biota at uptake of ballast water 

using the reaction on board ship between Purate® (a proprietary Preparation from Eka Chemicals 

containing 40% by weight sodium chlorate (NaClO3) and 8% by weight hydrogen peroxide 

(H2O2) in water) and sulphuric acid (78% by weight) to generate chlorine dioxide as 

Active Substance at a maximum allowable concentration of 5 mg/L to treat the ballast water for 

the killing of micro-organisms by oxidation and disinfection, employing injection of the chlorine 

dioxide into the incoming ballast water stream. The Group noted that no further treatment of the 

ballast water is performed at discharge. 

3.1.3 The Group confirmed that sulphuric acid is added to the Purate® during the chlorine 

dioxide generation process to ensure high chlorine dioxide production efficiency and thus a low 

concentration of sulphate ion (ca 19 mg/L) remains in treated ballast water, but this means that 

essentially all the chlorate is used up. The Group noted that the Applicant lists sulphate ions as a 

Relevant Chemical and Ecochlor presents justifications to fully explain the chemistry associated 

with the treatment process which clearly demonstrates that sulphate ions are not added to treated 

ballast water at environmentally relevant concentrations. This additional clarification regarding 

sulphuric acid has been added in response to the GESAMP-BWWG comment at Basic Approval. 

In conclusion, the Group considered that the addition of a small excess of sulphate ions to 

seawater as a result of treatment with the Ecochlor BWMS is unlikely to pose any unacceptable 

impacts on the marine environment. 

 Ballasting 

 Î 

Î Î Î

De-ballasting Í

Figure 2: Schematic process diagram of Ecochlor® BWMS 

Filtration

Treatment by Chlorine 

Dioxide, formed from 

Purate® and H2SO4 Ballast 

Water 

Tanks 
GESAMP-BWWG 10/6 

ANNEX 5 

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3.1.4 The Group noted that any excess H2O2 remaining from the chlorine dioxide generation 

process will react with chlorine dioxide Active Substance to form chloride/chlorite ions – and 

thus the Group concluded that H2O2 will not be considered further as a Relevant Chemical. 

3.1.5 As the BWMS requires the storage of chemicals on board ship, the Group recognized that 

there will be potential associated storage safety problems and, moreover, the Group recalled that 

detailed discussion of these issues had taken place for the assessment of Basic Approval of 

the BWMS. In conclusion, the Group was satisfied that such issues have been properly dealt 

with by the Applicant. 

3.2 Safety and control 

3.2.1 The Group recognized that the Applicant had already provided at Basic Approval, 

information on system controls and safety considerations for installation of the BWMS on board 

ship, together with provisions for maintenance and emergency operations of the system. 

However at Basic Approval, the Group asked for further clarification of fire mitigation measures 

and the Group noted that the Applicant has now provided further additional information, 

summarized as follows: 

.1 Ecochlor agrees that this is a critical aspect for safe installation of the BWMS. 

There are two potential scenarios related to the chemicals and fire risk. These 

are: 1) a fire on the ship that is not related to the BWMS, but within proximity of 

the system, and 2) a fire directly involving the chemicals. 

.2 In an onboard fire situation that is not related to the BWMS or the stored 

chemicals, but may be within proximity to the chemicals, the primary risk would 

be that the chemicals could become heated inside the storage tanks. The chemical 

properties of each substance (non-flammable) as well as the mitigation measures 

that are engineered into the BWMS to ensure proper chemical storage and 

ventilation greatly reduce a chemical fire starting from such a situation onboard. 

Additionally, although the fire fighting mediums for sulphuric acid and Purate®

are different, water can be used on the exterior of both chemical tanks (but not 

allowed to enter the tanks) to keep the storage tanks cool in the event of a fire 

situation that may cause the tanks to become heated. This is a practical fire 

mitigation measure should such a situation arise onboard. 

.3 Because both chemicals are non-flammable and Ecochlor ensures proper chemical 

storage, the likelihood of sulphuric acid or Purate® being the direct cause of a fire 

onboard is extremely low. 

.4 Additionally, ships typically have both water and CO2 (or other chemical fire 

suppressants) readily available and installed onboard for fire fighting. Considering 

the mitigation measures incorporated into the design of the BWMS and the typical 

fire fighting equipment onboard together with the low potential for the chemicals 

to be involved in a fire, the risk of fire related to the BWMS chemicals is almost 

non-existent. 
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3.2.2 The Group was partially satisfied with the response as the guidance provided was 

considered generic rather than specific. The Group understood the need for ship specific 

measures on a case-by-case basis as indicated, however, a more detailed description of 

arrangements to be put in place would be beneficial. 

3.3 Active Substance (AS), Relevant Chemicals (RC) and Other Chemicals (OC)

3.3.1 The Group recalled the chemical reactions involved, as reviewed and described in detail 

for the evaluation of Basic Approval of the BWMS where full details of the two Preparations 

Purate® and H2SO4 and the Active Substance chlorine dioxide were provided by the Applicant. 

Moreover, the Group noted that during land based testing, detectable levels of Active Substance 

chlorine dioxide were measured within 24 hours after treatment at concentrations ranging 

from 0.22 mg/L – 0.85 mg/L (mean = 0.63 mg/L). The Group was satisfied that these chemical 

compounds have been adequately addressed by the Applicant. 

3.3.2 The Group noted that the Applicant now lists the following substances as 

Relevant Chemicals: 

.1 Sulphate ion – the Group decided that this has already been dealt with by the 

Applicant (see above at section 3.1.3); 

.2 Chlorite ion; 

.3 Dibromoacetic acid (DBAA); and 

.4 Chlorate ion. 

3.3.3 As the primary reaction by-product in ballast water after disinfection with chlorine 

dioxide, the Group regarded chlorite ion or sodium chlorite (NaClO2) as a Relevant Chemical 

and noted that detailed information on chlorite ion was presented in the Final Approval dossier 

by the Applicant. Additional clarification regarding chlorite ion has been added by the Applicant 

in response to the GESAMP-BWWG comment at Basic Approval. The Group noted that during 

the land based testing for Final Approval, chlorite ion was measured in treated ballast water at 

concentrations ranging from 2.26 mg/L – 3.83 mg/L, with a mean concentration of 3.16 mg/L 

and the Applicant has provided detailed analytical data. 

3.3.4 The Group noted that dibromoacetic acid (DBAA) was measured by the Applicant at 

concentrations of 0.012 mg/L – 0.036 mg/L with a mean concentration of 0.023 mg/L in treated 

ballast water discharge samples collected during land based testing. Because these values are 

higher than previously measured in treated ballast water samples and because of comments 

Ecochlor received from the German Administration, additional information has been provided by 

the Applicant for this chemical. 

3.3.5 As already noted by the Group, essentially all the sodium chlorate is used up in the 

Active Substance generation process. However, the Applicant has measured chlorate ion at 

concentrations ranging from 0.98 mg/L– 2.42 mg/L, with a mean concentration of 1.39 mg/L, in 

samples of treated ballast water during land-based testing. Because these values are higher than 

previously measured in treated ballast water samples, additional information has been provided 

by the Applicant for this chemical. 
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3.3.6 The Group noted that the Applicant has provided analyses of treated ballast water for 

Other Chemicals (particularly trihalomethanes (THMs) and haloacetic acids (HAAs)) as part of 

this application for Final Approval. The Group also noted that the information provided in 

the Basic Approval dossier was obtained from laboratory and shipboard analysis of treated 

ballast water. During land based testing for Final Approval at the Royal Netherlands Institute 

for Sea Research (NIOZ), Texel, the Netherlands, the Group recognized that additional chemical 

analysis was performed on treated ballast water. This analysis was performed on eight separate 

discharge sampling events; four during brackish water test cycles and four during seawater test 

cycles. Water samples were collected on days 0, 1 and 5 from both treatment and control ballast 

tanks for full comparison. Sections 1 and 2 in the appendix provide, respectively, a summary of 

the chemical analysis results (for THMs and HAAs) and water quality data (for brackish and 

seawater) from discharge samples collected during land-based testing at NIOZ. 

3.3.7 The Group noted further information provided by the Applicant, as follows: 

.1 EPA Method 524.2 was used to analyse treated ballast water samples for THMs. The 

method explains: “Method detection limits (MDLs) are compound, instrument and 

especially matrix dependent and vary from approximately 0.02 μg/L – 1.6 μg/L. The 

applicable concentration range of this method is primarily column and matrix 

dependent, and is approximately 0.02 μg/L – 200 μg/L.” 

.2 EPA Method 552.2 was used to analyse treated ballast water samples for HAAs. 

The method explains: “Method Detection Limit (MDL) – The minimum 

concentration of an analyte that can be identified, measured and reported 

with 99% confidence that the analyte concentration is greater than zero.” 

3.3.8 The Group noted that according to the Applicant, the tables in section 1 of the appendix 

show the calculated MDL values for THMs and HAAs determined by the stated US EPA 

analytical methods. According to the Applicant, this information demonstrates that the methods 

are capable of the low detection limits suggested by the GESAMP-BWWG. The above MDL 

values apply to the previous data submitted by Ecochlor for Basic Approval as well as the new 

data generated during the land-based testing for Final Approval. The Minimal Risk Level (MRL) 

values in section 1 of the appendix are consistent with the <1.0 μg/L values reported with 

the THM and HAA data generated during analysis of ballast water samples treated with 

the Ecochlor system, and are a result of the method detection study performed by the analytical 

laboratory in accordance with US EPA requirements. The Group noted this information 

submitted by the Applicant. 

4 HUMAN HEALTH ASSESSMENT

4.1 Relation to Basic Approval assessment 

4.1.1 The Group noted that comments from the GESAMP-BWWG (MEPC 58/2/8, annex 5, 

section 4.9) indicated the information provided for HES and Human Health Risk 

Characterization were adequately addressed by the Applicant in the Basic Approval dossier. 

Therefore, the Group accepted that no further information has been added to this part of the 

Final Approval dossier by the Applicant and, consequently, for the purpose of providing a 

summary in this report, the Group drew the following conclusions in this area of assessment. 
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4.2 Assessment of exposure to ships’ crew 

4.2.1 The Group recalled the recommendations of the GESAMP-BWWG “Human Exposure 

Assessment”, in that work operations to be performed in the BWMS that may entail risk of 

occupational exposure should be identified. Although these operations are limited in duration 

and frequency, the risk was found to be present during system maintenance and chemical 

re-supply operations, or during emergency situations involving the BWMS. 

4.2.2 The Group concurred with the Applicant that measures adopted in this BWMS like 

adequate engineering control measures, technician and crew training and standard operating 

procedures (SOP) further mitigate potential human exposure to Active Substance, 

Relevant Chemicals or Other Chemicals in this system, through the exposure routes of concern 

assessed (dermal and inhalation). The Group considered that the unit operations where potential 

human exposure risks exist, e.g., maintenance and refilling operations, are limited in duration and 

frequency and risk mitigation measures were satisfactorily addressed by the Applicant. 

4.2.3 In addition, the Group recommended that precautionary measures e.g., by using personal 

protective equipment (PPE) should be followed when any operator enters the ballast tanks for 

inspection or for sampling operational procedures. 

4.3 Exposure of general public through the environment and food chain 

4.3.1 The Group noted that the THM in treated ballast water discharge were all below 1 μg/L. 

The highest concentration detected for HAA was 36 μg/L (DBAA). In neither of these cases did 

the values exceed the WHO standards for DW Quality. Therefore, the Group concluded that the 

possible scenarios of exposure to the general public through the environment and food chain 

were within acceptable risk. 

4.4 Conclusion of human health assessment 

4.4.1 Therefore, the Group was satisfied that these results show that the BWMS does not pose 

an unacceptable risk to ships’ crew (BWMS operators included) and to the general public. 

5 RISKS TO SAFETY OF THE SHIP, ITS CREW AND THE GENERAL PUBLIC

5.1 Safety of the ship 

5.1.1 The Group noted that specific countermeasures that can be employed in this system to 

deal with envisaged emergency and safety problems during the ballast water treatment have been 

developed by the Applicant. 

5.1.2 The Group noted that in response to the GESAMP-BWWG comment (in MEPC 58/2/8, 

annex 5, section 5.2), additional details of all corrosion coupon tests are provided in 

the Final Approval application. Corrosion tests have been conducted in ballast tanks treated by 

the Ecochlor® BWMS to verify the effect of chlorine dioxide treatment on ballast tank corrosion 

rates. Tests were conducted with C1010 mild steel corrosion test coupons and sent to 

Metal Samples Company, for analysis. The testing was done in conjunction with the land based 

testing at NIOZ Harbour on Texel Island in the Netherlands. As in the testing cycles, harbour 

water was pumped from the harbour into the coated concrete tanks (300 m3

 volume each) that 

simulate ballast water tanks Although the corrosion rates for the specimens exposed in the treated 

tank are slightly higher than the untreated controls, all of the corrosion rates are within the range 
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expected for carbon steels in natural seawater. However, the corrosion experts consulted by the 

Applicant suggested these results were insufficient to make a conclusion and in fact 

recommended more extensive testing. The Group concurred and recommended that further 

corrosion testing be conducted utilizing the guidance previously provided in of MEPC 59/2/16, 

section 5.1. 

5.2 Safety of the crew 

5.2.1 The Group considered that risk to safety of the ships’ crew (BWMS operators included) 

by exposure to chemicals and treated ballast water is judged to be acceptable based on the 

measures developed by the Applicant for installation on board ship. However, the Group strongly 

recommended that the provisions of the IMDG Code are followed as far as is practical and that 

the guidance provided in the IMO “Guidance to ensure safe handling and storage of chemicals 

and preparations used to treat ballast water and the development of safety procedures for risks to 

the ship and crew resulting from the treatment process” is also fully taken into account. 

5.3 Safety of the general public 

5.3.1 It is reasonably considered by the Group that the system poses no unacceptable risk to the 

health of the general public in light of the outcome of results of human risk assessment developed 

by the Applicant. 

6 ENVIRONMENTAL RISK ASSESSMENT 

6.1 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T) 

6.1.1 The Group recalled that as corroborated at the Basic Approval, neither the 

Active Substance nor the Relevant Chemicals and Other Chemicals are classified as PBT 

substances. The Group noted that, in order to re-confirm the situation, the Applicant has made a 

further comprehensive listing of P, B and T criteria for the Active Substance (chlorine dioxide), 

together with chlorite ion, chlorate ion and DBAA found in the treated ballast water. These 

physical and chemical characteristics, along with well-documented degradation and ecotoxicity 

behaviour, are listed in section 6 of the appendix, and the Group concluded that these chemicals 

do not meet the criteria to be classified as PBT substances.

6.1.2 Based on these results, the Group concluded that these chemicals should not be classified 

as PBT substances. 

6.2 Ecotoxicity testing of treated ballast water 

6.2.1 The Group noted that in this section, the results of acute and chronic aquatic ecotoxicity 

studies performed by the Applicant with treated ballast water as a test substance are presented in 

accordance with the “Procedure for approval of ballast water management systems that make use 

of Active Substances (G9)”. Moreover, the Group noted that a list of the aquatic ecotoxicity 

testing methods used in this work is provided at section 3 of the appendix. Ecochlor has 

contracted Grontmij│AquaSense of the Netherlands and Chemex Environmental of 

the United Kingdom to perform the ecotoxicity testing of the treated ballast water from 

land-based testing at the Royal Netherlands Institute for Sea Research (NIOZ), Texel, 

the Netherlands, from April to July 2008, and using two different time points (days 1 and 5 after 

treatment). These time points were selected to demonstrate that treated ballast water may be safe 

to discharge within 24 hours of treatment (day 1) and also after the holding time of 5 days 
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specified in Guidelines (G8) testing. Test samples received 5 mg/L of chlorine dioxide 

Active Substance, and were employed in the ecotoxicity testing together with standard control 

samples of ballast water. Results of this testing are presented in section 5 of the appendix 

(5.1 – acute and 5.2 – chronic) and are presented on the basis of percent by volume (% v/v) of 

treated ballast water. 

6.2.2 The Group noted that acute aquatic ecotoxicity tests were performed with fish, 

crustaceans, marine microalgae (diatoms), molluscs, rotifers and marine bacteria. Testing was 

performed for all six taxonomic groups during both brackish and seawater test cycles. However, 

although testing with algae at the higher salinity (seawater) was attempted multiple times, the 

laboratory control results did not meet quality control criteria to allow the data to be reported 

with confidence. Ultimately, two separate algae tests were completed successfully in brackish 

water. Because Procedure (G9) indicates that toxicity data from fresh water or saltwater species 

should be accepted, the Applicant proposes that algae toxicity testing in brackish water fulfils the 

data requested by the methodology, and the Group accepted this view. 

6.2.3 The Group noted the following acute aquatic ecotoxicity results. The mollusc 

Crassostrea gigas (Pacific oyster) was the most sensitive of the six taxonomic groups tested, 

with seawater EC50 ranging from 62.3% to 50.4% (1 day after treatment), and 73.6% 

(5 days after treatment). In the brackish water, EC50 ranged from 38.1% to 43.3%, and 36.3%, 

respectively. Marine algae results with brackish water were – EC50 ranged from >100% 

(no toxicity 1 day after treatment) to 75.8% (5 days after treatment). 

6.2.4 The Group noted that to evaluate chronic effects, short-term exposure with a sublethal 

endpoint (growth/development) was evaluated for the most sensitive taxonomic group identified 

from the acute testing. The Applicant stated that this approach allowed for testing on a wider 

range of taxonomic groups and also avoided unnecessary testing on organisms that did not show 

evidence of toxic effects with acute exposures. The Group noted that this approach for 

ecotoxicity testing was based on discussions and agreements between Ecochlor and the German 

Administration. 

6.2.5 The Group noted that the GESAMP-BWWG commented at Basic Approval 

(MEPC 58/2/8, annex 5, section 8.1.2) that toxicity tests of 7-day exposures are not recognized as 

chronic methods. However, the Applicant has provided the following discussion to explain the 

use and validity of short-term exposure chronic testing methods. The primary reasons for using 

short term exposure (sublethal endpoint) testing methods is that these methods are commonly 

recognized by regulatory agencies as acceptable chronic methods, and the physical properties of 

the chemicals associated with the Ecochlor® BWMS indicate that they degrade rapidly. 

Therefore, long-term exposure in the aquatic environment would not be expected. As a result of 

extensive studies that compared “traditional” long-term (full-life cycle) chronic toxicity test data 

with the data obtained using short-term chronic testing methods, the US EPA and independent 

scientific experts determined that short-term methods provided essentially the same information. 

The US EPA therefore adopted and recognizes short-term chronic testing methods as standard 

procedures for evaluating toxicity of substances and whole effluents. Environment Canada also 

considers short term testing as standard methods. For example, a 7-day survival and growth test 

with fathead minnow eggs and larvae is considered a standard long-term test. Additionally, a 

non-lethal endpoint test of 7 days with longer-lived crustaceans is considered a standard 

long-term test method. The ecotoxicity testing results presented in this dossier were performed in 

accordance with the short term chronic toxicity testing methods considered standard in 

the United States, which are also recognized internationally. Section 3.3.3.2 of Procedure (G9) 

also indicates that short term chronic testing methods are acceptable because identifying the 
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sensitive sublethal endpoints and vulnerable life stages is the goal of long-term exposure testing. 

As such, and in accordance with widely accepted testing guidelines, US EPA short-term chronic 

testing methods were used during testing with treated ballast water discharge. This is the basis for 

including and evaluating 7-day ecotoxicity tests under the chronic test data section of the dossier. 

In regard to the chemical properties, it is important to note that long term exposure chronic 

toxicity testing for both chlorine dioxide and chlorite ion is not the most practical approach due 

to the rapid degradation of these chemicals. Subjecting test organisms to 14, 21 or 28-day test 

protocols would not reflect realistic exposure times because chlorine dioxide and chlorite ion 

would not persist in the environment for these durations. The Group accepted the above 

argumentation of the Applicant. 

6.2.6 The Group noted that from the acute ecotoxicity testing series, the mollusc 

Crassostrea gigas (Pacific oyster) was identified as the most sensitive taxonomic group and 

additional chronic tests were performed with this species. Although the Crassostrea gigas testing 

method uses a short-term exposure, the test evaluates a chronic sublethal end point 

(development). As such, this test was determined by Grontmij|AquaSense to be the appropriate 

method to evaluate chronic effects with this species and is consistent with section 3.3.3.2 

of Procedure (G9). The Group noted that Crassostrea gigas tested with treated ballast water 

discharge one day after treatment resulted in EC50 values of 43.3% and 50.4% in brackish and 

seawater, respectively. Testing on day 5 samples with Crassostrea gigas resulted in EC50 values 

of 36.3% and 73.6% in brackish and seawater, respectively. One additional test with the algal 

species Phaeodactylum tricornutum was also performed with day 1 brackish water discharge. 

This test resulted in an EC50 of 75.8%. Poor growth performances of the laboratory controls 

during algae chronic testing in seawater caused the tests to be invalid, so although testing was 

performed multiple times, the controls did not meet the criteria to be reported with confidence. 

6.2.7 In summary, the Group concluded that from the land-based testing, treated ballast water 

discharge was evaluated for aquatic ecotoxicity to six different taxonomic groups. The most 

sensitive species was the mollusc Crassostrea gigas (Pacific oyster) with an average EC50 of 51% 

and an average NOEC of 31%. Therefore, a two-fold dilution is necessary to reach a 

concentration less than the EC50 and a three-fold dilution is necessary to reach a concentration 

less than the NOEC value for Crassostrea. 

6.3 Risk assessments of chemicals for aquatic organisms 

6.3.1 The Group recognized that the Applicant has performed aquatic organism risk 

assessments for the Active Substance and Relevant Chemicals, using calculation of the 

PEC/PNEC ratios, with respective PEC and PNEC values being obtained for the different 

chemicals as described below. 

6.3.2 Taking firstly the aquatic ecotoxicity assessment to provide PNEC values, the Group 

noted the provision by the Applicant of comprehensive aquatic ecotoxicity data on the chemicals 

in section 4 of the appendix (4.1 – acute and 4.2 – chronic). For the Active Substance chlorine 

dioxide, the Group recognized that the GESAMP-BWWG commented at Basic Approval that the 

Nautilus Environmental testing protocols with chlorine dioxide measured the effect 

concentrations of the Active Substance at the initiation of the tests. Ecochlor accepts and 

understands this criticism of the test results and has applied the lower LC50 of 0.02 mg/L 

(juvenile Pimephales promelas) for chlorine dioxide as suggested by the GESAMP-BWWG for 

the environmental risk assessment. Applying an AF of 1000 results in a PNEC = 0.02 μg/L for 

chlorine dioxide. The Group accepted this value. 
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6.3.3 Next, the Group considered chlorite ion and noted the following discussion provided by 

the Applicant. Nautilus Environmental performed a number of toxicity studies on chlorite ion to 

evaluate this chemical in treated ballast water. Although data can be found in literature that may 

present lower end point results, Ecochlor contends that the data generated by Nautilus is the most 

appropriate to use for this assessment. Studies found in literature were often conducted long ago 

and there is difficulty in knowing how the chlorite solution was made for a particular study, or 

the exact method the study was conducted with. Therefore, Ecochlor undertook toxicity testing to 

ensure that the testing accurately represented this Relevant Chemical in treated ballast water. 

In any case, Ecochlor accepts the suggested use of the Mysidopsis bahia LC50 of 0.58 mg/L and 

the higher assessment factor of 1000 for chlorite ion to derive a PNEC = 0.58 μg/L. The Group 

accepted this value. 

6.3.4 In the case of chlorate ion, the Group noted that the Applicant performed a literature 

search to locate acute and chronic aquatic ecotoxicity data for this chemical. The acute toxicity 

data set presents three data points for fish, four data points for crustaceans and five data points 

for algae. The chronic toxicity data set presents one result for fish, two results for crustaceans, 

and four results for algae. According to the Applicant, this justifies the use of an assessment 

factor of 100. The data indicate that algae are more sensitive to chlorate than invertebrates or 

fish. Based on the above discussion, and due to the large variability in toxicity data for chlorate 

found in the literature, Ecochlor selected the lowest chronic NOEC geometric mean value 

of 0.06 mg/L (60 μg/L) for marine macroalgae reported by van Wijk and Hutchinson to derive a 

PNEC value. This geometric mean value takes into account the very low data point (5 μg/L) that 

van Wijk inferred from the Rosemarin study, as well as other data points that are an order of 

magnitude higher. As such, the NOEC of 0.06 mg/L is more representative of the overall algal 

toxicity data for various species, yet is lower than the actual EC50 value of 0.08 mg/L for Fucus 

vesiculosus. The Group noted the statement from the Applicant that this NOEC value for chlorate 

provides adequate protection for aquatic species when used to derive a PNEC = 0.6 μg/L. 

The Group accepted this value. 

6.3.5 In the case of dibromoacetic acid (DBAA), the Group noted that the Applicant had 

performed a literature search to locate DBAA aquatic toxicity data; however, only limited data 

was located. Four LC50 endpoints, with exposure periods of one to four days, were located for the 

fathead minnow (Pimephales promelas). The lowest LC50 (69 mg/L) was obtained from the four 

day exposure. Data for other aquatic species was not located as the aquatic toxicity data set for 

dibromoacetic acid is very limited. Applying the highest assessment factor of 1000 

from Procedure (G9) results in a PNEC = 69.0 μg/L for DBAA. The Group accepted this value. 

6.3.6 The Group noted that the Applicant had performed a refined computer modelling 

assessment to obtain PEC values for the respective four chemicals, based on the results of the 

land-based testing. Two separate models were utilized to determine the PEC values – MAMPEC 

(beta release v2.5) and Delft-3D detailed model. Deltares (formerly Delft Hydraulics) is located 

in the Netherlands and is the firm that developed the MAMPEC and Delft-3D models and 

Deltares performed the analysis of the PEC values for Ecochlor’s BWMS. 

6.3.7 The Group noted that in the case of the MAMPEC model, the estuarine harbour was 

selected for this assessment. Two separate “locations” were simulated with MAMPEC for 

the Port of Rotterdam. The first location considered a specific part of the Nieuwe Waterweg, 

the Maashaven. The second MAMPEC “location” considered the Port of Rotterdam as a whole in 

which the release of ballast water due to all ships present was simulated.
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6.3.8 The Group noted that the Delft-3D detailed model was used to provide a simulation of 

treated water discharge within the Maashaven and also provided an indication of the overall 

suitability of the MAMPEC model to accurately predict ballast water discharge concentrations. 

The modelling input parameters are the same as those used for the MAMPEC model, with the 

only difference being that the discharge duration for the detailed model was 24 hours rather than 

continuous. Several scenarios were evaluated with the Delft-3D model. Further, scenarios with 

one ship at different locations within the harbour, as well as three ships in the harbour 

discharging simultaneously were simulated. Of all the scenarios simulated with the detailed 

model, the worst-case (where the PEC values are the highest) occurred when three ships 

discharge simultaneously. According to the Applicant, to determine the discharge volume and 

duration for both MAMPEC and Delft-3D models, Ecochlor chose vessel parameters to represent 

a worst case scenario within Maashaven. Moreover, the Group noted that the concentrations of 

chlorine dioxide, chlorite ion, chlorate ion and DBAA in treated ballast water discharge that were 

entered into the models for PEC derivation were the highest concentrations measured 24 hours 

after treatment during land based testing. 

6.3.9 The Group noted that the highest PEC for chlorine dioxide, chlorite ion and chlorate ion 

is generated with the detailed model for the worst case scenario of three ships discharging in 

the Maashaven simultaneously. These results are 4.98 x 10-5 mg/L, 6.62 x 10-5 mg/L 

and 2.90 x 10-4 mg/L, respectively. For DBAA, the highest PEC (8.74 x 10-4 mg/L) is generated 

with the MAMPEC model when one ship discharges in the back of the Maashaven. Therefore, 

since these are the highest PEC values derived for all modelling scenarios for both the MAMPEC 

and the Delft-3D model, the Group was satisfied that these are the values used for the 

environmental risk assessment to calculate PEC/PNEC ratios.

6.3.10 The Group was satisfied that in order to assess the risk to the aquatic environment, 

the Applicant has calculated the PEC/PNEC ratios for the Active Substance and Relevant 

Chemicals, and the results are presented in Table 2. 

Table 2: Derivation of PEC and PNEC Values and PEC/PNEC Ratios for the 

Active Substance and Relevant Chemicals 

Chemical 

Name 

Lowest 

observed 

effect 

concentration 

(mg/L) 

Assessment 

Factor 

PNEC 

(μg/L)

PEC 

(μg/L)

PEC/PNEC 

Ratio 

Chlorine 

dioxide 

0.02 1000 0.02 0.0498 2.49 

Chlorite ion 0.58 1000 0.58 0.0662 0.11 

Chlorate ion 0.06 100 0.6 0.290 0.48 

Dibromoacetic 

acid (DBAA) 

69.0 1000 69.0 0.874 0.013 
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6.3.11 The Group noted that according to the Applicant for all substances, with the exception 

of Active Substance chlorine dioxide, the PEC/PNEC ratio is <1, thereby indicating that no 

further evaluation or testing would be required for chlorite ion, chlorate ion and DBAA at the 

present time. The Group noted that for chlorine dioxide, the PEC/PNEC ratio = 2.49. However, 

this PEC was calculated for the Maashaven with the Delft-3D detailed model based on a worst 

case scenario. When the chlorine dioxide PEC result of 0.015 μg/L as calculated with 

the MAMPEC model for the Maashaven under a worst case scenario is considered, a PEC/PNEC 

ratio of 0.75 is achieved. Further, when the chlorine dioxide PEC result of 0.000973 μg/L as 

calculated with the MAMPEC model for the whole Port of Rotterdam is considered, 

a PEC/PNEC ratio of 0.049 is achieved. However, the Group did not agree with this view of 

the Applicant as indicated in the next point. 

6.3.12 Taking into account the results presented by the Applicant on the concentration of 

the Relevant Chemicals (see 6.4.2) and taking chlorite as the main representative the Group 

performed additional calculations with the MAMPEC-model. These calculations show that, 

according to the scenario the Group has established during their First Stocktaking Workshop 

of 21 and 22 January 2009, the concentration of chlorite in the harbour will reach a level of 

about 60 microgram/L. Comparing this to the PNEC of chlorite established in the evaluation of 

the Ecochlor® BWMS at Basic Approval and re-confirmed during this Final Approval 

of 0.6 microgram/L, it is clear that with a PEC/PNEC-ratio of about 100 there is a risk for aquatic 

ecosystems. 

6.3.13 Based on these additional calculations using chlorite as representative, the Group 

concluded that the systems proposed discharge concentrations would lead to concentrations in the 

environment that would not exclude unacceptable risks to the aquatic organisms in the receiving 

waters. 

6.4 Maximum Allowable Discharge Concentrations (MADC) 

6.4.1 The Group recognized that in most testing of treated ballast water, the chlorine dioxide 

Active Substance has a typical decay of around 24 hours and the Group noted that during land 

based testing, detectable levels of chlorine dioxide were measured within 24 hours after treatment 

at concentrations ranging from 0.22 mg/L – 0.85 mg/L (mean = 0.63 mg/L) – see section 3.3.1. 

The highest day 1 chlorine dioxide concentration of 0.85 mg/L was used in the modelling to 

determine the PEC. Moreover, the concentrations of Relevant Chemicals chlorite ion, chlorate 

ion and DBAA in treated ballast water discharge that were entered into the models for PEC 

derivation were the highest concentrations measured 24 hours after treatment during land based 

testing (see sections 3.3.3 to 3.3.5). 

6.4.2 Therefore, the MADC in treated ballast water based on the data of the Applicant 

at 24 hours would be as follows: 

Chlorine dioxide – 0.85 mg/L (= 0.44 mg/L TRO as Cl2); 

Chlorite ion – 3.8 mg/L (= 1.98 mg/L TRO as Cl2); 

Chlorate ion – 2.4 mg/L (= 1.01 mg/L TRO as Cl2); and 

Dibromoacetic acid (DBAA) – 0.036 mg/L. 
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6.4.3 The Group was of the opinion that MADCs based on these values would not be 

acceptable as they present a significant risk to aquatic organisms and also compared to decisions 

reached in the evaluation of other BWMS (see 6.6). 

6.5 Determination of Holding Time in treated ballast water 

6.5.1 The Group noted that the Applicant presented data to support a proposal for a ballast 

water holding time following treatment of 24 hours. 

6.6 Conclusion on environmental risk assessment 

6.6.1 The Group considered that the above-mentioned MADC for chlorine dioxide, chlorite ion 

and chlorate ion, which can be measured as part of the TRO, are significant in the evaluation of 

risks to the environment. The Group previously recommended that a discharge concentration 

of 0.1 mg/L to 0.2 mg/L TRO (as Cl2) should be the maximum allowable discharge concentration 

(MADC). These chemicals are all oxidants and therefore the MADC is significantly exceeded in 

this case. Hence, the Group was not satisfied that treated ballast water discharge will not present 

unacceptable risks to the aquatic environment from these chemicals when discharged 24 hours 

after treatment, following use of this BWMS. Based on these concentrations, the Group is not 

able to recommend Final Approval for the Ecochlor BWMS as presented. 

7 CONCLUSIONS AND RECOMMENDATIONS

7.1 Risks to safety of the ship 

7.1.1 The Group noted that specific countermeasures that can be employed in this system to 

deal with envisaged emergency and safety problems during the ballast water treatment have been 

developed by the Applicant. However the Group strongly recommended that the provisions of 

the IMDG Code are followed as far as is practical and that the guidance provided in the IMO 

“Guidance to ensure safe handling and storage of chemicals and preparations used to treat ballast 

water and the development of safety procedures for risks to the ship and crew resulting from the 

treatment process” is also fully taken into account. 

7.2 Risks to the crew and general public 

7.2.1 The Group considered that the Ecochlor® BWMS does not pose an unacceptable risk to 

ships’ crew (BWMS operators included) and to the general public regarding the exposure to 

chemicals and treated ballast water, based on the measures developed by the Applicant for 

installation on board ship. 

7.3 Risks to the environment 

7.3.1 The Group considered that the proposed MADC for chlorine dioxide, chlorite ion and 

chlorate ion, which can be measured as part of the TRO, are significant in the evaluation of risks to 

the environment. The Group previously recommended that a discharge concentration 

of 0.1 mg/L to 0.2 mg/L TRO (as Cl2) should be the maximum allowable discharge concentration 

(MADC). These chemicals are all oxidants and therefore the MADC is significantly exceeded in this 

case. Hence, the Group was not satisfied that treated ballast water discharge will not present 

unacceptable risks to the aquatic environment from these chemicals when discharged 24 hours after 

treatment, following use of this BWMS. Based on these concentrations, the Group is not able to 

recommend Final Approval for the Ecochlor® BWMS as presented. 
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7.4 Recommendation 

7.4.1 In conclusion, having reviewed all the information provided by the Applicant, the Group 

could not recommend to the MEPC that Final Approval be granted to the Ecochlor® BWMS. 

7.4.2 The Group noted that the following points should be given attention by the Applicant in 

support of any further application for Final Approval in the future: 

.1 The proposed MADCs for chlorine dioxide, chlorite ion and chlorate ion 

significantly exceed the discharge concentration of 0.1 mg/L to 0.2 mg/L TRO 

(as Cl2) previously recommended by the Group. 

 .2 To provide certainty for environmental safety, monitoring and control of the 

discharge should be incorporated to ensure that the finally agreed MADCs for 

all Active Substances and Relevant Chemicals are not exceeded. 

.3 The provisions of the IMDG Code should be followed as far as is practical and the 

guidance provided in the IMO “Guidance to ensure safe handling and storage of 

chemicals and preparations used to treat ballast water and the development of 

safety procedures for risks to the ship and crew resulting from the treatment 

process” should also be fully taken into account. 

.4 Further attention to procedures and risk mitigation measures applying to BWMS 

maintenance or chemical replenishment operations on board the ship. 

.5 Additional corrosion testing should be conducted in accordance with the guidance 

provided in document MEPC 59/2/16, section 5.1. 

 .6 A more detailed description of arrangements to be put in place for fire mitigation 

measures. 

* * * 
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APPENDIX 

PROPERTIES OF ACTIVE SUBSTANCE, RELEVANT CHEMICALS, OTHER 

CHEMICALS AND TREATED BALLAST WATER 

1 CHEMICAL ANALYSIS OF TREATED BALLAST WATER FROM 

LAND-BASED TESTING 

1.1 THMs 
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1.2 HAAs
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2 WATER QUALITY DATA FROM LAND BASED TESTING 

2.1 Brackish Water 
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2.2 Seawater 
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3 AQUATIC ECOTOXICITY TESTING METHODS EMPLOYED 
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4 AQUATIC RISK ASSESSMENT OF CHEMICALS 

4.1 Acute Ecotoxicity 
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4.2 Chronic Ecotoxicity 
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5 AQUATIC ECOTOXICITY TESTING OF TREATED BALLAST WATER FROM 

LAND BASED TESTING 

5.1 Acute Ecotoxicity 
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5.2 Chronic Ecotoxicity
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6 PBT CLASSIFICATION 

***
GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

ANNEX 6 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

SiCURETM Ballast Water Management System 

Submitted by Germany for Basic Approval 

0 SUMMARY 

0.1 Having reviewed all the data and information submitted by Germany with the application 

for Basic Approval and the information received from the Applicant during the 

GESAMP-BWWG meeting, the Group recommended to MEPC that Basic Approval be granted 

to SiCURETM Ballast Water Management System. 

0.2 The Group noted that the Siemens Water Technologies Ballast Water Management 

System (BWMS) uses a combination of filtration and on-demand in situ electrolysis of seawater 

to produce the Active Substance sodium hypochlorite to treat the ballast water, without the 

addition or mixing of any other chemicals. The Group noted that ballast water is treated on 

uptake only. The Siemens SiCURETM BWMS utilizes Chloropac, Concentric Tube Electrode 

(CTE) Technology to produce hypochlorite to provide disinfection of ballast water. 

Hypochlorite is generated and dosed to the ballast water to achieve a pre-determined oxidation 

reduction potential (ORP) which the Applicant states will result in a maximum allowable dose 

of 6 mg/L (TRO as Cl2). 

0.3 The Group noted that the treatment dosage of 6 mg/L (TRO as Cl2) was determined on 

the basis of the amount needed to achieve the Applicant required ORP for treatment efficacy 

utilizing waters from NIOZ. However, the Group considered that higher treatment concentrations 

may result when ballast waters having different organic loadings are treated. The Group further 

considered that on the basis of calculated dosage concentrations and treatment capacity volumes, 

the maximum calculated concentration may be 8.3 mg/L TRO (as Cl2). The Group recommended 

that this issue should be further clarified in any future application for Final Approval, which may 

include control system logic to verify the Applicant’s claims. 

0.4 The Group noted the requirement stated by the Applicant, for use of the SiCURETM

system to be restricted to those ships operating only in salt or brackish water. The Group 

recommended that the lower limit of salinity for operation of the system should be defined by 

the Applicant for Final Approval. 

0.5 As the BWMS does not require the storage of chemicals on board ship, the Group 

recognized that there will not be any associated storage safety problems. 

0.6 The Group recognized that the system utilizes an Active Substance and produces 

Relevant Chemicals and Other Chemicals with potential safety and environmental concerns and 

the Group has reviewed the hazards and risks associated with all these chemicals. 
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ANNEX 6 

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0.7 The Group recognized that the Applicant has provided detailed information on system 

controls and safety considerations for installation of the Siemens SiCURE BWMS on board ship, 

together with provisions for maintenance and emergency operations of the system. As such 

the Group considered that this information provided by the Applicant is sufficient to allow 

the Group to recommend Basic Approval. The Group recommended that an application 

for Final Approval of this system should include confirmation by testing, utilizing the guidance 

provided in section 5.1 of MEPC 59/2/16, that there will be no unacceptable risks to the safety of 

the ship from corrosion by treated ballast water.

0.8 In addition, the Group noted the provision by the Applicant of some analytical results for 

the Active Substance, Relevant Chemicals and Other Chemicals in treated ballast water. As such 

the Group considered that this information provided by the Applicant in the submitted dossier is 

sufficient to allow the Group to recommend Basic Approval. The Group recommended that an 

application for Final Approval of this system should include confirmation by further testing, that 

there will be no unacceptable risks (to ship safety, human health or the environment) due to the 

chemical composition of ballast water treated by this BWMS. The Group noted that 

the Applicant had acknowledged that the list for Relevant Chemicals may be incomplete and will 

be thoroughly investigated during land-based and shipboard testing for Final Approval. 

0.9 The Group noted the information submitted by the Applicant on human health assessment 

that includes occupational exposure to ships’ crew, BWMS operators and the exposure of the 

general public via the environment and the food chain. The Group found the information 

provided by the Applicant to address occupational risk useful although the route of exposure 

chosen by the Applicant was not considered by the Group to be the most appropriate to address a 

realistic exposure scenario. The Group recommended for Final Approval that inhalation and 

dermal routes should be considered by the Applicant as the Group believes these to be more 

appropriate in assessing the exposure of crew and BWMS operators. 

0.10 The Group recognized that the Applicant has provided information on environmental risk 

assessment for aquatic organisms and has proposed a maximum allowable discharge 

concentration (MADC) for the Active Substance of 0.1 mg/L (TRO as Cl2) to be achieved using 

a minimum holding time. The Group considered that the Applicant’s proposed MADC for 

the Active Substance is acceptable, with the provision that a minimum holding time is 

determined and justified. 

0.11 The Group noted that the Applicant did not provide any information on ecotoxicity 

testing of the treated ballast water that is a stipulated requirement for Basic Approval. However, 

after deliberation, the Group considered that the treated ballast water discharge ecotoxicity 

results were not likely to be substantially different from those obtained from electrolytic systems 

previously considered by the Group and granted Final Approval by MEPC. Hence, the Group 

agreed to make an exception in this case and further agreed that the lack of submitted data could 

be overlooked in this particular Basic Approval assessment. The Applicant should provide the 

results of acute and chronic aquatic ecotoxicity testing of treated ballast water, in accordance 

with the full requirements of the “Procedure for approval of ballast water management systems 

that make use of Active Substances (G9)”, to be reviewed for Final Approval. 

0.12 The Group noted that the proposed system does not include either a discharge control 

point for TRO to ensure that the MADC is not exceeded, or a neutralization step. The Group 

recommended that such measures be fully considered in the application for Final Approval, 

regardless of any proposed minimum holding time for the treated ballast water. 
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0.13 The Group did not agree with the MAMPEC modelling for PEC values presented by the 

Applicant as the Group was not able to recalculate their results. The Group did not agree with the 

way the results were presented and noted that there are mistakes in some of the input values 

provided and due to the degradation rates employed, results for the calculated concentrations may 

be too optimistic. The Group also considered that it is not clearly described how the results in 

the application are achieved. Also in this regard, the Group emphasized that a more realistic 

estimation of the decay rate of Active Substance is required, as the modelling currently shows 

there will be an estimated risk if the half-life is more than 0.5 h. For Final Approval, the Group 

expected to receive a revised and corrected PEC calculation submission. 

0.14 The Group noted that the Applicant intends to conduct a comprehensive evaluation of 

corrosion effects and provides some background literature which indicates that corrosion rates 

may be increased based on this treatment technology. The Group recommended that 

comprehensive testing be conducted, taking into account the guidance in section 5.1 of the 

“Report of the eighth meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16. 

0.15 In conclusion, having reviewed all the information submitted by Germany in the 

application for Basic Approval and the information supplied by the Applicant in response to 

questions posed by the Group during this GESAMP-BWWG meeting, the Group agreed to 

recommend to the MEPC that Basic Approval be granted to the Siemens SiCURETM BWMS. 

The Group recommended that in any future submission for Final Approval of this BWMS, the 

recommendations given in this report are taken into account. 

1 INTRODUCTION

1.1 The data used to evaluate this system were extracted from that supplied by Germany in 

document MEPC 59/2/11 and in the confidential dossier, which was supplemented by additional 

information provided by the Applicant after a request for further information by the Group during 

its meeting. 

2 COMPLETENESS OF DOSSIER AND APPLICANT RESPONSES TO DATA 

REQUESTS FROM THE GROUP

2.1 During the GESAMP-BWWG meeting, the Group posed nine questions to the Applicant 

on issues it felt needed further clarification in order to complete the evaluation 

for Basic Approval. The Group’s questions (in bold text), the Applicant’s responses (in plain 

text) and the reactions of the Group (in italic text) are noted below, in numerical order of the 

individual questions. 

Question 1: 

1 Can the Applicant confirm that based on electrolytic cell size and the appropriate 

DC power that the maximum available treatment dosage is 8.3 mg/L TRO (as Cl2)? 

Response 1: 

.1 The Siemens SiCURETM Ballast Water Management System is designed to deliver 

a maximum treatment dosage of 6 mg/L. The output from an electrolytic cell is 

proportional to the DC current. The Siemens SiCURETM BWMS is designed to 

deliver a maximum treatment dosage of 6 mg/L. This is achieved by limiting the 

current output of the transformer/rectifier. 
GESAMP-BWWG 10/6 

ANNEX 6 

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The Group was not satisfied with this response, and still considered that on the basis of 

calculated dosage concentrations (300 mg/L), dosage flow rate (5.5 m3

/h), and treatment 

capacity volumes (200 m3/h), the maximum calculated concentration may be 8.3 mg/L TRO 

(as Cl2). The Group recommended that this issue should be further clarified in any future 

application for Final Approval, which may include control system logic to verify the Applicant’s 

claims. 

Question 2: 

2 The Group noted that the ORP control requires a certain ORP potential (mV) (data 

deemed to be confidential and removed at the request of the submitting Administration)

mV for adequate efficacy and that this ORP setpoint results in 5 mg/L using NIOZ 

test waters. Does the Applicant include a control or over ride mechanism for cases 

in which higher chlorine doses may be required to achieve the desired ORP 

setpoint? Additionally, what is the maximum possible dose 8.3 mg/L as discussed in 

the question above? 

Response 2: 

.1 If the ORP setpoint is not achieved during ballast water treatment, the system 

logic will require the system to provide a maximum treatment dosage of 6 mg/L. 

The Group noted that the treatment dosage of 6 mg/L (TRO as Cl2) was determined on the basis 

of the amount needed to achieve the Applicant required ORP for treatment efficacy utilizing 

waters from NIOZ. However, the Group considered that higher treatment concentrations may 

result when ballast waters having different organic loadings are treated. The Group 

recommended that this issue should be further clarified in any future application for 

Final Approval, which may include control system logic to verify the Applicant’s claims. 

Question 3: 

3 Does the Applicant plan to include a control point for TRO upon discharge or a 

neutralization step? 

Response 3: 

.1 The Applicant is still in a process of collecting information about TRO/TRC. 

At this point, Applicant plans do not include incorporation of the neutralization 

step. A need for the TRO control point upon discharge will be assessed upon 

completion of the land-based test program. 

.2 (Data deemed to be confidential and removed at the request of the submitting 

Administration.)

The Group considered that a control point or neutralization step is required to adequately ensure 

TRO in treated ballast water will not exceed the MADC. 
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Question 4: 

4 The Applicant does not provide any information about “Toxicity testing of the 

treated Ballast Water” described in paragraph 5.2 of Procedure (G9). Are there any 

additional information of the ecotoxicity testing performed against simulated Ballast 

Water Discharge? If not, are there any arguments that these tests can be skipped 

at Basic approval in this particular case? 

Response 4: 

.1 The eco-toxicity testing was not conducted during proof-of-concept testing at 

NIOZ. However, the Applicant has carried out intensive literature studies on 

toxicity for all TRO and DBP found in the water treated during the 

proof-of-concept testing. That review has indicated that there was no risk for 

maritime life when discharging ballast water after day 5. In discussions with the 

German environmental agency Umweltbundesamt, Siemens agreed to carry out 

additional acute and chronic toxicity tests for those substances that no toxicity 

data was found for in the open literature. These studies are being carried out at this 

time as well as the eco-toxicity testing for the land-based testing program, but to 

date the results are not yet available. The results will be included in the dossier for 

the Final Approval. 

The Group noted that the Applicant did not provide any information on ecotoxicity testing of the 

treated ballast water that is a stipulated requirement for Basic Approval. However, after 

deliberation, the Group considered that the treated ballast water discharge ecotoxicity results 

were not likely to be substantially different from those obtained from electrolytic systems 

previously considered by the Group and granted Final Approval by MEPC. Hence, the Group 

agreed to make an exception in this case and further agreed that the lack of submitted data could 

be overlooked in this particular Basic Approval assessment. The Applicant should provide the 

results of acute and chronic aquatic ecotoxicity testing of treated ballast water, in accordance 

with the full requirements of Procedure (G9), to be reviewed for Final Approval. 

Question 5: 

5 For the sake of confirmation, the Group would like to have a more detailed 

explanation of the steps involved in the human health exposure assessment exercise 

done by the Applicant. This relates especially to the use of the modification factor 

of 7,300, the information presented in the Table 8.2.3-1 (non-confidential version) 

and the implications in the risk-based considerations. Most particularly, the Group 

need to be clarified about the values presented in the column “Water Source 

Concentration (mg/L)”. 

Response 5: 

.1 Standard risk assessment practice involves characterizing potential human 

exposure to chemical substances in the environment either qualitatively or 

quantitatively. In order to assess the potential health risk posed by the chemicals 

present in the SiCURETM BWMS, it was necessary to evaluate a hypothetical 

scenario by which a human receptor is exposed, including the specific exposure 

pathways (e.g., ingestion, dermal, inhalation) and the intensity of the exposure. 
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.2 Because of the numerous safety features inherent in the SiCURETM BWMS, 

which are described in detail in the dossier, it is highly unlikely that human 

exposure will occur. However, in order to quantitatively evaluate potential health 

risk, it was assumed that a ship technician comes into occasional contact with the 

treated ballast water. Because the primary exposure route of potential concern is 

incidental ingestion, use of guideline values that are considered safe for drinking 

water exposures are an appropriate benchmark for comparison with appropriate 

adjustment for the lower site-specific exposure that could occur for exposure to 

treated ballast water. The drinking water guideline values are assumed to be safe 

for all potential routes of human exposure, including dermal contact and 

inhalation, as well as ingestion. Therefore, their use, with adjustment to account 

for a lower intake rate and exposure frequency, is an appropriate method for 

estimating the potential health risk to a ship’s technician. The adjustment of the 

drinking water guideline values by factor of 7,300 is described in section 8.2.2 of 

the dossier. In summary, the exposure assumptions inherent in the derivation of 

the safe drinking water guideline values is that someone ingests 2 liters of water 

every day for a lifetime. As described in section 8.2.2 of the dossier, it is assumed 

that a technician performing maintenance of the SiCURETM BWMS may 

inadvertently ingest a small amount of treated ballast water (i.e. a mouthful 

or 0.01 liters). Because regular maintenance of the system is not required, it was 

conservatively assumed that the technician would be exposed 10 days per year. 

These site-specific exposure assumptions were used to modify the drinking water 

exposure assumptions of 2 liters and 365 days per year as shown in section 8.2.2 

of the dossier. 

.3 The resulting modifying factor of 7,300 was then multiplied by the drinking water 

guideline values presented in Table 8.2.3-1 to derive the concentrations shown in 

the column called “Risk-Based Criteria Based on Likely Exposure Scenario”. 

As shown in this table, the concentrations of Chemicals of Potential Concern 

(COPCs) in treated ballast water are all well below the risk-based concentrations. 

In fact, exposures as much as 1000-fold greater would still be acceptable. For 

example, several mouthfuls of the water could be consumed every day and there 

would still be no adverse health risks. As described in the dossier, potential health 

effects of the COPCs vary depending on route of exposure and dose, and include 

eye and skin irritation, kidney and liver effects, reproductive effects, and for two 

COPCs, potential carcinogenicity. However, based on the human health risk 

assessment performed using available toxicity information, and accounting for a 

site-specific exposure scenario, none of the potential adverse health effects 

associated with these COPCs are anticipated to occur. 

.4 The concentrations of COPCs in treated ballast water are presented in the Water 

Source Concentration column in Table 8.2.3-1. These concentrations were 

selected as typical for the treated water 24 hours and 120 hours after the treatment. 

The Group noted the information provided by the Applicant and found it useful to address the 

exposure risk of crew and BWMS operators. However the route of exposure chosen by the 

Applicant (ingestion), being the most unlikely to occur, was not considered by the Group to be 

the most appropriate to address a realistic exposure scenario. The Group recommended 

for Final Approval that inhalation and dermal routes should be used instead by the Applicant. 
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ANNEX 6 

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Question 6: 

6 The Group notes that there is a system requirement for a minimum holding time in 

the degas chamber of 5 minutes. Given that the ORP sensor, which provides a signal 

for the operational control of the electrochemical generator, is obviously in the main 

ballast line after injection, then this means there is a minimum time lag for chemical 

production adjustment of at least 5 minutes. Is this considered appropriate for 

dosage concentration control? 

Response 6: 

.1 The Applicant considers 5 minutes lag time due to the degas tank insignificant as 

the water quality is not expected to change dramatically within this time interval. 

The Applicant considers the 5 min time lag due to the degas tank insignificant for 

the process efficacy. It should be noted that the treatment with the 

Active Substance such as chlorine works both on impact (at a dosing 

concentration) and also in the ballast tank (at a residual biocide concentration). 

The Group accepted that provided the maximum dose rate as stated is maintained, then 

the 5 minutes time lag can be acceptable for this system. 

Question 7: 

7 The Group understands that chemical production is controlled by the ORP reading 

only. Is there any intention to provide TRO monitoring for added confidence? 

Response 7: 

.1 In polluted ports, use of TRO monitoring may have low value as biocides’ 

activity, not concentration, can be strongly influenced by pollutants. Siemens 

does not intend to add TRO monitoring. We believe that ORP control is the best 

measure of the system efficacy. Moreover, use of TRO monitoring may have 

limited value as biocides’ activity, not concentration, can be strongly influenced 

by pollutants. Same would apply to ports with clean water that has high pH 

(for example, in the Middle East). 

The Group was satisfied with this response, but the comments and recommendations of 

the Group to Question 2 above are also relevant here. 

Question 8: 

8 The Group notes that a secondary side stream provides a biocide dose downstream 

of the filter to provide an initial ballast water treatment. It is noted that the block 

diagram indicates the secondary side stream to be injected to the sea chest. Is there 

any monitoring or control of this biocide delivery system? It is normal for the sea 

chest to provide common supply to many other ship seawater services, how is the 

overboard discharge from these services to be ensured acceptable in port following 

this treatment? 
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Response 8: 

.1 We would like to apologize for the outdated block diagram. The purpose of the 

secondary side stream (here called BFC loop) is to provide a biofouling control to 

the filter and break up the colonies of marine organisms. This flow is now 

injected directly into the ballast water piping between the ballast water pump and 

the filter. It is monitored by flow. The biocide dosing level is quite low and 

practically no TRC is being found in the filter’s backwash flow. 

The Group noted that the problem identified is being addressed. 

Question 9: 

9 In the process of evaluating the SiCureTM Ballast Water Management System, one of 

the steps is to check the calculations performed with the MAMPEC model. Here we 

come across some difficulties as outlined below. 

.1 Input data and Environment definition: 

To our opinion these data are the same as used by you in your dossier. 

.2 Substance definition: 

Also these data are considered the same as you used in case of a half-life 

value of 1 day. 

.3 Emission definition: 

Here the most important thing is the total amount of TRO discharged into 

the harbour. We did not mind the specific distribution of the ships in the 

harbour. The value of 218350 g/d is achieved by multiplying the total volume 

discharged (397000 m3

/d) and the concentration after 24 hours (0.55 mg/L). 

.4 Conclusion: 

In the dossier the following results are mentioned for average, minimum and 

maximum concentration, respectively: 1.08E-2, 2.23E-3 and 1.93E μg/L. The 

results are a factor of about 250 higher. 

Could you see any mistake in the calculations performed above or is there an 

explanation for these differences? We would appreciate your views on this. 

Response 9: 

.1 We assume that having provided the average, maximum and minimum PEC 

of 1.08E-2, 2.23E-3 and 1.93E μg/L, the GESAMP-BWWG were referring to the 

Table 7.3.3-1 in the Siemens’ application dossier for a half-life of 24 hours. 

.2 Please note that this table provides results of MAMPEC calculations for a single 

ship in the port of Rotterdam. Therefore, the total amount of emissions used in 

the calculations should be at 2,729 (twenty seven hundred twenty nine) g/day for a 
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ANNEX 6 

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discharge 24 hours after treatment. Therefore, the average PEC 

of 2.4 microgram/L shown in the GESAMP-BWWG’s example should be reduced 

by a factor of 80, that is 3.0E-2. Still, there is a difference by a factor of 

about 2.8. 

.3 The MAMPEC specialist who was involved in the modelling per Siemens’ 

request, provided us with an additional information that indicates that in our 

calculations all three types of the degradation routes were used: abiotic, 

photolytic and biological – please see the picture below for half-life of 48 hours. 

The consultant also noted some differences in other input parameters. 

.4 Solubility of NaOCl at 23°C: 942 g·L-1 = 9.42 * 10^5 g/m3 and not 9.42 * 102. 

23 hPa is 23E+3 Pa and not 2.3E+1; the estimated Henry’s constant is then 0.182 

and not 0.0182. 

Although the Group appreciated the thorough analysis of the PEC at different half-lives in 

the Rotterdam harbour using MAMPEC, the Group did not agree with the way the results were 

presented. Therefore, the Group did not consider the response of the Applicant to this question 

as sufficient because: 

.1 There are mistakes in the input values provided: saturated vapour pressure is 

reported to be 23 Pa (dossier) whilst later in the correspondence a value 

of 23 hPa was described. 

.2 The degradation rate was considered to apply for all three degradation 

pathways, abiotic, photolytic and biological. This is not clearly reported in the 

dossier. The result is that as the rates of these processes may be added if first 

order kinetics apply, the final resulting degradation for all three process is higher, 

in this case a factor of 3 giving a rate constant for all processes together of 0.33. 

This gives a too optimistic result for the calculated concentration. 

.3 It is not clearly described how the results in the application are achieved. It is 

suggested by the Group to report results of MAMPEC calculation for TRO 

according to the output screens of MAMPEC. In this way there is no doubt which 

input and output parameters were used or achieved. 

The Group was not able to recalculate the results of the Applicant. For Final Approval 

the Group expects to receive a PEC calculation submission with all the above points addressed 

and mistakes corrected. 

2.2 Having reviewed all the data and information submitted by Germany for Basic Approval 

and the additional information supplied by the Applicant in response to questions posed by 

the Group during this GESAMP-BWWG meeting, the Group recommended to MEPC 

Basic Approval for the BWMS. The Group made the following recommendations, if this system 

is to be reviewed for Final Approval in the future: 

.1 The Group recommended that comprehensive corrosion testing be conducted, 

taking into account the guidance in section 5.1 of the “Report of the eighth 

meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16. 
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ANNEX 6 

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.2 The Group recommended that confirmation should be obtained from analytical 

results for the Active Substance, Relevant Chemicals and Other Chemicals in 

treated ballast water, that there will be no unacceptable risks (to ship safety, 

human health or the environment) in the chemical composition of treated ballast 

water caused by the use of this BWMS. 

.3 In accordance with the requirements of Procedure (G9), the Group recommended 

that acute and chronic aquatic ecotoxicity testing of treated ballast water should be 

performed. 

 .4 The Group recommended that the maximum treatment dosage of 6 mg/L stated by 

the Applicant should be further clarified and confirmed, particularly when ballast 

waters with different properties are treated by the system. This may include 

control system logic to verify the Applicant’s claims. 

.5 The Group recommended that an environmentally safe minimum holding time for 

treated ballast water is determined and justified. 

.6 The Group noted that the proposed system does not include either a discharge 

control point for TRO to ensure that the MADC is not exceeded, or a 

neutralization step. The Group recommended that such measures be fully 

considered, regardless of any proposed minimum holding time for the treated 

ballast water. 

.7 The Group recommended that the lower limit of salinity for operation of the 

system should be defined by the Applicant. 

.8 The Group recommended that inhalation and dermal routes of exposure should be 

considered by the Applicant as the Group believes these to be more appropriate in 

assessing the exposure and occupational risk of crew and BWMS operators. 

 .9 The Group recommended that a more realistic estimation of the decay rate 

(half-life time) of Active Substance in treated ballast water should be defined by 

the Applicant. 

.10 The Group recommended that a revised submission of MAMPEC modelling for 

PEC values should be produced, with all the above-mentioned points addressed 

and mistakes corrected. 

3 DESCRIPTION OF THE SYSTEM

3.1 Working Principles of the BWMS 

3.1.1 Overview 

3.1.1.1 The Group noted that the Siemens Water Technologies SiCURETM BWMS utilizes 

proven technology to disinfect ballast water with Active Substance sodium hypochlorite 

(NaOCl). The BWMS under consideration for Basic Approval produces sodium hypochlorite 

on-demand in situ, by electrolysis of seawater, utilizing the Siemens Concentric Tube Electrode 

(CTE) technology to produce NaOCl and inject the Active Substance into the ballast water 

intakes. This technology is well known in the maritime industry under trademark Chloropac. 
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The Group noted that disinfection with Active Substance is combined with filtration (40 micron) 

of the ballast water, and that the BWMS only treats ballast water upon uptake. Furthermore, 

the Group noted that Figure 1 schematically shows the BWMS being reviewed for 

Basic Approval. 

 Ballasting 

Î Î Î 

 De-ballasting Í

Figure 1 – Schematic process diagram of BWMS 

3.1.1.2 The Group recalled that sodium hypochlorite is also referred to as Free Available 

Chlorine (FAC) and is determined as TRO (expressed as mg Cl2/L). In the BWMS under 

consideration, the Applicant states that the Active Substance is applied at up to the maximum 

allowable dose of 6 mg/L (as TRO Cl2) into the ballast water with a minimum level 

of < 0.1 mg/L, which has been proposed by the Applicant as the MADC for the system. 

The Group noted that according to the Applicant, the production of the Active Substance by 

electrolysis is controlled by measuring the oxidation-reduction potential (also known as redox 

potential or ORP) of the ballast water being treated. 

3.1.1.3 The Group noted the requirement stated by the Applicant that the SiCURE system 

should be limited to those ships that meet the following criteria: 

- operate only in salt or brackish water; and 

- do not operate only in fresh water. 

The Group considered that this requirement will need to be confirmed by the Applicant for 

Final Approval. 

3.1.1.4 As the BWMS does not require the storage of chemicals on board ship, the Group 

recognized that there will not be any associated storage safety problems. 

3.1.2 Description of test system used for Basic Approval 

3.1.2.1 The Group noted that Active Substance is produced in situ in the electrochemical 

generator by using a 5.5 m3

/h (small capacity systems) or 11 m3/h (large capacity systems) side 

stream taken from the main ballast water intake. It is then cleared of the entrained by-products 

hydrogen gas and oxygen gas in the degas tank (where it remains for a minimum of 5 minutes) 

which are safely vented overboard, and immediately injected into the ballast water. While the 

flow of the side stream is maintained constant, the concentration of Active Substance in this flow 

is varied by the current drawn through the electrochemical cells which are arranged in series. 

Filtration Electrolysis 

Ballast 

Water 

Tanks 
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The Group noted that the BWMS is not based on a fixed Active Substance dose; it is based on 

variable dosing necessary to achieve a certain oxidizing power of the treated water – its ORP. 

The Group also noted that while the Applicant indicates a maximum allowable dose of 6 mg/L, 

the Group calculated the maximum possible dosage of the system as 8.3 mg/L TRO (as Cl2) 

given that the concentrated dose may be as high as 300 mg/L TRO (as Cl2) with a minimum rated 

volume of the system of 200 m3/h. 

3.1.2.2 The Group noted that the tests conducted in the laboratory using seawater from 

the North Sea off Texel Island, the Netherlands show that the required ORP can be achieved with 

an Active Substance dose not exceeding 6 mg/L, most likely within the 2 mg/L to 6 mg/L range. 

The Applicant plans that the land-based and shipboard testing programme for Final Approval will 

show if the maximum concentration of 6 mg/L can be lowered and the output of 

the SiCURETM BWMS will be adjusted accordingly. However, the Group considered that the 

proposed control system may result in concentrations higher than 6 mg/L since such doses are 

possible and may be necessary to achieve the required ORP with different organic loads than 

were present in NIOZ water. 

3.1.2.3 The Applicant informed that dosing of the Active Substance will be split about 10 to 1 

between the disinfection and filter biofouling control injection streams using preset flow control 

valves. Therefore, a typical dose range for disinfection will be between 2.0 mg/L and 5.5 mg/L, 

while a typical dose range for filter biofouling control will be at 0.2 mg/L to 0.5 mg/L. Required 

dosing will be determined based on an ORP reading and controlled by Programmable Logic 

Controller (PLC) to reduce or increase current drawn from the transformer-rectifier to the 

electrochemical generator as necessary. The Group assessed the effect of the side stream dosage 

to the filter and considered this to be insignificant with regard to environmental concern for the 

back-flush function. 

3.1.2.4 The Group noted that according to the Applicant, the BWMS can accommodate any 

ballast water capacity; a singular system will be designed for a ballast water flow from 200 m3/h 

to 3,000 m3/h. 

3.2 Safety and control 

3.2.1 The Group noted that according to the Applicant, the SiCURETM BWMS is controlled by 

a Siemens PLC, programmed to initiate operation when all the system permissives are satisfied. 

A Human-Machine Interface (HMI) is also provided which includes archiving capability. The 

system is designed to provide a safe mode of operation with a minimum involvement from the 

crew. The system includes all necessary instrumentation and controls. A System Control Panel 

includes PLC and all controls accessories for proper operation of the system. 

A communication module is included to connect to the ship’s bridge and relay process information. 

Also available to the bridge are start, stop and the emergency shutdown of the electrochlorination 

unit. The BWMS operation is linked to the start and stop of the ballast water intake. The instruments 

and control devices provided to monitor the process are listed in Table 1. 
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Table 1: Monitoring and control devices 

Device Purpose 

Monitoring Devices 

Differential Pressure 

Switch for the Filter 

Measure the pressure drop in the filtering basket. The unit will backwash 

automatically when a preset pressure differential is reached or is 

activated by a timer with preset flushing intervals. 

Flow Instrument for the 

filter backwash outlet 

Measure the backwash flow. 

Flow Instrument at 

generator inlet 

Measures flow of ballast water side-stream flow to the electrolyzer. 

Differential Pressure 

Switch for the generator 

Indicate any clogging of the chlorination cells. 

Leak detector for the 

generator 

Monitor any leak in the generator cells. 

Pressure Instrument at 

Air Blower Discharge 

Monitors air pressure when the blower is started. A low pressure 

indication will alarm and shut down the system. 

Flow Instrument at 

Degas Tank Vent 

Monitors air flow through the degas tank. A low flow indication will 

alarm and shutdown the system. 

Level Instrument for 

Degas Tank 

Monitor the hypochlorite solution level in the tank when the system is 

in operation. High- and low-level alarms are programmed for indication. 

At high level alarm the transformer rectifier and the inlet flow to the 

degassing tank are stopped. The hypochlorite dosing pump will continue 

to operate to bring down the level before shutting down. At low level the 

hypochlorite dosing pump will shut down. 

Flow Instrument for 

filter fouling control 

Measures flow of Active Substance upstream the filter. 

ORP Instrument Monitors ORP reading in the treated ballast water. 

Control Devices 

Failsafe Electronic and 

Pneumatic Valves 

Segregates SiCURE BWMS from the ship’s ballast water system in case 

of emergency such as a fire or a power loss. 

3.2.2 The Group noted that according to the Applicant, the SiCURETM BWMS will have a data 

acquisition system. PLC will collect and transmit to the data acquisition system those parameters that 

are vital for the reliable performance of the filtration and disinfection subsystems. The parameters 

will include differential pressure setpoint (backwash trigger), differential pressure and backwash 

duration for the filter and ORP setpoint, ORP value, DC current, DC voltage, electrochemical 

generator flow, differential pressure in the hydrogen degas tank – for the disinfection system. 

3.2.3 The Group noted that according to the Applicant, the instruments and equipment setup of 

the system will need to be in the ready state for it to begin operation. Any abnormal or alarm 

status will be indicated in the PLC. If any of the permissives is not ready to operate, an alarm 

will signal and will be logged in the alarm list. Information has been provided by the Applicant 

on the system’s common faults and the steps to resolve the condition. In addition, information 

has been provided to cover possible emergency events such as: 

.1 Measures for accidental release of Active Substance on board ship; and 

.2 Measures for marine environmental release. 
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3.2.4 The Group noted that according to the Applicant, operation of the SiCURE system is 

provided in a fully automated mode and requires minimum maintenance limited to: 

- inspecting all SiCURE equipment prior to operation and after ballasting is completed; 

- tightening any loose item in the system; 

- performing visual checks of the system in operation. Maintain system tidiness and 

ensure equipment is operating properly. Log any observation; 

- checking the ORP monitor as appropriate. Log extreme changes in reading; 

- checking the system data logger and examine the data recorded. Look for any 

variation; and 

- monitoring any abnormal alarm. 

3.2.5 The Group noted that according to the Applicant, the system’s mechanical equipment is 

composed of the following: 

- Automatic Backwash Seawater Inlet Filter with a Backwash Pump (if required); 

- Seawater Booster Pump (if required); 

- Electrochemical Generator; 

- Degassing Equipment; 

- Biocide Dosing Pump; 

- Bio Fouling Analyzer Booster Pump; 

- ORP Control Loop; and 

- Automatic and Manual Valves. 

The system’s electrical equipment iscomposed of the following: 

- Transformer/Rectifier; 

- System Control Panel; and 

- Motor Control Centre. 

3.2.6 The Group noted the following information provided by the Applicant: 

.1 In the event the seawater filter starts clogging and is required to be bypassed, raw 

seawater will be the supply for the SiCURE hypochlorite generator. Extended 

operation in this mode is not recommended as this will eventually result in 

clogging the generator cells resulting in an extensive clean-up of all the equipment 

before normal operation can commence. 
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.2 A separate strainer and a spare strainer basket are provided for the protection of 

the electrochlorination section of the system that will enable the user to finish 

ballasting. This electrochlorination strainer may experience frequent fouling and 

will need manual cleaning of the basket to keep its operation. When this happens, 

it will require shutting down the system for the time to replace the fouled strainer 

basket with the clean spare basket. One spare basket is available on board to keep 

the downtime to a minimum. Once the basket is replaced the system can 

commence operation. The defouled strainer basket will then be cleaned and will 

become the spare. 

3.2.7 In addition to the above information, the Group noted that the operation of the system 

results in the generation of hydrogen gas but the system includes a degas tank with air blowers 

and hydrogen gas detecting instrumentation to ensure that the hydrogen gas has been safely 

diluted with air prior to venting. Also, the electrochemical cells are housed in an enclosure that 

provides additional personnel protection. 

3.3 Chemical processes involved in the BWMS – Active Substance (AS), 

Relevant Chemicals (RC) and Other Chemicals (OC) 

3.3.1 The Group recalled the chemical reactions involved in the electrolysis of natural 

seawater. At the outlet of the electrochemical generator, seawater will contain several products of 

electrochemical reactions taking place at the anode and cathode surfaces. These are hypochlorous 

acid (HOCl) in equilibrium with hypochlorite ion (OCl-), hypobromous acid (HOBr) in 

equilibrium with hypobromous ion (OBr-), certain short-lived oxygenated chemical compounds 

and oxygen gas (O2) generated at the anode and hydrogen gas (H2) generated at the cathode. The 

Group also recalled that sodium hypochlorite is referred to as Free Available Chlorine (FAC) and 

is determined as TRO (expressed as mg Cl2/L). In the BWMS under consideration, the 

Active Substance is applied at up to the maximum allowable dose of 6 mg/L (as TRO Cl2) into 

the ballast water. 

3.3.2 The Group recognized that all short-lived and highly reactive oxygenated species, 

including hydrogen peroxide and ozone, present in the stream will decompose. For example, 

hydrogen peroxide will be reduced to water by free available chlorine and ozone will decompose 

into oxygen gas with chlorine acting as a catalyst. Therefore, these oxygenated species will not 

be considered as either Active Substance or Relevant Chemicals. In addition, hydrogen gas and 

oxygen gas are completely removed in the degas tank, and will not be considered further. 

3.3.3 The Group noted that the Applicant has provided analyses of treated ballast water 

for Active Substance, Relevant Chemicals and Other Chemicals as part of this application 

for Basic Approval. To date, Siemens has used two accredited laboratories for all 

analytical services: 

- Enviroscan Analytical Services, Rothschild, WI, United States; and 

- Underwriters Laboratories (UL), South Bend, United States. 

Enviroscan was responsible for analysis of trihalomethane (THM) and TOC and UL was 

responsible for analysis of haloacetic acid (HAA) and sodium bromate. All chlorine analysis was 

performed using HACH spectrophotometer and the HACH reagent kits. The analytical methods 

used for the Active Substance and Relevant Chemicals are listed in Table 2. 
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Table 2: Analytical Methods 

Chemical/ 

Parameter 

US EPA 

Method Description Method Reporting Limit* 

TOC 415.1 Combustion 0.5 mg/L 

TRO/FAC 330.5 DPD-colorimetric method 0 mg/L 

THM 524.2 Capillary column gas chromatography/

mass spectrometry 

Trichloromethane 0.4 μg/L 

Tribromomethane 0.2 μg/L 

Bromobichloromethane 0.4 μg/L 

Dibromochloromethane 0.2 μg/L 

HAA 552.2 Liquid extraction, derivatization and 

gas chromatography with electron 

capture detection 

Trichloroacetic acid 1.0 μg/L 

Tribromoacetic Acid 4.0 μg/L 

Dibromoacetic acid 1.0 μg/L 

Dichloroacetic acid 1.0 μg/L 

Monochloroacetic acid 2.0 μg/L 

Monobromoacetic acid 1.0 μg/L 

Sodium 

Bromate 

317.0 Ion chromatography with the addition 

of a postcolumn reagent for trace 

bromate analysis 

 1.0 μg/L 

*

 The indicated method report limits were demonstrated to be achievable, but depend on a sample matrix. 

3.3.4 In the case of Relevant Chemicals and Other Chemicals, the Group recognized that 

trihalomethanes (THM), haloacetic acids (HAA) and sodium bromate are disinfection 

by-products. A selected list of Relevant Chemicals is presented by the Applicant in Table 3 

below. Siemens acknowledges that the list for Relevant Chemicals may be incomplete at this 

point and will be thoroughly investigated during land-based and shipboard testing for Final 

Approval. Concentration levels of certain Relevant Chemicals presented in the table were 

obtained during laboratory tests with water from the North Sea (seawater) by simulating the 

SiCURETM BWMS, therefore, the data provided for fresh water are estimates only. Testing was 

carried out in collaboration with the Royal Netherlands Institute for Sea Research (NIOZ), Texel, 

the Netherlands. 
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Table 3: Potential Relevant Chemicals in the BWMS 

List of potential Relevant Chemicals produced in ballast water2

Concentration, 

μg/l 

Chemical Name Formula Molecular 

Weight 

CAS 

Number 

Fresh 

water1

Salt 

water 

(bio)degradation 

rate or half-life 

Trihalomethanes: 

Trichloromethane CHCl3 119.38 67-66-3 < 90 ND3 From no decay to 

28 days 

Dibromochloromethane CHBr2Cl 208.29 124-48-1 ND < 3 No decay 

Tribromomethane CHBr3 252.77 75-25-2 ND < 90 No decay 

Haloacetic acids: 

Dichloroacetic acid C2H2Cl2O2 128.94 79-43-6 < 30 < 3 > 60 days 

Trichloroacetic acid C2HCl3O2 163.39 76-03-9 < 33 ND > 60 days 

Dibromoacetic acid C2H2Br2O2 217.86 631-64-1 ND < 50 > 60 days 

Tribromoacetic acid C2HBr3O2 296.76 75-96-7 ND < 60 > 60 days 

Sodium Bromate NaBrO3 150.9 7789-38-0 ND < 80 > 60 days 

Note: 1 – Estimate. There were no tests performed to date with the fresh water. This will be addressed during 

land-based and shipboard testing. 

2

 – During land-based testing halogen acetonitrile compounds will be also included for analysis and be 

added to the list of potential Relevant Chemicals, if necessary. 

3

 – Indicates concentration below the analytical detection limits. See Table 2 for the detection limits. 

3.3.5 The Group recognized the preliminary nature of the data sets provided by the Applicant 

on the analysis of Active Substance, Relevant Chemicals and Other Chemicals in treated ballast 

water for Basic Approval. The Group recommended that the Applicant should thoroughly 

investigate these areas during land-based and shipboard testing for Final Approval. 

4 HUMAN HEALTH ASSESSMENT 

4.1 Considerations for risk assessment 

4.1.1 The Group noted that the Applicant assessed the toxicological hazards and potential 

human exposure associated with chemicals of potential concern generated by 

the SiCURETM BWMS, which include the Active Substance sodium hypochlorite and 

Relevant Chemicals such as chloroform, bromoform, dibromoacetic acid and bromate. 
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4.2 Assessment of exposure to ship’s crew 

4.2.1 The Group noted that under normal conditions the ship’s crew (including BWMS 

operators) would not be exposed to sodium hypochlorite and by-products in the treated ballast 

water unless there is a failure of the system or when performing service on the system. The risks 

associated with these scenarios are mitigated by numerous system safety measures (leak detection, 

hydrogen gas removal in the degas tank, equipment isolation, stray current protection, interlocks, etc.) 

and by following the use of appropriate personal protective equipment when performing 

maintenance and/or repair on the system. 

4.2.2 The Group noted that the Applicant developed a hypothetical exposure scenario based on 

the following assumptions: 

- a crew member exposed to ballast water for 10 events/year; 

- duration of exposure: max. 1 hour per event; 

- a typical incidental ingestion rate 0.01 L/h, (one-fifth of the amount ingested during 

swimming assumed by US EPA (US EPA, 1989). 

These factors were used to modify drinking water guidelines, which assumed daily ingestion of 

water at a rate of 2L/d. The following modification factor was calculated: 

7,300 10days/yr

365days/yr

0.01liter/day event

2liter/day × =

The resulting modification factor of 7,300 was then multiplied by the drinking water guideline 

values presented by the Applicant to derive the concentrations shown in the column called 

“Risk-based criteria based on likely Exposure Scenario”. The derived chemical concentrations 

were found to be below the threshold concentrations recommended by reliable international 

bodies. The concentration of chemicals in treated ballast water is presented. These concentrations 

were selected as typical for the treated water 24 and 120 hours after the treatment. 

4.2.3 The Group found this exercise useful although the chosen route of exposure by the 

Applicant (ingestion) was not the most appropriate to address a realistic occupational exposure 

scenario. The Group recommended for Final Approval that inhalation and dermal exposure 

routes are more adequate to assess the exposure of crew and BWMS operators. 

4.2.4 In addition, the Group recommended that precautionary measures e.g., by using personal 

protective equipment (PPE) should be followed when any operator enters the ballast tanks for 

inspection or for sampling operational procedures. 
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4.3 Exposure of general public through the environment and food chain 

4.3.1 The Group recalled that possible scenarios of exposure to the general public through the 

environment and food chain are limited to the following: 

Scenario 1: Oral exposure (through water drinking) of sea bathers and workers in the 

surrounding water areas; and 

Scenario 2: Oral exposure to the general public through the food chain (by way of 

marine foods). 

4.3.2 The Group considered that sea bathers in the harbour areas could potentially be exposed 

to ballast water released, however, concentrations in ballast water would be greatly diluted in the 

seawater to which bathers could be exposed. In addition, as discussed above, the measured 

ballast water concentrations of various chemicals were generally lower than their respective 

drinking water guideline values. Therefore, no adverse health effects would be expected from 

bathers exposed to diluted concentrations of these chemicals. 

4.3.3 The Group concurred with the Applicant that general public exposed via consuming 

seafood from the harbour area where the ballast water may be released is unlikely to be exposed 

to chemicals generated by the system due to low bioaccumulative potential (log Kow less than 4) 

and, consequently, would not be expected to persist in the food web. 

4.4 Conclusion on Human Health Assessment 

4.4.1 The Group considered that the semi-qualitative exposure assessment submitted by 

the Applicant makes possible to conclude that the operation of this BWMS poses no 

unacceptable risk to ships’ crew (BWMS operators included) and to the general public. 

5 RISKS TO SAFETY OF THE SHIP, ITS CREW AND THE GENERAL PUBLIC

5.1 Safety of the ship 

5.1.1 The Group noted that specific countermeasures that can be employed in this system to 

deal with envisaged emergency and safety problems during the ballast water treatment have been 

summarized above. In particular, a summary of the various safety measures developed by the 

Applicant is given above in section 3. 

5.1.2 The Group noted that the Applicant intends to conduct a comprehensive evaluation of 

corrosion effects and provides some background literature which indicates that corrosion rates 

may be increased based on this treatment technology. The Group recommended that 

comprehensive corrosion testing be conducted, taking into account the guidance in section 5.1 of 

the “Report of the eighth meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16. 

5.2 Safety of the crew 

5.2.1 The Group considered that risk to safety of the ships’ crew (BWMS operators included) 

by exposure to chemicals and treated ballast water is judged to be acceptable based on the 

measures developed by the Applicant for installation on board ship. A summary of the various 

safety measures developed by the Applicant is given above in section 3. The Group considered 
GESAMP-BWWG 10/6 

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that in this system, the risk to ships’ crew is judged to be appropriately managed based on the 

facts that the Active Substance is produced in situ as well as that system components are adopted 

that are expected to minimize the exposure risk of ships’ crew to chemicals and ballast water 

before and after treatment, through the exposure routes of concern assessed, as discussed above 

in section 4. 

5.3 Safety of the general public 

5.3.1 It was reasonably considered by the Group that the system has no unacceptable risk to the 

health of the general public in light of the outcome of the human exposure routes of concern 

assessed, as discussed above in section 4. 

6 ENVIRONMENTAL RISK ASSESSMENT 

6.1 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T) 

6.1.1 The Group noted that the Applicant has made a comprehensive listing of P, B and T 

criteria for the Active Substance and Relevant Chemicals found in the treated ballast water, with 

results being presented below and summarized in Table 4. 

6.1.2 In the case of persistence, the Group noted that the Active Substance (TRO, hypochlorous 

and hypobromous acids) is not persistent. All of the Relevant Chemicals are persistent 

using Procedure (G9) criteria of a half-life >60 days in marine water or >40 days in fresh water. 

6.1.3 In the case of bioaccumulation, the Group noted that none of the Active Substances or 

Relevant Chemicals is expected to bioaccumulate using Procedure (G9) criterion of a 

log Pow <3. 

6.1.4 In the case of toxicity, the Group noted that the chronic toxicity database in this dossier 

(see section 1 in the appendix of this report) indicates that none of the Active Substances appear 

to be toxic to fish (0.04 mg/L) and crustaceans (0.012 mg/L) based on a chronic NOEC criterion 

of <0.01 mg/L. The Active Substances may have the potential to be toxic to algae based on 

unacceptable OECD data when the chronic NOEC criterion of <0.01 mg/L is used. No chronic 

toxicity data were found for any trophic level exposed to hypochlorous acid or hypobromous 

acid. The Group noted that the chronic toxicity database shows for the Relevant Chemicals for 

which acceptable OECD chronic toxicity data are available (bromate and two THM) that these 

compounds are much less toxic than the Active Substances. For example, the bromate NOEC for 

algae is 8 mg/L which is almost 3 orders of magnitude above the <0.01 mg/L level set for 

the Active Substances. The chronic NOEC values for chloroform range from a low of 1.5 mg/L 

for fish up to 216 mg/L for algae. A 10 mg/L NOEC for algae exposed to bromoform is 3 orders 

of magnitude higher than the <0.01 mg/L level set for the Active Substances. No acceptable 

OECD chronic data were found for any of the four HAA under consideration for this dossier. 
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Table 4: PBT evaluation of Active Substance and Relevant Chemicals 

(as provided by the Applicant) 

Chemical (P) 

(Yes or No)

(B) 

(Yes or No)

(T) 

(Yes or No) 

Active Substance 

TRO No No Yes- Fish, crustaceans, and algae 

Hypochlorous acid No No Yes- Fish and Crustacean 

Hypobromous acid No No Yes- Based on the toxicity of 

hypochlorous acid 

FAC No No Yes- Fish data that did not meet 

OECD Guidelines 

Yes- Crustaceans data that did not 

meet OECD Guidelines 

Yes- Algal using spike tests data that 

did not meet OECD Guidelines 

Relevant Chemicals 

THM - Chloroform Yes No No- Fish, crustaceans, and algae 

THM -Dibromochloromethane Yes No No- Fish 

THM -Bromoform Yes No No- Fish, crustaceans, and algae 

HAA -Dichloroacetic acid Yes No No- Crustaceans and algae 

HAA -Trichloroacetic acid Yes No No- Fish, crustaceans, and algae 

HAA -Dibromoacetic acid Yes No Reliable data not found 

HAA-Tribromoacetic acid Yes No Reliable data not found 

Bromate Yes No No- Fish, crustaceans, and algae 

6.1.5 Based on these results, the Group concluded that these chemicals should not be classified 

as PBT-substances. 

6.2 Ecotoxicity testing of treated ballast water 

6.2.1 The Group noted that the Applicant did not provide any information on ecotoxicity 

testing of the treated ballast water that is a stipulated requirement for Basic Approval. However, 

after deliberation, the Group considered that the treated ballast water discharge ecotoxicity 

results were not likely to be substantially different from those obtained from electrolytic systems 

previously considered by the Group and granted Final Approval by MEPC. Hence, the Group 

agreed to make an exception in this case and further agreed that the lack of submitted data could 

be overlooked in this particular Basic Approval assessment. The Applicant should provide the 

results of acute and chronic aquatic ecotoxicity testing of treated ballast water, in accordance 

with the full requirements of Procedure (G9), to be reviewed for Final Approval. 

6.3 Risk assessments of chemicals for aquatic organisms 

6.3.1 Aquatic Ecotoxicity and Predicted No-Effect Concentration (PNEC) 

6.3.1.1 The Group noted that the Applicant has provided a comprehensive database of acute and 

chronic aquatic ecotoxicity data in the present dossier, for both the Active Substance and 

Relevant Chemicals. According to the Applicant, the data were selected to conform where possible 

to the relevant OECD Guidelines, for fish, crustaceans, and algae, respectively. In some cases 
GESAMP-BWWG 10/6 

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toxicity data could not be found that followed the OECD Guidelines. Thus, some toxicity data 

were taken that utilized other acceptable test procedures. In addition, selected data that did not 

meet OECD Guidelines or other accepted testing procedures were included to provide an indication 

only of potential toxicity. The data provided are the lowest toxicity values found in the literature 

for each of the test substances for fish, crustaceans and algae (see section 1 in the appendix of 

this report). 

6.3.1.2 The Group recognized that ecological risk of the Relevant Chemicals to aquatic 

organisms is less clear than the risk from the Active Substances because much less chronic 

NOEC toxicity data are available. Sufficient chronic data are available for chloroform only to 

conclude that the compound should not be a risk to predators, consumers, and plants because all 

of the NOEC values are 2-3 orders of magnitude above 0.01 mg/L. Because of the lack of a 

complete chronic database, the acute ecotoxicity database of the Relevant Chemicals provides 

additional data which may be used to assess ecological risk to fresh water and saltwater 

organisms (see section 1 in the appendix of this report). 

6.3.1.3 The Group accepted that the following PNEC values were obtained using the assessment 

factors given in Table 2 of “The Methodology for the information gathering and the conduct of 

work of the GESAMP-BWWG” (IMO, 2008) – see Table 5 below. 

Table 5: Predicted No-Effect Concentration (PNEC) for the Active Substance and 

Relevant Chemicals in Fresh water and Saltwater 

Chemical PNEC 

(μg/L) 

Factor 

Applied 

Comment(s) 

Active Substances 

TRO 0.04 N/A EU PNEC of 0.04 μg/L for HOCl was 

used because the value is more 

conservative than TRO 

HOCl 0.032 1,000 Lowest HOCl L(E)C50 from a fish, 

crustacean and alga 

Relevant Chemicals 

Bromate 8 1,000 Lowest L(E)C50 from a fish and alga 

THM -Chloroform 15 100 Lowest L(E)C50 and NOEC from a fish, 

crustacean, and alga 

THM -Bromoform 12 1,000 Lowest acute data from a fish, 

crustacean, and an alga 

THM -Dibromochloromethane 15 N/A Insufficient data; thus, aquatic PNEC 

taken from page 96 in EU (2007) 

HAA -Dichloroacetic acid 0.72 N/A PNEC taken from page 96 in EU (2007) 

HAA -Trichloroacetic acid 0.85 N/A PNEC taken from page 96 in EU (2007) 

HAA -Dibromoacetic acid 0.72 N/A PNEC was assumed to be the same value 

as that for dichloroacetic acid which was 

taken from page 96 in EU (2007) 

HAA -Tribromoacetic acid 0.85 N/A PNEC was assumed to be the same value 

as that for trichloroacetic acid which was 

taken from page 96 in EU (2007) 
GESAMP-BWWG 10/6 

ANNEX 6 

Page 23 

I:\MEPC\60\2-11.doc 

6.3.2 MAMPEC Modelling and Predicted Environmental Concentration (PEC) 

6.3.2.1 The Group noted that the Applicant had employed the MAMPEC model in this 

application for Basic Approval to calculate PEC values of Active Substance and 

Relevant Chemicals in the harbour water after discharge of treated ballast water – see section 2 in 

the appendix of this report for further details including parameterization of the model. As a worst 

case scenario, it was assumed in the model that all TRO is composed of HOCl (as sodium 

hypochlorite). PEC values of Relevant Chemicals were calculated based on a dilution factor 

determined during the MAMPEC simulation. For modelling of various environmental scenarios, 

a wide range of the half-life of TRO was used, from seconds to days. The measurements in the 

treated ballast water during preliminary tests revealed the following concentrations of TRO in the 

tank: 

start 5.60 mg/L 

after 24 hours 0.55 mg/L 

after 48 hours 0.36 mg/L 

after 72 hours 0.23 mg/L 

after 96 hours 0.21 mg/L 

The following discharge TRO concentrations were used in calculations: 

- 0.13 mg/L : a concentration observed in treated water 120 hours after treatment; 

 and 

- 0.55 mg/L : a concentration observed in treated water 24 hours after treatment. 

Further, the Group noted it was assumed by the Applicant that 1, 10 or 80 ships are present in the 

harbour and that all ships are equipped with the SiCURETM BWMS with the water characterized 

by the same holding time (TRO level). It was assumed by the Applicant that there were 80 ships 

anchored in the Port of Rotterdam on an average day, discharging 397,000 m3/d or 

about 16,540 m3

/h of treated ballast water into the harbour. These numbers for the Port 

of Rotterdam were used in the publicly available dossiers of other BWMS developers and it 

would be reasonable to maintain the same scenarios in the current calculations. For all runs 

of MAMPEC, the OECD-EU commercial harbour was chosen with the default settings given 

by MAMPEC. (See section 2 in the appendix of this report for further details.) 

6.3.2.2 The Group noted the final results of the PEC values of Active Substance TRO for the 

worst case scenario of 80 ships in the harbour are summarized in Table 6 below for the wide 

range of half-life values. 

Table 6: Summary of PEC calculations for 80 ships for Active Substance TRO 

(sodium hypochlorite) 

TRO in Treated Water, Maximum PEC, μg/L at a Half-Life of 

mg/L 1 min 30 min 1 h 4 h 24 h 48 h 

0.55 (1 day holding time) 0.001 0.036 0.071 0.270 1.50 2.90 

0.13 (5 days holding time) 0.003 0.008 0.017 0.064 0.370 0.68 
GESAMP-BWWG 10/6 

ANNEX 6 

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I:\MEPC\60\2-11.doc 

6.3.2.3 The Group noted that PEC values of Relevant Chemicals for the worst case scenario of 

80 ships in the harbour are summarized in Table 7 assuming no decay, 90 times dilution factor 

and maximum discharge concentrations reported in the dossier. 

Table 7: Summary of PEC calculations for 80 ships for Relevant Chemicals 

Relevant Chemical PEC, μg/L 

Fresh water Salt water 

Trihalomethanes: 

Trichloromethane < 1 0 

Dibromochloromethane 0 < 0.03 

Tribromomethane 0 < 1 

Haloacetic acids: 

Dichloroacetic acid < 0.3 < 0.03 

Trichloroacetic acid < 0.4 0 

Dibromoacetic acid 0 < 0.56 

Tribromoacetic acid 0 < 0.67 

Sodium Bromate 0 < 0.7 

6.3.2.4 The Group noted that PEC values of TRO vary significantly depending on which value of 

the TRO half-life was selected as a model parameter. For a half-life less than 4 hours and discharge 

concentrations between 0.13 mg/L and 0.55 mg/L, the range of average PEC values was 

between 3.2E-6 μg/L and 2.7E-3 μg/L. For a half-life greater than 4 hours and discharge 

concentrations between 0.13 mg/L and 0.55 mg/L, the range of average PEC values was 

between 0.001 μg/L and 0.076 μg/L. Results show that in stagnant waters of the port (maximum 

values) the PEC values may peak at 2 to 3 times that of the average value. The Group 

emphasized that analysis of the data presented underscores the importance of a properly selected 

half-life value for the Active Substance and this parameter will need to be investigated by 

the Applicant for Final Approval. 

6.3.2.5 The Group did not agree with the MAMPEC modelling for PEC values presented by the 

Applicant as the Group was not able to recalculate their results. Although the Group appreciated 

the thorough analysis of the PEC at different half-lives in the Rotterdam harbour using 

MAMPEC, the Group did not agree with the way the results were presented. The Group noted 

that there are mistakes in some of the input values provided and due to the degradation rates 

employed, results for the calculated concentrations may be too optimistic. The Group also 

considered that it is not clearly described how the results in the application are achieved. It is 

suggested by the Group to report results of MAMPEC calculation for TRO according to the 

output screens of MAMPEC. In this way there is no doubt which input and output parameters 

were used or achieved. For Final Approval the Group expects to receive a PEC calculation 

submission with all the above points addressed and mistakes corrected. 
GESAMP-BWWG 10/6 

ANNEX 6 

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I:\MEPC\60\2-11.doc 

6.3.3 Risk to the aquatic environment – PEC/PNEC Ratios 

6.3.3.1 The Group recognized that potential risk to the aquatic environment is based on a series 

of PEC/PNEC ratios using a worst case scenario. The lowest PNEC found was for 

the Active Substance (TRO or HOCl), so therefore the MAMPEC model was run by 

the Applicant using HOCl which is more toxic than any of the Relevant Chemicals. As a worst 

case, the model was run using HOCl concentrations of 0.55 mg/L and 0.13 mg/L for holding 

periods of 24 hours and 120 hours in the ballast water tanks, respectively, following initial 

treatment of the ballast water at 5.6 mg/L NaOCl. Various half-lives from 0.0083 hours 

(30 seconds) up to 48 hours were used as estimates of the decay caused by chlorine demand. 

In addition, it was assumed by the Applicant that up to 80 ships were present in the 

Port of Rotterdam in any given 24-hour period. 

6.3.3.2 The Group noted that the Applicant presented the PEC/PNEC ratios for the average, 

minimum, and maximum concentrations of HOCl for 1 ship, 10 ships, and 80 ships in the 

Port of Rotterdam using the dilutions predicted by the MAMPEC model for various HOCl decay 

half-lives. The worst case HOCl PNEC of 0.032 μg/L (see Table 5 above) was used for the 

various half-life PEC/PNEC ratios. 

6.3.3.3 The Group emphasized that the results presented by the Applicant demonstrate that 

the PEC/PNEC ratios indicate that no aquatic risk (ratio <1) exists when one ship discharges 

treated ballast water after either 24 or 120 hours duration in a ballast holding tank, following an 

initial chlorination at 5.6 mg/L HOCl and the residual Active Substance is subsequently mixed in 

the Port of Rotterdam with decay half-lives ranging from 0.0083 hours to 48 hours. When 10 

ships discharge, no risk is predicted when ballast water has been initially chlorinated 

with 5.6 mg/L HOCl held in the ballast water tanks for 120 hours and subsequently discharged 

into the Port of Rotterdam at an average concentration of 0.13 mg/L with decay half-lives 

ranging from 0.0083 hours to 10 hours. No risk is predicted when ballast water has been initially 

chlorinated with 5.6 mg/L HOCl held in the ballast water tanks for 24 hours and subsequently 

discharged into the Port of Rotterdam at an average concentration of 0.55 mg/L with decay 

half-lives ranging from 0.0083 hours up to 3 hours. When 80 ships discharge, no risk is 

predicted when ballast water has been initially chlorinated with 5.6 mg/L held in the ballast water 

tanks for 120 hours and subsequently discharged into the Port of Rotterdam at an average 

concentration of 0.13 mg/L with decay half-lives ranging from 0.0083 to 2 hours. Risk is 

predicted for 80 ships at a half-life >0.5 hours when ballast water has been initially chlorinated 

with 5.6 mg/L HOCl, held in the ballast water tanks for 24 hours and subsequently discharged at 

an average concentration of 0.55 mg/L into the Port of Rotterdam. 

6.3.3.4 The Group noted it is expected by the Applicant that PEC/PNEC ratios for Relevant 

Chemicals will be below 1 (no aquatic risk) taking into account dilution factor of 90 that was 

calculated for 80 ships discharging in the port of Rotterdam and PNEC values listed in Table 5 

above. Thus, it is expected by the Applicant that Relevant Chemicals will not present risk to the 

aquatic environment. 

6.3.3.5 The Group concluded that Siemens have identified the Active Substance sodium 

hypochlorite (TRO) as the most toxic chemical in the treated ballast water and conducted an 

environmental risk analysis based on the PEC/PNEC ratios. These ratios were calculated for a 

“typical” European port such as the Port of Rotterdam using MAMPEC model and 

assuming 1, 10 or 80 ships in port, all equipped with the SiCURE BWMS and simultaneously 

discharging ballast water with the same holding time of 120 hours and 24 hours. The analysis has 

shown that PEC/PNEC ratio for TRO is strongly affected by the value of the half-life model 
GESAMP-BWWG 10/6 

ANNEX 6 

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parameter. When chlorine demand is taken into account (half-life times of less than 0.5 hour) 

PEC/PNEC ratios were calculated at less than 1 for the treated water with the holding time of 24 hours 

and 120 hours or more. When no chlorine demand is taken into account, (half-life times of greater 

than about 48 hours) PEC/PNEC ratios were calculated as greater than 1 for the treated water 

with the holding time of 24 hours and 120 hours. For one ship the PEC/PNEC ratios were 

calculated as less than 1 for practically all environmental scenarios. 

6.3.3.6 Finally, the Group concluded that the risk analysis for aquatic organisms has shown that 

during the land-based and shipboard testing for Final Approval, special attention has to be paid 

by the Applicant to identifying a realistic decay rate (half-life time) of the Active Substance in 

order to be able to calculate PEC with a greater level of certainty. 

6.3.3.7 In addition, the Group noted, as already indicated above, that it was not able to 

recalculate the results achieved by the Applicant in using the model MAMPEC. It is stressed, 

also in relation to point 6.3.3.6 that a more realistic estimation of the decay rate is required, as it 

currently shows there will be an estimated risk if the half-life is more than 0.5 hour. It is 

recommended that further PEC calculations are performed with more reliable input data when 

applying for Final Approval.

6.4 Holding time of treated ballast water 

6.4.1 The Group noted that the retention time of the ballast water treated with SiCURETM

BWMS has to be defined based on the Active Substance residual concentration in the treated 

water prior to its discharge into the environment. The tests conducted to date by the Applicant 

show that 5 days after the treatment, the Active Substance level is expected to be about 0.1 mg/L 

or less which is proposed by the Applicant as the maximum allowable discharge concentration 

(MADC). At this point, at least till the land-based tests are completed for Final Approval, the 

Applicant has stated that the retention time will stand at 5 days. Future tests performed by the 

Applicant will show if Active Substance residual concentration could be achieved at 

environmentally safe levels in a shorter retention time, preferably within 1 day to 3 days. 

6.4.2 The Group recommended that the Applicant should define the SiCURETM BWMS 

environmentally safe holding time for treated ballast water and provide this for review 

at Final Approval. 

6.5 Conclusion from environmental risk assessment 

6.5.1 The Group recognized that the Applicant has provided information on environmental risk 

assessment for aquatic organisms and has proposed a maximum allowable discharge 

concentration (MADC) for the Active Substance of 0.1 mg/L (TRO as Cl2) to be achieved using 

a minimum holding time. The Group considered that the Applicant’s proposed MADC for 

the Active Substance is acceptable, with the provision that a minimum holding time is 

determined and justified at Final Approval. The Group noted that the Applicant did not provide 

any information on ecotoxicity testing of the treated ballast water that is a stipulated requirement 

for Basic Approval. However, after deliberation, the Group considered that the treated ballast 

water discharge ecotoxicity results were not likely to be substantially different from those 

obtained from electrolytic systems previously considered by the Group and granted 

Final Approval by MEPC. Hence, the Group agreed to make an exception in this case and 

further agreed that the lack of submitted data could be overlooked in this particular 

Basic Approval assessment. The Applicant should provide the results of acute and chronic 

aquatic ecotoxicity testing of treated ballast water, in accordance with the full requirements 
GESAMP-BWWG 10/6 

ANNEX 6 

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of Procedure (G9), to be reviewed for Final Approval. The Group did not agree with 

the MAMPEC modelling for PEC values presented by the Applicant as the Group was not able to 

recalculate their results. The Group did not agree with the way the results were presented and 

noted that there are mistakes in some of the input values provided and due to the degradation 

rates employed, results for the calculated concentrations may be too optimistic. The Group also 

considered that it is not clearly described how the results in the application are achieved. Also in 

this regard, the Group emphasized that a more realistic estimation of the decay rate 

of Active Substance is required, as the modelling currently shows there will be an estimated risk 

if the half-life is more than 0.5 hour. For Final Approval, the Group expected to receive a revised 

and corrected PEC calculation submission. 

6.5.2 The Group concluded that Basic Approval could be recommended, but with several 

points to be addressed for Final Approval, as described above. 

7 CONCLUSIONS AND RECOMMENDATIONS

7.1 Risks to safety of the ship 

7.1.1 The Group noted that specific countermeasures that can be employed in this system to 

deal with envisaged emergency and safety problems during the ballast water treatment have been 

described and discussed above. 

7.1.2 The Group noted that the Applicant intends to conduct a comprehensive evaluation of 

corrosion effects and provides some background literature which indicates that corrosion rates 

may be increased based on this treatment technology. The Group recommended that 

comprehensive corrosion testing be conducted, taking into account the guidance in section 5.1 of 

the “Report of the eighth meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16. 

7.1.3 The Group considered that sufficient information had been provided by the Applicant 

addressing risks to the safety of the ship to allow the Group to recommend Basic Approval for 

the Siemens SiCURETM BWMS. 

7.2 Risks to the crew and general public 

7.2.2 The Group considered that the Siemens SiCURETM BWMS poses no unacceptable risk to 

the health of the crew and the general public regarding the exposure to chemicals and treated 

ballast water, based on the information that the Active Substance is produced in situ and on the 

measures developed by the Applicant for installation on board ship. As such, the Group was able 

to recommend that Basic Approval can be granted to the Siemens SiCURETM BWMS. 

7.2.2 The Group recommended for Final Approval that inhalation and dermal routes should be 

considered by the Applicant as the Group believes these to be more appropriate in assessing the 

exposure of crew and BWMS operators. 
GESAMP-BWWG 10/6 

ANNEX 6 

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I:\MEPC\60\2-11.doc 

7.3 Risks to the environment 

7.3.1 The Group concluded that based on the Applicant’s proposal for a MADC of 

the Active Substance, the preliminary information submitted on holding time and the Group’s 

evaluation of the information provided on environmental risk assessment of the Active Substance 

and Relevant Chemicals, together with other information provided in the dossier, the Group was 

able to recommend Basic Approval for the Siemens SiCURETM BWMS. 

7.4 Recommendation 

7.4.1 Having reviewed all the data and information submitted by Germany for Basic Approval 

and the information supplied by the Applicant in response to questions posed by the Group 

during this GESAMP-BWWG meeting, the Group was able to recommend Basic Approval for 

the Siemens SiCURETM BWMS. 

7.4.2 The Group had the following requests for information, if this system is to be reviewed 

for Final Approval in the future: 

.1 The Group recommended that comprehensive corrosion testing be conducted, 

taking into account the guidance in section 5.1 of the “Report of the eighth 

meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16. 

 .2 The Group recommended that confirmation should be obtained from analytical 

results for the Active Substance, Relevant Chemicals and Other Chemicals in 

treated ballast water, that there will be no unacceptable risks (to ship safety, 

human health or the environment) in the chemical composition of treated ballast 

water caused by the use of this BWMS. 

.3 In accordance with the requirements of Procedure (G9), the Group recommended 

that acute and chronic aquatic ecotoxicity testing of treated ballast water should be 

performed. 

 .4 The Group recommended that the maximum treatment dosage of 6 mg/L stated by 

the Applicant should be further clarified and confirmed, particularly when ballast 

waters with different properties are treated by the system. This may include 

control system logic to verify the Applicant’s claims. 

.5 The Group recommended that an environmentally safe minimum holding time for 

treated ballast water is determined and justified. 

.6 The Group noted that the proposed system does not include either a discharge 

control point for TRO to ensure that the MADC is not exceeded, or a 

neutralization step. The Group recommended that such measures be fully 

considered, regardless of any proposed minimum holding time for the treated 

ballast water. 

.7 The Group recommended that the lower limit of salinity for operation of the 

BWMS be defined by the Applicant. 
GESAMP-BWWG 10/6 

ANNEX 6 

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.8 The Group recommended that inhalation and dermal routes of exposure should be 

considered by the Applicant as the Group believes these to be more appropriate in 

assessing the exposure and occupational risk of crew and BWMS operators. 

 .9 The Group recommended that a more realistic estimation of the decay rate 

(half-life time) of Active Substance in treated ballast water should be defined by 

the Applicant. 

.10 The Group recommended that a revised submission of MAMPEC modelling for 

PEC values should be produced, with all the above-mentioned points addressed 

and mistakes corrected. 

* * * 
GESAMP-BWWG 10/6 

ANNEX 6 

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APPENDIX 

RISK ASSESSMENTS OF CHEMICALS FOR AQUATIC ORGANISMS 

1 Effects on Aquatic Organisms – Information used to Derive PNEC Values 

 (As presented by Applicant) 

Table A1: Acute aquatic toxicitya

Test 

Substance 

F 

C 

A 

Species Test Type 

LC50/ 

EC50

mg/L 

NOEC 

mg/L 

Reference/ 

Comments

Active Substances

F Oncorhynchus 

mykiss 15-d survival 0.059 N/A Fisher et al.

(1999) 

C Daphnia magna 48-h survivalb 0.032 N/A Fisher et al.

(1999) TRO (Freshwater) 

A Natural 

phytoplankton 

47-h change in 

Chla

c (<0.1) NA Brooks and 

Liptak (1977) 

F Menidia 

beryllina 96-h survival 0.143 N/A Fisher et al.

(1999) 

C Mysidopsis 

bahia 96-h survivald

 0.062 N/A Fisher et al.

(1999) TRO (Saltwater) 

A Dunaliella 

primolecta 24-h growthe (0.075) N/A Videau et al.

(1979) 

F Oncorhynchus 

mykiss 96-h survival 0.032 N/A Thatcher 

(1978)

C Americamysis 

bahia 7-d survival 0.144 N/A Fisher et al.

(1994) HOCl 

A Porphyra 

yezoensis 10-d growth 1.400 N/A Maruyama 

et al. (1988) 

F *) No data found 

in literature 

C *) No data found 

in literature HOBr 

A *) No data found 

in literature 

Relevant Chemicals 

F Morone 

saxatilis 96-h survival 31 N/A Richardson 

et al. (1981) 

C Neomysis 

awatschensis 24-h survivalg

 176 N/A Crecelius 

(1979) Bromate 

A *) No data found 

in literature 

F Lepomis 

macrochirus 96-h survival 14 N/A Anderson 

et al. (1979) 

C Artemia salina 24-h survivalg 30 N/A Foster and 

Tullis (1984) Chloroform 

A Scenedesmus 

subspicatus 48-h growthh

 (950) N/A Kuhn and 

Pattard (1990) 
GESAMP-BWWG 10/6 

ANNEX 6 

Page 31 

I:\MEPC\60\2-11.doc 

Test 

Substance 

F 

C 

A 

Species Test Type 

LC50/ 

EC50

mg/L 

NOEC 

mg/L 

Reference/ 

Comments

F Cyprinodon 

variegatus 96-h survival 18 2.9 Heitmueller 

et al. (1981) 

C Daphnia magna 48-h 

immobilization 46 N/A LeBlanc, G.A. (1980) Bromoform 

A Skeletonema 

costatum 

96-h growth 

inhibition 12.3 N/A U.S. EPA (1978) 

F Cyprinus carpio 

72- to 120-h 

egg fertilization 

to hatchi 

34 N/A Mattice et al.

(1981) 

C *) No data found 

in literature 

Dibromochloromethane

A *) No data found 

in literature 

F *) No data found 

in literature 

C Daphnia magna 24-h 

immobilizationj 106 N/A Trenel and 

Kuhn (1982) Dichloroacetic acid 

A *) No data found 

in literature 

F Pimephales 

promelas 96-h survival 2000 N/A Dennis et al.

(1979) 

C Daphnia magna 48-h 

immobilization 2000 N/A Dennis et al.(1979) Trichloroacetic acid 

A Chlorella 

pyrenoidosa 72-h growth N/A 500 Huang and 

Gloyna (1968)

F *) No data found 

in literature 

C *) No data found 

in literature Dibromoacetic acid 

A *) No data found 

in literature 

F *) No data found 

in literature 

C *) No data found 

in literature Tribromoacetic acid 

A *) No data found 

in literature 
GESAMP-BWWG 10/6 

ANNEX 6 

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F = Fish; C = Crustacean; A = Algae. 

*) Siemens will obtain data executing own toxicity tests for Final Approval 

a

 Data shown in parenthesis do not meet OECD Guidelines or other accepted testing procedures but were 

included to provide an indication only of potential toxicity. 

b Study did not meet the OECD 202 Guidelines because the test evaluated survival rather than immobilization at 48 h. 

However, the test did meet U.S. EPA regulatory test requirements (Test Method 2021.0) for measuring the acute 

toxicity of effluents and receiving waters to Daphnia magna (U.S. EPA, 2002a). c Study did not meet OECD 201 Guidelines because the test evaluated a change in chlorophyll at 47 h rather than 

growth at 72 h. 

d Study did not meet OECD guidelines because the test evaluated survival at 96 h rather than immobilization at 48 h. 

However, the test did meet U.S. EPA regulatory test requirements (Test Method 2007.0) for measuring the acute 

toxicity of effluents and receiving waters to Mysidopsis bahia (U.S.EPA, 2002a). e Study did not meet OECD 201 Guidelines because the test evaluated a growth at 24 h rather than growth at 72 h. 

g Study did not meet OECD 202 Guidelines because the test evaluated survival at 24 h rather than immobilization 

at 48 h. However, the test did meet U.S. EPA regulatory test requirements (Test Method 2002.0) for measuring 

the acute toxicity of effluents and receiving waters to a representative crustacean (U.S.EPA, 2002a). 

h Study did not meet OECD 201 Guidelines because the test evaluated growth at 48 h rather than growth at 72 h. 

i

 Hatching of the embryos varied from 72 to 120 h; thus, a definitive exposure period for the LC50 could not be 

established. Test did not meet OECD 203 Guidelines; however, the test did meet U.S. EPA regulatory test 

requirements (Test Method 1001.0) for measuring the chronic toxicity of effluents and receiving waters to a 

freshwater fish (U.S.EPA, 2002b). 

j

 Study did not meet OECD 202 Guidelines because the test evaluated immobilization at 24 h rather than 

immobilization at 48 h. However, the test did meet U.S. EPA regulatory test requirements (Test Method 2002.0) 

for measuring the acute toxicity of effluents and receiving waters to a representative crustacean (U.S.EPA, 2002a). 

Table A2: Chronic Aquatic Toxicitya

Test 

Substance 

F 

C 

A 

Species Test Type 

LC50/ 

EC50

Mg/L 

NOEC 

mg/L 

Reference/ 

Comments

Active Substances

F Ictalurus 

punctatus

134-d growthb N/A (0.005) Hermanutz 

et al. (1990) 

C Gammarus 

pseudolimnaeus

70-d fecundity N/A 0.012 Authur et al.

(1975) 

TRO 

(Freshwater) 

A Natural algae 24-d inhibition of 

biomassc

N/A (0.079) Pratt et al.

(1988) 

F Menidia 

peninsula

32-d egg to posthatchN/A 0.04 Goodman et al.

(1983) 

C Panaeus 

kerathurus 

7-d growth/moultingd N/A (0.079) Saroglia and 

Scarano (1979) TRO (Saltwater) 

A Natural 

phytoplankton

21-d reduction in cell 

densityc

N/A (0.001) Sanders et al.

(1981) 

F Oncorhynchus 

kisutch 

23-d survivale N/A 0.042 Holland et al.

(1960) 

C Americamysis 

bahia 

7-d reproductiond N/A 0.048 Fisher et al.

(1994) HOCl 

A No data found 

in literature 
GESAMP-BWWG 10/6 

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Test 

Substance 

F 

C 

A 

Species Test Type 

LC50/ 

EC50

Mg/L 

NOEC 

mg/L 

Reference/ 

Comments

F No data found 

in literature 

C No data found 

in literature HOBr 

A No data found 

in literature 

Relevant Chemicals 

F Morone 

saxatilis

10-d survivalf (93) (50) Richardson 

et al. (1981) 

C No data found 

in literature Bromate 

A Isochrysis 

galbana 

7-d growth inhibition N/A 8 Erickson and 

Freeman (1978)

F Oryzias latipes 9-month growth N/A 1.5 Toussaint et al.

(2001) 

C Daphnia magna 21-d reproduction N/A 13 Kuhn et al.

(1989) Chloroform 

A Skeletonema 

costatum 

5-d reduction in cell 

volume 

477 216 Cowgill et al.

(1989) 

F No data found 

in literature 

C No data found 

in literature Bromoform 

A Selenastrum 

capricornutum 

96-h growth 

inhibition 

N/A 10 U.S. EPA 

(1978) 

F No data found 

in literature 

C No data found 

in literature 

Dibromochloromethane 

A No data found 

in literature 

F No data found 

in literature 

C No data found 

in literature 

Dichloroacetic 

acid 

A Scenedesmau 

subspicatus 

7-d cell proliferationg (1485 

EC3) 

N/A Trenel and 

Kuhn (1982) 

F *) No data found 

in literature 

C *) No data found 

in literature 

Trichloroacetic 

acid 

A Scenedesmus 

quadricauda 

7-d growth 

thresholdh

 (200) OECD SIDS 

(2008) 
GESAMP-BWWG 10/6 

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Test 

Substance 

F 

C 

A 

Species Test Type 

LC50/ 

EC50

Mg/L 

NOEC 

mg/L 

Reference/ 

Comments

F *) No data found 

in literature 

C *) No data found 

in literature 

Dibromoacetic 

acid 

A *) No data found 

in literature 

F *) No data found 

in literature 

C *) No data found 

in literature 

Tribromoacetic 

acid 

A *) No data found 

in literature 

F = Fish; C = Crustacean; A = Algae. 

*) Siemens will obtain data executing own toxicity tests for Final Approval 

a Data shown in parenthesis did not meet OECD Guidelines or other accepted testing procedures but were 

included to provide an indication only of potential toxicity. 

b Study did not meet OECD 210 Guidelines because the test was initiated with juveniles rather than the egg 

stage. c Study did not meet OECD 201 Guidelines because the test did not have control culture biomass data. 

d Study did not meet OECD 211 Guidelines because the test was not a 21-d reproduction test. The test did 

follow a portion of the protocol of the U.S. EPA OPPTS 850.1350 mysid chronic toxicity test (U.S. EPA, 

1996); however, moulting was only observed for 7 days rather than the minimum of 28 days. e Study did not meet OECD 210 Guidelines because the test exposure was 23 days rather than the required 

minimum of 28 days. 

f Study did not meet OECD 210 Guidelines because the test was initiated with 4-d old larvae (not eggs) and 

the post-hatch exposure was 10 days rather than the required minimum of 28 days. 

g Study did not meet OECD 201 Guidelines because the test used cell proliferation and as an endpoint rather 

than growth. 

h Study did not meet OECD 201 Guidelines because the test used toxicity threshold as the endpoint rather 

than growth. 

2 MAMPEC Modelling – Information used to Derive PEC Values 

 (As presented by Applicant) 

Introduction 

The Marine Anti-foulant model (MAMPEC) was used in this dossier to predict environmental 

concentrations of TRO in the port water after discharge. MAMPEC was originally programmed 

to calculate environmental concentrations of anti-fouling biocides released from ship coatings. 

In a modified way it can be used to calculate concentrations that are released constantly into the 

water by other processes like for example ballast water treatment. The applicability of the model 

to any chemical substance made it a useful tool for environmental impact studies. 

Active Substances and DBP 

As a worst case scenario, it was assumed in the model that all TRO is composed of the free 

available chlorine (FAC), by far the most toxic halogen compound. Further, the following 

calculations are therefore all based on HOCl (as sodium hypochlorite). PECs of DBP were 

calculated based on a dilution factor determined during MAMPEC simulation. 
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Parameterization of the model 

To determine the environmental concentration of the released compound in the harbour water 

and the sediment, several parameters are necessary. These parameters define the harbour and its 

characteristics, the compound that is being released and the amount of ships and the amount of 

the specified compound released by those ships. This section provides detailed parameterization 

of the model. 

Compound definitions 

TRO Molecular mass: 74.44 g·mol-1

Saturated vapour pressure at 20°C [Pa]: 23 Pa*

Solubility at 23°C 942 g·L-1

Octanol-water partition coefficient [10 log Kow]: -0,87 

Partition coefficient Koc [10 log Koc (l kg/OC)]: *

-0.209 

Acid dissociation constant pKa: 7.5 

Henry’s constant at 20°C [Pa m3 / mol]: **1.82·10-

2 

Melting temperature [°C]: 18-25°C 

* it is not clear what the correct value is: 23 or 2300 Pa ** not available and therefore estimated with MAMPEC 

Half-life 

For modelling of various environmental scenarios a wide range of the half-life was used, from 

seconds to days. Within MAMPEC it was not possible to include the decay of the compound of 

interest during emptying the ballast water tank. In this case, therefore, a worst case scenario was 

assumed that the water released from the ballast tanks has the same concentration at the start and 

at the end of discharge. 

TRO concentrations in the ballast water and amount of ballast water released 

The measurements in the treated ballast water during preliminary tests revealed the following 

concentrations of TRO in the tank: 

start 5.60 mg·l-1 

after 24 hours 0.55 mg·l-1 

after 48 hours 0.36 mg·l-1 

after 72 hours 0.23 mg·l-1 

after 96 hours 0.21 mg·l-1 

The following discharge TRO concentrations were used in calculations: 

- 0.13 mg/L - a concentration observed in treated water 120 hours after treatment; and 

- 0.55 mg/L - a concentration observed in treated water 24 hours after treatment. 

Further it was assumed that 1, 10 or 80 ships are present in the harbour and that all ships are 

equipped with the SiCURE BWM system with the water characterized by the same holding time 

(TRO level). 
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It was assumed that there were 80 ships anchored in the Port of Rotterdam on an average day, 

discharging 397,000 (three hundred ninety thousand) m3

/day or about 16,540 m3/ hour of ballast 

water into the harbour. These numbers for the Port of Rotterdam were used in the publicly 

available dossiers of other BWMS developers and it would be reasonable to maintain the same 

scenarios in the current calculations. 

The following model inputs result from the assumptions above. 

No. of ships Concentration of 

HOCl [mg·l-1] 

ballast water released 

per day [m3] 

HOCl released 

per day [g] 

1 0.13 4,962 645 

10 0.13 49,625 6,451 

80 0.13 397,000 51,610 

1 0.55 4,962 2,729 

10 0.55 49,625 27,294 

80 0.55 397,000 218,350 

Harbour definitions 

For all runs, the OECD-EU commercial harbour was chosen with the default settings given by 

MAMPEC, as follows: 

tidal period 12.41 h 

silt concentration 35 mg·l-1 

POC 1 mg OC l-1 

DOC 2 mg·l-1 

chlorophyll 3 μg·l-1 

salinity 34 PSU 

temperature 15°C 

latitude 50° N 

pH 7.5 

depth mixed sediment layer 0.2 m 

sediment density 1,000 kg·m-3

org C in sediment 0.03 

sedimentation velocity. 1 m·s-1

Exchange volume 5.1117·107

 m3 · tide-1
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x1 = 1,000 m 

y1 = 1,000 m 

x2 = 5,000 m 

y2 = 500 m 

depth = 15 m 

x3 = 2,500 m 

flow velocity 1 m·s-1 

Background concentration 

The background concentration of HOCL was assumed to be 0 to determine exactly the amount 

introduced by the SiCURETM BWM system. 

Results of modelling 

Modelling was carried out for a single ship as the results can be linearly scaled up for the total 

number of ships in the harbour. The results of modelling are presented below in Table A3. 

The model simulation results show that the total amount of HOCl in port after discharge is 

mainly made up by the soluble fraction. The suspended fraction in all considered scenarios was 

below 0.002%. 
GESAMP-BWWG 10/6 

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Table A3: MAMPEC modelling results 

PEC TRO, μg/l 

TRO in Discharge – 0.13 mg/L 

PEC TRO, μg/l 

TRO in Discharge – 0.55 mg/L 

Half-life, 

h 

average minimum maximum average minimum maximum 

0.0083 1.78E-06 8.70E-08 5.35E-06 6.75E-06 3.63E-07 7.50E-06 

0.0167 3.19E-06 3.19E-07 3.54E-06 1.35E-05 1.35E-06 1.50E-05 

0.25 4.71E-05 2.48E-05 5.31E-05 2.00E-04 1.05E-04 2.25E-04 

0.5 9.29E-05 6.11E-05 1.06E-04 3.93E-04 2.59E-04 4.48E-04 

1 1.80E-04 1.17E-04 2.09E-04 7.64E-04 4.94E-04 8.85E-04 

2 3.44E-04 1.81E-04 4.10E-04 1.45E-03 7.66E-04 1.74E-03 

3 4.94E-04 2.29E-04 6.08E-04 2.09E-03 9.69E-04 2.56E-03 

4 6.35E-04 2.68E-04 8.03E-04 2.69E-03 1.13E-03 3.39E-03 

5 7.66E-04 2.99E-04 9.96E-04 3.24E-03 1.26E-03 4.21E-03 

6 8.91E-04 3.26E-04 1.19E-03 3.78E-03 1.38E-03 5.03E-03 

7 1.01E-03 3.50E-04 1.38E-03 4.28E-03 1.48E-03 5.84E-03 

8 1.12E-03 3.70E-04 1.58E-03 4.75E-03 1.56E-03 6.65E-03 

9 1.23E-03 3.89E-04 1.76E-03 5.21E-03 1.65E-03 7.46E-03 

10 1.34E-03 4.05E-04 1.95E-03 5.65E-03 1.71E-03 8.28E-03 

16.56 1.96E-03 4.80E-04 3.21E-03 8.29E-03 2.03E-03 1.36E-02 

24 2.55E-03 5.26E-04 4.56E-03 1.08E-02 2.23E-03 1.93E-02 

33.6 3.20E-03 5.63E-04 6.19E-03 1.35E-02 2.38E-03 2.62E-02 

48 4.10E-03 5.96E-04 8.59E-03 1.74E-02 2.53E-03 3.63E-02 

96 6.46E-03 6.41E-04 1.55E-02 2.73E-02 2.71E-03 6.56E-02 

984 1.50E-02 6.88E-04 4.21E-02 6.35E-02 2.91E-03 1.78E-01 

1008 1.50E-02 6.88E-04 4.21E-02 6.35E-02 2.91E-03 1.78E-01 

1992 1.64E-02 6.90E-04 4.63E-02 6.93E-02 2.92E-03 1.96E-01 

4800 1.79E-02 6.93E-04 5.14E-02 7.56E-02 2.93E-03 2.17E-01 

8760 1.79E-02 6.93E-04 5.14E-02 7.56E-02 2.93E-03 2.17E-01 
GESAMP-BWWG 10/6 

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0.00

0.01

0.02

0.03

0.04

0.05

0.06

0 0 1 10 100 1000 10000

Half-Life, h

TRO PEC, μg/l

average

minimum

maximum

Figure: Results of MAMPEC modelling for one ship, PEC TRO vs. TRO half-life at 

discharge TRO of 0.13 mg/L. Half-life axe is in a logarithmic scale. 

0.00

0.05

0.10

0.15

0.20

0.25

0 0 1 10 100 1000 10000

Half-Life, h

TRO PEC, μg/l

average

minimum

maximum

Figure: Results of MAMPEC modelling for one ship, PEC TRO vs. TRO half-life at 

discharge TRO of 0.55 mg/L. Half-life axe is in a logarithmic scale. 

Predicted environmental concentrations of TRO (PEC TRO) based on the calculation with one ship 

vary significantly depending on which value of the TRO half-life was selected as a model parameter. 

For a half-life less than 4 hours and discharge concentrations between 0.13 mg/L and 0.55 mg/L, a 

range of the average PEC values was between 3.2E-6 μg/l and 2.7E-3 μg/l. For a half-life greater 

than 4 hours and discharge concentrations between 0.13 mg/L and 0.55 mg/L, a range of the 

average PEC values was between 0.001 μg/l and 0.076 μg/l. Results show that in stagnant waters 

of the port (maximum values) the predicted environmental concentration may peak at 2 to 3 times 

that of the average value. At half-lives of greater than several thousand hours (equal to no 
GESAMP-BWWG 10/6 

ANNEX 6 

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apparent decay) the predicted environmental concentration approaches an asymptotic value. 

An asymptotic value of the predicted environmental TRO at infinite half-life (an assumption of no 

decay) can be directly associated with a dilution factor. Based on the data provided above, the 

dilution factor can be calculated as about 7,200 times for a single ship in port and about 90 times 

for 80 ships in port. 

Analysis of the data presented underscores the importance of a properly selected half-life value. 

With a 1 hour chlorine demand of above 2 mg/L observed in preliminary tests most, if not all, of 

the discharged free available chlorine will dissipate within seconds or minutes. 

The charts below show maximum values of PEC for total residual oxidant in the port water 

assuming that there are 1, 10 and 80 ships in port, all being equipped with the SiCURETM BWMS 

and simultaneously discharging treated ballast water with the same holding time. It is expected 

that only about 10 ships in the port would actually be equipped with the SiCURETM BWMS. 

The first Figure presents the data for a half-life of 1 minute, the second Figure presents the data 

for a half-life of 30 minutes and the third Figure presents the data for a half-life of 1 hour for 

TRO in treated water at 0.55 mg/L (1 day holding time) and 0.13 mg/L (5 days holding time). 

0.0000

0.0002

0.0004

0.0006

0.0008

0.0010

0.0012

0.0014

1 10 80

Number of ships in harbor

PEC TRO, μg/l

0.13 mg/l

0.55 mg/l

Figure: Maximum concentration of TRO in the harbour calculated for 1, 10 and 80 ships 

for a half-life of 1 minute 
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0.0000

0.0050

0.0100

0.0150

0.0200

0.0250

0.0300

0.0350

0.0400

1 10 80

Number of ships in harbor

PEC TRO, μg/l

0.13 mg/l

0.55 mg/l

Figure: Average concentration of TRO in the harbour calculated for 1, 10 and 80 ships for 

half-life of 30 minutes 

0.0000

0.0100

0.0200

0.0300

0.0400

0.0500

0.0600

0.0700

0.0800

1 10 80

Number of ships in harbor

PEC TRO, μg/l

0.13 mg/l

0.55 mg/l

Figure: Average concentration of TRO in the harbour calculated for 1, 10 and 80 ships for 

half-life of 1 hour 

The final results of the predicted environmental concentrations of TRO for the worst case 

scenario of 80 ships in the harbour are summarized in Table A4 below for the wide range of 

half-life values. 
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Table A4: Summary of PEC calculations for 80 ships 

TRO in Treated Water, Maximum PEC, μg/l at a Half-Life of 

mg/L 1 min 30 min 1 h 4 h 24 h 48 h 

0.55 (1 day holding time) 0.001 0.036 0.071 0.270 1.50 2.90 

0.13 (5 days holding time) 0.003 0.008 0.017 0.064 0.370 0.68 

Predicted environmental concentrations of DBP for the worst case scenario of 80 ships in the 

harbour are summarized in Table A5 assuming no decay, 90 times dilution factor and maximum 

discharge concentrations reported in the dossier. 

Table A5: Disinfection by-products 

DBP PEC, μg/l 

Fresh water* Salt water 

Trihalomethanes: 

Trichloromethane < 1 0 

Dibromochloromethane 0 < 0.03 

Tribromomethane 0 < 1 

Haloacetic acids: 

Dichloroacetic acid < 0.3 < 0.03 

Trichloroacetic acid < 0.4 0 

Dibromoacetic acid 0 < 0.56 

Tribromoacetic acid 0 < 0.67 

Sodium Bromate 0 < 0.7 

SWT anticipates an extensive programme to determine the realistic decay rates of TRO and 

continue environmental modelling using models other than MAMPEC that take into 

consideration the effect of a chlorine demand. These results will be used to define the 

SiCURETM BWMS environmentally safe holding time and will be provided for review in a 

documentation to be submitted for Final Approval. 

***
GESAMP-BWWG 10/6 

I:\MEPC\60\2-11.doc 

ANNEX 7 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

Resource Ballast Technologies System 

Submitted by South Africa for Final Approval 

0 SUMMARY 

0.1 Having reviewed all the data and information submitted by South Africa with the application 

for Final Approval and the information received from the Applicant during the GESAMP-BWWG 

meeting, the Group recommended to MEPC that Final Approval be granted to the Resource Ballast 

Technologies System, provided that recommendations given below are taken into account. 

0.2 The Group recalled that Basic Approval of this ballast water management system 

(BWMS) was granted by MEPC 57 to Resource Ballast Technologies (Pty.) Ltd. of South Africa 

and the report is available at document MEPC 57/2/10 (BWWG 5/9, annex 5, Review 

of Proposal for Basic Approval of Active Substance). 

0.3 Following the Group’s review of the responses from the Applicant to questions posed by 

the Group and listed in the Basic Approval report, together with both the additional and further 

information provided by the Applicant in response to questions posed during 

the GESAMP-BWWG meeting, the Group was satisfied with the completeness of the dossier 

received from the Applicant. 

0.4 The Group noted that the Resource Ballast Technologies System uses a combination of 

cavitation as a primary treatment of the ballast water with small amounts of Active Substances 

(ozone and sodium hypochlorite) to assist the cavitation process, together with ballast water filtration. 

The Group also noted that the BWMS generates the two Active Substances on board ship, employing 

ambient air to form ozone in a generator unit and electrolysis of seawater in an electrochemical unit to 

produce hypochlorite. Hypochlorite is added to the ballast water up to a maximum allowable dose 

of 1 mg/L (TRO as Cl2), while the ozone is injected into the ballast water, also up to a maximum 

allowable dose of 1 mg/L (TRO as Cl2). The Group noted that ballast water is treated on uptake only. 

0.5 As the BWMS does not require the storage of chemicals on board ship, the Group 

recognized that there will be no associated storage safety problems. 

0.6 The Group recognized that the system utilizes Active Substances and produces Relevant 

Chemicals and Other Chemicals with potential safety and environmental concerns and the Group 

has reviewed the hazards and risks associated with all these chemicals. 

0.7 The Group recognized that the Applicant has provided detailed information on system controls 

and safety considerations for installation of the BWMS on board ship, together with provisions for 

maintenance and emergency operations of the system and acceptable results of corrosion testing. 

As such, the Group considered that the BWMS should present no unacceptable risks to the safety of the 

ship. Additional corrosion tests are in progress as part of the land-based and Type Approval tests. 
GESAMP-BWWG 10/6 

ANNEX 7 

Page 2 

I:\MEPC\60\2-11.doc 

0.8 In addition, the Group noted the provision by the Applicant of detailed analytical results 

for the Active Substances, Relevant Chemicals and Other Chemicals in treated ballast water. 

The Group accepted the view of the Applicant that there are no unacceptable risks in the 

chemical composition of ballast water caused by the use of this BWMS. 

0.9 The Group noted the human health assessment provided by the Applicant that includes 

occupational exposure to ships’ crew, BWMS operators and the exposure of the general public. 

The Group considered that the Resource Ballast Technologies System poses no unacceptable risk 

to the health of the crew and the general public regarding the exposure to chemicals and treated 

ballast water based on the submitted human exposure assessment and the mitigation measures 

developed by the Applicant for installation on board ship. 

0.10 The Group recognized that the Applicant has provided detailed information on 

ecotoxicity testing of treated ballast water, environmental risk assessment for aquatic organisms 

and a proposal for maximum allowable discharge concentration for the Active Substances, 

together with minimum holding time for the treated ballast water. The maximum allowable 

discharge concentration (MADC) with a minimum holding time of 3 hours is as follows: 

MADC of Total of Ozone and Sodium hypochlorite measured in TRO = 0.1 – 0.2 mg/L 

(as Cl2) 

In addition, to ensure that the TRO at discharge remains below the MADC, the Group 

recommended that a TRO monitoring and recording function be included at discharge. 

0.11 In conclusion, having reviewed all the information provided by the Applicant, the Group 

agreed to recommend to the MEPC that Final Approval be granted to the Resource Ballast 

Technologies System, subject to the Administration verifying that all recommendations have 

been fully addressed prior to the issuance of a Type Approval Certificate, as follows: 

.1 Hypochlorite is added to the ballast water up to a Maximum Allowable Dose 

of 1 mg/L (TRO as Cl2), while the ozone is injected into the ballast water, also up 

to a Maximum Allowable Dose Concentration of 1 mg/L (TRO as Cl2). 

.2 Maximum Allowable Discharge Concentration of Total of Ozone and Sodium 

hypochlorite measured in TRO = 0.1 – 0.2 mg/L (as Cl2). In addition, to ensure 

that the TRO at discharge remains below the MADC, the Group recommended 

that a TRO monitoring and recording function be included at discharge. 
GESAMP-BWWG 10/6 

ANNEX 7 

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I:\MEPC\60\2-11.doc 

1 INTRODUCTION

1.1 The data used to evaluate this system were extracted from that supplied by South Africa 

in document MEPC 59/2/10, which was supplemented by the confidential part of the dossier and 

by additional information provided by the Applicant after a request for further information by the 

Group during its meeting. 

2 COMPLETENESS OF DOSSIER AND APPLICANT RESPONSES TO DATA 

REQUESTS FROM THE GROUP

2.1 The Group recalled that it had already provided the following questions and 

concerns during its evaluation of the application for Basic Approval of the system 

(see MEPC 57/2/10 – BWWG 5/9, annex 5, Review of Proposal for Basic Approval of 

Active Substance), which it considered should be addressed by the Applicant for Final Approval. 

The Applicant’s responses received, and the Group’s reaction to these responses are shown in 

Table 1. 

Table 1: Applicant’s Responses to Data Requests set by the Group during Evaluation 

for Basic Approval 

Section 

No. 

Refs. 

from 

BA 

Report 

Group’s Question Applicant’s Response 

and Section No. in 

this Report 

(Appendix Nos. refer 

to the Applicant’s 

confidential dossier) 

Group’s Reaction 

2.1.1 0.4.2 Information regarding human 

exposure (HES, MEPC 56/2/2, 

annex 9) should be provided for 

Bromate. 

Information has been 

provided – See section 

No. 3.3.11. 

The Group was 

satisfied with this 

response. 

2.1.2 0.4.3 More detailed chemical analysis 

should be provided in the Final 

Approval application for 

Bromoform. 

Information has been 

provided – See section 

No. 3.3.9. 

See appendix of this 

report for detailed 

results of chemical 

analyses. 

The Group was 

satisfied with this 

response. 

2.1.3 0.5 Chlorinated and brominated 

disinfection by-products are the 

toxicologically relevant 

compounds generated by the 

process as they have a potential 

for human genotoxicity/ 

carcinogenicity. Therefore, they 

will have to be kept below 

toxicologically critical levels 

(bromate < 10 μg/L; bromoform 

< 100 μg/L; chloroform 

< 200 μg/L, WHO Guidelines for 

Information has been 

provided – See section 

Nos. 3.3.9 and 3.3.11

See appendix of this 

report for detailed 

results of chemical 

analyses. 

The Group was 

satisfied with this 

response. 
GESAMP-BWWG 10/6 

ANNEX 7 

Page 4 

I:\MEPC\60\2-11.doc 

Section 

No. 

Refs. 

from 

BA 

Report 

Group’s Question Applicant’s Response 

and Section No. in 

this Report 

(Appendix Nos. refer 

to the Applicant’s 

confidential dossier) 

Group’s Reaction 

Drinking Water Quality, 2003). 

2.1.4 0.6 Information concerning the 

Human Exposure Scenario 

(MEPC 56/2/2, annex 9) should 

be included in an application for 

Final Approval. 

Information has been 

provided – See section 

No. 4. 

The Group was 

satisfied with this 

response. 

2.1.5 0.7 The amount of hydrogen gas 

produced by the electro-chemical 

unit should be documented in the 

application for Final Approval. 

The same applies to chlorine gas. 

The Group recommends that a 

de-aeration component is added 

immediately following the 

electrolytic unit and that a hydrogen 

gas monitor is included in the 

system. 

Information has been 

provided – See section 

No. 4.1. 

See appendix 11 for the 

gas test report. 

The Group was 

satisfied with this 

response. 

2.1.6 0.9 The applicant should carefully 

consider the effect of organic 

matter levels on the production of 

by-products for the final 

operational mode(s) of the 

system and demonstrate this by 

appropriate measurements. 

Information has been 

provided – See section 

No. 3.3. 

See appendix of this 

report for detailed 

results of chemical 

analyses. 

The Group was 

satisfied with this 

response. 

2.1.7 0.10 The filter cake could contain 

treatment by-products and should 

therefore be considered as a 

waste stream warranting further 

investigation as part of the 

Final Approval process. 

Information has been 

provided – See section 

No. 3.3. 

See appendix of this 

report for detailed 

results of chemical 

analyses. 

The Group was 

satisfied with this 

response. 

2.1.8 0.12 The applicant must establish a 

PEC estimation in order to 

determine a PEC/PNEC ratio to 

identify a possible risk for the 

environment for the Relevant 

Chemicals in the application. 

Information has been 

provided – See section 

No. 6.3. 

The Group was 

satisfied with this 

response. 

2.1.9 2.2 The description and diagram of the 

system are insufficiently clear 

regarding the sequence and the 

conditions (e.g., seawater, fresh 

water) in which the treatment 

technologies are to be used, 

including how the reactor is 

Information has been 

provided – See section 

Nos. 3.1 and 3.2. 

The Group was 

satisfied with this 

response. 
GESAMP-BWWG 10/6 

ANNEX 7 

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I:\MEPC\60\2-11.doc 

Section 

No. 

Refs. 

from 

BA 

Report 

Group’s Question Applicant’s Response 

and Section No. in 

this Report 

(Appendix Nos. refer 

to the Applicant’s 

confidential dossier) 

Group’s Reaction 

operated. Clear information on the 

operation of the entire system is 

required in order to be able to 

assess the hazards and risks in the 

application for Final Approval. 

2.1.10 2.3 The control system should be 

described in detail including the 

sensors for Ozone and chlorine 

monitoring. 

Information has been 

provided – See section 

Nos. 3.1 and 3.2. 

Whilst the Group 

was satisfied with 

this response 

regarding the 

sensors for the 

initial dosage of 

chemicals to the 

ballast water, 

the Group 

recommended 

TRO monitoring 

and recording of 

the discharge to 

ensure 

environmental 

acceptability is 

always maintained.

2.1.11 2.4 The Group does not consider that 

the list of possible disinfection 

by-products provided by the 

Applicant is complete, nor does it 

cover the possible operating 

modes of the system, e.g., 

ozonation alone, electrochemical 

treatment alone or both together. 

Information has been 

provided – See section 

No. 3.3. 

See appendix of this 

report for detailed 

results of chemical 

analyses. 

The Group was 

satisfied with this 

response. 

2.1.12 2.5 A more comprehensive, 

measured data set on both the 

electrochemical and Ozone 

generation systems plus a 

thorough evaluation of Active 

Substances, Relevant Chemicals 

and by-products should be 

provided in the application for 

Final Approval. 

Information has been 

provided – See section 

No. 3.3. 

See appendix of this 

report for detailed 

results of chemical 

analyses. 

See appendices 1 to 6 

for data on the effects 

of Active Substances, 

Relevant Chemicals 

and Other Chemicals 

on aquatic plants, 

invertebrates, fish and 

other biota. 

The Group was 

satisfied with this 

response. 
GESAMP-BWWG 10/6 

ANNEX 7 

Page 6 

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Section 

No. 

Refs. 

from 

BA 

Report 

Group’s Question Applicant’s Response 

and Section No. in 

this Report 

(Appendix Nos. refer 

to the Applicant’s 

confidential dossier) 

Group’s Reaction 

2.1.13 2.6 It was noted that the Applicant 

did not carry out chronic aquatic 

toxicity tests; this should be 

included in the dossier for 

Final Approval. 

Information has been 

provided – See section 

No. 6.2. 

See appendices 7 and 8 

for reports on acute 

and chronic ecotoxicity 

testing of treated 

ballast water. 

The Group was 

satisfied with this 

response, however, 

the Group noted 

that appendix 7 

was exactly the 

same as that 

submitted for 

Basic Approval. 

2.2 Prior to the GESAMP-BWWG meeting, the IMO-GESAMP Consultant posed three 

questions to the Applicant, and during the meeting the Group posed seven questions to 

the Applicant. The questions (in bold text), the Applicant’s responses (in plain text) and the 

reactions of the Group (in italic text) are noted below, in numerical order of the individual 

questions. In addition, the Group noted that the Applicant had submitted documentation, 

additional to that originally submitted in the Final Approval dossier, partly in response to the 

questions posed by the IMO-GESAMP Consultant, as follows: 

.1 Appendix 9 – Human Exposure scenario, which replaces the old one in the 

original application; 

.2 Appendix 11 – Gas detection report; 

.3 Appendix 16 – Corrosion Testing Procedure; and 

.4 additional references. 

The questions posed by the IMO-GESAMP Consultant are as follows: 

Question 1: 

1 The IMO-GESAMP Consultant has some questions on your document 

MEPC 59/2/10 concerning your section 7.2.2 – Exposure to hydrogen gas and 

chlorine gas, as follows: The results of gas concentrations for the two methods 

(desk-top methods and by monitoring gas concentrations) do not give very similar 

results. Have you any comments? You make no recognition in your submission that 

these two methods do not give similar results. 
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ANNEX 7 

Page 7 

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Response 1: 

.1 The maximum measured concentration of hydrogen gas in the simulation ballast 

tanks were considerably lower than the worst case scenario estimates generated by 

the mass balance calculation (see paragraph 2.4.1, appendix 9). We do not believe 

that this should be of concern, and consider that it merely reaffirms that the 

calculated estimates of hydrogen gas production are worst case scenario 

estimates, and that the hydrogen gas, being lighter than the other gases, rises to the 

top of the tanks and is rapidly vented to the atmosphere. Further tests on the rate 

of hydrogen gas production and its concentration in the ballast tanks will be 

conducted as part of the shipboard trials included in the Type approval 

assessment, to confirm this. 

The Group was satisfied with the response 

Question 2: 

2 I cannot find in your confidential dossier (neither in appendix 8 nor in appendix 11) where 

does this information in section 7.2.2 come from? You say that the data was obtained from 

the 28-day fish chronic test but there is no mention of gas tests in the fish study report and 

the document in appendix 11 is brief and only consists of calibration tests. 

Response 2: 

.1 The information you seek is contained in appendix 11. This appendix is a report 

prepared by Pinnacle Instruments (Pty.) Ltd. (an independent company) who were 

contracted to take measurements of gas concentration in the header space 

of a 200 m3 simulation ballast tank at the RBT test facility in the Port of Cape 

Town, South Africa. These tests were run concurrently with the fish chronic 

toxicity tests described in appendix 8 of this application dossier, covering the 

latter 8 days of this experiment, continuing for a further 2 days after the 28-day 

fish experiment terminated. Gas detectors were installed in the header space of 

simulation ballast tanks and maintained in position for a period of 10 days where 

they were allowed to measure concentrations of hydrogen and chlorine gas in the 

header space continuously over this period. 

.2 Appendix 11 is a report provided by Pinnacle Instruments (Pty.) Ltd. on the 

procedure followed in measuring gas concentrations and the data collected. 

The order of the pages seems to have been mixed up in the copy included in the 

original application for Final Approval submitted in Decembert 2008. This has 

been corrected and a revised copy of appendix 11 is included with this letter. 

The actual report on the gas measurements covers the first 5 pages of 

appendix 11, with measurements taken being summarized on page 2 

(Table headed “Storage vessel” – average, minimum and maximum 

concentrations of hydrogen and chlorine gas), actual readings for Chlorine (ppm) 

and Hydrogen gas (%) are shown on pages 3 and 4, and the pen trace from the 

instrument is included on p5 (Pen 1= chlorine gas ppm, Pen 2 = hydrogen gas %). 

The remainder of this appendix (last 6 pages) comprises calibration certificates for 

the instruments used to take the measurements. 

The Group was satisfied with the response. 
GESAMP-BWWG 10/6 

ANNEX 7 

Page 8 

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Question 3: 

3 I have some concerns about the detailed calculations used in the desk-based methods, as 

follows: 1 Faraday cannot be equal to 1 Coulomb, which it appears to say in the text in 

your application document. This section is not very clear, please check and re-confirm. 

I have found the following information in the scientific literature 

“Faraday’s Law”: The amount of substance consumed or produced at one of the 

electrodes in an electrolytic cell is directly proportional to the amount of electricity 

(charge in Coulombs) that passes through the cell. By definition, one Coulomb (C) of 

charge is transferred when a one-ampere current flows for one second(s): Faraday’s 

Constant (F) is the charge in Coulombs on a mole of electrons: F = 96,454.56 Coulomb. 

Also there is another mistake in this calculation section. Your submission says, “Thus 

using a CE of 95%, the Cl2 output is 13.2275 x 96% = 8.598 g Cl2 per hour.” 

The mathematics here is obviously not correct. Please check and re-confirm. 

Response 3: 

We have checked desk top calculations of gas concentrations and acknowledge that there 

are some errors in these calculations. This assessment has been entirely redone. 

The revised risk assessment have been included in the attached “appendix 9”, which is 

designed to replace the appendix of this name in the original dossier. Assessment of risk 

due to hydrogen gas and chlorine gas have been revised accordingly. 

The Group was satisfied with the clarifications provided. 

The questions posed by the Group are as follows: 

Question 1: 

1 The Group notes that the analytical chemistry results for treated discharge had 

TRO > 0.2 mg/L, on that basis does the Applicant plan to include a neutralization 

step? 

Response: 

.1 The design of the RBT reactor as it stands does not include a neutralization step. 

The reasons for this is that our experiments have shown that the Total Residual 

Oxidants (TRO) within the treated ballast water decay to <0.2 mg/L 

within 2 hours of treatment (120 minutes) from initial values of 0.45 mg/L TRO 

for brine (salinity ~21 PSU) and 0.6‐0.7 mg/L for seawater (Figure 1 and 

Figure 2 – attached to Applicant’s response). Given that the ballast water is treated 

on uptake, and that the likelihood of being required to discharge the same ballast 

water within two hours of uptake is highly improbable, we do not consider it 

necessary to include a neutralization step in the process.

Although the Group was satisfied with the response, the Group recommended TRO monitoring 

and recording of the discharge to ensure environmental acceptability is always maintained. 
GESAMP-BWWG 10/6 

ANNEX 7 

Page 9 

I:\MEPC\60\2-11.doc 

Question 2: 

2 Can the Applicant clarify the dosage control for both ozone and electrolytic 

chlorination in the influent ballast? Specifically, how is the TRO monitored and are 

the injection of ozone and electrolytic chlorination modified through a feedback 

control mechanism to sustain the target treatment dosage? 

Response 2: 

.1 Ozone Dosage Control – O3 is generated in modular ozone cells applying a 

specific electrical current to air. There is a linear relationship between the air 

supplied to the ozone cell and the amount of ozone produced. The amount of 

ozone generated can also be altered by adjusting the power supplied to the ozone 

cells. As the flow rate of the ballast system increases so, too, does the number of 

ozone cells in the system in order to preserve the basic ratio. As the ozone is 

produced, it is vacuum extracted through SS 316 pipe work from the generation 

coronas using a venturi. The venturi is placed on a line that draws treated ballast 

water from after the filter and reintroduces it into the main line at the first reactor 

vessel. Immediately after the venturi, there is a mixing chamber which ensures the 

O3 is evenly dispersed in the flow. The Ozone maximum output is factory set 

according to the amount of water to be treated and the required dosage for a 

specific installation. Further control of the Ozone on site is done through an air 

mass flow sensor situated on the input side of the oxygen to Ozone electrode cell. 

The mass flow sensor is connected to the electronic controller producing the power 

that is delivered to the Ozone electrode cell. (Text deemed to be confidential and 

removed at the request of the submitting Administration.) Ozone is thus produced 

at a rate that is in proportion to the air flow rate through the ozone generator, which is 

in turn in proportion with the flow rate of the ballast water through the RBT reactor, 

thus ensuring the concentration of ozone in the treated ballast water remains more or 

less constant. 

.2 Ozone System safeguards – Ozone is produced in situ and only according to 

what is required; there is no storage of ozone involved. The venturi is the only 

component that causes air to pass through the ozone cell and it works on the 

principle of vacuum extraction. The venturi for each model of UBWTS is selected 

to be capable of extracting ozone at a rate that is required for the flow rate range 

of that model. An air mass flow sensor is fitted to the air intake for each of the 

ozone cells. Since the yield of ozone for a given air mass flow rate and current is 

fixed, the system can ensure that the maximum dosage of 1.0 ppm is not exceeded 

by adjusting the current to the ozone generator. If there were to be a crack in the 

ozone extraction pipeline to the venturi, ambient air would leak in rather than 

ozone leaking out due to the pressure gradient. This would also result in less air 

flow through the ozone cell and therefore a related drop in the amount of ozone 

produced. If there ozone extraction pipeline was to be completely broken, there 

would be no flow through the ozone cell and therefore no ozone produced. 

The ozone line is fitted with a non-return valve to ensure seawater cannot travel 

up the extraction ozone line. 
GESAMP-BWWG 10/6 

ANNEX 7 

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.3 Electrolytic Chlorination Control – Like the O3 the NaOCl generation is 

modular in design with progressively more modules being employed to treat 

increasing flow capacities. The maximum dosage rate is 1 ppm. The NaOCl is 

produced from electrodes that are mounted in the reactor vessels. The electrodes 

are powered by electro chemically activated devices (ECAs). Each model in the 

range consists of two reactors and each of these contains the same number of 

electrodes. All the electrodes are identical. There is proportional relationship 

between the power applied to the electrode and the amount of NaOCl produced. 

The system also features a chlorine sensor, which is mounted in the instrument 

chamber immediately before the venturi. It constantly measures the chlorine level 

and is used in a feedback loop to regulate the current to the electrodes in order to 

keep the dosage at the desired level. 

.4 Sodium Hypochlorite System safeguards – NaOCl is produced in situ and only 

according to what is required – there is no storage of NaOCl involved. There is 

absolutely no interaction between the ozone and the sodium hypochlorite. This 

mechanism fulfils G‐8 Annex 3, 4.10, which necessitates a means to 

automatically adjust the necessary treatment dosage. Due to the highly turbulent 

flow in the reactor vessels there will be no accumulation of NaOCl or O3 in them. 

In light of the foregoing design features we believe that all necessary precautions 

and measures have been taken to ensure that there is neither 

more Active Substance produced than intended and nor is it possible for leakage 

of Active Substances into workspaces. 

The Group was satisfied with the response. 

Question 3: 

3 The Group identifies there is a potential human health risk in the space where the system 

is located, from leakage of ozone from either the ozone generator or ozone gas piping and 

connection to the eductor system. Are measures incorporated to the system to mitigate 

this risk? 

Response 3: 

.1 The design of the ozone equipment does not allow Ozone gas to leak into the 

surrounding area. The Ozone Cell where the ozone gas is produced will only produce 

O3 gas when oxygen (O2) is present, which is obtained from the ambient air. Should 

there be no air flow through the O3 cell, no O3 gas will be produced. The venturi 

suction system on the RBT reactor is used to create the required airflow through the O3 

cell, as described above (response to question 2). The venturi (suction) is only 

operational when the ballast pump is in operation. Water flowing through the venturi 

causes a negative pressure that in turn sucks the ambient air through the O3 cell. 

The O3 cell is a closed unit that will not allow air into the cell without the ballast pump 

running. No form of air or gas compression is employed, thereby ensuring that no 

ozone gas can leak from the ozone cell into the surrounding area. 

The Group was satisfied with the response. 
GESAMP-BWWG 10/6 

ANNEX 7 

Page 11 

I:\MEPC\60\2-11.doc 

Question 4: 

4 The Applicant performed both acute and chronic toxicity tests at Final Approval. 

However, we cannot find out the evidence that these tests are performed as part of 

the land-based type approval process (described in paragraph 5.2.1 in 

Procedure (G9)). Could you provide more specific description how the treated 

ballast water was produced? 

Response 4: 

.1 All toxicity tests for Basic and Final Approval were conducted at the land-based 

facility in the Port of Cape Town. Please see attached layout for ease of reference. 

Description: Seawater is drawn from the Cape Town harbour by means of a series 

of pipes where it is passed through the RBT reactor and filtration system. 

Once treated the simulated ballast water is either pumped directly to holding 

vessels where the test animals are stored in the simulated ballast tanks at the RBT 

facility before discharge back to sea. Test samples are taken from sampling points 

arranged on the simulated ballast tank discharge pipeline. The South African 

Administration (SAMSA) oversaw and approved both the development of the 

full-scale land-based testing facility, as per Guidelines (G8) requirements. A letter 

from the Administration detailing this was provided with the original application 

dossier assessment report. We have requested that a duplicate be sent to us, which 

we hope to be able to forward to you during the course of today. 

While the specific land-based test report was not provided, the Administration verified by letter 

that the testing was conducted within the provisions of Guidelines (G8). Therefore, the Group 

considered that the ecotoxicity data were derived from appropriate samples. 

Other questions related to Question 4: 

4.1 How much is the TRC (Treatment Rated Capacity) of the BWMS used for toxicity 

testing? 

Response 4.1: 

.1 230 cubic meters per hour. 

The Group was satisfied with the response. 

4.2 What was the date of sampling of the treated ballast water? 

Response 4.2: 

.1 Intensive sampling of treated ballast water for the Final Approval application was 

undertaken in the period 29 October to 8 December 2008. Specific dates on which 

sampling was conducted over this period are as follows: (list provided). Dates on 

which samples were collected and analyzed are all indicated on the Laboratory 

test certificates included in appendix 13 of the application for Final Approval. 

The Group was satisfied with the response. 
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ANNEX 7 

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Question 5: 

5 Does the system design incorporate the concept that the ozone dose 

(more than 1 mg/L) will increase during treatment against purely fresh water? 

Response 5: 

.1 The ozone dose will not increase in the event of the treatment of fresh water. 

Ozone dosage is controlled by the flow rate of treated water, which in turn 

influences the negative pressure on the venturies through which the gas is drawn 

into the system, and the air flow mass sensor in the ozone generator which 

determines the production rate of ozone up to a maximum preset level. 

The control procedure is described in detail in the response to question 2 above. 

.2 The extended half-life of ozone in fresh water (~30 min vs. 6 s in seawater) is 

employed to treat fresh water, where the sodium chloride levels are reduced and 

affect the production of NaOCl. The incorporation of both the electrochemical 

(NaOCl) and ozone allow the RBT system to effectively treat both fresh and 

seawater. NaOCl is more effective in seawater condition and the ozone treatment 

is more effective in fresh water conditions. Measured concentrations of TRO in 

fresh water (a measure of all residual oxidants in the water – 03 + NaOCl) were on 

average 0.07 mg/L and never exceeded 0.09 mg/L, a function of the fact that these 

values reflect only the ozone in the water, production of NaOCl being negligible 

in freshwater. 

The Group appreciated the clarification provided. 

Question 6: 

6 The Group notes that the production of relevant chemicals may vary with salinity 

and organic matter concentrations. Can the Applicant clarify how the dosage of 

ozone and chlorination is modified to accommodate for these variations? Also, can 

the Applicant clarify how the ratio of ozone and chlorine is varied on the basis of 

salinity? 

Response 6: 

.1 Control of the chlorine concentration in the ballast water is achieved through a 

conventional control technique using a set point value that is preset on the 

electronic controller been compared to the actual value as recorded by a chlorine 

sensor, as indicated in the response to question 2 above. The dosage of ozone on 

the other hand, varies in response to the flow rate of water through the reactor as 

indicated in the response to question 2 above. The extended half life of ozone in 

fresh water (~30 min vs. 6 s in seawater) is employed to treat fresh water, where 

the sodium chloride levels are reduced and hence affect the production of NaOCl. 

The Group appreciated the clarification provided. 
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ANNEX 7 

Page 13 

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This leads us to also ask the following questions relating to Question 6: 

6.1 What condition was set on the ballast water treatment for toxicity test and chemical 

analysis in the dossier of final application? 

Response 6.1: 

.1 System settings used are as described in the response to questions 2, 5 and 6 

above. 

The Group was satisfied with the response. 

6.2 If the level of TRO in the water measured by probe for chlorine (TRO as Cl2 mg/L) 

how is the level of ozone in water monitored and regulated especially in fresh water? 

Response 6.2: 

.1 The dosage of ozone remains at a preset level, as indicated in the response 

to question 5 above. The extended half-life of ozone in fresh water 

(~30 minutes vs. 6 seconds in seawater) is employed to treat fresh water, where 

the sodium chloride levels are reduced and affect the production of NaOCl. 

The Group was satisfied with the response. 

6.3 Is there any information that the formation of bromates by oxidants does not vary 

according to the level of salinity and the mixture ratio of ozone and chlorine? 

Response 6.3: 

.1 Levels of Bromate were all below limits of detection (i.e. <10 μg/L) for all 

samples of seawater (35 PSU), brackish water (~20 PSU) and fresh water tested 

(See Table 2.7 in the application for Final Approval and laboratory test reports 

supplied by EAWAG, in appendix 13 of the application dossier. Mixture ratios of 

ozone and chlorine will have been in accordance with levels prescribed in the 

responses to questions 2, 5 and 6 above. 

The Group was satisfied with the response. 

Question 7: 

7 In the evaluation for Basic Approval it was suggested by the Group that the control 

system should be described in detail including the sensors for ozone and chlorine 

monitoring. The Group does not see the results of this suggestion and wonders what 

the reasons could be. Is this just an omission or were there scientific reasons for this 

decision? 
GESAMP-BWWG 10/6 

ANNEX 7 

Page 14 

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Response 7: 

.1 Section 4 of the original dossier application was intended to satisfy this 

component. However, now in reviewing the dossier we recognize the level of 

detail required may not have been adequate. Some of the descriptions required 

may have been addressed in the above questions. In addition, we are in the final 

stages of completing a revision, which is provided below. 

.2 Electric Control Cabinet (ECC) – The system has a local operator cabinet which 

is located in the engine room. It has a display on the front with a mimic diagram 

showing all components and how they are connected together (see Figure 1). 

The values of chlorine, conductivity and temperature in the treated water are also 

displayed here. When an alarm is initiated, it will appear in the alarm list. 

The operator panel is also equipped with an audible alarm. If required, this control 

system can be duplicated and integrated into ship’s automation in order to have 

remote operator panels in all stations from where ballast operation is normally 

performed. But the original cabinet will always remain in the engine room as 

standard delivery. All tests and maintenance have to be done after switching the 

system to manual mode. When doing this, there will be an alarm-light on the 

cabinet showing the system undergoing maintenance. No operation is possible 

from any remote panels when the system is turned to “MAN” mode. The PLC 

which is the brain and a data logger (recorder) are installed in this cabinet. 

Passwords will be used for the PLC so the access can be controlled. The data 

logger will be protected through both password and a seal for the memory card 

slot. The system has runtime counters for the electrodes which are consumables. 

When reaching the set value, there will be a visual warning so the electrodes can 

be replaced and there is a reset function to re-zero the counters when this is done. 

.3 Ozone generator and ECA rectifier cabinet – A separate cabinet is installed close 

to the reactors with the ECA rectifiers and ozone generators installed inside. 

The ozone producing cells are mounted on this cabinet outside. The chiller which 

cools the ozone producing cells is installed in the vicinity. The maximum length from 

ozone producing cells to the venturi is five (5) metres. The single line diagram 

prepared to give an overview of all valves and other components is attached 

(see attachment-1). This diagram contains all information needed for wiring and to 

connect every thing electrically. All components are controlled from the control 

cabinet. Therefore, all feed backs from the components are routed back to this 

cabinet. Some of the gathered information is supplied to the ozone generator and 

ECA rectifier cabinet to control the chlorine and the ozone dosages for the treatment. 

The ECA and ozone cabinet will have a seal which has to be broken to open the 

cabinet. 

.4 Monitoring and shut down – The system will always be in Auto-mode. 

The treatment process starts automatically when the PLC receives corresponding 

signal from a flow transmitter installed in the chamber and a running signal for the 

ballast pump is present. Please see the logic diagram attached (attachment 2). 

If there is no flow detected in the reactor while the pump is running, the system 

will initial an audible and a visual alarm so the operator is notified. At the same 

time the system will start automatic shut down of the treatment system to prevent 

any untreated water pumped to the tank. There is a by-pass valve installed for both 
GESAMP-BWWG 10/6 

ANNEX 7 

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the reactors and the filter. In the event of an emergency these valves could be 

opened manually by the operator. An audible and a visual alarm will be initiated 

and the operation will be recorded in the data logger. The data logger has a 

capacity to store data for more than 2 years. Data is stored on a memory card. 

If the data logger is replaced for any reason, the memory card should be kept on 

board fo 24 months, as per the G-8 requirements. Failures which result in 

improper operation of the system will have audible and visual alarm. All alarms 

are recorded in a protocol and stored for information. The procedure to 

acknowledge the critical alarms should be included in the Ballast Water 

Management Plan. The alarm log is accessible to port state control or any other 

authority doing the monitoring. 

The Group was satisfied with the response. 

2.3 In view of the above responses from the Applicant to questions posed by the 

IMO-GESAMP Consultant and the Group during the meeting, and considering all the data and 

information submitted by the Applicant in this dossier, the Group was satisfied with the 

completeness of the dossier received from the Applicant. 

3 DESCRIPTION OF THE SYSTEM

3.1 Overview 

3.1.1 The Group recalled that this BWMS had already been described and reviewed in the 

report for Basic Approval and the Group noted that Figure 1 schematically shows the BWMS 

being reviewed for Final Approval. 

3.1.2 The Group recalled that the Applicant proposes a BWMS that combines destruction of biota 

by cavitation and removal of sediment by filtration at uptake of ballast water, with a disinfection 

step based on injection of Active Substance ozone and use of natural components like chloride ions 

in seawater in an electrolytic process to produce Active Substance hypochlorite in situ for the 

killing of remaining micro-organisms. The Group also noted that the BWMS generates the two 

Active Substances on board ship, employing ambient air to form ozone in generator units and 

electrolysis of seawater in electrochemical units to produce hypochlorite. Hypochlorite is formed 

in the ballast water up to a maximum allowable concentration of 1 mg/L (TRO as Cl2), while the 

ozone is injected into the ballast water, also up to a maximum allowable concentration of 1 mg/L 

(TRO as Cl2). The Group noted that ballast water is treated on uptake only. 

3.1.3 The Group noted that two ozone generators are installed to supply ozone gas to the 

system. The ozone contact chamber mixes the gas and ballast water and ensures that the ozone 

gas is infused into the water. Ozone gas is sucked directly into the ballast water being treated. 

A non-return/one way valve, situated on the corona reactor ensures that no ozone gas escapes. 

This ozone infused water is then pumped into the electrochemical reactor units. The Group noted 

that according to the Applicant, the reactor unit is fitted to the suction side of the pump, in order 

to create sufficient mechanical cavitation, and cavitation inserts are also housed within the 

cavitation chamber. The Applicant describes mechanical cavitation as the main treatment 

method and states that cavitation is enhanced (data deemed to be confidential and removed at the 

request of the submitting Administration).
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ANNEX 7 

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 Ballasting 

Î Î Î Î Î 

 De-ballasting Í

Figure 3: Schematic process diagram of BWMS 

3.1.4 The Group noted that according to the Applicant, (data deemed to be confidential and 

removed at the request of the submitting Administration) Sodium hypochlorite (NaOCl) is also 

produced at the electrodes and together with the ozone gas, these two Active Substances perform 

the disinfection step on the ballast water. Finally, the water flow then passes through the pump, 

and is pumped through the filter under pressure. Residual concentrations of 

the Active Substances then assist in maintaining a sterile environment within the ballast tanks. 

No treatment is performed at discharge. 

3.1.5 As the BWMS does not require the storage of chemicals on board ship, the Group 

recognized that there will not be any associated storage safety problems. 

3.1.6 Therefore, the Group recognized that this application for Final Approval focuses on the 

system components and operations for ballast water treatment during uptake. A full-scale 

land-based test facility has been built at Cape Town Harbour capable of testing the Resource 

Ballast Technologies System for flow rates of 200 m3

/hour to 1500 m3/hour. The land-based test 

facility is situated on M-Berth within the Port of Cape Town, South Africa. 

3.2 Safety and control 

3.2.1 The Group noted that the Resource Ballast Technologies land-based test facility in 

Cape Town is configured with manual valves and switches that allow for the individual testing of 

each component. The Applicant states, when the BWMS is installed into a vessel, all components 

operate automatically, and are controlled by a programmable logistic computer (PLC), installed 

into the Electrical Control Panel (ECP). 

Ozonation Filtration 

Ballast 

Water 

Tanks 

Electrolysis Cavitation
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ANNEX 7 

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3.2.2 The Group noted that according to the Applicant, ozone gas is generated within the ozone 

cell at a pre-determined and preset amount according to the BWMS requirements. Ozone gas is 

drawn into the venturi from the ozone cell. The venturi fitted to the system operates within 

certain vacuum parameters that can vary depending on the flow of water through the venturi. In 

the event that the flow is either increased or decreased, due to varying pumping conditions such 

as back pressure or a reduction thereof, the venturi suction ability is directly influenced. Should 

the water flow through the venturi increase so will the suction capacity of the venturi increase. 

This directly affects the flow of ambient air through the ozone cell, thereby increasing the 

amount of available oxygen that can be converted into ozone gas. Should the flow of water 

through the venturi decrease, the amount of negative pressure created at the venturi will decrease 

proportionally, this reduced flow through the venturi will thus reduce the volume of air drawn 

into the ozone cell. As such the ozone production will decrease accordingly. 

3.2.3 The Group noted that according to the Applicant, control of the electrochemical reactor 

and thus production of NaOCl is via the electrochemically activated rectifier, which is controlled 

with the use of a Frequency Modulated Switch Mode Power Supply. 

3.3 Active Substances (AS), Relevant Chemicals (RC) and Other Chemicals (OC)

3.3.1 The Group noted that there are two Active Substances involved in this BWMS – ozone 

produced from oxygen in ambient air and sodium hypochlorite formed by electrolysis of ballast 

water. Moreover, the Group recalled the chemical reactions involved in the electrolysis of 

natural seawater and fresh water, as reviewed and described in detail for the evaluation of 

Basic Approval of the BWMS. Hypochlorite ions or Free Active Chlorine (FAC) are produced at 

the cathode of the electrolytic cell. They are highly reactive and decay within a few 

nanoseconds, producing chloride ions. Ozone is also very unstable and, after injection into raw 

water (e.g., natural seawater or fresh water), decomposes very rapidly, depending on conditions 

(half-life of a few seconds or minutes). In addition, chlorine gas (Cl2) and hydrogen gas (H2) are 

produced at the electrodes. Chlorine gas will decay to chloride ions. 

3.3.2 In addition, the Group recalled that in seawater, ozone and hypochlorite ions react with 

bromide ions to produce Relevant Chemicals hypobromous acid (HOBr) and hypobromite 

(OBr–), which are in equilibrium with one another, together with other brominated derivatives. 

These compounds have disinfection properties in addition to the Active Substances. Halogenated 

by-products (Other Chemicals), like trihalomethanes (THM) and halogenated acetic acids 

(HAA), are also formed by a reaction with natural organic matter in the water. 

3.3.3 The Group noted that in fresh water, ozone breaks down more slowly (minutes rather than 

seconds) into oxygen and water. The rate of decomposition increases with the presence of 

organic impurities and increasing pH. As pH increases, ozone turns into the very short-lived 

(microseconds) hydroxyl radicals (•OH). 

3.3.4 The Group recalled that hypochlorite ions can be referred to as Free Active Chlorine 

(FAC), whilst the halogenated oxidants (HOBr/OBr- and HOCl/OCl-) are referred to as Free 

Residual Oxidants (FRO), with the term Total Residual Oxidants (TRO) also including the 

halogenamines. FAC, FRO and TRO are expressed as mg Cl2/L. The Group noted that the 

Applicant has provided analyses of treated ballast water for Active Substances, Relevant 

Chemicals and Other Chemicals as part of this application for Final Approval. Thus ozone, 

hypochlorite, chlorine gas and hydroxyl radicals were all assessed together as total residual 

oxidants (TRO) and free residual oxidants (FRO) using standard colorimetric methods 
GESAMP-BWWG 10/6 

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(HACH DR2800 spectrophotometer; DPD powder pillow method). Results of these chemical 

analyses of ballast water are presented in a detailed series of tables in the appendix to this report. 

3.3.5 The Group recognized the detailed nature of these analytical results and summarized the main 

features as follows: 

Samples of water covering a range of different salt concentrations: natural seawater, brackish 

water and freshwater, and differing organic content: high organic (DOC >>1 mg/L) and low 

organic content (DOC <1 mg/L) were analysed on site and/or submitted to independent 

analytical laboratories in South Africa and Switzerland for characterization (see tables in 

appendix). Seawater samples comprised natural seawater drawn from the Port of Cape 

Town, fresh water samples were drawn from the City of Cape Town municipal drinking 

water supply and were filtered through a 50 micron spun-wound filter in an effort to 

reduce pre-existing background levels of chlorine breakdown products, and brackish 

water comprised a mixture of water from these two sources. The dissolved organic 

carbon (DOC) and particulate organic carbon (POC) of the natural seawater and 

municipal drinking water were both low (<1 mg/L) and were thus supplemented with 

barley malt to examine the effects of higher organic content on the production 

of Active Substances and their breakdown products. A broad range of DOC and POM 

concentrations in the “high organic” samples was recorded for freshwater samples 

(DOC: 117-567 mg/L, POM: 40-97%), brackish water samples (DOC: 3.3-274 mg/L, 

POM: 22-100%), seawater samples (DOC: 21-416 mg/L, POM: 81-100%) (see tables in 

appendix). 

3.3.6 The Group noted that TRO concentrations (expressed as mg Cl2/L) in treated ballast water 

ranged from 0.1-1.0 mg/L (average: 0.3 mg/L) and in the filter backwash water 

from 0.1 mg/L-0.8 mg/L (average: 0.2 mg/L). FRO concentrations (expressed as mg Cl2/L) in treated 

ballast water ranged from 0.0-0.7 mg/L (average: 0.2 mg/L) and in the filter backwash water 

from 0.0-0.6 mg/L (average: 0.2 mg/L). No significant relationships were evident between salinity 

and TRO or salinity and FRO, although both TRO and FRO were consistently low in treated 

freshwater and variable in brackish water and full strength seawater. This is assumed by the 

Applicant to be related to the lack of chlorine species (in the form of NaCl) in the fresh water and the 

rapid breakdown of ozone gas introduced into the water from the ozone generator. 

3.3.7 The Group noted that concentrations of Total Residual Oxidants (TRO) and Free Residual 

Oxidants (FRO) in treated ballast water and in filter backwash were similar for all three water 

types (natural seawater, fresh water, and brackish water) covering both high (DOC >>1 mg/L) 

and low organic levels (DOC < 1 mg/L). This suggests that the filter backwash water is unlikely 

to be any more toxic to biota than treated ballast water, at least in respect of the concentrations of 

TRO and FRO present. 

3.3.8 The Group recognized the detailed results of analyses of ballast water for disinfection 

by-products (DBP) or Other Chemicals, notably trihalomethanes (THM) and haloacetic acids (HAA). 

THM were preserved immediately after treatment and sent to ERWAT Laboratories for analysis 

(see tables in appendix). The results indicated that there was little time for the formation of DBP 

when samples were preserved immediately after treatment (immediate discharge scenario). A second 

series of tests were thus conducted in which samples were preserved with ascorbic acid 3 hours 

and 5 days after treatment and after which samples were analysed for the major THM. According to 

the Applicant, it was decided to preserve samples 3 hours after treatment as this was found to be the 

average time that it takes to fill and drain a 200 m3

 simulated ballast tank. 
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3.3.9 The Group noted the concentrations of the four THM as determined by Rand Water 

Analytical Laboratories using the headspace method. Concentration of the full suite of volatile 

organic compounds (VOCs) in the treated, control and filter backwash samples were determined 

by ERWAT laboratories using the purge and trap technique followed by GC-MS. Little or no 

THM or other volatile organic species were detected in measurable concentrations (i.e. 1 μg/L) in 

the treated natural seawater, brackish water or fresh water samples fixed with ascorbic acid 

immediately after treatment (see tables in appendix). However, a single THM species was 

detected in natural seawater, fresh water and brackish water samples preserved with ascorbic acid 

after three hours and those preserved after five days, this being bromoform. Concentrations of 

bromoform in all of these samples ranged from <0.5 μg/L up to 12.0 μg/L, averaging 4.4 μg/L. 

Thus, bromoform is included as a Relevant Chemical in this application. No significant 

relationships were evident between salinity and concentration of bromoform or between 

Dissolved Organic Carbon and bromoform. 

3.3.10 The Group noted the concentration of HAA in the treated, control and filter backwash 

samples as assessed by NanoSep laboratory using GS-MS according to EPA method 552.2. Only 

a single HAA species was detected in measurable concentrations (i.e. > 0.5 μg/L) in the treated 

natural seawater and municipal freshwater, this being dibromoacetic acid (DBAA, see tables in 

appendix). Concentrations in these samples ranged from <0.5 1 μg/L up to 13.1 μg/L, averaging 

3.16 μg/L. DBAA was also detected in similar concentration in the brackish water (mixture of 

natural seawater and municipal drinking water) along with a second HAA species −

dichloroacetic acid (DCAA). However, concentrations of DCAA were similar between the 

control and treated samples suggesting that the BWMS was not the source of the DCAA and that 

it was present in the municipal drinking water. Thus, DBAA is included as a Relevant Chemical 

in this application. No significant relationship was evident between salinity and concentration of 

DBAA but a significant negative correlation was evident between DBAA concentration 

and Dissolved Organic Carbon. Concentrations of DBAA in treated ballast water and in filter 

backwash were similar for all three water types (natural seawater, fresh water, and brackish 

water) covering both high (DOC >>1 mg/L) and low organic levels (DOC < 1 mg/L). 

This suggests that the filter backwash water is unlikely to be any more toxic to biota than treated 

ballast water, at least in respect of the concentrations of DBAA present. 

3.3.11 The Group noted the concentrations of bromate in seawater, brackish water and 

municipal water with high and low organic concentrations treated with the BWMS. Three 

replicate test cycles were performed for each water type, and samples were analysed by EAWAG 

laboratory, Switzerland, using High Performance Ion Chromatography (HPIC) with a post 

column-reaction and UV-detection. Every sample was measured at least twice and every second 

sample was verified by spiking bromate. The quantification limit was at 5 μg/L for freshwater 

samples and 10 μg/L for seawater and brackish water samples. The higher quantification limit for 

the latter samples is due to the strong matrix interferences encountered in seawater and brackish 

water. Immediately after collection samples were placed on ice, kept in the dark and couriered 

to ERWAT laboratory, Switzerland, for analysis. The Group recognized that concentrations of 

bromate in all seawater and brackish water samples (high and low organic content) were below 

the detection limit of 10 μg/L, and thus fall below the US EPA and Health Canada guidelines 

of 10 μg/L. The concentration of bromate in all freshwater samples fell below the detection limit 

of 5 μg/L and thus also fall below recommended guidelines in drinking water (see tables in 

appendix). 
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3.3.12 The Group recognized the comprehensive nature of the data sets provided by the 

Applicant on the analysis of Active Substances, Relevant Chemicals and Other Chemicals in 

treated ballast water. From chemical analyses of seawater, brackish water and fresh water 

samples treated using the BWMS, the chemicals listed in Table 2 have been identified as Active 

Substances or Relevant Chemicals. 

Table 2: Active Substances (AS) and Relevant Chemicals (RC) identified in 

water treated with the BWMS 

Chemical 

Name 

CAS 

number 

Molecular 

Mass 

Empirical 

formula 

Structural 

formula 

Maximum 

concentration

in treated 

ballast water 

AS or 

RC 

Ozone (TRO) 10028-15-6 48 O3 O=O–O 0.8 mg/L* AS 

Sodium 

hypochlorite 

(TRO) 

7681-52-9 74.4 NaClO 0.8 mg/L* AS 

Hydroxyl 

radical 

3352-57-6 17.01 HO* OH - RC 

Hydrogen gas 01333-74-0 2.015 H2 H – H - RC 

Chlorine gas 7782-50-5 70.9 Cl2 Cl – Cl - RC 

Bromoform 75-25-2 252.73 CHBr3 12.0 μg/L RC 

Dibromoacetic 

acid 

631-64-1 217.84408 C2H2Br2O2 13.1 μg/L RC 

*

 This is the maximum concentration of Total Residual Oxidants in water samples treated with the BWMS. Note 

that Ozone is dosed at an estimated rate of 1 mg/L. Thus, concentrations of TRO in the reactor chamber 

(the sum of all TRO including Ozone) are probably somewhat higher than those reported here but these 

substances decay so rapidly (within a few minutes) that by the time measurements can be taken concentrations 

have already fallen below 1 mg/L. 

4 HUMAN HEALTH ASSESSMENT

4.1 Assessment of exposure to ship’s crew 

4.1.1 The Group was satisfied with the information provided by the Applicant concerning 

hazard identification and occupational exposure assessment of chemicals and by-products 

generated by the BWMS. 

4.1.2 The Group recognized that under all operating conditions, the event of ozone leakage in 

the compartment where the BWMS is located is very unlikely. 

4.1.3 Bromate was not detected in any of the water samples treated using the BWMS 

(MDL 10 μg/L); nevertheless the Applicant recommended additional PPE/RPE to the crew when 

entering ballast tanks. 
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4.1.4 Bromoform was detected at concentration levels of 12 μg/L in the treated ballast water. 

According to the Applicant ́s human exposure assessment, the following calculation was 

performed: using the Mackay model level III, and assuming a partition into the atmosphere 

of 3.25%, the crew could be exposed by inhalation to 0.0017 g/m3

 of bromoform in the ballast 

tank. Taking into account several assumptions (crew member works 5 h/d, once a month, 

weighs 60 kg, breathing volume of 10 m3

 in a 5 h-shift), the exposure was calculated 

as 0.195 mg/kg bw. A MOS of 3.6 was derived based on Minimum Risk Level (MRL) 0.7 mg/kg bw/day. 

The risk was concluded as being acceptable for inhalation exposure to the crew. Notwithstanding 

this, the Applicant recommended additional PPE/RPE when entering ballast tanks. 

4.1.5 Dibromoacetic acid (DBAA) was detected at concentration levels of 13.1 μg/L in the 

treated ballast water. Based on the low Henry’s constant, the Group considered that human 

exposure to this substance would not be of concern. 

4.1.6 The Group recognized that risks associated with crew exposure to hydrogen gas and chlorine 

gas produced by the electrochemical reactor have been assessed by the Applicant and proven to be 

acceptable through estimating the rate of production for these gases using desk-based methods and by 

monitoring gas concentrations in the header space of a 200 m3

 simulation ballast tank. 

4.2 Exposure of general public through the environment and food chain 

4.2.1 The Group addressed the potential risk of general public exposure to the disinfectant 

by-products present in the treated ballast water by comparing the concentration levels of THM 

and HAA measured in the treated ballast water with standards for DW Quality (WHO, 2006) and 

safe recreational water environments, volume 1: coastal and fresh waters (WHO, 2003). 

4.2.2 The Group noted that the maximum concentrations of bromoform, dibromoacetic acid 

and TRO (Cl2) measured in 100% treated ballast water were well below the guideline values 

recommended as protective for human exposure in the above-mentioned WHO Guidelines 

(see Table 23 below). Bromate, a disinfection by-product of concern to human health was below 

detection limits in 100% treated ballast water. 
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4.2.3 The Group considered that the risk to the general public by exposure to Active Substances 

and Other Chemicals present in the treated ballast water to be acceptable. 

4.3 Conclusion on Human Health Assessment 

4.3.1 Therefore, the Group was satisfied that results of the human health assessment show that 

the BWMS poses no unacceptable risk to ships’ crew (BWMS operators included) and to the 

general public. 

5 RISKS TO SAFETY OF THE SHIP, ITS CREW AND THE GENERAL PUBLIC

5.1 Safety of the Ship 

5.1.1 The Group noted that specific countermeasures that can be employed in this system to 

deal with envisaged emergency and safety problems during the ballast water treatment have been 

summarized above. In particular, a summary of the various safety measures developed by the 

Applicant is given above in section 3.2. 

5.1.2 The Group noted that the Applicant has submitted assessments of the effects of seawater 

and fresh water treated using the BWMS on the corrosion of ballast tank steel and ballast tank 

coatings through a desk-based literature review and through accelerated corrosion tests 

undertaken by Chemical Investigation Services and the Centre for Materials Engineering, 

University of Cape Town, respectively. The Group noted that reports prepared from these 

studies are included in appendix 10 of the Applicant dossier. 

5.1.3 The Group concurred with the Applicant that the treated ballast water should have no 

significant increase in corrosion rates to ballast water tanks or other equipment in the ship, 

compared with normal seawater, as hypochlorite (FAC) is added to the ballast water up to a 

maximum allowable concentration of 1 mg/L (TRO as Cl2) which is recognized as the lower 

limit for any corrosive effect from chlorine. 

5.2 Safety of the Crew 

5.2.1 The Group considered that risk to safety of the ships’ crew (BWMS operators included) 

by exposure to chemicals and treated ballast water is judged to be acceptable based on the 

measures developed by the Applicant for installation on board ship. A summary of the various 

safety measures developed by the Applicant is given above in section 3.2. The Group considered 

the risk to ships’ crew is appropriately managed based on the facts that the Active Substances are 

produced automatically and in situ as well as that system components are adopted that are 

expected to minimize the exposure risk of ships’ crew to chemicals and ballast water before and 

after treatment. 

5.3 Safety of the General Public 

5.3.1 It was reasonably considered by the Group that the system has an acceptable risk to the health 

of the general public in light of the outcome of results of human risk assessment presented above. 
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6 ENVIRONMENTAL RISK ASSESSMENT 

6.1 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T) 

6.1.1 The Group recalled that as corroborated at the Basic Approval, neither the 

Active Substances nor the Relevant Chemicals are classified as PBT substances. The Group 

noted that, in order to re-confirm the situation, the Applicant has made a further comprehensive 

listing of P, B and T criteria for the Active Substances and Relevant Chemicals, with summarized 

results being presented in Table 3. 

Table 3: PBT evaluation of Active Substances and Relevant Chemicals 

(as provided by the Applicant)

 Persistent 

(y/n) 

Bioaccumulative 

(y/n) 

Toxic 

(y/n) 

Ozone No No Yes

Free active chlorine No No Yes

Bromoform Yes No Yes

Bromate No No Yes

Hydrogen No No No 

Dibromoacetic acid No No Yes 

6.1.2 Based on these results, the Group concluded that these chemicals should not be classified 

as PBT-substances. 

6.2 Ecotoxicity testing of treated ballast water 

6.2.1 The Group noted that in this section, the results of acute and chronic aquatic ecotoxicity 

studies performed by the Applicant with 100% treated ballast water as a test substance are 

presented in accordance with the “Procedure for approval of ballast water management systems 

that make use of Active Substances (G9)”. 

6.2.2 The Group recognized that whole effluent ecotoxicity tests were conducted to assess 

acute aquatic ecotoxicity of natural seawater treated with the BWMS to a range of marine 

species. Tests were conducted by Anchor Environmental Consultants CC, South Africa. 

Full details on the methods used to conduct these tests and results obtained are provided in 

appendix 7 of the Applicant dossier and are summarized below. The Group noted that the acute 

aquatic ecotoxicity studies report submitted was exactly the same as that submitted for Basic 

Approval. Six local marine and/or estuarine species: a marine sea weed Gracilaria verrucosa; a 

crustacean Diogenes brevirostris; two species of gastropod mollusc Bullia digitalis and Haliotis 

midae; and two species of fish Liza richardsonii and Psammogobius knysnaensis were exposed 

to five concentrations of treated ballast water (TBW) (100%, 50%, 25%, 12.5% and 6.25%) 

in 96-hour flow through tests. Five identical, replicate experimental tanks were stocked 

with 10 similar sized individuals of each species (n = 300 per trial) for each concentration and for 

a control of untreated seawater. TBW was diluted and pumped through the experimental tanks 

immediately post treatment with the BWMS. Water quality measurements (salinity, temperature, 

pH and dissolved oxygen) and chemical analyses of dissolved organic carbon, free chlorine and 

trihalomethanes were undertaken daily during experimental trials. 
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6.2.3 The Group noted that growth of G. verrucosa was inhibited in 100% TBW (IC50 = 59%). 

All of the invertebrates tested survived the 96-hour experiments and no obvious adverse effects 

were detected in any concentration of TBW. Both species of fish suffered 100% mortality in 

the 100% TBW treatment while 50% TBW also caused 100% mortality for P. knysnaensis 

(LC50 = 35% TBW) but had no effect on L. richardsonii (LC50 = 72% TBW). A follow-up static 

toxicity test using P. knysnaensis was conducted with TBW that was held in a simulated ballast 

tank for 24 to 48 hours. After both 24 hours and 48 hours, TBW had no observed effect on P. 

knysnaensis (n = 60) at 100% concentration during a five-day test. Chemical analysis confirmed 

that total chlorine levels dropped to about one-third of immediately post-treatment levels within 

24 hours and to below detection limits after 72 hours. Disinfection by-products created by the 

BWMS were limited to low concentrations of bromoform (0-9 μg/L), which was well below 

published values that are known to be toxic to marine organisms. 

6.2.4 The Group recognized that whole effluent chronic aquatic ecotoxicity tests were 

conducted on three trophic levels of marine organisms in order to assess the potential ecotoxicity 

of BWMS treated ballast water (TBW) to marine life. Tests were conducted by Anchor 

Environmental Consultants CC, South Africa. Full details on the methods used to conduct these 

tests and results obtained are provided in appendix 8 of the Applicant dossier and are 

summarized below. Tests were conducted on one species of fish (Liza richardsonii), one 

invertebrate (Tripneustes gratilla) and one alga (Skeletonema costatum). A 28-day fish juvenile 

growth test (OECD 215) was employed to assess chronic ecotoxicity to fish, a 72-hour algal 

growth inhibition test was used to determine toxic effects on algae (ISO 10253:2006 (E)), and the 

sea urchin fertilization test (1 hour and 10 minutes) was used to assess ecotoxicity to 

invertebrates (Standard Methods, 2005, EPA-821-R-02-014). 

6.2.5 The Group noted that organisms were exposed to five concentrations of TBW 

(100%, 50%, 25%, 12.5% and 6.25%) over varying periods of time, and sublethal endpoints were 

used to calculate no observed effect concentrations (NOEC), lowest observed effect 

concentrations (LOEC) and inhibition concentrations where applicable. Liza richardsonii did not 

show any significant reduction in growth at 100% TBW, and thus the NOEC was estimated to be 

100% TBW. Similarly the algal growth inhibition test with Skeletonema costatum did not result 

in significant growth inhibition at 100% TBW, and NOEC was estimated at 100% TBW. The 

sea urchin fertilization test with Tripneustes gratilla was the most sensitive chronic test, with a 

NOEC of 50% TBW and a LOEC of 100% TBW. The IC25 and IC50 concentrations for the sea 

urchin fertilization test were calculated to be 57.73% and 72.35%, respectively. Although the 

Group noted that the algal toxicity test indicated that the control did not match the validity 

criteria in the method stated in their report the tests were considered valid the other organisms. 

The Group decided to finally to accept it as the Group did in other evaluations as well. 

6.2.6 Therefore in summary, the Group noted that six acute aquatic ecotoxicity tests and three 

chronic aquatic ecotoxicity tests on a total of seven local marine and/or estuarine species were 

conducted using seawater treated with the BWMS. Ecotoxicity tests were conducted on one 

seaweed species, one unicellular algal species, a crustacean, two gastropod species and two fish 

species. From the acute ecotoxicity tests, the most sensitive species was found to be the fish 

P.knysnaensis (LC50 = 35% TBW, NOEC = 25% TBW), and the most sensitive species from the 

chronic ecotoxicity tests was the sea urchin T.gratilla (NOEC = 50% TBW and LOEC = 100% 

TBW). The Group concluded that dilution of the TBW by around four-fold upon discharge to 

the environment would be needed to reach a concentration less than the most sensitive NOEC 

value obtained in the aquatic ecotoxicity testing. 
GESAMP-BWWG 10/6 

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6.3 Risk assessments of chemicals for aquatic organisms 

6.3.1 Predicted Environmental Concentrations (PEC) 

6.3.1.1 The Group noted that predicted environmental concentrations (PEC) of bromoform, 

dibromoacetic acid and TRO were estimated using the MAMPEC version 2.0 simulation model for a 

worst case scenario “OECD commercial harbour”. The MAMPEC model was developed for the 

leaching of anti-fouling paints from ships and it calculates the steady state concentration of pollutants 

assuming a permanent source is present. The model was developed by Delft Hydraulics (DELTARES) 

and the Free University, Amsterdam. The MAMPEC “OECD commercial harbour” scenario is based 

on the Rotterdam harbour in the Netherlands, which is situated along a large estuarine river 2 km from 

the mouth (OECD, 2005). The harbour may have additional flushing from a small river or urban 

drainage system discharging at the rear of the harbour (OECD, 2005). According to the Applicant, in 

order to estimate the PEC of bromoform, dibromoacetic acid and TRO entering the port of Rotterdam, 

it is necessary to know the amount of ballast water discharged daily into the Port. An inventory 

conducted by the Port of Rotterdam in February 2008 revealed that ballast water intake for 2008 

amounted to 6.13 million m3 and total ballast water discharge to 2.76 million m3 

(Port of Rotterdam, 2008). This indicates that the port of Rotterdam is mainly a ballast water exporting 

port. The results of discharge in the report are also considered to be worst case scenario due to the fact 

that a number of vessels will take in and/or discharge ballast water during their voyage, while the 

inventory assumed that all ballast water was taken in/discharged directly into the harbour (Port of 

Rotterdam, 2008). In order to calculate a daily discharge of ballast water, the monthly discharge 

quantity was divided by 29, giving an estimated daily release of 95,172.4 m3

/day. 

6.3.1.2 In the case of the PEC for bromoform, the Group noted that the Applicant used the 

maximum concentration of bromoform in seawater treated with the BWMS. This corresponded 

to 12 μg/L (see section 3.3 above). Bromoform was assumed to be persistent with no abiotic, 

biological or photolytic degradation (worst case scenario). Given the discharge of 95,172.4 m3 ballast 

water per day, this would result in worst case scenario daily release of 1142.06 g bromoform per day 

(maximum). The PEC of bromoform in a standard OECD “commercial harbour” are summarized 

below (Table 4), and reveal a maximum PEC of 0.0706 μg/L in the harbour and the surrounding 

waters for worst case scenario of maximum bromoform concentration. 

Table 4: PEC of bromoform in an OECD “commercial harbour” scenario determined 

using MAMPEC version 2.0 with a maximum bromoform concentration 

of 12 μg/l and a daily emission rate of 1142.06 g/d 

 Unit In harbour In surrounding waters 

Maximum concentration μg/L 0.0706 0.00400 

95% concentration μg/L 0.0686 0.00344 

Average concentration μg/L 0.0257 0.000724 

Median concentration μg/L 0.00842 0.00140 

Minimum Concentration μg/L 0.00125 0.000707 
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6.3.1.3 In the case of the PEC for dibromoacetic acid (DBAA), the Group noted that the 

Applicant used the maximum concentration of DBAA in seawater treated with the BWMS. 

This corresponded to 13.1 μg/L (see section 3.3 above). DBAA was assumed to be persistent 

with no abiotic, biological or photolytic degradation (worst case scenario). Given the discharge 

of 95,172 m3 ballast water per day, containing 13.1 μg/L DBAA, this would result in worst case 

scenario daily release of 1246.75 g DBAA per day. The PEC of DBAA in a standard OECD 

“commercial harbour” are summarized below (Table 5), and reveal a maximum PEC 

of 0.111 μg/L in the harbour and the surrounding waters. 

Table 5: PEC of DBAA in an OECD “commercial harbour” scenario determined using 

MAMPEC version 2.0 with a maximum DBAA concentration 

of 13.1 μg/L and a daily emission rate of 1246.75 g/d 

 Unit In harbour In Surrounding Waters 

Maximum concentration μg/L 0.111 0.005 

95% concentration μg/L 0.109 0.00446 

Average concentration μg/L 0.0387 0.000894 

Median concentration μg/L 0.0103 0.00177 

Minimum Concentration μg/L 0.00104 0.000872 

6.3.1.4 In the case of the PEC for TRO, the Group noted that the Applicant used the maximum 

concentration of TRO in seawater treated with the BWMS, this corresponded to 0.8 mg/L 

(see section 3.3 above). Given the discharge of 95,172 m3 ballast water per day, 

containing 0.8 mg/L TRO, this would result in worst case scenario daily release of 76,137.92 g 

TRO per day. The PEC of TRO in a standard OECD “commercial harbour” are summarized 

below (Table 6), and reveal a maximum PEC of 0.135 μg/L in the harbour and the surrounding 

waters. 

Table 6: PEC of TRO in an OECD “commercial harbour” scenario determined using 

MAMPEC version 2.0 with a maximum TRO concentration of 0.8 mg/L 

and a daily emission rate of 76,137.92 g/d 

 Unit In harbour In Surrounding 

Waters 

Maximum concentration μg/L 0.135 0.011 

95% concentration μg/L 0.133 0.0107 

Average concentration μg/L 0.056 0.00221 

Median concentration μg/L 0.0412 0.00457 

Minimum Concentration μg/L 0.00889 0.00191 

6.3.2 Predicted No Effect Concentrations (PNEC) and PEC/PNEC Ratios 

6.3.2.1 The Group noted that predicted no effect concentrations (PNEC) for bromoform and 

dibromoacetic acid were determined using data from the most sensitive of the ecotoxicity tests 

performed on treated ballast water - chronic sea urchin fertilization test (see section 6.2 above). 

Since TRO concentrations were below the detection limits for the sea urchin test, the PNEC 

for TRO was estimated using the results from the P.knysnaensis acute test (see section 6.2 

above). Bromoform and dibromoacetic acid were the only Relevant Chemicals present in the 

treated ballast water used for the sea urchin test, with concentrations of 2.7 μg/L (bromoform) 

and 1.7 μg/L (dibromoacetic acid) in the NOEC of 50% treated ballast water (TBW). The 

maximum concentration of TRO in 25% TBW from the most sensitive acute test was 0.12 mg/L. 
GESAMP-BWWG 10/6 

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6.3.2.2 The Group noted that according to the Applicant, the sea urchin fertilization test is known to be 

a very sensitive short-term chronic test. It is important to note that in this case the sea urchin fertilization 

test was exceptionally sensitive, resulting in NOEC concentrations for bromoform and dibromoacetic 

acid that are well below those reported by the literature: Japan Basic Approval NOECbromoform = 2.9 

mg/L, PNECbromoform = 0.29 mg/L, PNECdibromoacetic acid = 6.9 μg/L (MEPC, 2006). (Note, though, 

that chronic toxicity test results reported in document MEPC 55/2 “Basic Approval of Active 

Substances used by Special Pipe Ballast Water Management System”, submitted by Japan, 

indicate no obvious toxicity was noted for three groups of organisms at levels above 160 μg/L 

bromoform). The Group recognized that PNEC values for bromoform, dibromoacetic acid and 

TRO were calculated using NOEC data from the relevant chronic and acute ecotoxicity tests 

using an assessment factor (AF) of 10. The Group also noted that no toxic effects were observed 

in 100% TBW in the chronic algae and fish tests (see section 6.2 above), further highlighting the 

sensitivity of the sea urchin fertilization test. The PNEC values were thus calculated as follows: 

PNECbromoform = 2.7 μg/L / 10 = 0.27 μg/L; 

PNECdibromoacetic acid = 1.7 μg/L / 10 = 0.17 μg/L; and 

PNECTRO = 0.12 mg/L / 10 = 0.012 mg/L. 

6.3.2.3 The Group recognized that PEC/PNEC ratios for harbour water for bromoform, 

dibromoacetic acid and TRO are presented below in Table 7. 

Table 7: PEC, PNEC and PEC/PNEC ratios for bromoform, dibromoacetic acid and 

TRO produced by the treatment of ballast water using the BWMS 

Bromoform 

 Ballast water discharge of 

Maximum bromoform 

concentration (12.0 μg/L) 

 Harbour 

PEC (μg/L) 0.0706 

PNEC (μg/L) 0.27 

PEC/PNEC 0.261 

Dibromoacetic acid (DBAA) 

 Ballast water discharge of 

Maximum DBAA concentration 

(13.1 μg/L) 

 Harbour 

PEC (μg/L) 0.111 

PNEC (μg/L) 0.17 

PEC/PNEC 0.65 

TRO 

 Ballast water discharge of 

Maximum TRO concentration 

(0.8 mg/L) 

 Harbour 

PEC (μg/L) 0.135 

PNEC (μg/L) 12.0 

PEC/PNEC 0.01125 
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6.3.2.4 The Group accepted that the PEC/PNEC ratio is less than 1 for all these chemicals of 

concern, and the Group agreed that there is no unacceptable risk to the aquatic environment in a 

“OECD commercial harbour” scenario – particularly as these calculations have assumed several 

stacked worst cases. Just to be sure, the Group decided, that since PNEC for TRO was calculated 

from acute data instead of chronic data, to also determine PEC/PNEC ratios if assessment factors 

of 100 and 1000 were applied. The PNEC for TRO applying an AF of 100 is 1.2 μg/L, which 

results in a PEC/PNEC ratio of 0.1125. 

6.4 Determination of holding time for treated ballast water 

6.4.1 The Group noted that decay experiments were conducted in order to determine the 

minimum holding time necessary to reduce TRO and FRO concentrations to below 0.1 mg/L 

(as Cl2). The decay of residual oxidant concentrations (total and free) was measured in natural 

seawater and brackish water under simulated ballast water treatment conditions. Decay rates 

were faster for FRO than TRO, and decay rates for brackish water were greater than those for 

seawater. The Group noted from the results that it is evident that TRO and FRO decrease most 

rapidly 30 minutes after treatment and reach concentrations of <0.1 mg/L (as Cl2) after 3 hours 

using seawater sourced locally at the testing facility. To ensure that the TRO at discharge 

remains below the MADC, the Group recommended that a TRO monitoring and recording 

function be included at discharge. 

6.5 Conclusion from environmental risk assessment 

6.5.1 The Group accepted that the above discussion and calculations confirm that there is no 

unacceptable risk to the aquatic environment from use of this BWMS, and discharge of treated 

ballast water directly into the harbour should pose no unacceptable risk to the aquatic 

environment. It was however noted by the Group that the sea urchin toxicity test was conducted 

using ballast water that was at least 21⁄2 hours old, in which TRO concentrations were 

undetectable. In order to make the assumption that treated ballast water is not toxic to the 

immediate receiving environment, the Group agreed with the Applicant that the treated ballast 

water is held for a minimum of 3 hours before release. This is also the amount of time required 

for almost complete decay of total residual oxidants (TRO <0.1 mg/L as Cl2), and thus holding 

ballast water for this period would provide a further safeguard against exposure of organisms to 

oxidants. This agrees well with the outcome from the ecotoxicity testing of treated ballast water 

where the Group concluded that dilution of the TBW by around four-fold upon discharge to the 

environment would be needed to reach a concentration less than the most sensitive NOEC value 

obtained in the aquatic ecotoxicity testing. As an additional safeguard, to ensure that the TRO at 

discharge remains below the MADC, the Group recommended that a TRO monitoring and 

recording function be included at discharge. 

7 CONCLUSIONS AND RECOMMENDATIONS

7.1 Risks to safety of the ship 

7.1.1 The Group noted that the specific countermeasures to be employed in this system to deal 

with envisaged emergency and safety problems during the ballast water treatment have been well 

described and discussed above, and as such the Group considered that the Resource Ballast 

Technologies System should present no unacceptable risks to the safety of the ship. 
GESAMP-BWWG 10/6 

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Page 29 

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7.2 Risks to the crew and general public 

7.2.3 The Group considered that the Resource Ballast Technologies System has no 

unacceptable risk to the health of the crew and the general public regarding the exposure to 

chemicals and treated ballast water based on the submitted human exposure assessment and the 

mitigation measures developed by the Applicant for installation on board ship. 

7.3 Risks to the environment 

7.3.1 Having reviewed all of the information submitted with this application, the Group 

accepted the view of the Applicant that there should be no unacceptable risks to the environment 

posed by the use of this BWMS, based on the maximum allowable discharge concentration 

(MADC) and a minimum holding time for treated ballast water of 3 hours as follows: 

MADC of Ozone and Sodium hypochlorite (TRO) = 0.1 – 0.2 mg/L (as Cl2) 

As an additional safeguard, to ensure that the TRO at discharge remains below the MADC, the 

Group recommended that a TRO monitoring and recording function be included at discharge. 

The Group noted that the monitored TRO is less than MADC, the system could discharge its 

treated ballast water even with holding time less than 3 hours. 

7.4 Recommendation 

7.4.1 In conclusion, having reviewed all the information provided by the Applicant, the Group 

agreed to recommend to the MEPC that Final Approval be granted to the Resource Ballast 

Technologies System, provided that all the recommendations given in this report are taken into 

account. 

* * * 
GESAMP-BWWG 10/6 

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Page 30 

I:\MEPC\60\2-11.doc 

APPENDIX 

RESULTS OF CHEMICAL ANALYSIS OF TREATED BALLAST WATER 

The Applicant has carried out detailed analyses of treated ballast water for Active Substances, 

Relevant Chemicals and Other Chemicals as part of this application for Final Approval. Results 

of these chemical analyses of ballast water are presented in a detailed series of tables in this 

appendix. 

* * * 
I:\MEPC\60\2-11.doc Table A1: Chemical analysis of natural seawater samples treated with the RBT reactor (Treat), as well as samples c

(Filter), and control samples collected prior to treatment (Control). Three replicate samples of each tyapart and analysed immediately on site (Salinity, TRO, FRO) or submitted to accredited laboratories for 

CSIR Analytical Laboratories; Haloacetic acids – Naosep Laboratories; VOC – ERWAT Laboratory Serv

Samples analysed for VOCs were preserved with the reducing reagent ascorbic acid (625 mg/L). Certifi

(aCSIR 099P, bNanoSep 0810367, cEAWAG 01, dERWAT 2008/11/169). 

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Salinity PSU 37.1 36.7 36.9 36.9 37.0 TRO mg Cl/l nd 0.67 0.28 0.01 0.79 FRO mg Cl/l nd 0.59 0.23 0.03 0.28 DOC (filtered)a mg/L 0.29 0.29 0.29 0.33 0.24 DOC (unfiltered)a mg/L 0.39 0.61 0.56 0.61 0.5 TSSa mg/L 51.7 50.4 90.9 52.1 11.7 POMa % 1.849 1.236 5.455 2.207 - Bromateb μg/l <10 <10 <10 <10 <10 Haloacetic acidscchloroacetic acid μg/l nd nd nd nd nd bromoacetic acid μg/l nd nd nd nd nd dichloroacetic acid μg/l nd nd nd nd nd trichloroacetic acid μg/l nd nd nd nd nd bromochloroacetic acid μg/l nd nd nd nd nd dibromoacetic acid μg/l <0.5 6.7 2.4 <0.5 13.1 bromodichloroacetic acid μg/l nd nd nd nd nd chlorodibromoacetic acid μg/l nd nd nd nd nd tribromoacetic acid μg/l nd nd nd nd nd dVolatile organic compounds 
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m + p - Xylenes μg/l <1 <1 <1 <1 <1 Bromoform μg/l <1 <1 3 <1 <1 Styrene μg/l <1 <1 <1 <1 <1 o-Xylene μg/l <1 <1 <1 <1 <1 1,1,2,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 1,2,3-Trichloropropane μg/l <1 <1 <1 <1 <1 Isopropylbenzene μg/l <1 <1 <1 <1 <1 Bromobenzene μg/l <1 <1 <1 <1 <1 2-Chlorotoluene μg/l <1 <1 <1 <1 <1 n-Propylbenzene μg/l <1 <1 <1 <1 <1 4-Chlorotoluene μg/l <1 <1 <1 <1 <1 1,3,5-Trimethylbenzene μg/l <1 <1 <1 <1 <1 tert-Butylbenzene μg/l <1 <1 <1 <1 <1 1,2,4-Trimethylbenzene μg/l <1 <1 <1 <1 <1 1,3-Dichlorobenzene μg/l <1 <1 <1 <1 <1 sec-Butylbenzene μg/l <1 <1 <1 <1 <1 1,4-Dichlorobenzene μg/l <1 <1 <1 <1 <1 4-Isopropyltoluene μg/l <1 <1 <1 <1 <1 1,2-Dichlorobenzene μg/l <1 <1 <1 <1 <1 n-Butylbenzene μg/l <1 <1 <1 <1 <1 1,2-Dibromo-3-chloropropane μg/l <1 <1 <1 <1 <1 1,2,4-Trichlorobenzene μg/l <1 <1 <1 <1 <1 Naphthalene μg/l <1 <1 <1 <1 <1 1,2,3-Trichlorobenzene μg/l <1 <1 <1 <1 <1 Hexachlorobutadiene μg/l <1 <1 <1 <1 <1 Trichlorofluoromethane μg/l <1 <1 <1 <1 <1 
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1,1-Dichloroethene μg/l <1 <1 <1 <1 <1 Trans-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 1,1-Dichloroethane μg/l <1 <1 <1 <1 <1 Cis-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 2,2-Dichloropropane μg/l <1 <1 <1 <1 <1 Bromochloromethane μg/l <1 <1 <1 <1 <1 Chloroform μg/l <1 <1 <1 <1 <1 1,1,1-Trichloroethane μg/l <1 <1 <1 <1 <1 1,2-Dichloroethane μg/l <1 <1 <1 <1 <1 1,1-Dichloropropene μg/l <1 <1 <1 <1 <1 Carbon Tetrachloride μg/l <1 <1 <1 <1 <1 Benzene μg/l <1 <1 <1 <1 <1 Fluorobenzene μg/l <1 <1 <1 <1 <1 1,2-Dichloropropane μg/l <1 <1 <1 <1 <1 Trichloroethene μg/l <1 <1 <1 <1 <1 Dibromomethane μg/l <1 <1 <1 <1 <1 Bromodichloromethane μg/l <1 <1 <1 <1 <1 Trans-1,3,-Dichloropropene μg/l <1 <1 <1 <1 <1 Cis-1,3-Dichloropropene μg/l <1 <1 <1 <1 <1 Toluene μg/l <1 <1 <1 <1 <1 1,1,2-Trichloroethane μg/l <1 <1 <1 <1 <1 1,3-Dichloropropane μg/l <1 <1 <1 <1 <1 Dibromochloromethane μg/l <1 <1 <1 <1 <1 1,2-Dibromoethane μg/l <1 <1 <1 <1 <1 Tetrachloroethene μg/l <1 <1 <1 <1 <1 
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ANNEX 7 Page 34 I:\MEPC\60\2-11.doc Table A2: Chemical analysis of natural seawater supplemented with barley malt to increase the dissolved organic c

(POM) content and treated with the RBT reactor (Treat), as well as samples collected when the filte

samples collected prior to treatment (Control). Three replicate samples of each type were collected apimmediately on site (Salinity, TRO, FRO) or submitted to accredited laboratories for analysis in South 

Laboratories; Haloacetic acids – Naosep Laboratories; VOC – ERWAT Laboratory Services) and Sw

analysed for VOCs were preserved with the reducing reagent ascorbic acid (625 mg/L). Certificat

(aCSIR 100, bNanoSep 0810370, cEAWAG 01, dERWAT 2008/11/169) 

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Salinity PSU 36.7 36.5 37 36.3 36.8 36.7 36.8 3TRO 

mg 

Cl/l nd 0.14 0.16 nd 0.16 0.18 nd 0

FRO 

mg 

Cl/l nd 0.13 0.07 nd 0.13 0.08 nd 0

DOC (filtered)a mg/L 54 24 30 42 24 47 29 DOC (unfiltered)a mg/L 610 96 38 178 96 159 108 TSSa mg/L 59 41 392 102 242 544 59 2POMa % 52 49 58 36 51 81 29 Bromateb μg/l <10 <10 <10 <10 <10 <10 <10 <Haloacetic acidscchloroacetic acid μg/l nd nd nd nd nd nd nd bromoacetic acid μg/l nd nd nd nd nd nd nd dichloroacetic acid μg/l nd nd nd nd nd nd nd trichloroacetic acid μg/l nd nd nd nd nd nd nd bromochloroacetic acid μg/l nd nd nd nd nd nd nd dibromoacetic acid μg/l nd nd 1.8 nd 0.8 1.4 <0.5 <bromodichloroacetic acid μg/l nd nd nd nd nd nd nd chlorodibromoacetic acid μg/l nd nd nd nd nd nd nd 
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tribromoacetic acid μg/l nd nd nd nd nd nd nd dVolatile organic compounds m + p - xylenes μg/l <1 <1 <1 <1 <1 <1 <1 Bromoform μg/l <1 <1 3 <1 <1 2 <1 Styrene μg/l <1 <1 <1 <1 <1 <1 <1 o-Xylene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,2,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2,3-Trichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Isopropylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 Bromobenzene μg/l <1 <1 <1 <1 <1 <1 <1 2-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 n-Propylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 4-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 1,3,5-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 tert-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2,4-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,3-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 sec-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,4-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 4-Isopropyltoluene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 n-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dibromo-3-chloropropane μg/l <1 <1 <1 <1 <1 <1 <1 1,2,4-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 Naphthalene μg/l <1 <1 <1 <1 <1 <1 <1 1,2,3-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 
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Hexachlorobutadiene μg/l <1 <1 <1 <1 <1 <1 <1 Trichlorofluoromethane μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Trans-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 Cis-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 2,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Bromochloromethane μg/l <1 <1 <1 <1 <1 <1 <1 Chloroform μg/l <1 <1 <1 <1 <1 <1 <1 1,1,1-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Carbon Tetrachloride μg/l <1 <1 <1 <1 <1 <1 <1 Benzene μg/l <1 <1 <1 <1 <1 <1 <1 Fluorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Trichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Dibromomethane μg/l <1 <1 <1 <1 <1 <1 <1 Bromodichloromethane μg/l <1 <1 <1 <1 <1 <1 <1 Trans-1,3,-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Cis-1,3-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Toluene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,2-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,3-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Dibromochloromethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dibromoethane μg/l <1 <1 <1 <1 <1 <1 <1 
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Tetrachloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Chlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,1,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 Ethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 
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ANNEX 7 Page 38 I:\MEPC\60\2-11.doc Table A3: Chemical analysis of a mixture natural seawater with municipal drinking water treated with the RBT reactor (Tr

unit was backwashed (Filter), and control samples collected prior to treatment (Control). Municipal drin

spun-wound filter prior to testing and treatment in an effort to reduce pre-existing background levels of chlorinof each type were collected approximately 30 minutes apart and analysed immediately on site (Salinity, TRO, Fanalysis in South Africa (DOC, TSS, POM – CSIR Analytical Laboratories; Haloacetic acids – Naosep Labor

and Switzerland (Bromate – EAWAG). Samples analysed for VOCs were preserved with the reducing reaanalysis are included in appendix 13 (aCSIR 105, bNanoSep 0810374, cEAWAG 01, dERWAT 2008/11/169) 

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Salinity PSU 19.78 19.39 19.81 19.58 19.8 20.03 20.1 19TRO mg Cl/l nd 0.4 0.32 nd 0.59 0.4 nd 0FRO mg Cl/l nd 0.3 0.29 nd 0.44 0.31 nd 0DOC (filtered)a mg/L 1.1 0.9 0.8 1.2 1 1 1 0DOC (unfiltered)a mg/L 1.3 1.2 1.1 1.4 1.1 1.4 1.1 TSSa % 3 4 3 3 3 4 3 POMa mg/L 41 28 45 38 34 35 38 3Bromateb μg/l <10 <10 <10 <10 <10 <10 <10 <Haloacetic acidscchloroacetic acid μg/l nd nd nd nd nd nd nd nbromoacetic acid μg/l 0.5 nd nd nd nd nd 0.5 ndichloroacetic acid μg/l 1.5 4.8 <0.5 1 4.4 nd 1 <trichloroacetic acid μg/l nd nd nd nd nd nd nd nbromochloroacetic acid μg/l nd nd nd nd nd nd nd ndibromoacetic acid μg/l <0.5 2.3 0.6 <0.5 1 <0.5 <0.5 1bromodichloroacetic acid μg/l nd nd nd nd nd nd nd nchlorodibromoacetic acid μg/l nd nd nd nd nd nd nd ntribromoacetic acid μg/l nd nd nd nd nd nd nd n
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dVolatile organic 

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m+p-xylenes μg/l <1 <1 <1 <1 <1 <1 <1 <Bromoform μg/l <1 1 2 <1 1 2 <1 Styrene μg/l <1 <1 <1 <1 <1 <1 <1 <o-Xylene μg/l <1 <1 <1 <1 <1 <1 <1 <1,1,2,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 <1,2,3-Trichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 <Isopropylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 <Bromobenzene μg/l <1 <1 <1 <1 <1 <1 <1 <2-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 <n-Propylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 <4-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 <1,3,5-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 <tert-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 <1,2,4-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 <1,3-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 <sec-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 <1,4-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 <4-Isopropyltoluene μg/l <1 <1 <1 <1 <1 <1 <1 <1,2-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 <n-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 <1,2-Dibromo-3-chloropropane μg/l <1 <1 <1 <1 <1 <1 <1 <1,2,4-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 <Naphthalene μg/l <1 <1 <1 <1 <1 <1 <1 <1,2,3-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 <
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Hexachlorobutadiene μg/l <1 <1 <1 <1 <1 <1 <1 <Trichlorofluoromethane μg/l <1 <1 <1 <1 <1 <1 <1 <1,1-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 <Trans-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 <1,1-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 <Cis-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 <2,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 <Bromochloromethane μg/l <1 <1 <1 <1 <1 <1 <1 <Chloroform μg/l 17 19 19 3 9 18 18 11,1,1-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 <1,2-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 <1,1-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 <Carbon Tetrachloride μg/l <1 <1 <1 <1 <1 <1 <1 <Benzene μg/l <1 <1 <1 <1 <1 <1 <1 <Fluorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 <1,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 <Trichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 <Dibromomethane μg/l <1 <1 <1 <1 <1 <1 <1 <Bromodichloromethane μg/l 4 5 5 1 3 5 4 Trans-1,3,-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 <Cis-1,3-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 <Toluene μg/l <1 <1 <1 <1 <1 <1 <1 <1,1,2-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 <1,3-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 <Dibromochloromethane μg/l 1 2 2 <1 <1 2 2 1,2-Dibromoethane μg/l <1 <1 <1 <1 <1 <1 <1 <
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Tetrachloroethene μg/l <1 <1 <1 <1 <1 <1 <1 <Chlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 <1,1,1,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 <Ethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 <
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ANNEX 7 Page 42 I:\MEPC\60\2-11.doc Table A4: Chemical analysis of a mixture natural seawater with municipal drinking water, supplemented with b

carbon (DOC) and particulate organic matter (POM) content, and treated with the RBT reactor (Treat), unit was backwashed (Filter), and control samples collected prior to treatment (Control). Municipal drin

spun-wound filter prior to testing and treatment in an effort to reduce pre-existing background levels of c

samples of each type were collected approximately 30 minutes apart and analysed immediately on accredited laboratories for analysis in South Africa (DOC, TSS, POM – CSIR acids – Naosep Laboratories; VOC – ERWAT Laboratory Services) and Switzerland (Bromate – EA

preserved with the reducing reagent ascorbic acid (625 mg/L). Certificates of analysis are included in a

cEAWAG 01, dERWAT 2008/11/169) 

Chemical 

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BH01 

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T

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B

Salinity PSU 17.48 18.15 17.53 12.24 13.8 13.84 26.8 TRO mg Cl/l nd 0.15 0.16 nd 0.12 0.12 nd FRO mg Cl/l nd 0.13 0.06 nd 0.11 0.06 nd DOC (filtered)a mg/L 12.2 3.3 0.9 75 51.8 26.6 115 DOC (unfiltered)a mg/L 27.4 21.1 30.8 98.4 68.4 32.8 191.7 TSSa % 52 51 80 57 76 22 96 POMa mg/L 79 75 95 71 72 100 145 Bromateb μg/l <10 <10 <10 <10 <10 <10 <10 Haloacetic acidscchloroacetic acid μg/l nd nd nd nd nd nd nd bromoacetic acid μg/l nd 0.7 <0.5 nd nd <0.5 <0.5 dichloroacetic acid μg/l 5.4 4 3.2 5.1 5.6 1.9 1.4 trichloroacetic acid μg/l nd nd nd nd nd nd nd bromochloroacetic acid μg/l nd nd nd nd nd nd nd dibromoacetic acid μg/l 0.7 1.3 1.9 1 1.9 0.9 <0.5 bromodichloroacetic acid μg/l nd <0.5 nd <0.5 <0.5 nd nd chlorodibromoacetic acid μg/l nd nd nd nd nd nd nd tribromoacetic acid μg/l nd nd nd nd nd nd nd 
I:\MEPC\60\2-11.doc 

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T

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B

dVolatile organic compounds m + p-xylenes μg/l <1 <1 <1 <1 <1 <1 <1 Bromoform μg/l 2 2 3 3 2 1 <1 Styrene μg/l <1 <1 <1 <1 <1 <1 <1 o-Xylene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,2,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2,3-Trichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Isopropylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 Bromobenzene μg/l <1 <1 <1 <1 <1 <1 <1 2-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 n-Propylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 4-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 1,3,5-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 tert-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2,4-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,3-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 sec-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,4-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 4-Isopropyltoluene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 n-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dibromo-3-chloropropane μg/l <1 <1 <1 <1 <1 <1 <1 1,2,4-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 Naphthalene μg/l <1 <1 <1 <1 <1 <1 <1 1,2,3-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 Hexachlorobutadiene μg/l <1 <1 <1 <1 <1 <1 <1 Trichlorofluoromethane μg/l <1 <1 <1 <1 <1 <1 <1 
GESAMP-BWWG 10/6 

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Chemical 

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BH07 

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BH02 

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BH08 

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BH03 

T

T

B

1,1-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Trans-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 Cis-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 2,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Bromochloromethane μg/l <1 <1 <1 <1 <1 <1 <1 Chloroform μg/l 17 20 24 32 27 12 8 1,1,1-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Carbon Tetrachloride μg/l <1 <1 <1 <1 <1 <1 <1 Benzene μg/l <1 <1 <1 <1 <1 <1 <1 Fluorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Trichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Dibromomethane μg/l <1 <1 <1 <1 <1 <1 <1 Bromodichloromethane μg/l 4 5 6 8 6 3 2 Trans-1,3,-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Cis-1,3-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Toluene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,2-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,3-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Dibromochloromethane μg/l 2 2 5 4 3 1 <1 1,2-Dibromoethane μg/l <1 <1 <1 <1 <1 <1 <1 Tetrachloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Chlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,1,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 Ethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 
I:\MEPC\60\2-11.doc Table A5: Chemical analysis of municipal drinking water treated with the RBT reactor (Treat), as well as samples c

(Filter), and control samples collected prior to treatment (Control). Municipal drinking water was filte

prior to testing and treatment in an effort to reduce pre-existing background levels of chlorine breakdow

type were collected approximately 30 minutes apart and analysed immediately on site (Salinity, TRO, FR

analysis in South Africa (DOC, TSS, POM – CSIR Analytical Laboratories; Haloacetic acids – Naosep Services) and Switzerland (Bromate – EAWAG). Samples analysed for VOCs were preserved with the 

Certificates of analysis are included in appendix 13 (aCSIR 009P, b

dERWAT 2008/11/169). 

Chemical 

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FL01 

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FL04 

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F

Salinity PSU 0.3 0.3 0.4 0.3 0.2 0.2 0.2 TRO mg Cl/l 0.02 0.09 0.07 nd 0.06 0.06 0.06 FRO mg Cl/l 0.04 0.07 0.02 nd 0.03 0.02 0.02 DOC (filtered)a mg/L 1.09 1.13 1.17 1.09 1.09 1.34 1 DOC (unfiltered)a mg/L 1.38 1.52 1.76 1.57 1.38 1.48 1.38 TSSa mg/L 5.3 2.4 4.7 3.2 2.8 3.2 2.3 POMa μg/l <5 <5 <5 <5 <5 <5 <5 Bromatebchloroacetic acid μg/l nd nd nd nd nd nd nd bromoacetic acid μg/l nd nd nd nd nd nd nd dichloroacetic acid μg/l nd nd nd nd nd nd nd trichloroacetic acid μg/l nd nd nd nd nd nd nd bromochloroacetic acid μg/l nd nd nd nd nd nd nd dibromoacetic acid μg/l <0.5 1 3.4 <0.05 2.6 2 <0.5 bromodichloroacetic acid μg/l nd nd nd nd nd nd nd chlorodibromoacetic acid μg/l nd nd nd nd nd nd nd tribromoacetic acid μg/l nd nd nd nd nd nd nd dVolatile organic compounds 
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F

m+p-xylenes μg/l <1 <1 <1 <1 <1 <1 <1 Bromoform μg/l 3 <1 <1 <1 <1 <1 <1 Styrene μg/l <1 <1 <1 <1 <1 <1 <1 o-Xylene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,2,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2,3-Trichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Isopropylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 Bromobenzene μg/l <1 <1 <1 <1 <1 <1 <1 2-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 n-Propylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 4-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 1,3,5-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 tert-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2,4-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,3-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 sec-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,4-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 4-Isopropyltoluene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 n-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dibromo-3-chloropropane μg/l <1 <1 <1 <1 <1 <1 <1 1,2,4-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 Naphthalene μg/l <1 <1 <1 <1 <1 <1 <1 1,2,3-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 Hexachlorobutadiene μg/l <1 <1 <1 <1 <1 <1 <1 Trichlorofluoromethane μg/l <1 <1 <1 <1 <1 <1 <1 
I:\MEPC\60\2-11.doc 

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1,1-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Trans-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 Cis-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 2,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Bromochloromethane μg/l <1 <1 <1 <1 <1 <1 <1 Chloroform μg/l 41 3 7 <1 8 6 1,1,1-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Carbon Tetrachloride μg/l <1 <1 <1 <1 <1 <1 <1 Benzene μg/l <1 <1 <1 <1 <1 <1 <1 Fluorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Trichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Dibromomethane μg/l <1 <1 <1 <1 <1 <1 <1 Bromodichloromethane μg/l 10 1 2 <1 2 2 Trans-1,3,-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Cis-1,3-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Toluene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,2-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,3-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Dibromochloromethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dibromoethane μg/l 3 <1 <1 <1 <1 <1 <1 Tetrachloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Chlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 
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Chemical 

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1,1,1,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 Ethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 
I:\MEPC\60\2-11.doc Table A6: Chemical analysis of municipal drinking water, supplemented with barley malt to increase the dissolved o

matter (POM) content, and treated with the RBT reactor (Treat), as well as samples collected when the filsamples collected prior to treatment (Control). Municipal drinking water was filtered through an 40 m

treatment in an effort to reduce pre-existing background levels of chlorine breakdown products. Three r

approximately 30 minutes apart and analysed immediately on site (Salinity, TRO, FRO) or submitted to 

Africa (DOC, TSS, POM – CSIR Analytical Laboratories; Haloacetic acids – Naosep Laboratories; 

Switzerland (Bromate – EAWAG). Samples analysed for VOCs were preserved with the reducing reage

analysis are included in appendix 13 (aCSIR 100, bNanoSep 0810370, cEAWAG 01, dERWAT 2008/11/16

Chemical 

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Sample ID Salinity PSU 0.12 1.01 2.84 4.15 0.5 1.95 0.12 TRO 

mg 

Cl/l nd 0.07 0.07 nd 0.05 0.06 0.02 

FRO 

mg 

Cl/l nd 0.02 0.07 nd 0.05 0.03 0.03 

DOC (filtered)a mg/L 187 225 222 215 338 178 311 DOC (unfiltered)a mg/L 315 355 320 415 415 375 445 TSSa % 69 84 74 68 68 97 73 POMa mg/L 34 39 55 83 36 52 33 Bromateb μg/l <5 <5 <5 <5 <5 <5 <5 Haloacetic acidscchloroacetic acid μg/l nd nd nd nd nd nd nd bromoacetic acid μg/l nd nd nd nd nd nd nd dichloroacetic acid μg/l nd nd nd nd nd nd nd trichloroacetic acid μg/l nd nd nd nd nd nd nd bromochloroacetic acid μg/l nd nd nd nd nd nd nd dibromoacetic acid μg/l nd 1.7 2.1 nd nd 1.4 nd bromodichloroacetic acid μg/l nd nd nd nd nd nd nd 
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ANNEX 7 Page 50 I:\MEPC\60\2-11.doc 

Chemical 

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chlorodibromoacetic acid μg/l nd nd nd nd nd nd nd tribromoacetic acid μg/l nd nd nd nd nd nd nd dVolatile organic compounds m+p-xylenes μg/l <1 <1 <1 <1 <1 <1 <1 Bromoform μg/l <1 <1 <1 <1 <1 <1 <1 Styrene μg/l <1 <1 <1 <1 <1 <1 <1 o-Xylene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,2,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2,3-Trichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Isopropylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 Bromobenzene μg/l <1 <1 <1 <1 <1 <1 <1 2-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 n-Propylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 4-Chlorotoluene μg/l <1 <1 <1 <1 <1 <1 <1 1,3,5-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 tert-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2,4-Trimethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,3-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 sec-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,4-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 4-Isopropyltoluene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 n-Butylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dibromo-3-chloropropane μg/l <1 <1 <1 <1 <1 <1 <1 1,2,4-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 Naphthalene μg/l <1 <1 <1 <1 <1 <1 <1 1,2,3-Trichlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 
I:\MEPC\60\2-11.doc 

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Hexachlorobutadiene μg/l <1 <1 <1 <1 <1 <1 <1 Trichlorofluoromethane μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Trans-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 Cis-1,2-Dichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 2,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Bromochloromethane μg/l <1 <1 <1 <1 <1 <1 <1 Chloroform μg/l 10 3 2 8 7 8 10 1,1,1-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,1-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Carbon Tetrachloride μg/l <1 <1 <1 <1 <1 <1 <1 Benzene μg/l <1 <1 <1 <1 <1 <1 <1 Fluorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,2-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Trichloroethene μg/l <1 <1 <1 <1 <1 <1 <1 Dibromomethane μg/l <1 <1 <1 <1 <1 <1 <1 Bromodichloromethane μg/l 2 <1 <1 2 2 2 2 Trans-1,3,-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Cis-1,3-Dichloropropene μg/l <1 <1 <1 <1 <1 <1 <1 Toluene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,2-Trichloroethane μg/l <1 <1 <1 <1 <1 <1 <1 1,3-Dichloropropane μg/l <1 <1 <1 <1 <1 <1 <1 Dibromochloromethane μg/l 1 <1 <1 <1 <1 <1 <1 1,2-Dibromoethane μg/l <1 <1 <1 <1 <1 <1 <1 Tetrachloroethene μg/l <1 <1 <1 <1 <1 <1 <1 
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Chlorobenzene μg/l <1 <1 <1 <1 <1 <1 <1 1,1,1,2-Tetrachloroethane μg/l <1 <1 <1 <1 <1 <1 <1 Ethylbenzene μg/l <1 <1 <1 <1 <1 <1 <1 
I:\MEPC\60\2-11.doc Table A7: Chemical analysis of natural seawater samples treated with the RBT reactor (Treat), as well as samples c

(Filter), and control samples collected prior to treatment (Control). Three replicate samples of each ty

apart and analysed immediately on site (Salinity, TRO, FRO) or submitted to accredited laboratories for CSIR Analytical Laboratories; THMs – Rand Water Analytical Services). Samples analysed for THMs 

prescribed by Rand Water) after 3 hours to allow TROs present in the treated water to breakdown and readisinfection by-products. Duplicate samples were kept for 5 days in the dark after which they were 

submitted to Rand Water for analysis. Certificates of analysis are included in appendix 

cRand Water 2008/853). 

Chemical 

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SL03 

Salinity PSU 35.5 34.6 35.2 35.5 35.1 35.2 35.5 TRO mg Cl/l 0.01 0.57 0.3 nd 0.65 0.15 0.02 FRO mg Cl/l 0.02 0.5 0.41 nd 0.46 0.21 0.02 DOC (filtered) a mg/L <1 <1 <1 <1 <1 <1 <1 DOC (unfiltered) a mg/L <1 <1 <1 <1 <1 <1 <1 TSSa mg/L 6 70 20 5 37 12 4 POMa % 100 30 41 100 40 57 94 Trihalomethanesbbromodichloromethane μg/l <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 bromoform μg/l <0.543 6.2 8.2 <0.543 7.2 7.6 <0.543 chloroform μg/l <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 dibromochloromethane μg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 
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ANNEX 7 Page 54 I:\MEPC\60\2-11.doc 

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dibromochloromethane μg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 

 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 

Percentage increase/decrease of THMs in 5-day old samples 5-Day Old samples c Test 1 

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dibromochloromethane μg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 

 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 

Percentage increase/decrease of THMs in 5-day old samples bromodichloromethane % 0 0 0 0 0 0 0 bromoform % 0 54.8 22.0 0.0 - 15.8 0.0 chloroform % 0 0 0 0 0 0 0 dibromochloromethane % 0 0 0 0 0 0 0 
I:\MEPC\60\2-11.doc Table A8: Chemical analysis of natural seawater, supplemented with barley malt to increase the dissolved organic 

(POM) content, and treated with the RBT reactor (Treat), as well as samples collected when the filte

samples collected prior to treatment (Control). Three replicate samples of each type were collected ap

immediately on site (Salinity, TRO, FRO) or submitted to accredited laboratories for analysis in South Laboratories; THMs – Rand Water Analytical Services). Samples analysed for THMs were preserveby Rand Water) after 3 hours to allow TROs present in the treated water to breakdown and react disinfection by-products. Duplicate samples were kept for 5 days in the dark after which they were submitted to Rand Water for analysis. Certificates of analysis are included in appendix 13 (aCSIR 198, bR

Chemical 

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SH03 

Salinity PSU 34.9 34.4 35.7 34.4 35.2 35.2 35.2 TRO mg Cl/l nd 0.11 0.18 nd 0.28 0.19 nd FRO mg Cl/l 0.03 0.04 0.16 0.02 0.1 0.09 0.03 DOC (filtered)a mg/L 92 567 58 416 394 401 117 DOC (unfiltered)a mg/L 1594 367 79 575 472 283 199 TSSa mg/L 223 207 293 140 142 324 243 POMa % 100 100 100 81 100 100 94 Trihalomethanesbbromodichloromethane μg/l <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 bromoform μg/l <0.543 2.2 12 <0.543 10 3.8 <0.543 chloroform μg/l <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 dibromochloromethane μg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 
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ANNEX 7 Page 56 I:\MEPC\60\2-11.doc 

5-Day Old samples Test 1 

Control 

SH16 

Test 1 

Treat 

SH10 

Test 1 

Filter 

SH13 

Test 2 

Control 

SH17 

Test 2 

Treat 

SH11 

Test 2 

Filter 

SH14 

Test 3 

Control 

SH18 

bromodichloromethane μg/l <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 bromoform μg/l <0.543 0.83 11 <0.543 9.9 1.1 <0.543 chloroform μg/l <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 dibromochloromethane μg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 Percentage increase/decrease of THMs in 5-day old samples bromodichloromethane % 0.0 0.0 0.0 0.0 0.0 0.0 0.0 bromoform % 0.0 -62.3 -8.3 0.0 -1.0 -71.1 0.0 chloroform % 0.0 0.0 0.0 0.0 0.0 0.0 0.0 dibromochloromethane % 0.0 0.0 0.0 0.0 0.0 0.0 0.0 
I:\MEPC\60\2-11.doc Table A9: Chemical analysis of a mixture natural seawater with municipal drinking water treated with the RBT 

when the filter unit was backwashed (Filter), and control samples collected prior to treatment (Contrthrough a 40 micron spun-wound filter prior to testing and treatment in an effort to reduce pre-existinproducts. Three replicate samples of each type were collected approximately 30 minutes a(Salinity, TRO, FRO) or submitted to accredited laboratories for analysis in South Africa (DOC, TSS, PO

Rand Water Analytical Services). Samples analysed for THMs were preserved with ascorbic ac

after 3 hours to allow TROs present in the treated water to breakdown and react with organic matter to pDuplicate samples were kept for 5 days in the dark after which they were preserved with ascorbic acianalysis. Certificates of analysis are included in appendix 13 (aCSIR 198, bRand Water2008/841, cRand W

Chemical 

Test 1 

Control 

BL01 

Test 1 

Treat 

BL04 

Test 1 

Filter 

BL07 

Test 2 

Control 

BL02 

Test 2 

Treat 

BL05 

Test 2 

Filter 

BL08 

Test 3 

Control 

BL03 

Salinity PSU 19.85 19.62 20.23 22.3 22.2 20.15 20.64 TRO mg Cl/l nd 0.43 0.24 nd 0.27 0.19 nd FRO mg Cl/l 0.02 0.43 0.17 nd 0.16 0.13 nd DOC (filtered) a mg/L <1 <1 <1 <1 <1 <1 <1 DOC (unfiltered) a mg/L <1 <1 <1 <1 <1 <1 <1 TSSa mg/L 45 10 17 15 12 37 21 POaM % 89 62 54 66 60 37 36 Trihalomethanesbbromodichloromethane μg/l 2.6 3 2.9 2 2.6 2.9 2.7 bromoform μg/l <0.543 8.6 8.9 <0.543 8.4 10 <0.543 chloroform μg/l 14 16 14 10 13 15 14 dibromochloromethane μg/l 1.8 2.5 2.4 1.5 2.2 2.6 1.7 
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ANNEX 7 Page 58 I:\MEPC\60\2-11.doc 

THMs in samples produced via RBT treatment (treat/filter – control) 

Test 1 

Control 

BL01 

Test 1 

Treat 

BL04 

Test 1 

Filter 

BL07 

Test 2 

Control 

BL02 

Test 2 

Treat 

BL05 

Test 2 

Filter 

BL08 

Test 3 

Control 

BL03 

bromodichloromethane μg/l - 0.4 0.3 - 0.6 0.9 - bromoform μg/l - 8.6 8.9 - 8.4 10 - chloroform μg/l - 2 0 - 3 5 - dibromochloromethane μg/l - 0.7 0.6 - 0.7 1.1 - 5-Day Old samples c Test 1 

Control 

BL16 

Test 1 

Treat 

BL10 

Test 1 

Filter 

BL13 

Test 2 

Control 

BL17 

Test 2 

Treat 

BL11 

Test 2 

Filter 

BL14 

Test 3 

Control 

BL18 

bromodichloromethane μg/l 3.1 3.5 3.4 2.7 2.9 md md bromoform μg/l 0.8 12 11 0.59 7 md md chloroform μg/l 17 18 17 16 15 md md dibromochloromethane μg/l 2.2 3.4 3.1 1.9 2.6 md md Percentage increase/decrease of THMs in 5-day old samples bromodichloromethane % 19.23 16.67 17.24 35.00 11.54 - bromoform % 47.33 39.53 23.60 8.66 -16.67 - chloroform % 21.43 12.50 21.43 60.00 15.38 - dibromochloromethane % 22.22 36.00 29.17 26.67 18.18 Note: md denotes missing data due to incomplete laboratory report supplied by Rand Water 
I:\MEPC\60\2-11.doc Table A10: Chemical analysis of a mixture natural seawater with municipal drinking water, supplemented with b

carbon (DOC) and particulate organic matter (POM) content, and treated with the RBT reactor (Treat), 

unit was backwashed (Filter), and control samples collected prior to treatment (Control). Municipal drin

spun-wound filter prior to testing and treatment in an effort to reduce pre-existing background levels of c

samples of each type were collected approximately 30 minutes apart and analysed immediately on accredited laboratories for analysis in South Africa (DOC, TSS, POM – CSIR Analytical Laboratories

Samples analysed for THMs were preserved with ascorbic acid (5.2 g/l as prescribed by Rand Water) 

treated water to breakdown and react with organic matter to produce to relevant disinfection bfor 5 days in the dark after which they were preserved with ascorbic acid (5.2 g/l) and submitted to Rand 

are included in appendix 13 (aCSIR 198, bRand Water2008/844, cRand Water 2008/857. 

Chemical 

Test 1 

Control 

BH01 

Test 1 

Treat 

BH04 

Test 1 

Filter 

BH07 

Test 2 

Control 

BH02 

Test 2 

Treat 

BH05 

Test 2 

Filter 

BH08 

Test 3 

Control 

BH03 

Salinity PSU 19.6 19.5 19.6 19.9 19.5 19.5 19.9 TRO mg Cl/l 0.03 0.16 0.14 0.02 0.1 0.13 0.01 FRO mg Cl/l nd 0.08 0.1 nd nd 0.09 nd DOC (filtered) a mg/L 232 260 264 218 241 274 254 DOC (unfiltered) a mg/L 261 311 300 233 267 322 289 TSSa mg/L 147 96 434 109 124 306 129 POMa mg/L 98 97 87 100 100 85 100 Trihalomethanesbbromodichloromethane <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 bromoform <0.543 <0.543 <0.543 <0.543 <0.543 0.63 <0.543 chloroform 11 13 12 11 13 13 12 dibromochloromethane <1.168 <1.169 <1.170 <1.171 <1.172 <1.173 <1.174 
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ANNEX 7 Page 60 I:\MEPC\60\2-11.doc 

THMs in samples produced via RBT treatment (treat/filter – control) 

Test 1 

Control 

BH01 

Test 1 

Treat 

BH04 

Test 1 

Filter 

BH07 

Test 2 

Control 

BH02 

Test 2 

Treat 

BH05 

Test 2 

Filter 

BH08 

Test 3 

Control 

BH03 

bromodichloromethane μg/l - 0 0 - 0 0 - bromoform μg/l - 0 0 - 0 0 - chloroform μg/l - 2 1 - 2 2 - dibromochloromethane μg/l - 0 0 - 0 0 - 5-Day Old samples c Test 1 

Control 

BH16 

Test 1 

Treat 

BH10 

Test 1 

Filter 

BH13 

Test 2 

Control 

BH17 

Test 2 

Treat 

BH11 

Test 2 

Filter 

BH14 

Test 3 

Control 

BH18 

bromodichloromethane μg/l <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 bromoform μg/l <0.543 <0.543 <0.543 <0.543 <0.543 0.63 <0.543 chloroform μg/l 14 14 14 0 16 15 14 dibromochloromethane μg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 Percentage increase/decrease of THMs in 5-day old samples bromodichloromethane % 0.00 0.00 0.00 0.00 0.00 0.00 0.00 bromoform % 0.00 0.00 0.00 0.00 0.00 0.00 0.00 chloroform % 27.27 7.69 16.67 -100.00 23.08 15.38 16.67 dibromochloromethane % 0.00 0.00 0.00 0.00 0.00 0.00 0.00 
I:\MEPC\60\2-11.doc Table A11: Chemical analysis of municipal drinking water treated with the RBT reactor (Treat), as well as samples co

(Filter), and control samples collected prior to treatment (Control). Municipal drinking water was filtered 

to testing and treatment in an effort to reduce pre-existing background levels of chlorine breakdown pro

were collected approximately 30 minutes apart and analysed immediately on site (Salinity, TRO, FRO) 

analysis in South Africa (DOC, TSS, POC – CSIR Analytical Laboratories; THMs – Rand Water Analyt

were preserved with ascorbic acid (5.2 g/l as prescribed by Rand Water) after 3 hours to allow TROs prreact with organic matter to produce to relevant disinfection by-products. Duplicate samples were kept fpreserved with ascorbic acid (5.2 g/l) and submitted to Rand Water for analysis. Certificates (aCSIR 198, bRand Water2008/841, cRand Water 2008/853). 

Chemical 

Test 1 

Control 

FL01 

Test 1 

Treat 

FL04 

Test 1 

Filter 

FL07 

Test 2 

Control 

FL02 

Test 2 

Treat 

FL05 

Test 2 

Filter 

FL08 

Test 3 

Control 

FL03 

Salinity PSU 0.18 0.2 0.24 0.24 0.1 0.15 0.1 TRO mg Cl/l nd nd nd 0.01 0.01 0.1 nd FRO mg Cl/l nd 0.02 nd 0.03 0.02 0.04 0.02 DOC (filtered) a mg/L <1 <1 <1 <1 <1 <1 <1 DOC (unfiltered) a mg/L 2 2 2 2 2 3 2 TSSa mg/L 14 7 5 11 7 6 7 POMa % 48 104 86 75 100 100 100 Trihalomethanesbbromodichloromethane μg/l 6.5 8.7 7.8 7.2 7.7 7.3 5.7 bromoform μg/l 1.8 2.8 2.6 1.4 2.1 2.6 1.1 chloroform μg/l 32 38 35 34 35 36 28 dibromochloromethane μg/l 4 4.7 5 4 4.7 4.9 3.3 
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ANNEX 7 Page 62 I:\MEPC\60\2-11.doc 

THMs in samples produced via RBT treatment (treat/filter – control) 

Test 1 

Control 

FL01 

Test 1 

Treat 

FL04 

Test 1 

Filter 

FL07 

Test 2 

Control 

FL02 

Test 2 

Treat 

FL05 

Test 2 

Filter 

FL08 

Test 3 

Control 

FL03 

bromodichloromethane μg/l - 2.2 1.3 - 0.5 0.1 - bromoform μg/l - 2.8 2.6 - 2.1 2.6 - chloroform μg/l - 6 3 - 1 2 - dibromochloromethane μg/l - 0.7 1 - 0.7 0.9 - 5-Day Old samples c Test 1 

Control 

FL16 

Test 1 

Treat 

FL10 

Test 1 

Filter 

FL13 

Test 2 

Control 

FL17 

Test 2 

Treat 

FL11 

Test 2 

Filter 

FL14 

Test 3 

Control 

FL18 

bromodichloromethane μg/l Md 8.6 8.5 7.3 9.2 7.6 8.1 bromoform μg/l Md 2.7 2.7 1.9 2.6 2.8 2.1 chloroform μg/l md 41 39 37 41 37 39 dibromochloromethane μg/l md 5.7 5.4 4.5 5.7 5.3 4.8 Percentage increase/decrease of THMs in 5-day old samples bromodichloromethane % Md -1.15 8.97 1.39 19.48 4.11 42.11 bromoform % Md -3.57 3.85 35.71 23.81 7.69 90.91 chloroform % md 7.89 11.43 8.82 17.14 2.78 39.29 dibromochloromethane % md 21.28 8.00 12.50 21.28 8.16 45.45 
I:\MEPC\60\2-11.doc Table A12: Chemical analysis of a mixture natural seawater with municipal drinking water, supplemented with barley 

(DOC) and particulate organic matter (POM) content, and treated with the RBT reactor (Treat), as well abackwashed (Filter), and control samples collected prior to treatment (Control). Municipal drinkinspun-wound filter prior to testing and treatment in an effort to reduce pre-existing background levels of chsamples of each type were collected approximately 30 minutes apart and analysed immediately on site (Sa

laboratories for analysis in South Africa (DOC, TSS, POM – CSIR Analytical Laboratories; THMs – analysed for THMs were preserved with ascorbic acid (5.2 g/l as prescribed by Rand Water) after 3 hours 

breakdown and react with organic matter to produce to relevant disinfection by-products. Duplicate sam

which they were preserved with ascorbic acid (5.2 g/l) and submitted to Rand Water for analysis. Certific

(aCSIR 198, bRand Water2008/844, cRand Water 2008/857). 

Chemical 

Test 1 

Control 

FH01 

Test 1 

Treat FH04 

Test 1 

Filter FH07 

Test 2 

Control 

FH02 

Test 2 

Treat FH05 

Test 2 

Filter FH08 

Test 3 

Control 

FH03 

Salinity PSU 0.22 0.23 0.26 0.17 0.2 0.18 0.37 TRO mg Cl/l nd nd 0.08 0.02 0.04 0.01 nd FRO mg Cl/l 0.03 0.04 nd 0.03 0.03 nd 0.03 DOC (filtered) a mg/L 416 394 401 117 274 284 567 DOC (unfiltered) a mg/L 416 394 417 117 274 289 675 TSSa mg/L 214 151 237 93 137 202 209 POMa % 45 54 38 56 75 82 40 Trihalomethanesbbromodichloromethane μg/l 4 4.2 4.6 3.8 4.6 4.2 4.4 bromoform μg/l 0.67 0.8 0.8 <0.543 0.75 0.8 0.69 chloroform μg/l 30 31 33 32 33 32 31 dibromochloromethane μg/l 1.2 1.5 1.5 <1.168 1.5 1.5 1.4 
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ANNEX 7 Page 64 I:\MEPC\60\2-11.doc 

THMs in samples produced via RBT treatment (treat/filter – control) 

Test 1 

Control 

FH01 

Test 1 

Treat FH04 

Test 1 

Filter FH07 

Test 2 

Control 

FH02 

Test 2 

Treat FH05 

Test 2 

Filter FH08 

Test 3 

Control 

FH03 

bromodichloromethane μg/l - 0.2 0.6 - 0.8 0.4 - bromoform μg/l - 0.13 0.13 - 0.75 0.8 - chloroform μg/l - 1 3 - 1 0 - dibromochloromethane μg/l - 0.3 0.3 - 1.5 1.5 - 5-Day Old samples c Test 1 

Control 

FH16 

Test 1 

Treat FH10 

Test 1 

Filter FH13 

Test 2 

Control 

FH17 

Test 2 

Treat FH11 

Test 2 

Filter FH14 

Test 3 

Control 

FH18 

bromodichloromethane μg/l 6 5.4 5.5 5.8 5.8 5.5 6 bromoform μg/l <0.543 <0.543 <0.543 0.6 <0.543 <0.543 <0.543 chloroform μg/l 30 28 27 30 29 31 30 dibromochloromethane μg/l 2.5 2.4 2.3 2.6 2.4 2.2 2.5 Percentage increase/decrease of THMs in 5-day old samples bromodichloromethane % 50.0 28.6 19.6 52.6 26.1 31.0 36.4 bromoform % 0.0 0.0 0.0 0.0 0.0 0.0 0.0 chloroform % 0.0 -9.7 -18.2 -6.3 -12.1 -3.1 -3.2 dibromochloromethane % 108.3 60.0 53.3 122.6 60.0 46.7 78.6 

___________