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

I:\MEPC\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 ORGANI SMS IN BALLAST WATER

Report of the tenth meeting of th e 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 ma in body of the GESAMP-BWWG’s reports is translated in all th e 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-Ba llast Water Working Group (GESAMP-BWWG) was held at IMO Headquarters from 14 to 18 Se ptember 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 remain ing 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 tw o meetings will be needed before MEPC 60

to evaluate all the new submissions. It wa s 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 th e interested Administrations. In accordance with the approved timetable for activities rela ted to the GESAMP-BWWG meetings, the deadline for submission of proposals to be co nsidered 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-Patrol TM Ballast Water Management System submitted by the Republic of Korea in documen t MEPC 59/2/7 (see annex 4);

.2 agree that Final Approv al not be granted to Ecochlor® Ballast Water Management System submitted by German y in document MEPC 59/2/9 (see annex 5);

.3 agree that Basic Approval be granted to SiCURE TM Ballast Water Management System submitted by Germ any in document MEPC 59/2/11(see annex 6);

.4 agree that Final Approval be grante d 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) a nd invite Members to submit their proposals for approval and the non-confid ential 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 ................. 10GESAMP-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 referen ce for the Technical Group

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

use of Active Substances – GloEn-Patrol TM Ballast Water Management System – Submitted by the Re public of Korea fo r Final Approval

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

use of Active Substances – SiCURE TM Ballast Water Management System – Submitted by Germany for Basic Approval

Annex 7 Review of proposals for approval of ba llast 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-Ba llast 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 atte nded this meeting is sh own 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 Bios afety Section, who conveyed the appreciation of the Di rector of Marine Environment Division for the effort made by

the members of the GESAMP-BWWG to have th is 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 pr oposals 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 ME PC 59, in particular, that the Committee agreed with the recommendation of the Gro up to hold a Second Stocktaking Workshop,

back-to-back to the GESAMP-BWWG 11 in Oc tober 2009, with a view to expediting the development of the new tools identified to increas e the effectiveness and efficiency of the Group. It was emphasized that, in view of the rapidl y increasing workload and the need for timely review of the proposals for approval, IMO is pr epared to take all th e possible actions to maximize the effectiveness and efficiency of th e 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 Huma n Exposure Scenario (HES) and on adapting the MAMPEC model to the specific ity of ballast water discharges and invited the members of the Group to make every effort to achieve th ese 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 prepar ing this meeting and revi ewing a large amount of documentation in a relatively short period of time.

1.6 Finally, Mr. Pughiuc reported on the contractual arrangemen ts 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 Ge rmany (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 natu re of the information was recogni zed by the Group and was treated as such in order to protect the commercial intere sts of the manufacturers concerned. In order to ensure that the report did not contain any confidential info rmation, 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 Activ e Substances (G9)”, all information gathered, materials, notes and reports obtained or ma de out during the work of the GESAMP-BWWG, were, and will be, treated as c onfidential. 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, dul y signed and dated by al l involved, were filed with the Technical Secretary of the Group and wi ll 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 worki ng 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/lapt ops 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 RELA TED TO GESAMP-BWWG MEETINGS

Timeline Activity

28 weeks before MEPC Deadline for submission of app lication dossiers and related documents to be reviewed by the GESAMP-BWWG

(8 weeks) Preparation of the meeting, includ ing 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 c onfidential data are contained in the report

(1 week) Produce the final report addressi ng 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 deadli ne (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 pla ce 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 tenta tively scheduled from 11 to 15 October 2010 and considering the activities contained in th e 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, th e Group agreed that there are a number of points arising, which it wished to bring to the atte ntion of the MEPC. These are addressed in the

rest of this section.

4.1.3 The Group recommended that Administra tions, before submitting a proposal for Final Approval to the Organization , should check and confirm whethe r 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 test s, 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 meeti ng, it was necessary to request additional information or clarification from all the Applican ts, as the dossiers were either incomplete or, more commonly, the information provided was uncl ear, so slowing down the evaluation process.

4.2 Detailed review of the submissions

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

Annex Ballast Water Management System (BWMS) Administration

4 GloEn-Patrol TM Ballast Water Management System The Republic of Korea

5 Ecochlor® Ballast Water Mana gement System Germany

6 SiCURE TM Ballast Water Management System Germany

7 Resource Ballast Technologies System South AfricaGESAMP-BWWG 10/6 - 6 -

I:\MEPC\60\2-11.doc 4.2.2 Bearing in mind the criteria related to Procedure (G9) an d having reviewed all of the information associated with these submissions, the Group recommended that:

.1 Final Approval be granted to GloEn-Patrol TM 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 SiCURE TM Ballast Water Management System (Germany); and

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

4.3 Specific comments relat ed to GloEn-Patrol TM Ballast Water Management System

4.3.1 The Group noted that the Pa nasia Co. Ltd. GloEn-Patrol TM 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 informa tion submitted by the Republic of Korea with the application for Final Approval, the Group was sa tisfied with the comple teness of the dossier

and recommended to MEPC that Final A pproval be granted to the GloEn-Patrol TM Ballast Water Management System.

4.3.3 The Group accepted the view of the Applican t that there should be no unacceptable risks to the ship, to human health or to the environm ent 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 wate r with the Active Substance chlorine dioxide by oxidation and disinfection. It was submitted for Final Approval by Germa ny.

4.4.2 The Group agreed that the information provided in the proposal submitted by Germany for Final Approval, supplemented by that provi ded by the Applicant in response to questions, was sufficient to enable an appropr iate evaluation to be made.

4.4.3 Having reviewed all the data and inform ation received, the Gr oup 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 atten tion by the Applicant in support of any further application for Final Approval in the future:

.1 The proposed discharge concentrations fo r 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, th e 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 Ac tive Substances, the provi sions 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 stor age 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 pro cess” should also be fully taken into

account.

.4 Further attention to procedures and risk mitigation measures applying to BWMS maintenance or chemical replenishm ent operations on board the ship.

.5 Additional corrosion testing should be c onducted in accordance with the guidance provided in Section 5.1 of MEPC 59/2/16.

.6 A more detailed description of arrangemen ts to be put in place for fire mitigation measures is required.

4.5 Specific comments related to SiCURE TM Ballast Water Management System

4.5.1 Siemens SiCURE TM Ballast Water Management System c onsists of filtra tion and treatment

of the ballast water with Active Substan ce sodium hypochlorite, formed by on-demand in situ electrolysis of seawater, without the additi on 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 re commend to the MEPC that Ba sic 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 st ipulated requirement for Basic Approval. However, after deliberation, the Gr oup considered that the treated ba llast water discharge ecotoxicity results were not likely to be substantially differe nt from those obtained from electrolytic systems previously considered by the Group and gran ted Final Approval by MEPC. Hence, the Group agreed to make an exception in this case and furt her agreed that the lack of submitted data could be overlooked in this particular Basic Approva l assessment. The Appli cant should provide the results of acute and chronic aquatic ecotoxicity te sting 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 comprehe nsive corrosion testing be conducted, taking into account the guidance in secti on 5.1 of the “Repor t of the eighth meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16.

.2 The Group recommended that confirmati on 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 th e chemical composition of treated ballast water caused by the us e of this BWMS.

.3 In accordance with the requirements of Procedure (G9), the Group recommended that acute and chronic aquatic ecotoxicity testing of treat ed 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 trea ted by the system. This may include control system logic to veri fy the Applicant’s claims.

.5 The Group recommended that an envir onmentally 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 th at the MADC is not exceeded, or a neutralization step. The Group recomme nded 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 an d dermal routes of exposure should be considered by the Applicant as the Group be lieves these to be more appropriate in assessing the exposure and occupational risk of crew and BWMS operators.

.9 The Group recommended that a more r ealistic 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 revi sed 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 Resou rce 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 cav itation process, together with ballast water filtration. The Group also noted that this BWMS generates the two Activ e 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 inform ation submitted by South Africa with the application for Final Approval and the informati on received from the A pplicant, the Group was satisfied with the completeness of the dossier and recommended to MEPC that Final Approval be granted to the Resource Ballast Technologies Sy stem, subject to the Administration verifying that all recommendations have been fully addre ssed prior to the issuan ce 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 environm ent 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 deci sion of MEPC 59 with regard to the appropriateness for the evaluation of BWMS that utilize UV irradiation as a disinfection under Procedure (G9). Recognizing th at the decision was taken th at it is for the National

Administration to determine if a BWMS that us es UV light produces Activ e Substances and to decide if it needs to make a proposal for approv al 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 bot h the environment and human health. The Group noted that any risk posed could not be attr ibuted to any particular level

of irradiation and should be as sessed 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 irradiati on together with a cata lyst accelerating the reaction, commonly produce free radi cals that are normally consid ered 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. Le Chevalier, M. (20 03). Assessing perfor mance for treatment

of finished water. Wa ter Science and Technolo gy 47 (3), pp 179-184.

.2 Cooper, W.J. (198 9). Sunlight – induced photochemistry of humic substances in natural waters: major reactive species. In: Suffet, I.H., MacCarthy, P,. Aquatic humic substances – In fluence on fate and treatment of pollutants. Advances in Chemis try series 219, American Chemical society, Washington DC, 1989.

.3 Cooper, W.J., Adam, C.J., Wh itehead, R.F., Zika, R.G. (2007). Sunlight-induced photochemical deca y 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 aq ueous solution. Jo urnal of the Chem ical 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, Milli pore Corporation.

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

the marine environment. Cambri dge 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 Rese arch, 40 (10), 2033-2043.GESAMP-BWWG 10/6 - 10 -

I:\MEPC\60\2-11.doc 5.4 In preparation for the Second Stocktaki ng Workshop, the Group held a planning session regarding the objectiv es and the agenda of the Workshop. The Group agreed on the need to finalize the development of the “new tools” id entified 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 met hods 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 con tinue its consultations with the US EPA experts through teleconference and to invite Dr. A. Philips, Health and Safety Executive, Chemicals Regulation Directorate (Unite d 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 fo r the agreed ballast water standard port. The Group also decided to allocate time to de velop a checklist for Basic Approval and Final Approval to assist Applicants/Administr ations in prepari ng their proposals.

5.7 The Group agreed to prepare, in advance for the meeting, working by correspondence and recommended that informal Questions and Answer s sessions with interested parties could be organized during MEPC 60 to provide clarificati on 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-par agraph review, the Group agreed on the final text and requested the Secretariat to make the n ecessary editorial changes to ensure consistency with IMO documents’ format and style.

6.2 The Chairman expressed his appreciation fo r the long hours and substantial efforts made by the members of the Group throughout the w eek and closed the meeting at 17 h 30.

***GESAMP-BWWG 10/6

I:\MEPC\60\2-11.doc ANNEX 1

LIST OF MEMBERS WHO A TTENDED 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 Jane iro, 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 Sc ience 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

240-475-6918GESAMP-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 Biol ogy 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 9604GESAMP-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 approva l of ballast water management systems that make use of

Active Substances

.1 Republic of Korea – GloEn-Patrol TM Ballast Water Management System for Final Approval

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

.3 Germany – SiCURE TM 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 de velopment of necessary methodologi es and information requirements

in accordance with the “Procedur e for approval of ballast water management systems that make use of Active Substances (G 9)” (adopted by reso lution 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 th e 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 th e risks to the ship and pers onnel to include consideration of the storage, handling and appl ication of the Active Substance (see paragraph 6.3 of Procedure (G9));

.4 scientific evaluation of any furthe r information submitted (see paragraph 8.1.2.6 of Procedure (G9));

.5 scientific review of the risk characterization and an alysis 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 a ddressing 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 toxi city of the discharge conforms to the evaluation undertaken for Basic Approval and that the previous eval uation of the risks to the ship and personnel including consideration of the storage, handling and applicat ion 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 confiden tial 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 APPRO VAL OF BALLAST WATER MANAGEMENT

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES

GloEn-Patrol TM Ballast Water Management System

Submitted by the Republic of Korea for Fina l Approval

0 SUMMARY

0.1 Having reviewed all the data and informa tion 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 recomme nded to MEPC that Final Approval be granted to the Panasia Co. Ltd. GloEn-Patrol TM 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 App licant to questions posed by the Group in the Basic Approval report, together with the in formation received from the Applicant during the GESAMP-BWWG meeting, the Group was satisfi ed with the completeness of the dossier received from the Applicant.

0.4 The Group noted that the Pa nasia Co. Ltd. GloEn-Patrol TM Ballast Water Management System uses a combination of filtration with Medi um Pressure UltraViolet (MPUV) irradiation to

treat the ballast water.

0.5 As the BWMS does not require the stor age of chemicals on board ship, the Group recognized that there will not be any associated chemical storag e related safety problems.

0.6 The Group recognized that the BWMS has pot ential safety and envi ronmental concerns and the Group has reviewed the hazards and ri sks associated with th e use of the system.

0.7 The Group recognized that the Applicant ha s 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-Patrol TM BWMS, when installed and operated as described in the submission, should present no unacceptable risk s to the safety of the ship.

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

in treated ballast water. The Grou p accepted the view of the Applican t that there are no unacceptable risks in the chemical composit ion of treated ballast water ca used by the use of this BWMS.

0.9 The Group noted the human health assessmen t provided by the Applicant that includes occupational exposure to ships’ crew and BW MS operators. The Gr oup 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 accordan ce 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 Appli cant has provided detailed information on ecotoxicity testing of treated ballast water. Th e Group accepted the view of the Applicant that there should be no unacceptabl e risks to the environment posed by the use of this BWMS.

0.11 The Group identified a concern that the filtration cycle co mmences 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 th e next ballast uptake port . Following a question posed to the Applicant during the BWWG meeti ng, the Group noted that the Applicant is to incorporate procedures to address the concer n 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 proj ect plan (QAPP) was in place from the start of the tests performed for this ap plication for Final Approval.

0.13 In conclusion, having reviewed all the in formation provided by the Applicant, the Group agreed to recommend to the MEPC that Final Approval be granted to the Panasia Co. Ltd.

GloEn-Patrol TM Ballast Water Management System.

1 INTRODUCTION

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

of Korea in document MEPC 59/2/7 and in th e 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 AP PLICANT’S RESPONSES TO DATA REQUESTS FROM THE GROUP

2.1 The Group recalled that it had already provi ded the following questions and concerns during its evaluation of the application for Ba sic 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 Approva l. The Applicant’s responses received, and the Group’s r eaction to these responses are shown in Table 1:GESAMP-BWWG 10/6ANNEX 4Page 3I:\MEPC\60\2-11.docTable 1: Applicant’s Responses to Data Requests set by the Group during evaluation for Basic ApprovalSectionNo.Group’s Question Applicant’sResponse and Section No. inthis ReportGroup’s Reaction2.1.1The Group strongly recommended that wholeeffluent ecotoxicity testing and related chemicalanalysis with QA be carried out for Final Approval.Samples should be taken during efficacy tests tomeet Guidelines (G8) (Ref. Procedure (G9), 5.2.1).The purpose is to demonstrate conclusively boththe lack of any ecotoxicity and the lack of anydisinfection by-products.Whole effluent ecotoxicity testing:Applicant has provided full set of ecotoxicitystudies on treated ballast water – acute, chronicand sediment, see section 6.2.Chemical analysis with QA:Applicant has provided full analytical data onOther Chemicals in treated ballast water – seesection 3.3.Samples should be taken during efficacy teststo meet Guidelines (G8):Applicant has provided full informationon this aspect of the sampling regime – seesections 3.3.3 – 3.3.5.Demonstrate conclusively both the lack of anyecotoxicity and the lackof any disinfectionby-products:Applicant has confirmed these two aspects in theresults of the testing– see sections 6.2.5 and3.3.7, respectively.The Group was satisfied withthe information supplied.2.1.2The Group noted that a QAPP had been submitted, butthe exact procedures for sampling and handling of thesamples for chemical analysis, the ballast watertreatment conditions applied in the test, and the waterquality parameters werenot included. The Group wastherefore not able to evaluatethe reliability of the lowdetection limits reported by the Applicant.Procedures for sampling and handling of thesamples for chemical analysis:See sections 3.3.3 – 3.3.5.The ballast water treatment conditionsapplied in the test:See sections 3.3.3 – 3.3.5.The water quality parameters:See appendix.The Group was satisfied withthe information supplied.GESAMP-BWWG 10/6

ANNEX Page 4

I:\MEPC\60\2-11.doc 2.2 During the GESAMP-BWWG meeti ng, the Group posed three quest ions to the Applicant. The Group’s questions (in bold text ), the Applicant’s responses (i n 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 instructio n manual (1.3.3 control panel), there appears a possibility for manual control of the th ree-stage power level namely minimum, medium and maximum, and that a power co ntrol option is available. However,

there is neither instruction on how to se lect the appropriate power level nor any indication that the power level is to be au tomatically adjusted. Please further explain how power level to arc lamps is to be selected.

Response 1:

.1 Power level to arc lamps is fixed. Manua l 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 automatica lly 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 thr ee level power switching.

.5 Our all relevant tests have been ma de 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 compar ed to the setting value. In case the current dose is higher than the setting va lue, the power level is step down by PLC. This is a complex algorithm.

– Judging from your question, we think our specification mi ght need to be changed and so auto power control is not option. Automa tic power control was option, however, we think that auto power control is not an option any more judging from your questio n. Our specification remain s 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 base d 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-Patrol TM Ballast Water Management System, photon is an

“Active Substance” and •OH is defined “relevant chemical”. B ecause photons have no residuality in water, photon does not induce any ecotoxicity in treated water. Possible chemicals related to ecotoxicity w ould 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/cm 2 ), 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 subm itting 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 f act, even the higher UV exposur e, no significant amount of •OH would be expected to re main in the treated water.

.3 The key method of GloEn-Patrol TM system to inactivate harmful aquatic micro-organisms and pathogens is use of direct photolysis with the MPUV irradiation. Even though •OH could be pr oduced 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 orga nic 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 halogenate d 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 le vel 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, increasi ng 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 filt ration cycle commences when th e 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 ba ckflush 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 pr ocess is required. The filter will enter the cleaning process by manually pressing the “cycl e run (for cleaning )” button on the main screen then the suction pump on the backflushing line will re move the backfl ush matter.

.2 Manual cleaning/backflush process wh ich 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 in corporate procedures to address the concern identified. The Group recommended that such procedures form par t 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 Wate r 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 pr oposes 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

MPUVGESAMP-BWWG 10/6

ANNEX 4 Page 7

I:\MEPC\60\2-11.doc 3.1.3 As the BWMS does not require the storag e of chemicals on boa rd ship, the Group recognized that there will not be any a ssociated storage safety problems.

3.1.4 Therefore, the Group recognized that this a pplication for Final Approval focuses on the system components and operations for ballast wate r treatment during uptake and discharge. The Group noted that for this Final Approval applica tion, the system is installed on a special barge that has been designed and manu factured to meet IMO’s require ment for the land-based testing, with four ballast tanks, each of which has a capacity of 237 m 3

.

3.1.5 The Group noted that the system consists of a specified number of UV lamps that are designed at specified ballast wa ter 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 conf idential 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 require d 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 hea lth 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 Gr oup 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 ma in 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 fl ow-rate of the li quid passing through the system is sufficient. In order to monitor correct operation, a temperatur e detector is fitted to the UV chamber so that unsafe situations caused by possible breakdowns ar e 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 re moved 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 accordin g to the Applicant, UV lamp s 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 hum an health unless personnel are di rectly exposed to the UV light under emergency or abnormal conditions, and accordin g to the Applicant, this risk is minimized due to the lamp design. The Group further note d that the App licant 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 Chem icals (RC) and Other Chemicals (OC)

3.3.1 The Group agreed with the view of the Applic ant that in this syst em, the MPUV irradiation process produces photons as the only Active Subs tance, which are completely responsible for inactivating all harmful aqua tic micro-organisms and pathogens presen t in the ballast wa ter. The Group therefore defined photons as the Acti ve Substance in the GloEn-Patrol TM BWMS.

3.3.2 The Group agreed with the view of the Ap plicant that in this system, the MPUV irradiation process produces hydroxyl radical (•OH) as a Rele vant Chemical. The Group therefore defined hydroxyl radical (•OH) as a Relevant Chemical in the GloEn-Patrol TM BWMS. The Group noted that •OH instantaneously disappears within milli-seconds as soon as the water

leaves the UV chamber due to its extreme reac tivity 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 na tural constituents present in seawater to produce so-called Ot her Chemicals and the Applicant has provided analyses of treated ballast water for these Othe r Chemicals as part of this application for Final Approval. The Group noted that test wa ter was prepared in two tanks of 440 m 3 in total (about 220 m 3 per tank) using high salinity natural seawater which was pumped from the

sea 2 miles off Busan coastal harbour or br ackish 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 m 3 of water was used for both the test and control samples, with

treated ballast water be ing 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 Appr oval, analytical chemistry testi ng and whole-efflue nt ecotoxicity testing (WET) were simultaneously performed unde r the same conditions. The testing was accredited by KORDI for the performance efficacy test, Yonsei University for specific analysis of •OH, H 2 O 2 and TRO, by the SGS Testing Korea Co. Ltd. for ge neral 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 assura nce project plan (QAPP). The Group also noted that all analyses of Other Chemicals were c onducted 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 Chem icals that might be formed during use of

the BWMS in the seawater a nd the brackish water are summ arized in Tables 2 and 3, respectively.

3.3.6 The Group noted the results in Tables 2 an d 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, how ever, 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 note d the statement from th e 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 Chemical s 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-Patrol TM BWMS does not significantly alter the seawater or brackish water chemical

characteristics.

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

after GloEn-Patrol TM 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 reliabl y measured within specified limits of precision and accuracy during routine laboratory opera ting 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

ANNEX 4 Page 10

I:\MEPC\60\2-11.doc (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).GESAMP-BWWG 10/6

ANNEX 4 Page 11

I:\MEPC\60\2-11.doc (3) Treated water Test dates: 8-13 August 2008 (Report No.: G280-2)

Test period Day 0 Day 3 Day 5

Procedure Ballasting Storage Discharge

Parameter Unit Untreated

Water 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 12000 c 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 hal ogenated organic during sampling. However, it

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

ANNEX 4 Page 12

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 Page 13

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

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

River after GloEn-Patrol TM 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 Page 14

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 potenti al hazards for human health related to overheating of UV lamps and exposure to UV irradia tion resulting from operating this system were sufficiently addressed by the Applicant by engineering cont rol 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 inst allation on board ship for Final Approval mitigate the risk of human e xposure 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 we re 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 Applican t 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 Page 15

I:\MEPC\60\2-11.doc 4.4 The Group considered that there is no unaccep table 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 operato rs 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 meas ures are to be employed in this system to deal with envisaged emergency and safety pr oblems during the ballas t 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’ ball ast 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 (BWM S operators included) by exposure to chemicals and treated ballast wa ter is judged to be acceptable based on the measures developed by the Appl icant for installation on board sh ip. A summary of the various safety measures developed by the Applicant is gi ven above in section 3. 2. The Group considered that in this system, the risk to ships’ cr ew is judged to be appropriately managed.

5.3 Safety of the general public

5.3.1 It was reasonably considered by the Group th at 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), Bi oaccumulation (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 Chemical s are classified as PB T 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 resu lts of aquatic ecotoxic ity studies performed by the Applicant with 100% treated ballast water as a test substa nce are presented in accordance with the “Procedure for approva l 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 passedGESAMP-BWWG 10/6

ANNEX 4 Page 16

I:\MEPC\60\2-11.doc through the filtering system (pore size 0.45 μ m) by using peristaltic pump, and then water parameters – pH, temperature, salinity a nd 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 evalua ted the ability to kill 50% (LC 50 ) 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 accordan ce 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 incu bation at 25oC in darkness. Af ter 24 hours, the rotifers were

observed and considered dead if no movement of the cilia and mast ax 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 trea ted ballast water (seawater or br ackish water) was compared to control water (seawater or brackish water), ther e was no significant difference in the survival

rate. The LC 50 and NOEC could not be determined.

Therefore, the treated ballast wa ter (seawater or brackish water) di d 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 (EC 50 ) 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 Toxic ity 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 EC 50 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% (LC 50 ) 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

ANNEX 4 Page 17

I:\MEPC\60\2-11.doc The assay was performed in basic accordance with US EPA 821/R-02/014 Standard Guide for Short-term Methods for Estimating the Chronic T oxicity 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 trea ted ballast water (seawater or br ackish water) was compared to control water (seawater or brackish water), ther e was no significant difference in the survival

rate. The LC 50 and NOEC could not be determined.

Therefore, the treated ballast water di d 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 (EC 50 ) of Brachionus plicatilis, marine water rotifer for 96 hours using treated ballast water (seawater or brackish water) and this was co mpared 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-ch ronic toxicity tests with the freshwater rotifer Brachionus calyciflorus . The study used 24 hours old rotifers hatc hed from the resting eggs, with incubation

at 25 o C 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 EC 50 and NOEC could not be determined.

Therefore, the treated ballast water did not i nduce reproduction (or popula tion 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 popul ation growth toxicity with sheepshead minnow, using the ability to produce 50% growth inhibition (EC 50 ) 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 (s eawater or brackish water).

The assay was performed in basic accordan ce with US EPA 821/R-02/014 Standard Guide for Short-term Methods for Estimating the Chroni c 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 gr owth inhibition to Cyprinodon
variegatus (larvae) at any concentrati ons. When treated ballast wa ter (seawater or brackish water) was compared to control water (seawater or brackish water), there was no significant difference in the growth rate. The EC 50 and NOEC could not be determined.GESAMP-BWWG 10/6

ANNEX 4 Page 18

I:\MEPC\60\2-11.doc Therefore, the treated ballast water did not induce population grow th 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% (LC 50 ) of Monocorophium
acherusicum, marine water amphipod, for 10 days usin g treated ballast water (seawater or brackish water) and this was compared to cont rol 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. Sali nity, temperature and dissolved oxygen were maintained at 30 PSU, 20 o C and over 80%, respectively. The tr eated ballast water or control water samples were spiked with se diment 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, th ere was no significant

difference in the survival rate. The LC 50 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 Appli cant that the results of the a quatic ecotoxicity testing show that no significant acute or chro nic toxicity and sediment toxici ty was observed in any of the

studies with both seawat er and brackish water.

6.3 Risk assessments of chem icals for aquatic organisms

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

it was stated that the calculati on of PEC/PNEC ratios is not appropriate. The Group confirmed this view for Final Approval of the BWMS and cons idered 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 r econfirmed 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 Page 19

I:\MEPC\60\2-11.doc 6.4 Conclusion for environmental risk assessment

6.4.1 The Group concluded that there is no unaccepta ble 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 an d safety problems during this ballast water treatment process

have been well described and disc ussed above, and as such the Gr oup considered that the Panasia

Co. Ltd. GloEn-Patrol TM 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-Patrol TM BWMS raises no unacceptable risks to the health of the crew and the genera l public, regarding the ex posure to chemicals and

treated ballast water.

7.3 Risks to the environment

7.3.1 Having reviewed all of the information subm itted with this applic ation, the Group agreed that use of this system will not pose a ny unacceptable risks for the environment.

7.4 Recommendation

7.4.1 In conclusion, having reviewed all the in formation provided by the Applicant, the Group agreed to recommend to the MEPC that Final Approval be granted to the Panasia Co. Ltd.

GloEn-Patrol TM Ballast Water Management System.

* * *GESAMP-BWWG 10/6

ANNEX 4 Page 20

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-Patrol TM treatment, the number of living orga nisms 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 Nakdon g River: test cycles 3 to 5

The organism concentrations of test water for the land-based test sampling were set following Guidelines (G8). The water quality of the location is summarized in the following table. In this test, after GloEn-Patrol TM treatment, the number of living orga nisms for all groups in control and treated water met regulation D-2 of the BWM Convention.GESAMP-BWWG 10/6

ANNEX 4 Page 21

I:\MEPC\60\2-11.doc Table: Water quality of bracki sh 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 APPRO VAL 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 informati on 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 Syst ems that make use of Active Substances).

0.3 In view of the responses from the Applican t 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 informa tion 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 (NaClO 3 ) and 8% by weight hydrogen peroxide (H 2 O 2 ) in water) and sulphuric acid (H 2 SO 4 ) to generate chlorine dioxide as Ac tive Substance at a maximum allo wable concentration of 5 mg/L

to treat the ballast water by oxidation and disinfection.

0.5 The Group noted that the Applicant has provi ded information on ecotoxicity testing of treated ballast water, environmental risk assess ment for aquatic organi sms, 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 Cl 2 );

Chlorite ion – 3.8 mg/L (= 1.98 mg/L TRO as Cl 2 );

Chlorate ion – 2.4 mg/L (= 1.01 mg/L TRO as Cl 2 ); and

Dibromoacetic acid (DBAA) – 0.036 mg/L.

0.6 The Group noted that the Appli cant indicated in its dossier fo r Final Approval that all the discharge concentrations mentione d above were higher than had b een 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, th e chlorite and chlorate ions, which are primaryGESAMP-BWWG 10/6

ANNEX 5 Page 2

I:\MEPC\60\2-11.doc by-products when chlorine dioxi de degrades, are toxic to a quatic organisms. The Group considered that the discharge concentrations of ch lorite and chlorate ions , which can be measured as part of the TRO, are si gnificant in the evaluation of risks to the environment.

0.7 The Group noted that the discharged ball ast water contains 3.8 mg chlorite/L (= 1.98 mg/L TRO as Cl 2 ) 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 evaluate d. The Group previously recommended to other systems that a discharge concentration in th e range of 0.1 mg/L to 0.2 mg/L TRO (as Cl 2 ) should be set as the maximum allowable discharge c oncentration (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 ri sks for aquatic organisms had b een 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 chlo rite as representative, the Group concluded that the systems proposed discharge concentrat ions would lead to c oncentrations in the environment that would not exclude unacceptable ri sks to the aquatic organisms in the receiving

waters.

0.9 The Group noted that the results of the Whole Effluent Tests (WET) cl early 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 chemi cals on board ship, the Group recognized that there will be a potential risk associ ated with storage safety problems. The submission states that as the chemicals used are ship’s stores, then the provisi ons of the IMDG Code are not applicable. The Group recognized that this is the case, howev er strongly recommended that the provisions of the IMDG Code are followed as far as is practi cal 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 th e 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 revi ewed the hazards and ri sks associated with

the Active Substance.

0.12 The Group recognized that the Applicant has provided some information on system controls and safety considerations for installa tion of the BWMS on board ship, together with provisions for maintenance and chemical replenis hments 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 a pplying to BWMS maintenance or chemical replenishment operations on board the ship.

0.13 The Group noted that while additional corr osion tests had been conducted they were insufficient and additional testing was recommended by the Applicant’s corrosion testing laboratory. The Group concurred and recommende d 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 Page 3

I:\MEPC\60\2-11.doc 0.14 The Group noted the human health assessmen t provided by the Applicant and the Group accepted the view of the Applicant that there sh ould 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 in formation 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 fr om 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 th e 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 alr eady provided the foll owing questions and concerns during its evaluation of the application for Basi c Approval of the system (see MEPC 58/2/8 – BWWG 7/9, annex 5, Review of Proposals for appr oval of Ballast Water Management Systems that make use of Active Substances), which it considered should be addressed by the Applicant for Final Approv al. The Applicant’s re sponses received, and the Group’s reaction to these res ponses are shown in Table 1:GESAMP-BWWG 10/6ANNEX 5Page 4I:\MEPC\60\2-11.docTable 1 : Applicant Responses toData Requests set by the Group during Evaluation for Basic ApprovalSectionNo.(BAReportsection)Group’s Question Applicant’sResponse and Section No. inthis ReportGroup’s Reaction2.1.1(0.3)After the injection of chlorine dioxide to the ballast water,chlorite ion is produced as a reaction between seawater andchlorine dioxide and is considered by the Group to be anActive Substance (in addition to the chlorine dioxide) in needof full evaluation in the application for Final Approval.Information from the Applicant has been added inresponse to the GESAMP-BWWG comment indicatingthat chlorite ion is considered an Active Substance. InEcochlor’s Basic Approval dossier chlorite ion wasclassified as a Relevant Chemical based on thedefinition provided in Procedure (G9).This definition accurately describes chlorite ion, whichis formedafteremployment of the Ecochlor BWMS.Chlorite ion is not produced due to the reactionbetween seawater and chlorine dioxide. Rather, chloriteion is the primary by-product when chlorine dioxidedegrades, regardless of the matrix (fresh or seawater).Known chlorine dioxide disinfection chemistry clearlyindicates that chlorite is the primary reactionby-product of chlorine dioxide oxidation rather than anActive Substance.Ecochlor agrees with the GESAMP-BWWG that thecontent of chlorite ion in treated ballast water must beconsidered in regards to potential aquatic toxicity.However, based on Procedure (G9) definition,evaluation of chlorite ion remains under the RelevantChemicals section in this dossier. The Basic Approvaldossier included full information for chlorite ion. Inresponse to the GESAMP-BWWG request, additionalinformation to supplement the evaluation of chlorite ionhas been included insection 3.3.3.The Group was satisfied with theresponse from the Applicant.2.1.2(0.3)Purate® containing 40% by weight sodium chlorate (NaClO3)and 8% by weight hydrogen peroxide (H2O2) is considered tobe a Preparation.No Response Required.GESAMP-BWWG 10/6ANNEX 5Page 5I:\MEPC\60\2-11.docSectionNo.(BAReportsection)Group’s Question Applicant’sResponse and Section No. inthis ReportGroup’s Reaction2.1.3(0.3)Sulfuric acid is considered to be a Relevant Chemical.In Ecochlor’s Basic Approval dossier sulfuric acid wasclassified as a Preparation, and also discussed as aRelevant Chemical because of the small excess that iscombined with Purate® to generate chlorine dioxide.Comments from the GESAMP-BWWG suggest thatsulfuric acid is considered a Relevant Chemical.Ecochlor would like to further emphasize that in water,sulfuric acid will be completely dissociated intohydrogen ions (H+) and sulfate ions (SO42-). Therefore,the slight excess of acid can only be present in treatedballast water as the ions, not as sulfuric acid. Theinterchangeable use of sulfuric acid and sulfate ions inthe discussion of these constituents in treated ballastwater unintentionally confused the evaluation of sulfateion in treated ballast water. Because sulfuric acidcompletely ionizes in water, the only potential impactsof the small amount of acid that may remain after thegeneration of chlorine dioxide are: 1) an addition ofsulfate ions to treated ballast water, or 2) lowering thepH of treated ballast water. Section 2.0.3.1 in theBasic Approval dossier (MEPC 58/2/2) providedsulfate ion concentration and pH data for treated ballastwater, which demonstrated that neither are present intreated ballast water at levels that could present aquaticor human health concerns. Further, theGESAMP-BWWG agreed thatsulfate ion is notconsidered a Relevant Chemical (MEPC 58/2/8,annex 5, section 3.2.3).Therefore, no additionalevaluation of sulfate ions is presented in thisapplication for Final Approval.The Group was satisfied with theresponse from the Applicant.GESAMP-BWWG 10/6ANNEX 5Page 6I:\MEPC\60\2-11.docSectionNo.(BAReportsection)Group’s Question Applicant’sResponse and Section No. inthis ReportGroup’s Reaction2.1.4(0.4)The maximum allowable discharge level of the ActiveSubstances (chlorine dioxide and chlorite) needs to bedefined in the application for Final Approval.The Applicant has provided full information onproposed definition of maximum allowable dischargeconcentrations. (Seesection 6.4).The Group was satisfied with theresponse from the Applicant.2.1.5(0.5)The Group considers the Level of Quantification (LOQ) forthe THMs and HAAs used in the analyses of treated ballastwater too high. It is common to determine these contaminantsin surface waters at levels of 0.01 – 0.05 μg/L. It remains tobe confirmed that the potential amount of by-productsproduced by the system is sufficiently low and meets theinternational standards on these substances. This uncertaintyshould be <0.1 μg/L.The GESAMP-BWWG commented that the Level ofQuantification (LOQ) associated with the analyticaldata provided in the Basic Approval dossier was toohigh to confirm that THMsand HAAs in treated waterdischarge are at sufficiently low levels to ensure thatinternational discharge standards are not exceeded.Clarification on the LOQ comment was requested fromthe GESAMP-BWWG because the LOQ suggested wasvery low (0.01 – 0.05 μg/L). The response provided tothe German Administration on 4 November 2008explained that the detection limits noted by theGESAMP-BWWG “...were taken from informationprovided in previous applications.” Due to the variationin detection limits and terminology that is discussed inthis Final Approval, using other applications as“guidance documents” canlead to incorrect datacomparisons. Other Applicants may have useddetection limit terms differently, produced data byvarying methods or in differing matrices (fresh vs.seawater), or had possible errors. As noted by otherApplicants, and acknowledged by GESAMP-BWWG,chemical analysis in seawater presents challenges dueto potential interferences with the analytical methods.The information herein demonstrates that the THM andHAA data presented has sufficient detection limits andshows that regulatory standards for these constituentsare not exceeded in treated ballast discharge.Seesections 3.3.6 to 3.3.10.The Group was satisfied with theresponse from the Applicant.GESAMP-BWWG 10/6ANNEX 5Page 7I:\MEPC\60\2-11.docSectionNo.(BAReportsection)Group’s Question Applicant’sResponse and Section No. inthis ReportGroup’s Reaction2.1.6(0.6)The Group noted that whole effluent ecotoxicity testing still hasto be carried out for Final Approval. Samples should be takenduring the land-based efficacy tests to meet Guidelines (G8)(Ref. Procedure (G9), 5.2.1) and should include samplestaken at day 0, 2 and 5 after treatment to demonstrateconclusively eventual remaining ecotoxicity at discharge aftervarying holding time in ballast tanks. Chemical analyses witha sufficient low LOQ should be carried out on the samples inorder to identify substances responsible for any toxic effectsencountered.Whole effluent ecotoxicity testing has been performedon samples taken during the land-based efficacy tests tomeet Guidelines (G8) (Ref. Procedure (G9), 5.2.1).Seesection 6.2.Comments received from the GESAMP-BWWGsuggested that samples be taken at day 0, 2 and 5 aftertreatment to demonstrate ecotoxicity at various holdingtimes. Ecochlor would like to note that chlorine dioxidewould still be present in treated ballast water at day 0(i.e. immediately after treatment), conductingecotoxicity testing at this time point would moreaccurately reflect efficacy testing. This is due to the factthat the Active Substance, chlorine dioxide, is injectedduring ballast uptake and decays over time in theballast tank(s). Therefore, sampling treated ballastwater immediately after chlorine dioxide injectionwould only be expected to produce mortality of aquaticorganisms. Testing a broader range of taxonomicgroups at time points that represent more realisticonboard situations (days 1and 5) demonstrates thattreated water is safe to discharge within 24 hours oftreatment and provides more useful information thanconfirming the efficacy ofchlorine dioxide byecotoxicity testing on samples collected immediatelyafter injection.The Group considered thatinsufficient data were provided toclarify that the samples used forecotoxicity testing were valid. TheGroup sought the view of theAdministration and it indicated thatthe test cycles employed may beaccepted for the purpose ofProcedure (G9) ecotoxicity testing.2.1.7(0.7)A full environmental risk assessment is required for theapplication for Final Approval. This should apply modelcalculations of environmental concentrations using definedemissions scenarios and include the use of the maximumallowable discharge level of both Active Substances and theRelevant Chemicals in the treated ballast water as well as theeventual toxicity of the whole effluent sample.The Applicant has provided full information for allthese points concerning the environmental riskassessment.Seesection 6.3.The Group was satisfied with theresponse from the Applicant.GESAMP-BWWG 10/6ANNEX 5Page 8I:\MEPC\60\2-11.docSectionNo.(BAReportsection)Group’s Question Applicant’sResponse and Section No. inthis ReportGroup’s Reaction2.1.8(0.8)For Final Approval the Group recommends additional longterm (at least three months duration) corrosion tests with thetreated ballast water to be carriedout and also to confirm thatepoxy ballast tank coatings commonly in use will not beadversely affected by the use of this BWMS.Information has been provided by the Applicant oncorrosion testing.Seesection 5.1.The Group noted that whileadditional corrosion tests had beenconducted they were insufficientand additional testing wasrecommended by the Applicant’sCorrosion Testing Laboratory. TheGroup concurred andrecommended that additionaltesting should be conductedutilizing the guidance provided insection 5.1 of MEPC 59/2/16.2.1.9(0.9)The Group recommends theprovision of appropriatechemical resistant save-all protection by way of the storagetanks and any other locations considered necessary to provideprotection to the ship in the event of leakage or spillage of thechemicals used.Detailed information was provided in the BasicApproval dossier (MEPC 58/2/2). Additionalclarification based on GESAMP-BWWG comments isprovided here below.The use of the terms “secondary containment” todescribe additional measures to ensure protection to theship in the unlikely eventof a chemical leak isequivalent to the terminology “save-all protection” usedby the GESAMP-BWWG. This is an engineered aspectof the BWMS to ensure safe installation. Preparing forBWMS installation onboard a ship requires detailedreviews by Ecochlor’s marine engineers, the vesselengineers, as well as the ship’s classification society.Additional mitigation measures that may be identifiedfor safe BWMS installation on a specific ship duringthese reviews will be implemented as needed.The Group strongly recommendedthat the provisions of the IMDGCode are followed as far as ispractical and that the guidanceprovided in the IMO “Guidance toensure safe handling and storage ofchemicals and preparations used totreat ballast water and thedevelopment of safety proceduresfor risks to the ship and crewresulting from the treatmentprocess” is also fully taken intoaccount.GESAMP-BWWG 10/6ANNEX 5Page 9I:\MEPC\60\2-11.docSectionNo.(BAReportsection)Group’s Question Applicant’sResponse and Section No. inthis ReportGroup’s Reaction2.1.10(5.6-5.7)Further information should be provided on fire mitigationmeasures.Ecochlor provides information in response to theGESAMP-BWWG comment regarding fire mitigationmeasures. Seesection 3.2.The Group was partially satisfiedwith the responseas the guidanceprovided was considered genericrather than specific. The Groupunderstood the need for shipspecific measures on a case by casebasis as indicated, however, a moredetailed description ofarrangements to be put in placewould be beneficial.2.1.11(7.6+9.3)Full information is required on chemical analysis and waterquality data for treated ballast water discharge from the landbased test set up.German Administration requested that Ecochlor discuss andpresent information on dibromoacetic acid (DBAA) as aRelevant Chemical.In addition to ecotoxicity data, this Final Approvaldossier presents chemical analysis and water qualitydata for treated ballast water discharge from the landbased test set up. (Seesection 3.3) Based on this newdata from Guidelines (G8) land-based testing, theGerman Administration requested that Ecochlor discussand present information on dibromoacetic acid (DBAA)as a Relevant Chemical (seesection 3.3.4). Also, basedon chemical analysis of treated water discharge fromland-based testing, chlorate ion has been added to thelist of Relevant Chemicals by the Applicant.(See relevant parts ofsection 3.3.)The Group was satisfied with theresponse from the Applicant, butthe Group noted that the level ofthe Relevant Chemicals was foundto be significantly higher than inthe application for Basic Approvaland therefore an additional riskassessment was considerednecessary.GESAMP-BWWG 10/6

ANNEX 5 Page 10

I:\MEPC\60\2-11.doc 2.2 During the GESAMP-BWWG meeting, the Group pos ed four questions to the Applicant. The Group’s questions (in bold text ), the Applicant’s responses (i n 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 BW MS 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 Over view and Process Description Section 3.0.3 – System Monitoring and Control, Crew Interaction Section 3.0.4 – System Requiremen ts (i.e. Technical Installation Specifications; – Main tenance Requirements) Section 3.0.6 – System Locations, Considerations and Limitations Section 3.0.7 – BWTS Operationa l 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 reas on the dossier provides only general

information to address the informati on 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 comple te safety evaluation to be made. The safety procedures to be followed by the manufacture r’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 pr ovided 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 rateGESAMP-BWWG 10/6

ANNEX 5 Page 11

I:\MEPC\60\2-11.doc 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 treatme nt over the entire ballast uptake.

– A chlorine dioxide optical sensor pr ovides 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 co ntent variations:

– As presented in sec tion 3.0.1 of the Final Appr oval 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 do ssier 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 Meas ured Residual vs. Dosage of ClO 2 with Cl 2 for a Heavily Contaminated Water.”GESAMP-BWWG 10/6

ANNEX 5 Page 12

I:\MEPC\60\2-11.doc .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 lo ading, the 5.0 mg/L dosag e is sufficient to ensure proper control of aquatic invasive species to meet a ny current or proposed

standard.

The Group recommended that, to provide certaint y for environmental sa fety, monitoring and control of the discharge is in corporated 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 ar e performed as part of th e land-based type approval process (described in paragraph 5.2.1 in Pr ocedure (G9)). Could you provide more specific description of the treated water? What was the water cri teria (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 Re search (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 discharg e samples. Data from land-based testing at NI OZ is identified within the dossier. The ec otoxicity data

from land-based treated ballast water di scharge is presented in Tables T-2.9a and T-2.10a. Additionally, further ev idence is found in reference 29 (Grontmij | AquaSense, Report of Ecotoxi cological Studies, October 2008), which verifies that the samples were obtai ned during the testing of the Ecochlor ® BWMS

at NIOZ.

.2 The aquatic toxicity approach used duri ng land-based testing was developed based on discussions with the German Authorities, expert ecotoxicologi sts, 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 sec tion 2.1, paragraphs 9 – 12. Br iefly, the agreed approach was to test a broader range of organisms for acute toxicity, while chronic testing would only be performed on the most se nsitive taxonomic group identified during the acute testing series.

.3 Consequently, the acute aquatic te sting series demonstrated that Crassostrea gigas was the most sensitive group. For this species, the chronic testing method evaluates a sublethal endpoint (developmen t), which requires only a short term exposure period. So, although it appears th at only acute ecotoxicity testing was performed, the test method is evaluating a sublethal endpoint on whole effluent,GESAMP-BWWG 10/6

ANNEX 5 Page 13

I:\MEPC\60\2-11.doc which meets the requirements of sec tion 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 chr onic test method would have been employed for that species. It is simply a matte r of using the most appropriate industry

standard chronic te sting method as determined by the ecotoxicologists for a particular species.

.4 Water quality data from the NIOZ land-ba sed testing can be found in Tables T2.8e and T2.8f and is as reported by NIOZ. Th ese tables include water quality data for the intake harbour water and discharge wate r 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 Au thorities. An electronic copy (in PDF format only, as pr ovided to Ecochlor from NIOZ) can be provided to GESAMP-BWWG if requested.

.5 The NIOZ water quality data meets the Gu ideline 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. Th erefore, the water quality conditions fluctuate with the tidal cycles.

.6 Section 2.1.1.6 describes that samples ev aluated for acute aquatic testing were collected one (1) day after treatment. Section 2.1.2.4 describes that samples evaluated for chronic (sublethal) ecotoxic ity 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 wi thin a cooler maintained at 4 ° C prior to transportation to the laboratory. Secti on 2 of the Grontmij | AquaSense report (reference No. 29) also presents sample handling procedures.

The Group considered that acute toxicity tes ting, semi-chronic testing on the most sensitive species, and chemical analyses are sufficient to evaluate risks by ba llast water discharge.

The Group reviewed the land based testing result s and was unable to identify neither which test runs the ecotoxicity testing samples were obtai ned from, nor the exact water quality data for each test run, hence the test cycle validity coul d not be established. The Group noted that the expectation is that the ecotoxicit y 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 indi cated that the test cycles employed may be accepted for the purpose of Procedure (G9) ecotoxicity testing.GESAMP-BWWG 10/6

ANNEX 5 Page 14

I:\MEPC\60\2-11.doc Question 4:

4 The Group notes the statement in the s ubmission – “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 flushe d to. Please explain further.

Response 4:

.1 The flushing process is briefly descri bed in sections 3.03 and 3.04, but Ecochlor appreciates the opportunity to elaborate the specifics of this process here. To clarify, the term “flushi ng” was used in the dossier but in actuality the reactor column is “evacuated” and the injection pi ping 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 s huts off the chemical pumps and thus, the generation of chlorine dioxide stops. Mo tive water continues to be pumped past the venturi maintaining the vacuum on th e 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 di oxide is removed from the column and the motive water continues to pump chlorine-d ioxide 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 fl ows 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 submitt ed by the Applicant in this dossier, the Group was in a position to evaluate the proposed BWMS.GESAMP-BWWG 10/6

ANNEX 5 Page 15

I:\MEPC\60\2-11.doc 3 DESCRIPTION OF THE SYSTEM

3.1 Overview

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

been described and reviewed in detail in the re port for Basic Approval an d the Group noted that Figure 1 schematically shows the BWMS being reviewed for Final Approval.

3.1.2 The Group recalled that the Applicant propos es 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 (NaClO 3 ) and 8% by weight hydrogen peroxide (H 2 O 2 ) in water) and sulphuric acid (78% by we ight) 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, empl oying 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 chlori ne dioxide production efficiency and thus a low concentration of sulphate ion ( ca 19 mg/L) remains in treated balla st water, but this means that essentially all the chlorate is us ed up. The Group noted that the A pplicant lists sulphate ions as a Relevant Chemical and Ecochlor pr esents 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 concentr ations. 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 add ition 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 H 2 SO 4 Ballast

Water

TanksGESAMP-BWWG 10/6

ANNEX 5 Page 16

I:\MEPC\60\2-11.doc 3.1.4 The Group noted that any excess H 2 O 2 remaining from the chlorine dioxide generation process will react with chlorine dioxide Active S ubstance to form chloride/chlorite ions – and thus the Group concluded that H 2 O 2 will not be considered furt her as a Relevant Chemical.

3.1.5 As the BWMS requires the storage of chemi cals 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 take n 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 consid erations for installation of the BWMS on board ship, together with provisions for maintenan ce and emergency operations of the system. However at Basic Approval, the Group asked for fu rther clarification of fire mitigation measures and the Group noted that the Applicant has now provided fu rther 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 re lated to the BWMS, but within proximity of the system, and 2) a fire dire ctly 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 me diums for sulphuric acid and Purate® are different, water can be used on the ex terior of both chemical tanks (but not allowed to enter the tanks) to keep the st orage 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 typica lly have both water and CO 2 (or other chemical fire suppressants) readily available and instal led 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.GESAMP-BWWG 10/6

ANNEX 5 Page 17

I:\MEPC\60\2-11.doc 3.2.2 The Group was partially satisfied with the response as the guidance provided was considered generic rather th an 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 Chem icals (RC) and Other Chemicals (OC)

3.3.1 The Group recalled the chemical reactions invo lved, as reviewed and described in detail for the evaluation of Basic Approval of the BW MS where full details of the two Preparations

Purate® and H 2 SO 4 and the Active Substance chlorine diox ide were provided by the Applicant. Moreover, the Group noted that du ring land based testing, detectable levels of Active Substance

chlorine dioxide were measured within 24 ho urs 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 no w lists the following substances as

Relevant Chemicals:

.1 Sulphate ion – the Group decided that th is 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 ball ast water after disinfection with chlorine dioxide, the Group regarded chlorite ion or sodium chlorite (NaClO 2 ) as a Relevant Chemical

and noted that detailed informa tion on chlorite ion was presente d in the Final Approval dossier by the Applicant. Additional clarif ication 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 (D BAA) was measured by the Applicant at concentrations of 0.012 mg/L – 0.036 mg/L with a mean concentr ation 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 ba llast water samples and because of comments

Ecochlor received from the German Administra tion, additional information has been provided by the Applicant for this chemical.

3.3.5 As already noted by the Group, essentially al l 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 sa mples, additional information has been provided by the Applicant for this chemical.GESAMP-BWWG 10/6

ANNEX 5 Page 18

I:\MEPC\60\2-11.doc 3.3.6 The Group noted that the Applicant has provi ded analyses of treated ballast water for Other Chemicals (particularly trihalomethanes (T HMs) and haloacetic acid s (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 Fina l 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 wate r 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, resp ectively, a summary of the chemical analysis results (for THMs and H AAs) and water quality data (for brackish and seawater) from discharge samples collect ed during land-based testing at NIOZ.

3.3.7 The Group noted further information pr ovided by the Applicant, as follows:

.1 EPA Method 524.2 was used to analyse treated ballast water samples for THMs. The method explains: “M ethod 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 Detect ion Limit (MDL) – The minimum concentration of an analyte that can be identified, meas ured and reported with 99% confidence that the analyte c oncentration is greater than zero.”

3.3.8 The Group noted that according to the Applican t, the tables in section 1 of the appendix

show the calculated MDL values for THMs a nd HAAs determined by the stated US EPA analytical methods. According to the Applicant, th is information demonstrates that the methods are capable of the low detect ion 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 a ppendix are consistent with the <1.0 μg/L values reported with the THM and HAA data generated during analys is of ballast water samples treated with the Ecochlor system, and are a result of the me thod detection study performed by the analytical laboratory in accordance with US EPA require ments. 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 pr ovided for HES and Human Health Risk Characterization were adequately addressed by the Applicant in the Basic A pproval 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 follo wing conclusions in this area of assessment.GESAMP-BWWG 10/6

ANNEX 5 Page 19

I:\MEPC\60\2-11.doc 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. Al though these operations are limited in duration and frequency, the risk was found to be pres ent during system maintenance and chemical re-supply operations, or during emerge ncy situations involving the BWMS.

4.2.2 The Group concurred with the Applicant th at measures adopted in this BWMS like adequate engineering control measures, technici an and crew training and standard operating procedures (SOP) further mitigate poten tial human exposure to Active Substance,

Relevant Chemicals or Other Chem icals in this system , through the exposure routes of concern assessed (dermal and inhalation). The Group consider ed that the unit operat ions where potential human exposure risks exist, e.g., maintenance and refilling operations, ar e limited in duration and frequency and risk mitigation measures were satisfactorily addressed by the Applicant.

4.2.3 In addition, the Group recommended that pre cautionary measures e.g., by using personal protective equipment (PPE) should be followed wh en any operator enters the ballast tanks for inspection or for sampling operational procedures.

4.3 Exposure of general public thro ugh the environment and food chain

4.3.1 The Group noted that the THM in treated ball ast 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 Qu ality. Therefore, the Group concluded that the possible scenarios of exposure to the general public through the enviro nment and food chain were within acceptable risk.

4.4 Conclusion of human health assessment

4.4.1 Therefore, the Group was satisfied that thes e results show that th e BWMS does not pose an unacceptable risk to ships’ crew (BWMS ope rators 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 problem s 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), additiona l details of all corrosion c oupon tests are provided in the Final Approval application. Corrosion tests ha ve been conducted in ba llast tanks treated by the Ecochlor® BWMS to verify the effect of ch lorine 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 testi ng 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 m 3 volume each) that

simulate ballast water tanks Alt hough the corrosion rates for the sp ecimens exposed in the treated tank are slightly higher than the untreated controls , all of the corrosion rate s are within the rangeGESAMP-BWWG 10/6

ANNEX 5 Page 20

I:\MEPC\60\2-11.doc expected for carbon steels in natural seawater. However, the corrosion experts consulted by the Applicant suggested these resu lts 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 guida nce 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 (BWM S operators included) by exposure to chemicals and treated ballast wa ter is judged to be acceptable based on the measures developed by the Applicant for instal lation 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 en sure safe handling and storage of chemicals and preparations used to treat ballast water and th e 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 outco me of results of human risk assessment developed by the Applicant.

6 ENVIRONMENTAL RISK ASSESSMENT

6.1 Assessment of Persistence (P), Bi oaccumulation (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 situa tion, the Appli cant has made a further comprehensive listing of P, B and T crit eria for the Active Substa nce (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 degrad ation and ecotoxicity behaviour, are listed in section 6 of the appendi x, 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 resu lts of acute and chronic aquatic ecotoxicity studies performed by the Applicant with treated balla st 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)”. Mo reover, the Group noted that a li st of the aquatic ecotoxicity testing methods used in this work is provide d 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 Roya l Netherlands Institute for Sea Research (NIOZ), Texel, the Netherlands, from April to July 2008, and usi ng two different time points (days 1 and 5 after treatment). These time points were selected to dem onstrate that treated ballast water may be safe to discharge within 24 hours of treatment (day 1) and also after the holding time of 5 daysGESAMP-BWWG 10/6

ANNEX 5 Page 21

I:\MEPC\60\2-11.doc specified in Guidelines (G8) testing. Test samples received 5 mg/L of chlorine dioxide Active Substance, and were employed in the ecotoxi city 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 presente d on the basis of percent by volume (% v/v) of

treated ballast water.

6.2.2 The Group noted that acute aquatic ecotoxi city tests were pe rformed with fish, crustaceans, marine microalgae (diatoms), mollus cs, rotifers and marine bacteria. Testing was performed for all six taxonomic gr oups during both brackish and seaw ater test cycles. However, although testing with algae at the higher salin ity (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) indi cates that toxicity data from fresh water or saltwater species should be accepted, the Applicant proposes that alg ae toxicity testing in br ackish water fulfils the data requested by the methodology, and the Group accepted this view.

6.2.3 The Group noted the following acute aqua tic ecotoxicity resu lts. The mollusc Crassostrea gigas (Pacific oyster) was the most sensitive of the six taxonomic groups tested,

with seawater EC 50 ranging from 62.3% to 50.4% (1 day after treatment), and 73.6% (5 days after treatment). In the brackish water, EC 50 ranged from 38.1% to 43.3%, and 36.3%, respectively. Marine algae results with brackish water were – EC 50 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 e ffects, short-term exposure with a sublethal endpoint (growth/development) was evaluated fo r the most sensitive ta xonomic group identified from the acute testing. The Applic ant stated that this approach allowed for testing on a wider range of taxonomic groups and al so avoided unnecessary testing on organisms that did not show evidence of toxic effects with acute exposur es. 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-B WWG 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 disc ussion to explain the use and validity of short-term exposure chroni c testing methods. The primary reasons for using short term exposure (sublethal endpoint) testin g methods is that these methods are commonly recognized by regulatory agencies as acceptable ch ronic 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-te rm (full-life cycle) chr onic toxicity test data with the data obtained using short-term chroni c testing methods, the US EPA and independent scientific experts determ ined that short-term methods provide d essentially the same information. The US EPA therefore adopted an d recognizes short-term chronic testing methods as standard procedures for evaluating toxicity of substances and whole efflue nts. 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 consider ed a standard long-term test. Additionally, a non-lethal endpoint test of 7 da ys with longer-lived crustace ans is considered a standard long-term test method. The ecotoxici ty testing results presented in this dossier were performed in

accordance with the short term chronic toxici ty testing methods considered standard in the United States, which are also recognized in ternationally. Section 3 .3.3.2 of Procedure (G9)

also indicates that short term chronic tes ting methods are acceptable because identifying theGESAMP-BWWG 10/6

ANNEX 5 Page 22

I:\MEPC\60\2-11.doc sensitive sublethal e ndpoints and vulnerab le 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 te sting with treated balla st water discharge. This is the basis for including and evaluating 7-day ecoto xicity tests under the chronic te st data section of the dossier. In regard to the chemical prope rties, it is important to note that long term exposure chronic toxicity testing for both chlorine dioxide and chlo rite ion is not the most practical approach due to the rapid degradation of these chemicals. S ubjecting test organisms to 14, 21 or 28-day test protocols would not reflect realistic exposure tim es because chlorine di oxide 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 ec otoxicity testing series, the mollusc Crassostrea gigas (Pacific oyster) was identified as the most sensitive taxonomic group and additional chronic tests were perfor med 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 determin ed by Grontmij|AquaSense to be the appropriate

method to evaluate chronic eff ects 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 EC 50 values of 43.3% and 50.4% in brackish and seawater, respectively. Testing on day 5 samples with Crassostrea gigas resulted in EC 50 values

of 36.3% and 73.6% in brack ish and seawater, respectively. On e additional test with the algal species Phaeodactylum tricornutum was also performed with day 1 brackish water discharge.

This test resulted in an EC 50 of 75.8%. Poor growth performan ces 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 EC 50 of 51% and an average NOEC of 31%. Therefore, a tw o-fold dilution is necessary to reach a

concentration less than the EC 50 and a three-fold dilution is n ecessary to reach a concentration

less than the NOEC value for Crassostrea

.

6.3 Risk assessments of chem icals for aquatic organisms

6.3.1 The Group recognized that the Applicant has performed aquatic organism risk

assessments for the Active Substance and Rele vant 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 asse ssment to provide PNEC values, the Group noted the provision by the Applican t 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 LC 50 of 0.02 mg/L (juvenile Pimephales promelas ) for chlorine dioxide as sugg ested 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.GESAMP-BWWG 10/6

ANNEX 5 Page 23

I:\MEPC\60\2-11.doc 6.3.3 Next, the Group considered chlorite ion a nd 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 f ound 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. Ther efore, 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 LC 50 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 i on, the Group noted that the App licant performed a literature search to locate acute and chronic aquatic ecotoxic ity 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 th at 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 th e lowest chronic NOEC geometric mean value of 0.06 mg/L (60 μ g/L) for marine macroalgae reported by va n Wijk and Hutchinson to derive a PNEC value. This geometric mean value take s into account the very low data point (5 μ g/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 EC 50 value of 0.08 mg/L for Fucus

vesiculosus . The Group noted the statement from the App licant that this NOEC value for chlorate provides adequate protection for aquatic sp ecies when used to derive a PNEC = 0.6 μ g/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 a quatic toxicity data; ho wever, only limited data

was located. Four LC 50 endpoints, with exposure periods of one to four days, were located for the fathead minnow ( Pimephales promelas ). The lowest LC 50 (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 μ g/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 ut ilized 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 de veloped the MAMPEC and Delft-3D models and Deltares performed the analysis of th e PEC values for Ecochlor’s BWMS.

6.3.7 The Group noted that in th e 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 consider ed a specific part of the Nieuwe Waterweg,

the Maashaven. The second MAMPEC “location” cons idered the Port of Ro tterdam as a whole in which the release of ballast water due to all ships present was simulated.GESAMP-BWWG 10/6

ANNEX 5 Page 24

I:\MEPC\60\2-11.doc 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 mode l to accurately predict ballast water discharge concentrations. The modelling input parameters are the same as those used for the MAMP EC 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 ha rbour, 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 Delf t-3D models, Ecochlor chose vessel parameters to represent

a worst case scenario within Maashaven. Moreover , the Group noted that the concentr ations 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 dioxid e, chlorite ion and chlorate ion is generated with the detailed model for the wors t case scenario of three ships discharging in

the Maashaven simultaneousl y. These result s 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 satisf ied 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 rati os 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 0.013GESAMP-BWWG 10/6

ANNEX 5 Page 25

I:\MEPC\60\2-11.doc 6.3.11 The Group noted that according to the Applicant for all substances, with the exception of Active Substance chlorine dioxide, the PEC/PN EC ratio is <1, thereby indicating that no further evaluation or testing w ould 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 th e Maashaven under a worst case scen ario is considered, a PEC/PNEC

ratio of 0.75 is achieved. Furthe r, when the chlorine dioxid e 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 chlo rite as the main representative the Group performed additional calculations with the MA MPEC-model. These calculations show that, according to the scenario the Group has estab lished during their First Stocktaking Workshop of 21 and 22 January 2009, the concentration of ch lorite 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 a nd re-confirmed during this Final Approval of 0.6 microgram/L, it is cl ear that with a PEC/PNEC-ratio of a bout 100 there is a risk for aquatic

ecosystems.

6.3.13 Based on these additional calculations us ing chlorite as repr esentative, the Group concluded that the systems proposed discharge concen trations would lead to concentrations in the environment that would not exclude unacceptable ri sks to the aquatic orga nisms in the receiving

waters.

6.4 Maximum Allowable Discharge Concentrations (MADC)

6.4.1 The Group recognized that in mo st 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 measur ed 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 concentrati on 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 conc entrations measured 24 hours af ter 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 Cl 2 );

Chlorite ion – 3.8 mg/L (= 1.98 mg/L TRO as Cl 2 );

Chlorate ion – 2.4 mg/L (= 1.01 mg/L TRO as Cl 2 ); and

Dibromoacetic acid (DBAA) – 0.036 mg/L.GESAMP-BWWG 10/6

ANNEX 5 Page 26

I:\MEPC\60\2-11.doc 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 a quatic 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 App licant presented data to sup port 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 significa nt in the evaluation of risks to the environment. The Group previously recommended that a di scharge concentration of 0.1 mg/L to 0.2 mg/L TRO (as Cl 2 ) 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 problem s during the ballast water treatment have been developed by the Applicant. However the Group strongly recommended th at the provisions of the IMDG Code are followed as far as is practi cal 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 fo r 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 M ADC 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 r ecommended that a discharge concentration of 0.1 mg/L to 0.2 mg/L TRO (as Cl 2 ) should be the maximum allo wable discharge concentration (MADC). These chemicals are all oxidants and therefore the MADC is significantly exceeded in this case. Hence, the Group was not satisfied th at 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 th ese concentrations, the Group is not able to recommend Final Approval for the Ecochlor® BWMS as presented.GESAMP-BWWG 10/6

ANNEX 5 Page 27

I:\MEPC\60\2-11.doc 7.4 Recommendation

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

could not recommend to the MEPC that Final A pproval 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 dioxi de, chlorite ion and chlorate ion significantly exceed the discharge concen tration of 0.1 mg/L to 0.2 mg/L TRO (as Cl 2 ) previously recommended by the Group.

.2 To provide certainty for environmenta l safety, monitoring and control of the discharge should be incorporated to ensu re that the finall y agreed MADCs for

all Active Substances and Releva nt 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 trea t ballast water and the development of safety procedures for risks to the ship and crew resulting from the treatment process” should also be fu lly taken into account.

.4 Further attention to procedures and risk mitigation measures applying to BWMS maintenance or chemical replenishm ent operations on board the ship.

.5 Additional corrosion testing should be c onducted in accordance with the guidance provided in document MEPC 59/2/16, section 5.1.

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

measures.

* * *GESAMP-BWWG 10/6

ANNEX 5 Page 28

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

PROPERTIES OF ACTIVE SUBSTANCE, RELEVANT CHEMICALS, OTHER

CHEMICALS AND TREA TED BALLAST WATER

1 CHEMICAL ANALYSIS OF TREATED BALLAST WATER FROM

LAND-BASED TESTING

1.1 THMsGESAMP-BWWG 10/6

ANNEX 5 Page 29

I:\MEPC\60\2-11.doc 1.2 HAAsGESAMP-BWWG 10/6

ANNEX 5 Page 30

I:\MEPC\60\2-11.doc 2 WATER QUALITY DATA FROM LAND BASED TESTING

2.1 Brackish WaterGESAMP-BWWG 10/6

ANNEX 5 Page 31

I:\MEPC\60\2-11.doc 2.2 SeawaterGESAMP-BWWG 10/6

ANNEX 5 Page 32

I:\MEPC\60\2-11.doc 3 AQUATIC ECOTOXICITY TE STING METHODS EMPLOYEDGESAMP-BWWG 10/6

ANNEX 5 Page 33

I:\MEPC\60\2-11.doc 4 AQUATIC RISK ASSE SSMENT OF CHEMICALS

4.1 Acute EcotoxicityGESAMP-BWWG 10/6

ANNEX 5 Page 34

I:\MEPC\60\2-11.docGESAMP-BWWG 10/6

ANNEX 5 Page 35

I:\MEPC\60\2-11.docGESAMP-BWWG 10/6

ANNEX 5 Page 36

I:\MEPC\60\2-11.doc 4.2 Chronic EcotoxicityGESAMP-BWWG 10/6

ANNEX 5 Page 37

I:\MEPC\60\2-11.docGESAMP-BWWG 10/6

ANNEX 5 Page 38

I:\MEPC\60\2-11.doc 5 AQUATIC ECOTOXICITY TESTING OF TREATED BALLAST WATER FROM

LAND BASED TESTING

5.1 Acute EcotoxicityGESAMP-BWWG 10/6

ANNEX 5 Page 39

I:\MEPC\60\2-11.doc 5.2 Chronic EcotoxicityGESAMP-BWWG 10/6

ANNEX 5 Page 40

I:\MEPC\60\2-11.doc 6 PBT CLASSIFICATION

***GESAMP-BWWG 10/6

I:\MEPC\60\2-11.doc ANNEX 6

REVIEW OF PROPOSALS FOR APPRO VAL OF BALLAST WATER MANAGEMENT

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES

SiCURE TM 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 r eceived from the Applicant during the GESAMP-BWWG meeting, the Group recommended to MEPC that Basic Approval be granted

to SiCURE TM 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 hypochlor ite 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 SiCURE TM BWMS utilizes Chloropac, Concentric Tube Electrode (CTE) Technology to produce hypochl orite to provide disinfec tion of ballast water. Hypochlorite is generated and dosed to the ball ast water to achieve a pre-determined oxidation reduction potential (ORP) which the Applicant st ates will result in a maximum allowable dose of 6 mg/L (TRO as Cl 2 ).

0.3 The Group noted that the treatment dosage of 6 mg/L (TRO as Cl 2 ) was determined on

the basis of the amount needed to achieve th e 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 tr eated. The Group further considered that on the basis of calculated dosag e concentrations and treatment capacity volumes,

the maximum calculated concentra tion may be 8.3 mg/L TRO (as Cl 2 ). The Group recommended

that this issue should be further clarified in any future appl ication 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 SiCURE TM
system to be restricted to t hose ships operating only in salt or brackish water. The Group recommended that the lower limit of salinity fo r operation of the system should be defined by the Applicant for Final Approval.

0.5 As the BWMS does not require the storag e of chemicals on boa rd ship, the Group recognized that there will not be any a ssociated storage safety problems.

0.6 The Group recognized that the system utilizes an Active Substance and produces Relevant Chemicals and Other Chemicals with pot ential safety and environmental concerns and the Group has reviewed the hazards and risk s associated with a ll these chemicals.GESAMP-BWWG 10/6

ANNEX 6 Page 2

I:\MEPC\60\2-11.doc 0.7 The Group recognized that th e Applicant has provided deta iled information on system controls and safety considerations for installa tion of the Siemens SiCU RE 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 App licant is sufficient to allow the Group to recommend Basic Approval. Th e Group recommended that an application for Final Approval of this system should includ e confirmation by testing, utilizing the guidance provided in section 5.1 of MEPC 59/ 2/16, that there will be no unaccep table risks to the safety of the ship from corrosion by treated ballast water.

0.8 In addition, the Group noted the provision by th e Applicant of some an alytical results for the Active Substance, Relevant Chemicals and Other Chemicals in treated ballast water. As such the Group considered that this information provide d by the Applicant in the submitted dossier is sufficient to allow the Group to recommend Basi c Approval. The Group recommended that an application for Final Approval of this system s hould 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 Re levant 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 exposur e to ships’ crew, BWMS operato rs 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 occupation al risk useful although the route of exposure chosen by the Applicant wa s not considered by the Group to be the most appropriate to address a realistic exposure scenario. The Group recomme nded for Final Approval that inhalation and dermal routes should be considered by the App licant as the Group believe s these to be more appropriate in assessing the expos ure of crew and BWMS operators.

0.10 The Group recognized that the A pplicant 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 Cl 2 ) to be achieved using a minimum holding time. The Group considered that the Applicant’ s proposed MADC for the Active Substance is acceptable, with th e provision that a mi nimum 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 st ipulated requirement for Basic Approval. However, after deliberation, the Gr oup considered that the treated ba llast water discharge ecotoxicity results were not likely to be substantially differe nt from those obtained from electrolytic systems previously considered by the Group and gran ted Final Approval by MEPC. Hence, the Group agreed to make an exception in this case and furt her agreed that the lack of submitted data could be overlooked in this particular Basic Approva l assessment. The Appli cant should provide the results of acute and chronic aquatic ecotoxicity te sting 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 doe s 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 cons idered in the application for Final Approval, regardless of any proposed minimum holding time for the treated ballast water.GESAMP-BWWG 10/6

ANNEX 6 Page 3

I:\MEPC\60\2-11.doc 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 th ere are mistakes in some of the input values provided and due to the degradati on rates employed, results for th e calculated concentrations may be too optimistic. The Group also considered that it is not clearly descri bed how the results in the application are achieved. Also in this re gard, the Group emphasized that a more realistic estimation of the decay rate of Active Substanc e is required, as the modelling currently shows

there will be an estimated risk if the half-life is more than 0.5 h. For Fi nal Approval, the Group expected to receive a revised and corrected PEC calculation submission.

0.14 The Group noted that the App licant intends to c onduct a comprehensive evaluation of corrosion effects and provides some background lit erature which indicates that corrosion rates may be increased based on this treatment technology. The Group recommended that comprehensive testing be conducted, taking in to account the guidance in section 5.1 of the “Report of the eighth meeting of the GE SAMP-BWWG”, contained in MEPC 59/2/16.

0.15 In conclusion, having reviewed all th e information submitted by Germany in the application for Basic Approval and the informa tion supplied by the App licant in response to questions posed by the Group during this GE SAMP-BWWG meeting, the Group agreed to recommend to the MEPC that Basic Appr oval be granted to the Siemens SiCURE TM BWMS. The Group recommended that in any future subm ission for Final Approval of this BWMS, the recommendations given in this re port are taken into account.

1 INTRODUCTION

1.1 The data used to evaluate this system we re 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 re quest 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 clarifica tion 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 treatm ent dosage is 8.3 mg/L TRO (as Cl2)?

Response 1:

.1 The Siemens SiCURE TM Ballast Water Management Sy stem is designed to deliver a maximum treatment dosage of 6 mg/L. Th e output from an electrolytic cell is proportional to the DC current. The Si emens 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 Page 4

I:\MEPC\60\2-11.doc 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 m 3 /h), and treatment capacity volumes (200 m 3 /h), the maximum calculated concentration may be 8.3 mg/L TRO (as Cl 2 ). The Group recommended that this issue s hould be further clarified in any future application for Final Approval, wh ich may include control system logic to verify the Applicant’s

claims.

Question 2:

2 The Group noted that the ORP contro l requires a certain ORP potential (mV) (data deemed to be confidential and removed at th e request of the subm itting Administration) mV for adequate efficacy and that this OR P 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 maxi mum 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 treatmen t dosage of 6 mg/L (TRO as Cl 2 ) was determined on the basis of the amount needed to achi eve the Applicant requ ired ORP for treatment efficacy utilizing waters from NIOZ. However, the Group considered that higher treatment concentrations may result when ballast waters having differen t organic loadings are treated. The Group recommended that this issue should be furt her clarified in any future application for Final Approval, which may include control syst em 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 in clude 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 neut ralization step is require d to adequately ensure

TRO in treated ballast water will not exceed the MADC.GESAMP-BWWG 10/6

ANNEX 6 Page 5

I:\MEPC\60\2-11.doc Question 4:

4 The Applicant does not provide any info rmation about “Toxicity testing of the treated Ballast Water” described in paragr aph 5.2 of Procedure (G9). Are there any

additional information of th e ecotoxicity testing perfor med against simulated Ballast Water Discharge? If not, are there any ar guments that these tests can be skipped at Basic approval in this particular case?

Response 4:

.1 The eco-toxicity testing was not conduc ted 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. Th at 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 Umweltbunde samt, Siemens agreed to carry out

additional acute and chronic t oxicity tests for those substances that no toxicity data was found for in the open literature. Th ese 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 ecot oxicity testing of the treated ballast water that is a stipulated requirement for Basic Approval. However, after deliberation, the Group considered that the trea ted ballast water dischar ge ecotoxicity results were not likely to be substantially different from those obtained from electrolytic systems previously considered by the Gr oup and granted Final Approval by MEPC. Hence, the Group agreed to make an exception in this case and furthe r agreed that the lack of submitted data could be overlooked in this particular Basic Approv al assessment. The Applicant should provide the results of acute and chronic aquatic ecotoxicity testing of treate d ballast water, in accordance with the full requirements of Procedure (G 9), 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 especial ly 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 co nsiderations. 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 th e environment either qualitatively or quantitatively. In order to assess the poten tial health risk posed by the chemicals present in the SiCURE TM 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, inhala tion) and the intensity of the exposure.GESAMP-BWWG 10/6

ANNEX 6 Page 6

I:\MEPC\60\2-11.doc .2 Because of the numerous safety features inherent in the SiCURE TM 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 primar y exposure route of potential concern is incidental ingestion, use of guideline values that are considered safe for drinking water exposures are an appropriate benc hmark for comparison with appropriate adjustment for the lower site-specific e xposure 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 expos ure, including dermal contact and inhalation, as well as ingestion. Therefore, their use, with adjustment to account for a lower intake rate and exposure fr equency, is an appropriate method for estimating the potential health risk to a sh ip’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 assu mptions inherent in the derivation of the safe drinking water guideli ne 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 SiCURE TM BWMS may inadvertently ingest a small amount of treated ballast water (i.e. a mouthful or 0.01 liters). Because regular maintenanc e 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 da ys 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 E xposure 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 e ffects, reproductive effects, and for two COPCs, potential carcinogenicity. Howeve r, based on the human health risk assessment performed using available toxicity information, and accounting for a site-specific exposure scen ario, none of the potentia l 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 Tabl e 8.2.3-1. These concentrations were selected as typical for the treated wa ter 24 hours and 120 hours after the treatment.

The Group noted the information provided by th e Applicant and found it useful to address the exposure risk of crew and BWMS operators. Ho wever 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 realis tic exposure scenario. The Group recommended for Final Approval that inhalation and dermal ro utes should be used instead by the Applicant.GESAMP-BWWG 10/6

ANNEX 6 Page 7

I:\MEPC\60\2-11.doc Question 6:

6 The Group notes that there is a system re quirement for a minimu m holding time in the degas chamber of 5 minutes. Given that the ORP sensor, which provides a signal for the operational control of the electrochem ical generator, is obviously in the main ballast line after injection, th en this means there is a mi nimum time lag for chemical production adjustment of at least 5 mi nutes. 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 expect ed 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 ta nk (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 pro duction 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 monito ring may have low value as biocides’ activity, not concentration, can be strongl y influenced by pollutants. Siemens does not intend to add TRO monitoring. We believe that ORP control is the best measure of the system efficacy. More over, use of TRO monitoring may have limited value as biocides’ activity, not c oncentration, can be strongly influenced by pollutants. Same would apply to por ts with clean water that has high pH (for example, in the Middle East).

The Group was satisfied with this respon se, 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 wa ter 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?GESAMP-BWWG 10/6

ANNEX 6 Page 8

I:\MEPC\60\2-11.doc Response 8:

.1 We would like to apologize for the outd ated block diagram. The purpose of the secondary side stream (here called BFC l oop) is to provide a biofouling control to the filter and break up the colonies of ma rine 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. Th e 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 SiCure TM Ballast Water Manageme nt System, one of the steps is to chec k the calculations performed with the MAMPEC model. Here we

come across some difficult ies 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 to tal amount of TRO discharged into the harbour. We did not mind the speci fic distribution of the ships in the harbour. The value of 218350 g/d is achi eved by multiplyin g the total volume discharged (397000 m 3 /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, respectivel y: 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 calcul ations 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 th e average, maximum and minimum PEC of 1.08E-2, 2.23E-3 and 1.93E μ g/L, the GESAMP-BWWG were referring to the Table 7.3.3-1 in the Siemens’ applicati on dossier for a half-life of 24 hours.

.2 Please note that this table provides resu lts of MAMPEC calcula tions for a single ship in the port of Rotterdam. Therefor e, the total amount of emissions used in the calculations should be at 2,729 (twent y seven hundred twenty nine) g/day for aGESAMP-BWWG 10/6

ANNEX 6 Page 9

I:\MEPC\60\2-11.doc discharge 24 hours after treatment. Therefore, the average PEC of 2.4 microgram/L shown in the GESA MP-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 – pl ease see the picture below for half-life of 48 hours.

The consultant also noted some diff erences 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 es timated Henry’s constant is then 0.182

and not 0.0182.

Although the Group appreciated the thorough analysis of the PEC at diff erent half-lives in the Rotterdam harbour using MAMPEC, the Group di d not agree with the way the results were presented. Therefore, the Group di d 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) whils t later in the co rrespondence 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 rate s of these processes may be added if first order kinetics apply, the final resulting de gradation 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 resu lts in the application are achieved. It is suggested by the Group to report resu lts of MAMPEC ca lculation 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 re sults 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 mee ting, the Group recommended to MEPC Basic Approval for the BWMS. The Group made th e following recommendations, if this system

is to be reviewed for Fi nal Approval in the future:

.1 The Group recommended that comprehe nsive corrosion testing be conducted, taking into account the guidance in secti on 5.1 of the “Repor t of the eighth meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16.GESAMP-BWWG 10/6

ANNEX 6 Page 10

I:\MEPC\60\2-11.doc .2 The Group recommended that confirmati on 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 th e chemical composition of treated ballast water caused by the us e of this BWMS.

.3 In accordance with the requirements of Procedure (G9), the Group recommended that acute and chronic aquatic ecotoxicity testing of treat ed 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 trea ted by the system. This may include control system logic to veri fy the Applicant’s claims.

.5 The Group recommended that an envir onmentally 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 th at the MADC is not exceeded, or a neutralization step. The Group recomme nded 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 an d dermal routes of exposure should be considered by the Applicant as the Group be lieves these to be more appropriate in assessing the exposure and occupational risk of crew and BWMS operators.

.9 The Group recommended that a more r ealistic 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 al l 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 SiCURE TM 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 th e Active Substance into the ballast water intakes. This technology is well known in the maritime industry under trademark Chloropac.GESAMP-BWWG 10/6

ANNEX 6 Page 11

I:\MEPC\60\2-11.doc The Group noted that disinfection with Active Subs tance is combined with filtration (40 micron) of the ballast water, and that the BWMS only treats ballast wa ter 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 hypochlorit e is also referred to as Free Available Chlorine (FAC) and is determin ed as TRO (expressed as mg Cl 2 /L). In the BWMS under consideration, the Applicant states that the Ac tive Substance is applied at up to the maximum allowable dose of 6 mg/L (as TRO Cl 2 ) into the ballast water with a minimum level of < 0.1 mg/L, which has been proposed by th e Applicant as the MADC for the system. The Group noted that according to the Applicant, the produc tion 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 th at 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 w ill need to be confirmed by the Applicant for Final Approval.

3.1.1.4 As the BWMS does not require the stor age of chemicals on board ship, the Group recognized that there will not be any a ssociated 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 m 3 /h (small capacity systems) or 11 m 3 /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 (whe re 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

TanksGESAMP-BWWG 10/6

ANNEX 6 Page 12

I:\MEPC\60\2-11.doc 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 dosa ge of the system as 8.3 mg/L TRO (as Cl 2 ) given that the concentr ated dose may be as high as 300 mg/L TRO (as Cl 2 ) with a minimum rated volume of the system of 200 m 3 /h.

3.1.2.2 The Group noted that the tests conducte d in the laboratory using seawater from the North Sea off Texel Island, the Netherlands s how that the required ORP can be achieved with

an Active Substance dose not excee ding 6 mg/L, most likely within the 2 mg/L to 6 mg/L range. The Applicant plans that the land-based and ship board testing programme for Final Approval will

show if the maximum concentration of 6 mg/L can be lowered and the output of

the SiCURE TM BWMS will be adjusted accordingly. Ho wever, 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 re quired 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 contro l injection streams using preset flow control valves. Therefore, a typical dose range for di sinfection will be betw een 2.0 mg/L and 5.5 mg/L, while a typical dose range for filt er biofouling control will be at 0.2 mg/L to 0.5 mg/L. Required dosing will be determined based on an ORP re ading and controlled by Programmable Logic Controller (PLC) to reduce or increase current drawn from th e transformer-rect ifier to the electrochemical generator as necessary. The Group assessed the effect of the side stream dosage to the filter and considered this to be insignific ant 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 ba llast 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 SiCURE TM BWMS is controlled by a Siemens PLC, programmed to initiate operation wh en all the system permissives are satisfied. A Human-Machine Interface (HMI) is also provi ded 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 instrume ntation 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 th e 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 inta ke. The instruments and control devices provided to mon itor the process are listed in Table 1.GESAMP-BWWG 10/6

ANNEX 6 Page 13

I:\MEPC\60\2-11.doc 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 dega s 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 al arms are programmed for indication. At high level alarm the transformer r ectifier and the inlet flow to the degassing tank are stopped. The hypochlorite dosing pump will continue to operate to bring down the level be fore 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 readi ng in the treated ballast water.

Control Devices

Failsafe Electronic and

Pneumatic Valves Segregates SiCURE BWMS from the sh ip’s ballast water system in case of emergency such as a fire or a power loss.

3.2.2 The Group noted that accordi ng to the Applicant, the SiCURE TM BWMS will have a data acquisition system. PLC will collect and transmit to the data acquisiti on system those pa rameters that are vital for the reliable performanc e of the filtration and disinfecti on subsystems. The parameters

will include different ial pressure setpoint (backwash trigger), differential pressure and backwash

duration for the filter and ORP setpoint, ORP value, DC curren t, DC voltage, electrochemical generator flow, differential pressure in the hydro gen degas tank – for th e disinfection system.

3.2.3 The Group noted that according to the Appli cant, 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 r eady 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.GESAMP-BWWG 10/6

ANNEX 6 Page 14

I:\MEPC\60\2-11.doc 3.2.4 The Group noted that accordin g 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 op eration 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 appropriat e. Log extreme changes in reading;

- checking the system data logger and ex amine the data recorded. Look for any variation; and

- monitoring any abnormal alarm.

3.2.5 The Group noted that according to the Applic ant, the system’s mechanical equipment is composed of the following:

- Automatic Backwash Seawater Inlet Filt er 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 equipmen t 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 SiCU RE hypochlorite generator. Extended operation in this mode is not recommende d 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.GESAMP-BWWG 10/6

ANNEX 6 Page 15

I:\MEPC\60\2-11.doc .2 A separate strainer and a spare strainer basket are provided for the protection of the electrochlorination section of the syst em that will enable the user to finish ballasting. This electrochlorination strain er 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 fo r the time to replace the fouled strainer basket with the clean spare basket. One spar e 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 Gr oup noted that the ope ration of the system results in the generation of hydr ogen gas but the system includes a degas tank with air blowers and hydrogen gas detecting instru mentation 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 th e 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 gene rator, seawater will cont ain 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 oxyge nated chemical compounds and oxygen gas (O 2 ) generated at the anode and hydrogen gas (H 2 ) generated at the cathode. The Group also recalled that sodium hyp ochlorite is referred to as Fr ee Available Chlorine (FAC) and is determined as TRO (expressed as mg Cl 2 /L). In the BWMS under consideration, the Active Substance is applied at up to the ma ximum allowable dose of 6 mg/L (as TRO Cl 2 ) 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 decom pose. For example, hydrogen peroxide will be reduced to water by free available chlorine and ozone will decompose into oxygen gas with chlo rine acting as a catalyst. Therefore, these oxyge nated species will not

be considered as either Active Substance or Re levant 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 analys es of treated ballast water for Active Substance, Relevant Chemicals and Other Ch emicals as part of this application for Basic Approval. To date , Siemens has used two accr edited laboratories for all analytical services:

- Enviroscan Analytical Services, Rothschild, WI, United States; and

- Underwriters Laboratories (U L), 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.GESAMP-BWWG 10/6

ANNEX 6 Page 16

I:\MEPC\60\2-11.doc 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 μ g/L

Tribromomethane 0.2 μ g/L

Bromobichloromethane 0.4 μ g/L

Dibromochloromethane 0.2 μ g/L HAA 552.2 Liquid extraction, derivatization and gas chromatography with electron capture detection Trichloroacetic acid 1.0 μ g/L

Tribromoacetic Acid 4.0 μ g/L

Dibromoacetic acid 1.0 μ g/L

Dichloroacetic acid 1.0 μ g/L

Monochloroacetic acid 2.0 μ g/L

Monobromoacetic acid 1.0 μ g/L

Sodium

Bromate 317.0 Ion chromatography with the addition of a postcolumn reagent for trace bromate analysis 1.0 μ g/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 Ot her Chemicals, the Group recognized that trihalomethanes (THM), haloacetic acids ( HAA) and sodium brom ate are disinfection by-products. A selected list of Relevant Chemi cals 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 duri ng land-based and shipboa rd testing for Final Approval. Concentration levels of certain Relevant Chemicals presented in the table were obtained during laboratory tests with water fr om the North Sea (seawater) by simulating the

SiCURE TM BWMS, therefore, the data provided for fresh water are estimates only. Testing was carried out in collaboration with the Royal Nether lands Institute for Sea Research (NIOZ), Texel,

the Netherlands.GESAMP-BWWG 10/6

ANNEX 6 Page 17

I:\MEPC\60\2-11.doc Table 3: Potential Relevant Chemicals in the BWMS

List of potential Relevant Chem icals produced in ballast water 2

Concentration, μg/l Chemical Name Formula Molecular Weight CAS

Number

Fresh

water 1 Salt

water (bio)degradation

rate or half-life

Trihalomethanes:

Trichloromethane CHCl 3 119.38 67-66-3 < 90 ND 3 From no decay to 28 days

Dibromochloromethane CHBr 2 Cl 208.29 124-48-1 ND < 3 No decay

Tribromomethane CHBr 3 252.77 75-25-2 ND < 90 No decay

Haloacetic acids:

Dichloroacetic acid C 2 H 2 Cl 2 O 2 128.94 79-43-6 < 30 < 3 > 60 days

Trichloroacetic acid C 2 HCl 3 O 2 163.39 76-03-9 < 33 ND > 60 days

Dibromoacetic acid C 2 H 2 Br 2 O 2 217.86 631-64-1 ND < 50 > 60 days

Tribromoacetic acid C 2 HBr 3 O 2 296.76 75-96-7 ND < 60 > 60 days

Sodium Bromate NaBrO 3 150.9 7789-38-0 ND < 80 > 60 days

Note : 1 – Estimate. There were no tests performed to date w ith the fresh water. This will be addressed during land-based and shipboard testing.

2 – During land-based testing halogen acetonitrile com pounds will be also includ ed 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 recomme nded 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 assess ed the toxicological hazards and potential human exposure associated with chemical s of potential concern generated by

the SiCURE TM BWMS, which include the Active S ubstance sodium hypochlorite and Relevant Chemicals such as chloroform, brom oform, dibromoacetic acid and bromate.GESAMP-BWWG 10/6

ANNEX 6 Page 18

I:\MEPC\60\2-11.doc 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 hypo chlorite 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 me asures (leak detection, hydrogen gas removal in the degas tank, equipment isolation, stray current protection, interlocks, etc.) and by following the use of appropriate pers onal protective equipment when performing maintenance and/or repair on the system.

4.2.2 The Group noted that the A pplicant developed a hypothetica l 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 inges tion 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 wa ter guidelines, which assu med daily ingestion of

water at a rate of 2L/d. The followi ng modification factor was calculated:

7,300 10days/yr 365days/yr

event day 0.01liter/ 2liter/day

= ×

The resulting modification factor of 7,300 was th en multiplied by the drinking water guideline values presented by the Applican t to derive the concentrations shown in the column called “Risk-based criteria based on likely Exposure Scenar io”. The derived chemical concentrations

were found to be below the threshold concentr ations recommended by re liable international

bodies. The concentration of chemi cals 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 alt hough 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 A pproval that inhalation and dermal exposure routes are more adequate to assess th e exposure of crew and BWMS operators.

4.2.4 In addition, the Group recommended that pr ecautionary measures e.g., by using personal protective equipment (PPE) should be followed wh en any operator enters the ballast tanks for inspection or for sampling operational procedures.GESAMP-BWWG 10/6

ANNEX 6 Page 19

I:\MEPC\60\2-11.doc 4.3 Exposure of general public throug h 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 publ ic through the food chain (by way of marine foods).

4.3.2 The Group considered that sea bathers in th e 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 chemi cals were generally lower than their respective drinking water guideline values. Therefore, no adverse health effects would be expected from bathers exposed to diluted concen trations of these chemicals.

4.3.3 The Group concurred with the Applicant th at general public exposed via consuming

seafood from the harbour area where the ballast wate r may be released is unlikely to be exposed to chemicals generated by the system due to low bioaccumulative potential (log K

ow less than 4) and, consequently, would not be expect ed 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 th at the operation of this BWMS poses no unacceptable risk to ships’ crew (BWMS opera tors 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 problem s during the ballast water treatment have been summarized above. In particular , a summary of the various safe ty measures developed by the Applicant is given above in section 3.

5.1.2 The Group noted that the A pplicant intends to conduct a comprehensive evaluation of corrosion effects and provides some background lit erature which indicates that corrosion rates may be increased based on this treatment technology. The Group recommended that comprehensive corrosion testing be conducted, taki ng into account the guid ance 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 (BWM S operators included) by exposure to chemicals and treated ballast wa ter is judged to be acceptable based on the measures developed by the Appl icant for installation on board sh ip. A summary of the various safety measures developed by the Applicant is given above in section 3. The Group consideredGESAMP-BWWG 10/6

ANNEX 6 Page 20

I:\MEPC\60\2-11.doc 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 syst em components are adopted that are expected to minimize the exposure risk of ships’ crew to chem icals and ballast water before and after treatment, through the exposure r outes 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 unacc eptable risk to the health of the general public in light of the out come of the human exposure routes of concern assessed, as discussed above in section 4.

6 ENVIRONMENTAL RISK ASSESSMENT

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

6.1.1 The Group noted that the Applicant has ma de a comprehensive listing of P, B and T

criteria for the Active Substance and Relevant Chemicals found in th e 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 ha lf-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 expect ed to bioaccumulate using Pr ocedure (G9) criterion of a log Pow <3.

6.1.4 In the case of toxici ty, the Group noted that the chronic toxicity database in this dossier (see section 1 in the appendix of this report) indi cates that none of the Active Substances appear to be toxic to fish (0.04 mg/L) and crustac eans (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 cr iterion of <0.01 mg/L is used. No chronic toxicity data were found for any trophic le vel exposed to hypochlorous acid or hypobromous acid. The Group noted that the chro nic toxicity database shows fo r 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 S ubstances. For example, the bromate NOEC for algae is 8 mg/L which is almo st 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 NO EC for algae exposed to bromoform is 3 orders of magnitude higher than the <0.01 mg/L leve l set for the Active Substances. No acceptable OECD chronic data were found for any of the four HAA under considera tion for this dossier.GESAMP-BWWG 10/6

ANNEX 6 Page 21

I:\MEPC\60\2-11.doc Table 4: PBT evaluation of Acti ve 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 st ipulated requirement for Basic Approval. However, after deliberation, the Gr oup considered that the treated ba llast water discharge ecotoxicity results were not likely to be substantially differe nt from those obtained from electrolytic systems previously considered by the Group and gran ted Final Approval by MEPC. Hence, the Group agreed to make an exception in this case and furt her agreed that the lack of submitted data could be overlooked in this particular Basic Approva l assessment. The Appli cant should provide the results of acute and chronic aquatic ecotoxicity te sting of treated ballast water, in accordance with the full requirements of Procedure (G9), to be reviewed for Final Approval.

6.3 Risk assessments of chem icals for aquatic organisms

6.3.1 Aquatic Ecotoxicity and Predicte d No-Effect Concentration (PNEC)

6.3.1.1 The Group noted that the Applicant has pr ovided a comprehensive database of acute and chronic aquatic ecotoxicity data in the present dossier, for bo th 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, crust aceans, and algae, respectively. In some casesGESAMP-BWWG 10/6

ANNEX 6 Page 22

I:\MEPC\60\2-11.doc toxicity data could not be found that followed th e OECD Guidelines. Thus, some toxicity data were taken that utilized other acceptable test pro cedures. In addition, sel ected data that did not

meet OECD Guidelines or other a ccepted 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, crust aceans 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 ch ronic 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 “T he Methodology for the informati on gathering and the conduct of work of the GESAMP-BWWG” (IMO, 2008) – see Table 5 below.

Table 5: Predicted No-Effect Concentrat ion (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 μ g/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 MAMP EC model in this application for Basic Approval to calcul ate 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 Chemical s were calculated based on a dilution factor determined during the MAMPEC simulation. For m odelling 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 reveal ed 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 concentra tions were used in calculations:

- 0.13 mg/L : a concentrat ion observed in treated wate r 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 assu med by the Applicant that 1, 10 or 80 ships are present in the harbour and that all ships ar e equipped with the SiCURE TM 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 m 3 /d or about 16,540 m 3 /h of treated ballast water into the harbour. These numbers for the Port of Rotterdam were used in the publicly ava ilable dossiers of other BWMS developers and it

would be reasonable to maintain the same scenar ios in the current calculations. For all runs of MAMPEC, the OECD-EU commercial harbour wa s 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)

Maximum PEC, μg/L at a Half-Life of TRO in Treated Water, 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 0.68GESAMP-BWWG 10/6

ANNEX 6 Page 24

I:\MEPC\60\2-11.doc 6.3.2.3 The Group noted that PEC values of Releva nt Chemicals for the worst case scenario of 80 ships in the harbour are summarized in Ta ble 7 assuming no decay, 90 times dilution factor and maximum discharge concentrat ions reported in the dossier.

Table 7: Summary of PEC calculations for 80 ships for Relevant Chemicals

PEC, μg/L Relevant Chemical

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-lif e less than 4 h ours and discharge concentrations between 0.13 mg/L and 0.55 mg/L , the range of average PEC values was

between 3.2E-6 μ g/L and 2.7E-3 μ g/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 μ g/L and 0.076 μ g/L. Results show that in stagnant waters of the port (maximum values) the PEC values may peak at 2 to 3 tim es 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 recalcula te their results. Although the Group appreciated the thorough analysis of the PEC at different half-lives in the Ro tterdam 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 va lues provided and due to the degradation rates employed, results for the calculated concentrati ons 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 re ceive a PEC calculation submission with all the above points a ddressed and mistakes corrected.GESAMP-BWWG 10/6

ANNEX 6 Page 25

I:\MEPC\60\2-11.doc 6.3.3 Risk to the aquatic envi ronment – 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 s cenario. 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 concentr ations of 0.55 mg/L an d 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 pres ented the PEC/PNEC ratios for the average, minimum, and maximum concentrations of HOC l for 1 ship, 10 ships, and 80 ships in the Port of Rotterdam using the dilutions predic ted by the MAMPEC model for various HOCl decay

half-lives. The worst case HOCl PNEC of 0.032 μ g/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 pr esented by the Applicant demonstrate that the PEC/PNEC ratios indicate that no aquatic risk (ratio <1) exists when one ship discharges

treated ballast water af ter either 24 or 120 hour s duration in a ballast holding tank, following an initial chlorination at 5.6 mg/L HOCl and the residual Active Subs tance 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 subs equently 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 pr edicted when ballast water has been initially chlorinated with 5.6 mg/L HOCl held in the ball ast 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 be en 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 ship s at a half-life >0.5 hours when ballast water has b een 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 A pplicant that PEC/PNEC ratios for Relevant Chemicals will be below 1 (no aq uatic 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 th e 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 equippe d with the SiCURE BW MS 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 modelGESAMP-BWWG 10/6

ANNEX 6 Page 26

I:\MEPC\60\2-11.doc 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 fo r 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 calcul ated 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 practi cally 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, speci al attention has to be paid by the Applicant to identifying a realistic decay ra te (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 alrea dy indicated above, that it was not able to recalculate the results achieved by the Applican t 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 pe rformed 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 SiCURE TM

BWMS has to be defined based on the Active Substance residual concen tration 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 retenti on time, preferably within 1 day to 3 days.

6.4.2 The Group recommended that the Applicant should define the SiCURE TM 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 Cl 2 ) to be achieved using a minimum holding time. The Group considered that the Applicant’ s proposed MADC for the Active Substance is acceptable, with th e provision that a mi nimum holding time is determined and justified at Final Approval. Th e Group noted that the A pplicant did not provide any information on ecotoxicity testing of the treate d ballast water that is a stipulated requirement for Basic Approval. However, after deliberation, the Group considered th at the treated ballast water discharge ecotoxicity result s were not likely to be subs tantially different from those obtained from electrolytic systems previ ously considered by the Group and granted Final Approval by MEPC. Hence, the Group agr eed 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 requirementsGESAMP-BWWG 10/6

ANNEX 6 Page 27

I:\MEPC\60\2-11.doc of Procedure (G9), to be reviewed for Fina l 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 cal culated 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 mo re realistic estimation of the decay rate of Active Substance is required, as the modelling currently shows ther e 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 Ba sic Approval could be recomm ended, 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 problem s during the ballast water treatment have been

described and discussed above.

7.1.2 The Group noted that the App licant intends to c onduct a comprehensive evaluation of corrosion effects and provides some background lit erature which indicates that corrosion rates may be increased based on this treatment technology. The Group recommended that comprehensive corrosion testing be conducted, taki ng into account the guid ance 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 info rmation 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 SiCURE TM BWMS.

7.2 Risks to the crew and general public

7.2.2 The Group considered th at the Siemens SiCURE TM 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 installa tion on board ship. As such, the Group was able to recommend that Basic Approval can be granted to the Siemens SiCURE TM 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 appropr iate in assessing the exposure of crew and BWMS operators.GESAMP-BWWG 10/6

ANNEX 6 Page 28

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 environm ental 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 SiCURE TM 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 meet ing, the Group was able to recommend Basic Approval for

the Siemens SiCURE TM 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 comprehe nsive corrosion testing be conducted, taking into account the guidance in secti on 5.1 of the “Repor t of the eighth meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16.

.2 The Group recommended that confirmati on 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 th e chemical composition of treated ballast water caused by the us e of this BWMS.

.3 In accordance with the requirements of Procedure (G9), the Group recommended that acute and chronic aquatic ecotoxicity testing of treat ed 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 trea ted by the system. This may include control system logic to veri fy the Applicant’s claims.

.5 The Group recommended that an envir onmentally 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 th at the MADC is not exceeded, or a neutralization step. The Group recomme nded 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 Page 29

I:\MEPC\60\2-11.doc .8 The Group recommended that inhalation an d dermal routes of exposure should be considered by the Applicant as the Group be lieves these to be more appropriate in assessing the exposure and occupational risk of crew and BWMS operators.

.9 The Group recommended that a more r ealistic 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 al l the above-mentioned points addressed

and mistakes corrected.

* * *GESAMP-BWWG 10/6

ANNEX 6 Page 30

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

RISK ASSESSMENTS OF CHEMI CALS FOR AQUATIC ORGANISMS

1 Effects on Aquatic Organisms – Inform ation used to Derive PNEC Values (As presented by Applicant)

Table A1: Acute aquatic toxicity a

Test

Substance F

C

A Species Test Type LC 50 /

EC 50 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 survival b 0.032 N/A Fisher et al. (1999) TRO (Freshwater)

A Natural phytoplankton 47-h change in

Chl

a 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 survival d 0.062 N/A Fisher et al. (1999) TRO (Saltwater)

A Dunaliella primolecta 24-h growth e (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 survival g 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 survival g 30 N/A Foster and Tullis (1984) Chloroform

A Scenedesmus subspicatus 48-h growth h (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 LC 50 /

EC 50 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 hatch i 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

immobilization j 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 literatureGESAMP-BWWG 10/6

ANNEX 6 Page 32

I:\MEPC\60\2-11.doc 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 Guid elines 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 re quirements (Test Method 2021 .0) for measuring the acute toxicity of effluents an d receiving waters to Daphnia magna (U.S. EPA, 2002a).

c Study did not meet OECD 201 Guidelines because the test evaluated a change in chloro phyll at 47 h rather than growth at 72 h.

d Study did not meet OECD guide lines because the test evaluated survival at 96 h rather than immo bilization at 48 h. However, the test did meet U.S. EPA regulatory test re quirements (Test Method 2007 .0) for measuring the acute toxicity of effluents an d receiving waters to Mysidopsis bahia (U.S.EPA, 2002a).

e Study did not meet OECD 201 Guidelines because the test ev aluated 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 regulato ry test requirements (Test Method 2002.0) for measuring the acute toxicity of effluents and receiving wate rs to a representative crustacean (U.S.EPA, 2002a).

h Study did not meet OECD 201 Guidelines because the test ev aluated 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 LC 50 could not be established. Test did not meet OECD 203 Guidelines; however, the test did meet U.S. EPA regulatory test requirements (Test Method 10 01.0) 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 toxici ty of effluents and receiving waters to a representa tive crustacean (U.S.EPA, 2002a).

Table A2: Chronic Aquatic Toxicity a

Test

Substance F

C

A Species Test Type LC 50 /

EC 50 Mg/L NOEC mg/L Reference/

Comments

Active Substances

F Ictalurus

punctatus 134-d growth b 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

biomass c N/A (0.079) Pratt et al. (1988)

F Menidia peninsula 32-d egg to posthatch N/A 0.04 Goodman et al. (1983)

C Panaeus

kerathurus 7-d growth/moulting d N/A (0.079) Saroglia and Scarano (1979) TRO (Saltwater)

A Natural phytoplankton 21-d reduction in cell density c N/A (0.001) Sanders et al. (1981)

F Oncorhynchus

kisutch 23-d survival e N/A 0.042 Holland et al. (1960)

C Americamysis

bahia 7-d reproduction d N/A 0.048 Fisher et al. (1994) HOCl

A No data found

in literatureGESAMP-BWWG 10/6

ANNEX 6 Page 33

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

Substance F

C

A Species Test Type LC 50 /

EC 50 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 survival f (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 literatureDibromochloromethane

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 proliferation g (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

threshold h (200) OECD SIDS (2008)GESAMP-BWWG 10/6

ANNEX 6 Page 34

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

Substance F

C

A Species Test Type LC 50 /

EC 50 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 parenthesi s did not meet OECD Guidelines or othe r accepted testing procedures but were included to provide an indication only of potential toxicity.

b Study did not meet OECD 210 Guide lines because the test was initiated w ith juveniles rath er than the egg

stage.

c Study did not meet OECD 201 Guid elines because the test did not have control culture biomass data.

d Study did not meet OECD 211 Guidelines because the te st was not a 21-d reproduc tion 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 Guide lines because the test exposure was 23 days rather than the required minimum of 28 days.

f Study did not meet OECD 210 Guide lines 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 te st used cell proliferation and as an endpoint rather than growth.

h Study did not meet OECD 2 01 Guidelines because the test used toxi city 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 wa s originally programmed

to calculate environmental concentrations of anti -fouling biocides released from ship coatings. In a modified way it can be used to calculate con centrations that are released constantly into the water by other processes like for example ballast wa ter 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 theref ore all based on HOCl (as sodium hypoc hlorite). PECs of DBP were

calculated based on a dilution factor determined during MAMPEC simulation.GESAMP-BWWG 10/6

ANNEX 6 Page 35

I:\MEPC\60\2-11.doc Parameterization of the model

To determine the environmental concentration of the released compound in the harbour water and the sediment, several parameters are necessar y. These parameters define the harbour and its characteristics, the compound that is being rele ased and the amount of ships and the amount of the specified compound released by t hose ships. This section provi des 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 coe fficient [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 therefor e 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 po ssible to include the de cay of the compound of interest during emptying the ballast water tank. In this case, theref ore, a worst case scenario was

assumed that the water released from the ballast tanks has the same concen tration at the start and at the end of discharge.

TRO concentrations in the ballast wat er 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 concentra tions 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 ho urs 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 th e water characterized by the same holding time (TRO level).GESAMP-BWWG 10/6

ANNEX 6 Page 36

I:\MEPC\60\2-11.doc 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) m 3 /day or about 16,540 m 3 / 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 re asonable 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 wa s 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 μ g·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 5.1117·10 7 m3 · tide -1GESAMP-BWWG 10/6

ANNEX 6 Page 37

I:\MEPC\60\2-11.doc 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 assume d to be 0 to determ ine exactly the amount introduced by the SiCURE TM BWM system.

Results of modelling

Modelling was carried out for a si ngle 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 tota l amount of HOCl in por t after discharge is mainly made up by the soluble fraction. The susp ended fraction in all c onsidered scenarios was

below 0.002%.GESAMP-BWWG 10/6

ANNEX 6 Page 38

I:\MEPC\60\2-11.doc 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-01GESAMP-BWWG 10/6

ANNEX 6 Page 39

I:\MEPC\60\2-11.doc 0.00 0.01 0.02 0.03 0.04 0.05 0.06

0 0 1 10 100 1000 10000

Half-Life, hTRO PEC, μg/l

average

minimum

maximum

Figure: Results of MAMPEC modelling for one ship, PE C TRO vs. TRO half-life at discharge TRO of 0.13 mg/L. Half-lif e 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, hTRO PEC, μg/l

average

minimum

maximum

Figure: Results of MAMPEC modelling for one ship, PE C TRO vs. TRO half-life at discharge TRO of 0.55 mg/L. Half-lif e axe is in a logarithmic scale.

Predicted environmental concentrations of TRO (P EC TRO) based on the calculation with one ship vary significantly de pending on which value of the TRO half-lif e was selected as a model parameter.

For a half-life less than 4 hours and discharge concentrations be tween 0.13 mg/L and 0.55 mg/L, a range of the average PEC values was between 3.2E-6 μ g/l and 2.7E-3 μ g/l. For a half-life greater than 4 hours and discharge co ncentrations between 0.13 mg/L and 0.55 mg/L, a range of the average PEC values was between 0.001 μ g/l and 0.076 μ g/l. Results show that in stagnant waters of the port (maximum values) the predicted envir onmental concentration may peak at 2 to 3 times that of the average value. At half-lives of greater than several thousand hours (equal to noGESAMP-BWWG 10/6

ANNEX 6 Page 40

I:\MEPC\60\2-11.doc apparent decay) the predicted environmental con centration approaches an asymptotic value. An asymptotic value of the predicted environmenta l TRO at infinite half-l ife (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 ti mes for a single ship in port and about 90 times for 80 ships in port.

Analysis of the data presented underscores the impor tance of a properly select ed half-life value. With a 1 hour chlorine demand of above 2 mg/L obser ved 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 PE C for total residual oxidant in the port water assuming that there are 1, 10 and 80 ships in port, all being equipped with the SiCURE TM BWMS and simultaneously discharging treated ballast wate r with the same holding time. It is expected that only about 10 ships in the port would actually be equipped with the SiCURE TM BWMS. The first Figure presents the data for a half-lif e 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 holdi ng 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 harborPEC 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 minuteGESAMP-BWWG 10/6

ANNEX 6 Page 41

I:\MEPC\60\2-11.doc 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 harborPEC TRO, μg/l 0.13 mg/l

0.55 mg/l

Figure: Average concentration of TRO in th e 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 harborPEC TRO, μg/l 0.13 mg/l

0.55 mg/l

Figure: Average concentration of TRO in th e harbour calculated for 1, 10 and 80 ships for

half-life of 1 hour

The final results of the predicted environmen tal concentrations of TRO for the worst case scenario of 80 ships in the harbour are summari zed in Table A4 below for the wide range of

half-life values.GESAMP-BWWG 10/6

ANNEX 6 Page 42

I:\MEPC\60\2-11.doc Table A4: Summary of PEC calculations for 80 ships

Maximum PEC, μg/l at a Half-Life of TRO in Treated Water, 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

PEC, μg/l DBP

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 mode ls other than MAMPEC that take into

consideration the effect of a chlorine demand. These results will be used to define the

SiCURE TM 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 APPRO VAL 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 Sout h Africa with the application for Final Approval and the info rmation received from the Applicant during the GESAMP-BWWG meeting, the Group recomm ended to MEPC that Final Approval be granted to the Resource Ballast Technologies System, provided that recommendations given below are take n into account.

0.2 The Group recalled that Basic Approval of this ballast water management system (BWMS) was granted by MEPC 57 to Resource Balla st 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 satisfi ed 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 ballas t water with small amounts of Active Substances (ozone and sodium hypochlorite) to assist the cavitation process, togeth er 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 gene rator unit and electrolysis of seawat er 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 Cl 2 ), while the ozone is injected into the ballast water, also up to a maximum allowable dose of 1 mg/L (TRO as Cl 2 ). The Group noted that ballast water is treated on uptake only.

0.5 As the BWMS does not require the stor age of chemicals on board ship, the Group recognized that there will be no asso ciated storage safety problems.

0.6 The Group recognized that the system utilizes Active Substances and produces Relevant Chemicals and Other Chemicals with potential sa fety and environmental concerns and the Group

has reviewed the hazards and risks asso ciated with all these chemicals.

0.7 The Group recognized that the A pplicant 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 ar e in progress as part of the la nd-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 th e Applicant of detailed analytical results for the Active Substances, Relevant Chemicals a nd Other Chemicals in tr eated ballast water. The Group accepted the view of the Applicant that there are no unacceptable risks in the chemical composition of ballast wate r caused by the use of this BWMS.

0.9 The Group noted the human health assessmen t provided by the Applicant that includes occupational exposure to ships’ crew, BWMS op erators and the exposure of the general public. The Group considered that the Resource Ballast Technologies System pose s no unacceptable risk

to the health of the crew and the general public regarding the e xposure to chemicals and treated ballast water based on the submitted human expos ure assessment and the mitigation measures developed by the Applicant fo r installation on board ship.

0.10 The Group recognized that the Applican t has provided detailed information on ecotoxicity testing of treated ballast water, envi ronmental risk assessment for aquatic organisms and a proposal for maximum allowable discha rge concentration for the Active Substances, together with minimum holding time for the tr eated 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 hypoc hlorite measured in TRO = 0.1 – 0.2 mg/L (as Cl 2 )

In addition, to ensure that the TRO at discharge remains below the MADC, the Group recommended that a TRO monitoring and reco rding function be incl uded at discharge.

0.11 In conclusion, having reviewed all the in formation provided by the Applicant, the Group agreed to recommend to the MEPC that Fina l Approval be granted to the Resource Ballast Technologies System, subject to the Administration verifying th at 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 Cl 2 ), while the ozone is injected into the ballast water, also up to a Maximum Allowable Dose Concentration of 1 mg/L (TRO as Cl 2 ).

.2 Maximum Allowable Discharge Concentr ation of Total of Ozone and Sodium hypochlorite measured in TRO = 0.1 – 0.2 mg/L (as Cl 2 ). In addition, to ensure that the TRO at discharge remains below the MADC, the Group recommended that a TRO monitoring and recording f unction be included at discharge.GESAMP-BWWG 10/6

ANNEX 7 Page 3

I:\MEPC\60\2-11.doc 1 INTRODUCTION

1.1 The data used to evaluate this system we re 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 alread y provided the following questions and concerns during its evaluation of the appli cation 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 Applic ant for Final Approval. The Applicant’s responses received, and the Group ’s reaction to these re sponses are shown in

Table 1.

Table 1: Applicant’s Responses to Data Re quests 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 Page 5

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

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

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, th e IMO-GESAMP Consul tant 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 numeri cal 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 th e 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-GESA MP 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 co ncentrations) 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.GESAMP-BWWG 10/6

ANNEX 7 Page 7

I:\MEPC\60\2-11.doc Response 1:

.1 The maximum measured concentration of hydrogen gas in the simulation ballast tanks were considerably lower than the wo rst case scenario estimates generated by the mass balance calculation (see paragra ph 2.4.1, appendix 9). We do not believe

that this should be of c oncern, and consider that it merely reaffirms that the calculated estimates of hydrogen gas pr oduction are worst case scenario estimates, and that the hydroge n gas, being lighter than th e 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 concentr ation in the ballast tanks will be conducted as part of the shipboard tr ials 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 (n either in appendix 8 nor in appendix 11) where

does this information in section 7.2.2 come fr om? You say that the data was obtained from the 28-day fish chronic test but there is no ment ion of gas tests in the fish study report and the document in appendix 11 is brief and only consis ts 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 r un concurrently with the fish chronic toxicity tests described in appendix 8 of this application dossier, covering the latter 8 days of this experiment, conti nuing for a further 2 days after the 28-day fish experiment terminated. Gas detector s 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 concentra tions of hydrogen and chlorine gas in the header space continuou sly over this period.

.2 Appendix 11 is a report provided by Pinnacle Instru ments (Pty.) Ltd. on the procedure followed in measuring gas co ncentrations and the data collected. The order of the page s seems to have been mixed up in the co py 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 measurem ents 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 ga s), actual readings for Chlorine (ppm) and Hydrogen gas (%) are shown on page s 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 page s) 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

I:\MEPC\60\2-11.doc Question 3:

3 I have some concerns ab out the detailed calculations used in the desk-based methods, as follows: 1 Faraday cannot be equal to 1 Coul omb, 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 informatio n in the scientific literature “Faraday’s Law”: The amount of substanc e 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 th e cell. By definition, one Coulomb (C) of charge is transferred when a one-ampere cu rrent 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 subm ission 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 co rrect. Please check and re-confirm.

Response 3:

We have checked desk top calcu lations of gas concentrations and acknowledge that there

are some errors in these calculations. Th is assessment has been entirely redone.

The revised risk assessment have been incl uded 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 ga s 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 ch emistry results for treated discharge had TRO > 0.2 mg/L, on that basis does the App licant plan to include a neutralization step?

Response:

.1 The design of the RBT reactor as it sta nds does not include a neutralization step. The reasons for this is that our experi ments 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 hi ghly improbable, we do not consider it necessary to include a neutra lization step in the process.

Although the Group was satisfied with the resp onse, the Group recommended TRO monitoring and recording of the discharge to ensure enviro nmental 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 co ntrol for both ozone and electrolytic chlorination in the influent ballast? Speci fically, how is the TRO monitored and are the injection of ozone and el ectrolytic chlorination modified through a feedback control mechanism to sustain the target treatment dosage?

Response 2:

.1 Ozone Dosage Control – O3 is generated in m odular 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 ad justing the power supplied to the ozone cells. As the flow rate of the ballast syst em increases so, too, does the number of ozone cells in the system in order to pr eserve 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 pl aced 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 th e 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 si de of the oxygen to Oz one electrode cell. The mass flow sensor is connected to the electronic controller producing the power

that is delivered to th e Ozone electrode cell. (Text deemed to be confidential and removed at the request of th e submitting Administration.) Ozone is thus produced at a rate that is in proporti on to the air flow ra te through the ozone ge nerator, which is in turn in proportion with th e flow rate of th e ballast water thr ough the RBT reactor, thus ensuring the concentrati on of ozone in the treated ballast wate r 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 ventur i 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 ma ximum 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 grad ient. 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 extracti on 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 Page 10

I:\MEPC\60\2-11.doc .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 reacto r vessels. The electrodes are powered by electro chemi cally 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 iden tical. There is proportional relationship between the power applied to the elect rode and the amount of NaOCl produced. The system also features a chlorine sens or, 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 inte nded 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 hum an health risk in th e space where the system is located, from leakage of ozone from either the ozone gen erator 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 Ce ll 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 que stion 2). The ventur i (suction) is only operational when the ballast pump is in ope ration. 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 compressi on 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 dr awn from the Cape Town ha rbour by means of a series of pipes where it is passed through th e 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 a pproved 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 Admi nistration verified by letter that the testing was conducted within the provisi ons of Guidelines (G8). Therefore, the Group considered that the ecotoxicity data we re derived from appropriate samples.

Other questions related to Question 4:

4.1 How much is the TRC (Treatment Rated Ca pacity) 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 ar e 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.GESAMP-BWWG 10/6

ANNEX 7 Page 12

I:\MEPC\60\2-11.doc Question 5:

5 Does the system design incorporat e 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 de scribed 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 inco rporation of both th e electrochemical (NaOCl) and ozone allow the RBT system to effectively treat both fresh and

seawater. NaOCl is more effective in s eawater condition and the ozone treatment

is more effective in fresh water conditions. Measured concentrations of TRO in fresh water (a measure of all residual oxida nts 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 wate r, production of NaOC l 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 th e Applicant clarify how the dosage of

ozone and chlorination is modified to a ccommodate for these variations? Also, can the Applicant clarify how the ratio of ozon e 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 se t point value that is preset on the electronic controller been compared to th e actual value as recorded by a chlorine sensor, as indicated in th e response to question 2 above. The dosage of ozone on the other hand, varies in res ponse to the flow rate of water through the reactor as indicated in the response to question 2 a bove. 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.GESAMP-BWWG 10/6

ANNEX 7 Page 13

I:\MEPC\60\2-11.doc This leads us to also ask the followi ng questions relating to Question 6:

6.1 What condition was set on the ballast wat er 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 oz one remains at a preset level, as indicated in the response to question 5 above. The extended ha lf-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 formatio n of bromates by oxi dants 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 Fina l Approval and laborat ory 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 wa s suggested by the Group that the control system should be described in detail in cluding the sensors for ozone and chlorine monitoring. The Group does not see the resul ts of this suggestion and wonders what the reasons could be. Is this just an omissi on or were there scientif ic reasons for this

decision?GESAMP-BWWG 10/6

ANNEX 7 Page 14

I:\MEPC\60\2-11.doc 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 adequa te. Some of the descriptions required may have been addressed in the above que stions. In addition, we are in the final stages of completing a revisi on, 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 ar e connected together (see Figure 1). The values of chlorine, c onductivity 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 maintena nce 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 ma intenance. 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 (r ecorder) are installe d in this cabinet.

Passwords will be used for the PLC so the access can be controlled. The data logger will be protected th rough 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 re set 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 cel ls are mounted on this cabinet outside. The chiller which cools the ozone producing cells is installe d in the vicinity. Th e maximum length from ozone producing cells to the venturi is five (5) metres. The single line diagram prepared to give an over view of all valves and ot her components is attached (see attachment-1). This diagram contains all information need ed for wiring and to connect every thin g electrically. All components are controlled from the control cabinet. Therefore, all feed backs from the co mponents are routed back to this cabinet. Some of the gathered information is supplied to the ozone generator and

ECA rectifier cabinet to cont rol the chlorine and the ozon e dosages for th e 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 automatica lly 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 r eactor 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 bothGESAMP-BWWG 10/6

ANNEX 7 Page 15

I:\MEPC\60\2-11.doc the reactors and the filter. In the event of an emergency these valves could be opened manually by the operator. An audibl e and a visual alarm will be initiated and the operation will be recorded in th e data logger. The data logger has a capacity to store data for more than 2 y ears. 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 stor ed for information. The procedure to acknowledge the critical alarms should be included in the Ballast Water Management Plan. The alarm log is accessi ble 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 th e 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 rece ived from the Applicant.

3 DESCRIPTION OF THE SYSTEM

3.1 Overview

3.1.1 The Group recalled that this BWMS had alre ady been described a nd 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 balla st water, with a disinfection step based on injection of Activ e Substance ozone and use of natu ral 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 Gro up 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 allowa ble concentration of 1 mg/L (TRO as Cl 2 ), while the ozone is injected into the ballast water, also up to a maximum allowable conc entration of 1 mg/L (TRO as Cl 2 ). 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 suck ed directly into the ballast water being treated. A non-return/one way valve, situated on the cor ona 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, th e reactor unit is fitted to the suct ion side of the pump, in order to create sufficient mechanical cavitation, and cavitation inserts are al so housed within the cavitation chamber. The Applicant describes mechanical cavitation as the main treatment

method and states that ca vitation is enhanced ( data deemed to be confidential and removed at the request of the submitting Administration ).GESAMP-BWWG 10/6

ANNEX 7 Page 16

I:\MEPC\60\2-11.doc 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 t ogether with the ozone gas, thes e two Active Substances perform the disinfection step on the balla st water. Finally, the water fl ow then passes through the pump, and is pumped through the filter under pr essure. 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 stor age 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 ap plication 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 cap able of testi ng the Resource Ballast Technologies System for flow rates of 200 m 3 /hour to 1500 m 3 /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 BW MS is installed into a vessel, all components operate automatically, and are controlled by a progr ammable logistic computer (PLC), installed into the Electrical Control Panel (ECP). Ozonation Filtration

Ballast

Water

Tanks Electrolysis CavitationGESAMP-BWWG 10/6

ANNEX 7 Page 17

I:\MEPC\60\2-11.doc 3.2.2 The Group noted that according to the Applican t, ozone gas is generated within the ozone cell at a pre-determined and preset amount accor ding to the BWMS requirements. Ozone gas is

drawn into the venturi from the ozone cell. Th e venturi fitted to the system operates within certain vacuum parameters that can vary depend ing 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 vent uri suction ability is dire ctly influenced. Should the water flow through the venturi increase so w ill the suction capacity of the venturi increase. This directly affects the flow of ambient ai r through the ozone cell, thereby increasing the

amount of available oxygen that can be converted in to ozone gas. Should the flow of water through the venturi decrease, the am ount of negative pressure create d at the venturi will decrease proportionally, this reduced flow through the vent uri will thus reduce th e 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 Applic ant, control of the el ectrochemical reactor and thus production of NaOCl is via the electrochemi cally activated rectifier, which is controlled with the use of a Frequency M odulated Switch Mode Power Supply.

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

3.3.1 The Group noted that there are two Active S ubstances involved in this BWMS – ozone produced from oxygen in ambient ai r 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 deta il 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 an d 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), d ecomposes very rapidly, depending on conditions (half-life of a few seconds or minut es). In addition, chlorine gas (Cl 2 ) and hydrogen gas (H 2 ) are produced at the electrodes. Chlorine gas will decay to chloride ions.

3.3.2 In addition, the Group recalle d that in seawater, ozone a nd 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 Ac tive Substances. Halogenated by-products (Other Chemicals), like trihalom ethanes (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 br eaks down more slowly (minutes rather than seconds) into oxygen and water. The rate of d ecomposition increases w ith 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 Tota l Residual Oxidants (TRO) also including the halogenamines. FAC, FRO and TRO are expressed as mg Cl 2 /L. The Group noted that the Applicant has provided analyses of treated ba llast 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 we re all assessed togeth er as total residual oxidants (TRO) and free residual oxidants (FRO ) using standard colorimetric methodsGESAMP-BWWG 10/6

ANNEX 7 Page 18

I:\MEPC\60\2-11.doc (HACH DR2800 spectrophotometer; DP D powder pillow method). Results of these chemical analyses of ballast water are presen ted in a detailed series of tables in the appendix to this report.

3.3.5 The Gr oup recognized the detailed nature of these analytical results and summarized the main

features as follows:

Samples of water covering a range of different salt concentrati ons: natural seawater, brackish water and freshwater, and differing organic co ntent: high organic (DOC >>1 mg/L) and low organic content (DOC <1 mg/L) were analys ed on site and/or submitted to independent analytical laboratories in S outh Africa and Switzerland for ch aracterization (see tables in appendix). Seawater samples comprised natura l seawater drawn from the Port of Cape Town, fresh water samples were drawn from th e 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 ch lorine 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 th e 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 th eir 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%), bracki sh 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 con centrations (expressed as mg Cl 2 /L) in treated ballast water ranged from 0.1-1.0 mg/L (average: 0.3 mg /L) and in the filte r backwash water from 0.1 mg/L-0.8 mg/L (average: 0.2 mg/L). FRO concentrations (expressed as mg Cl 2 /L) in treated ballast water ranged fro m 0.0-0.7 mg/L (average: 0.2 mg/L) an d in the filter backwash water from 0.0-0.6 mg/L (average : 0.2 mg/L). No signif icant 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 fu ll strength seawater. This is assumed by the Applicant to be related to the lack of chlorine spec ies (in the form of NaCl) in the fresh water and the rapid breakdown of oz one gas introduced into the wa ter from the ozone generator.

3.3.7 The Group noted that concentrations of Tota l 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 brack ish water) covering both high (DOC >>1 mg/L) and low organic levels (DOC < 1 mg/L). This s uggests that the filter ba ckwash water is unlikely to be any more toxic to biota than treated ballast wa ter, 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 trih alomethanes (THM) and ha loacetic acids (HAA). THM were preserved immed iately after treatment and sent to ERWAT Laboratori es for analysis (see tables in appendix). The re sults indicated that th ere was little ti me for the form ation of DBP when samples were preserved imme diately after treatment (immediate discharge scenar io). A second

series of tests were thus con ducted in which samples were pres erved with ascorb ic acid 3 hours and 5 days after treatment and af ter which samples were analysed for the majo r THM. According to the Applicant, it was decided to preserve samples 3 hours after treatment as th is was found to be the average time that it takes to fill and drain a 200 m 3 simulated ba llast tank.GESAMP-BWWG 10/6

ANNEX 7 Page 19

I:\MEPC\60\2-11.doc 3.3.9 The Group noted the concentrations of th e four THM as determined by Rand Water Analytical Laboratories using the headspace met hod. 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 brac kish water samples preserved with ascorbic acid after three hours and those preser ved 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 Ch emical 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 usi ng 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 ra nged from <0.5 1 μg/L up to 13.1 μg/L, averaging 3.16 μg/L. DBAA was also detected in similar c oncentration in the bracki sh water (mixture of natural seawater and municipal drinking water) along with a second HAA species

− dichloroacetic acid (DCAA). However, concen trations 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. T hus, DBAA is included as a Relevant Chemical in this application. No significant relationship wa s evident between salinity and concentration of DBAA but a significant negative correlati on 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 un likely 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 tr eated with the BWMS. Three replicate test cycles were performed for each wa ter type, and samples were analysed by EAWAG laboratory, Switzerland, using High Performan ce Ion Chromatography (HPIC) with a post column-reaction and UV-detection. Every sample wa s measured at least twice and every second sample was verified by spiking bromate. The quantification limit was at 5 μ g/L for freshwater samples and 10 μ g/L for seawater and brackish water samp les. The higher quantification limit for the latter samples is due to the strong matrix interferences encount ered 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 samp les (high and low organic content) were below

the detection limit of 10 μ g/L, and thus fall below the US EPA and Health Canada guidelines

of 10 μ g/L. The concentration of bromate in all fre shwater samples fell below the detection limit

of 5 μ g/L and thus also fall below recommended gui delines in drinking water (see tables in appendix).GESAMP-BWWG 10/6

ANNEX 7 Page 20

I:\MEPC\60\2-11.doc 3.3.12 The Group recognized the comprehensive na ture of the data se ts 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 liste d in Table 2 have been identified as Active

Substances or Relevant Chemicals.

Table 2: Active Substances (AS) and Re levant 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 O 3 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 H 2 H – H - RC Chlorine gas 7782-50-5 70.9 Cl 2 Cl – Cl - RC

Bromoform 75-25-2 252.73 CHBr 3 12.0 μg/L RC

Dibromoacetic

acid 631-64-1 217.84408 C 2 H 2 Br 2 O 2 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 so mewhat 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 informa tion provided by the Applicant concerning hazard identification and occupational exposur e 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 th e water samples treated using the BWMS (MDL 10 μg/L); nevertheless the Applicant reco mmended additional PPE/RPE to the crew when entering ballast tanks.GESAMP-BWWG 10/6

ANNEX 7 Page 21

I:\MEPC\60\2-11.doc 4.1.4 Bromoform was detected at concentration leve ls of 12 μg/L in the treated ballast water. According to the Applicant ́s human exposur e 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/m 3 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 m 3 in a 5 h-shift), the exposure was calculated as 0.195 mg/kg bw. A MOS of 3.6 was derived based on Mi nimum Risk Level (MRL) 0.7 mg/kg bw/day. The risk was concluded as being acceptable for inhalation exposure to th e 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 th at risks associated with crew exposure to hydrogen gas and chlorine gas produced by the electrochemical reactor have been assessed by the App licant and prov en to be acceptable through estimating the ra te of production for th ese gases using desk-b ased methods and by monitoring gas concen trations in the header space of a 200 m 3 simulation ballast tank.

4.2 Exposure of general public thro ugh 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 (Cl 2 ) measured in 100% treated ballast wate r 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.GESAMP-BWWG 10/6

ANNEX 7 Page 22

I:\MEPC\60\2-11.doc 4.2.3 The Group considered that the risk to the general public by exposure to Active Substances and Other Chemicals present in the treat ed ballast water to be acceptable.

4.3 Conclusion on Human Health Assessment

4.3.1 Therefore, the Group was satisfied that result s 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 problem s during the ballast water treatment have been summarized above. In particular , a summary of the various safe ty measures developed by the Applicant is given above in section 3.2.

5.1.2 The Group noted that the Applicant has submitte d 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 re view 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 appendi x 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 concentra tion of 1 mg/L (TRO as Cl 2 ) 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 wa ter is judged to be acceptable based on the measures developed by the Applicant for instal lation 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 manage d based on the facts that the Active Substances are produced automatically and in situ as well as that system co mponents are adopted that are expected to minimize the exposure risk of ships’ crew to chemicals and ba llast 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 as sessment presented above.GESAMP-BWWG 10/6

ANNEX 7 Page 23

I:\MEPC\60\2-11.doc 6 ENVIRONMENTAL RISK ASSESSMENT

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

6.1.1 The Group recalled that as corroborat ed at the Basic Approval, neither the

Active Substances nor the Relevant Chemicals ar e 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 Substa nces 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 resu lts of acute and chroni c 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 E nvironmental Consultants CC, South Africa.

Full details on the methods used to conduct thes e tests and results obtained are provided in appendix 7 of the Applicant dossi er and are summarized below. The Group noted that the acute aquatic ecotoxicity studies report submitted was ex actly the same as that submitted for Basic Approval. Six local marine and/or estu arine 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 balla st 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 dilu ted and pumped through the experimental tanks immediately post treatment with the BWMS. Water quality measurem ents (salinity, temperature, pH and dissolved oxygen) and chemical analyses of dissolved organic carbon, free chlorine and

trihalomethanes were undertaken daily during experimental trials.GESAMP-BWWG 10/6

ANNEX 7 Page 24

I:\MEPC\60\2-11.doc 6.2.3 The Group noted that growth of G. verrucosa was inhibited in 100% TBW (IC 50 = 59%).

All of the invertebrates tested survived the 96-hour experime nts and no obvious adverse effects were detected in any concentration of TBW. Bo th species of fish suffered 100% mortality in

the 100% TBW treatment while 50% TB W also caused 100% mortality for P. knysnaensis (LC 50 = 35% TBW) but had no effect on L. richardsonii (LC 50 = 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% concentra tion during a five-day test. Chemical analysis confirmed that total chlorine levels dropped to about one-thi rd of immediately post-treatment levels within

24 hours and to below dete ction limits after 72 hours. Disi nfection by-products created by the

BWMS were limited to low concen trations of bromoform (0-9 μ g/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 ecot oxicity tests were conducted on three trophic levels of marine organi sms in order to assess the potential ecotoxicity

of BWMS treated ball ast water (TBW) to marine life. Tests were conducted by Anchor Environmental Consultants CC, South Africa. Fu ll 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 conduc ted 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 Me thods, 2005, EPA-821-R-02-014).

6.2.5 The Group noted that organisms were expo sed to five concentrations of TBW (100%, 50%, 25%, 12.5% and 6.25%) over varying peri ods of time, and sublethal endpoints were

used to calculate no observe d effect concentrations (NOE C), lowest observed effect concentrations (LOEC) a nd inhibition concentrati ons 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 inhibiti on 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 IC 25 and IC 50 concentrations for the sea

urchin fertilization test were calculated to be 57.73% a nd 72.35%, respectively. Although the Group noted that the algal toxic ity test indicated th at the control did not match the validity

criteria in the method stated in their report the tests were consid ered valid the other organisms. The Group decided to finally to accept it as th e Group did in other evaluations as well.

6.2.6 Therefore in summary, the Group noted that si x acute aquatic ecotoxicity tests and three chronic aquatic ecotoxicity tests on a total of se ven local marine and/or estuarine species were conducted using seawater treate d with the BWMS. Ecotoxicity tests were conducted on one seaweed species, one unicellular algal species, a crustacean, two gastrop od species and two fish species. From the acute ecotoxicity tests, the mo st sensitive species was found to be the fish P.knysnaensis (LC 50 = 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

ANNEX 7 Page 25

I:\MEPC\60\2-11.doc 6.3 Risk assessments of chem icals for aquatic organisms

6.3.1 Predicted Environmental Concentrations (PEC)

6.3.1.1 The Group noted that predicted environmen tal concentrations (PEC) of bromoform,

dibromoacetic acid and TRO were estimated usi ng the MAMPEC version 2.0 simulation model for a

worst case scenario “OECD comme rcial harbour”. The MAMPEC model was developed for the leaching of anti-fouling paints from ships and it cal culates the steady state concentration of pollutants assuming a permanent source is present. The m odel 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 a dditional flushing from a small river or urban drainage system discharging at the rear of the harb our (OECD, 2005). Accordi ng to the Applicant, in order to estimate the PEC of bromoform, dibromo acetic acid and TRO enteri ng the port of Rotterdam, it is necessary to know the amount of ballast wate r 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 m 3 and total ballast water discharge to 2.76 million m 3
(Port of Rotterdam, 2008). This indicates that the po rt of Rotterdam is mainly a ballast water exporting port. The results of discharge in the report are also considered to be wo rst case scenario due to the fact

that a number of vessels will ta ke 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 di scharge of ballast water, the monthly discharge quantity was divided by 29, giving an estimated daily release of 95,172.4 m 3 /day.

6.3.1.2 In the case of the PEC for bromoform, the Group noted that the A pplicant used the

maximum concentration of bromof orm in seawater treated with the BWMS. This corresponded

to 12 μ g/L (see section 3.3 above). Br omoform was assumed to be pe rsistent with no abiotic, biological or photolytic degradat ion (worst case scenario). Gi ven the discharg e of 95,172.4 m 3 ballast water per day, this would result in worst case sc enario daily release of 1142.06 g bromoform per day (maximum). The PEC of bromoform in a standa rd OECD “commercial ha rbour” are summarized below (Table 4), and reve al a maximum PEC of 0.0706 μ g/L in the harbour and the surrounding

waters for worst case scenario of maximum br omoform concentration.

Table 4: PEC of bromoform in an OECD “c ommercial 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 μ g/L 0.0706 0.00400

95% concentration μ g/L 0.0686 0.00344 Average concentration μ g/L 0.0257 0.000724

Median concentration μ g/L 0.00842 0.00140

Minimum Concentration μ g/L 0.00125 0.000707GESAMP-BWWG 10/6

ANNEX 7 Page 26

I:\MEPC\60\2-11.doc 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 tr eated with the BWMS. This corresponded to 13.1 μ g/L (see section 3.3 above). DBAA was assumed to be persistent with no abiotic, biological or photo lytic degradation (worst case sc enario). Given the discharge of 95,172 m 3 ballast water per day, containing 13.1 μ g/L DBAA, this would result in worst case scenario daily release of 1246.75 g DBAA per da y. The PEC of DBAA in a standard OECD

“commercial harbour” are summarized below (Table 5), and reveal a maximum PEC

of 0.111 μ g/L in the harbour and the surrounding waters.

Table 5: PEC of DBAA in an OECD “commerc ial harbour” scenario determined using

MAMPEC version 2.0 with a m aximum 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 μ g/L 0.111 0.005

95% concentration μ g/L 0.109 0.00446 Average concentration μ g/L 0.0387 0.000894

Median concentration μ g/L 0.0103 0.00177

Minimum Concentration μ g/L 0.00104 0.000872

6.3.1.4 In the case of the PEC for TRO, the Gr oup noted that the Applicant used the maximum

concentration of TRO in seaw ater treated with the BWMS, this corresponded to 0.8 mg/L (see section 3.3 above). Given the discharge of 95,172 m 3 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 har bour” are summarized below (Table 6), and rev eal a maximum PEC of 0.135 μ g/L in the harbour and the surrounding

waters.

Table 6: PEC of TRO in an OECD “commerc ial 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 μ g/L 0.135 0.011

95% concentration μ g/L 0.133 0.0107 Average concentration μ g/L 0.056 0.00221

Median concentration μ g/L 0.0412 0.00457

Minimum Concentration μ g/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 fr om the most sensitive of the ecotoxicity tests performed on treated ballast wate r - chronic sea urchin fertilization test (see section 6.2 above).

Since TRO concentrations were below the detec tion 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 ur chin test, with concentrations of 2.7 μ g/L (bromoform)

and 1.7 μ g/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

ANNEX 7 Page 27

I:\MEPC\60\2-11.doc 6.3.2.2 The Group noted that according to the Applicant, the se a 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 NOEC bromoform = 2.9 mg/L, PNEC bromoform = 0.29 mg/L, PNEC dibromoacetic acid = 6.9 μ g/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 toxi city was noted for three groups of organisms at levels above 160 μg/L bromoform). The Group recognized that PNEC valu es 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 toxi c effects were observed in 100% TBW in the chronic algae and fish test s (see section 6.2 above), further highlighting the sensitivity of the sea urchin fertilization test. The PNEC values were t hus calculated as follows:

PNEC bromoform = 2.7 μ g/L / 10 = 0.27 μ g/L;

PNEC dibromoacetic acid = 1.7 μ g/L / 10 = 0.17 μ g/L; and

PNEC TRO = 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 μ g/L)

Harbour PEC ( μ g/L) 0.0706 PNEC ( μ g/L) 0.27

PEC/PNEC 0.261 Dibromoacetic acid (DBAA) Ballast water discharge of

Maximum DBAA concentration (13.1 μ g/L)

Harbour PEC ( μ g/L) 0.111 PNEC ( μ g/L) 0.17

PEC/PNEC 0.65

TRO Ballast water discharge of

Maximum TRO concentration (0.8 mg/L)

Harbour PEC ( μ g/L) 0.135 PNEC ( μ g/L) 12.0

PEC/PNEC 0.01125GESAMP-BWWG 10/6

ANNEX 7 Page 28

I:\MEPC\60\2-11.doc 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 un acceptable risk to the a quatic environment in a

“OECD commercial harbour” scenario – particularly as these calcu lations 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 μ g/L, which

results in a PEC/PNEC ratio of 0.1125.

6.4 Determination of holding ti me 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 TR O and FRO concentrations to below 0.1 mg/L (as Cl 2 ). The decay of residual oxidant concentrations (total and free) was measured in natural

seawater and brackish water under simulated ba llast 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 TR O and FRO decrease most rapidly 30 minutes after treatment and re ach concentrations of <0.1 mg/L (as Cl 2 ) after 3 hours using seawater sourced locally at the testing facility. To ensure that the TRO at discharge remains below the MADC, the Group recomme nded 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 a nd 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 toxi city test was conducted using ballast water that was at least 21⁄2 hours old, in wh ich TRO concentrations were undetectable. In order to make the assumption th at 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 Cl 2 ), and thus holding ballast water for this period would provide a furt her 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 th e TBW by around four-fold upon discharge to the

environment would be needed to reach a concen tration less than the most sensitive NOEC value obtained in the aquatic ecotoxicity testing. As an additional safegua rd, to ensure that the TRO at discharge remains below the MADC, the Gr oup recommended that a TRO monitoring and recording function be incl uded 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 duri ng the ballast water treatment have been well described and discussed above, and as such th e Group considered that the Resource Ballast Technologies System should present no unaccepta ble risks to the safety of the ship.GESAMP-BWWG 10/6

ANNEX 7 Page 29

I:\MEPC\60\2-11.doc 7.2 Risks to the crew and general public

7.2.3 The Group considered that the Resour ce 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 th e 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 sh ould 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 treat ed ballast water of 3 hours as follows:

MADC of Ozone and Sodium hypochlorite (TRO) = 0.1 – 0.2 mg/L (as Cl 2 )

As an additional safeguard, to ensure that th e TRO at discharge remains below the MADC, the Group recommended that a TRO monitoring and reco rding function be incl uded 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 in formation provided by the Applicant, the Group agreed to recommend to the MEPC that Fina l Approval be granted to the Resource Ballast Technologies System, provided that all the recomme ndations given in this report are taken into

account.

* * *GESAMP-BWWG 10/6

ANNEX 7 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 pr esented in a detailed series of tables in this appendix.

* * *GESAMP-BWWG 10/6ANNEX 7Page 31I:\MEPC\60\2-11.docTable A1: Chemical analysis of natural seawater samples treatedwith the RBT reactor (Treat), aswell as samples collected whenthe filter unit was backwashed(Filter), and control samples collected prior to treatment (Control). Three replicate samples of each type were collected approximately 30 minutesapart and analysed immediately on site (Salinity, TRO, FRO) or submitted to accreditedlaboratories for analysis in South Africa (DOC, TSS, POM –CSIR Analytical Laboratories; Haloacetic acids – Naosep Laboratories; VOC – ERWAT Laboratory Services) and Switzerland (Bromate– EAWAG).Samples analysed for VOCs were preserved with the reducing reagentascorbic acid (625 mg/L). Certificates of analysis are included in appendix 13(aCSIR 099P,bNanoSep 0810367,cEAWAG 01,dERWAT 2008/11/169).ChemicalTest 1ControlSL01Test 1TreatSL04Test 1FilterSL07Test 2ControlSL02Test 2TreatSL05Test 2FilterSL08Test 3ControlSL03Test 3TreatSL06Test 3FilterSL09Salinity PSU 37.1 36.7 36.9 36.9 37.0 36.9 36.9 36.7 36.8TRO mg Cl/l nd 0.67 0.28 0.01 0.79 0.78 0.04 0.75 0.63FRO mg Cl/l nd 0.59 0.23 0.03 0.28 0.59 0.05 0.74 0.51DOC (filtered)amg/L 0.29 0.29 0.29 0.33 0.24 0.29 0.29 0.29 0.26DOC (unfiltered)amg/L 0.39 0.61 0.56 0.61 0.5 0.5 0.56 0.56 0.56TSSamg/L 51.7 50.4 90.9 52.1 11.7 79.2 51.7 8.5 39.2POMa% 1.849 1.236 5.455 2.207 - 5.23 2.015 - 9.843Bromatebμg/l <10 <10 <10 <10 <10 <10 <10 <10 <10Haloacetic acidscchloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromoacetic acidμg/l nd nd nd nd nd nd nd nd nddichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndtrichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromochloroacetic acidμg/l nd nd nd nd nd nd nd nd nddibromoacetic acidμg/l <0.5 6.7 2.4 <0.5 13.1 6.4 <0.5 6.3 3.6bromodichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndchlorodibromoacetic acidμg/l nd nd nd nd nd nd nd nd ndtribromoacetic acidμg/l nd nd nd nd nd nd nd nd nddVolatile organic compoundsGESAMP-BWWG 10/6ANNEX 7Page 32I:\MEPC\60\2-11.docChemicalTest 1ControlSL01Test 1TreatSL04Test 1FilterSL07Test 2ControlSL02Test 2TreatSL05Test 2FilterSL08Test 3ControlSL03Test 3TreatSL06Test 3FilterSL09m + p - Xylenesμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromoformμg/l <1 <1 3 <1 <1 5 <1 <1 <1Styreneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1o-Xyleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Isopropylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Propylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3,5-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1tert-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1sec-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,4-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Isopropyltolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromo-3-chloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Naphthaleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Hexachlorobutadieneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichlorofluoromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 33I:\MEPC\60\2-11.docChemicalTest 1ControlSL01Test 1TreatSL04Test 1FilterSL07Test 2ControlSL02Test 2TreatSL05Test 2FilterSL08Test 3ControlSL03Test 3TreatSL06Test 3FilterSL091,1-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trans-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromochloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chloroformμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,1-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Carbon Tetrachlorideμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Benzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Fluorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromomethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromodichloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trans-1,3,-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,3-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Tolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromochloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromoethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Tetrachloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 34I:\MEPC\60\2-11.docTable A2: Chemical analysis of natural seawater supplemented with barley malt to increase the dissolved organic carbon (DOC) and particulate organic matter(POM) content and treated with the RBT reactor (Treat), as well as samples collectedwhen the filter unit was backwashed (Filter), and controlsamples collected prior to treatment (Control). Three replicatesamples of each type were collected approximately 30 minutes apart and analysedimmediately on site (Salinity, TRO, FRO) orsubmitted to accredited laboratories for analysis in South Africa (DOC, TSS, POM –CSIR AnalyticalLaboratories; Haloacetic acids – Naosep Laboratories; VOC – ERWAT Laboratory Services) and Switzerland (Bromate – EAWAG). Samplesanalysed for VOCs were preserved with thereducing reagent ascorbic acid (625 mg/L).Certificates of analysis are included inappendix 13(aCSIR 100,bNanoSep 0810370,cEAWAG 01,dERWAT 2008/11/169)ChemicalTest 1ControlSH01Test 1TreatSH04Test 1FilterSH07Test 2ControlSH02Test 2TreatSH05Test 2FilterSH08Test 3ControlSH03Test 3TreatSH06Test 3FilterSH09Salinity PSU 36.7 36.5 37 36.3 36.8 36.7 36.8 36.8 37.1TROmgCl/l nd 0.14 0.16 nd 0.16 0.18 nd 0.12 0.1FROmgCl/l nd 0.13 0.07 nd 0.13 0.08 nd 0.02 0.02DOC (filtered)amg/L 54 24 30 42 24 47 29 21 45DOC (unfiltered)amg/L 610 96 38 178 96 159 108 46 120TSSamg/L 59 41 392 102 242 544 59 258 191POMa% 52 49 58 36 51 81 29 69 58Bromatebμg/l <10 <10 <10 <10 <10 <10 <10 <10 <10Haloacetic acidscchloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromoacetic acidμg/l nd nd nd nd nd nd nd nd nddichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndtrichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromochloroacetic acidμg/l nd nd nd nd nd nd nd nd nddibromoacetic acidμg/l nd nd 1.8 nd 0.8 1.4 <0.5 <0.5 1.3bromodichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndchlorodibromoacetic acidμg/l nd nd nd nd nd nd nd nd ndGESAMP-BWWG 10/6ANNEX 7Page 35I:\MEPC\60\2-11.docChemicalTest 1ControlSH01Test 1TreatSH04Test 1FilterSH07Test 2ControlSH02Test 2TreatSH05Test 2FilterSH08Test 3ControlSH03Test 3TreatSH06Test 3FilterSH09tribromoacetic acidμg/l nd nd nd nd nd nd nd nd nddVolatile organic compoundsm + p - xylenesμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromoformμg/l <1 <1 3 <1 <1 2 <1 <1 1Styreneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1o-Xyleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Isopropylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Propylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3,5-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1tert-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1sec-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,4-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Isopropyltolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromo-3-chloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Naphthaleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 36I:\MEPC\60\2-11.docChemicalTest 1ControlSH01Test 1TreatSH04Test 1FilterSH07Test 2ControlSH02Test 2TreatSH05Test 2FilterSH08Test 3ControlSH03Test 3TreatSH06Test 3FilterSH09Hexachlorobutadieneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichlorofluoromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trans-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromochloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chloroformμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,1-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Carbon Tetrachlorideμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Benzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Fluorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromomethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromodichloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trans-1,3,-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,3-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Tolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromochloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromoethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 37I:\MEPC\60\2-11.docChemicalTest 1ControlSH01Test 1TreatSH04Test 1FilterSH07Test 2ControlSH02Test 2TreatSH05Test 2FilterSH08Test 3ControlSH03Test 3TreatSH06Test 3FilterSH09Tetrachloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,1,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Ethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 38I:\MEPC\60\2-11.docTable A3: Chemical analysis of a mixture natural seawater with municipal drinking water treated withthe RBT reactor (Treat), as well as samples collected when the filterunit was backwashed (Filter), and control samples collected prior to treatment (Control). Municipal drinking water was filtered through a 40 micronspun-wound filter prior to testing and treatment in an effort toreduce pre-existing background levels of chlorine breakdown products. Three replicate samplesof each type were collected approximately30 minutes apart and analysed immediately onsite (Salinity, TRO, FRO) or submitted to accredited laboratories foranalysis in South Africa (DOC, TSS, POM – CSIR Analytical Laboratories; Haloaceticacids – Naosep Laboratories; VOC – ERWAT Laboratory Services)and Switzerland (Bromate – EAWAG). Samples analysed for VOCs werepreserved with the reducing reagent ascorbic acid (625 mg/L). Certificates ofanalysis are included in appendix 13 (aCSIR 105,bNanoSep 0810374,cEAWAG 01,dERWAT 2008/11/169)ChemicalTest 1ControlBL01Test 1TreatBL04Test 1FilterBL07Test 2ControlBL02Test 2TreatBL05Test 2FilterBL08Test 3ControlBL03Test 3TreatBL06Test 3FilterBL09Salinity PSU 19.78 19.39 19.81 19.58 19.8 20.03 20.1 19.95 20.02TRO mg Cl/l nd 0.4 0.32 nd 0.59 0.4 nd 0.8 0.41FRO mg Cl/l nd 0.3 0.29 nd 0.44 0.31 nd 0.55 0.25DOC (filtered)amg/L 1.1 0.9 0.8 1.2 1 1 1 0.9 0.9DOC (unfiltered)amg/L 1.3 1.2 1.1 1.4 1.1 1.4 1.1 1 1TSSa% 3 4 3 3 3 4 3 4 3POMamg/L 41 28 45 38 34 35 38 31 37Bromatebμg/l <10 <10 <10 <10 <10 <10 <10 <10 <10Haloacetic acidscchloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromoacetic acidμg/l 0.5 nd nd nd nd nd 0.5 nd nddichloroacetic acidμg/l 1.5 4.8 <0.5 1 4.4 nd 1 <0.5 1trichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromochloroacetic acidμg/l nd nd nd nd nd nd nd nd nddibromoacetic acidμg/l <0.5 2.3 0.6 <0.5 1 <0.5 <0.5 1.2 <0.5bromodichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndchlorodibromoacetic acidμg/l nd nd nd nd nd nd nd nd ndtribromoacetic acidμg/l nd nd nd nd nd nd nd nd ndGESAMP-BWWG 10/6ANNEX 7Page 39I:\MEPC\60\2-11.docChemicalTest 1ControlBL01Test 1TreatBL04Test 1FilterBL07Test 2ControlBL02Test 2TreatBL05Test 2FilterBL08Test 3ControlBL03Test 3TreatBL06Test 3FilterBL09dVolatile organiccompoundsm+p-xylenesμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromoformμg/l <1 1 2 <1 1 2 <1 2 3Styreneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1o-Xyleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Isopropylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Propylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3,5-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1tert-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1sec-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,4-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Isopropyltolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromo-3-chloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Naphthaleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 40I:\MEPC\60\2-11.docChemicalTest 1ControlBL01Test 1TreatBL04Test 1FilterBL07Test 2ControlBL02Test 2TreatBL05Test 2FilterBL08Test 3ControlBL03Test 3TreatBL06Test 3FilterBL09Hexachlorobutadieneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichlorofluoromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trans-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromochloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chloroformμg/l 17 19 19 3 9 18 18 18 171,1,1-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Carbon Tetrachlorideμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Benzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Fluorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromomethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromodichloromethaneμg/l 4 5 5 1 3 5 4 4 4Trans-1,3,-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,3-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Tolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromochloromethaneμg/l 1 2 2 <1 <1 2 2 2 21,2-Dibromoethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 41I:\MEPC\60\2-11.docChemicalTest 1ControlBL01Test 1TreatBL04Test 1FilterBL07Test 2ControlBL02Test 2TreatBL05Test 2FilterBL08Test 3ControlBL03Test 3TreatBL06Test 3FilterBL09Tetrachloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,1,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Ethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 42I:\MEPC\60\2-11.docTable A4: Chemical analysis of a mixture natural seawater with municipal drinking water, supplemented with barley malt to increase the dissolved organiccarbon (DOC) and particulate organic matter (POM) content, and treated with the RBT reactor (Treat), as well as samples collected when the filterunit was backwashed (Filter), and control samples collected priorto treatment (Control). Municipal drinking water was filtered through a 40 micronspun-wound filter prior to testingand treatment in an effort to reduce pre-existing background levels of chlorine breakdown products. Three replicatesamples of each type were collected approximately 30 minutes apart and analysed immediately on site (Salinity, TRO, FRO) or submitted toaccredited laboratories for analysis in South Africa (DOC, TSS, POM – CSIR Analytical Laboratories; Haloaceticacids – Naosep Laboratories; VOC – ERWAT Laboratory Services) and Switzerland (Bromate –EAWAG). Samples analysed for VOCs werepreserved with the reducing reagent ascorbic acid (625 mg/L). Certificates of analysis are included in appendix 13 (aCSIR 105,bNanoSep 0810374,cEAWAG 01,dERWAT 2008/11/169)ChemicalTest 1ControlBH01Test 1TreatBH04Test 1FilterBH07Test 2ControlBH02Test 2TreatBH05Test 2FilterBH08Test 3ControlBH03Test 3TreatBH06Test 3FilterBH09Salinity PSU 17.48 18.15 17.53 12.24 13.8 13.84 26.8 28.4 26.6TRO mg Cl/l nd 0.15 0.16 nd 0.12 0.12 nd 0.18 0.12FRO mg Cl/l nd 0.13 0.06 nd 0.11 0.06 nd 0.1 0.09DOC (filtered)amg/L 12.2 3.3 0.9 75 51.8 26.6 115 55.7 52.7DOC (unfiltered)amg/L 27.4 21.1 30.8 98.4 68.4 32.8 191.7 74.6 64.8TSSa% 52 51 80 57 76 22 96 87 27POMamg/L 79 75 95 71 72 100 145 147 165Bromatebμg/l <10 <10 <10 <10 <10 <10 <10 <10 <10Haloacetic acidscchloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromoacetic acidμg/l nd 0.7 <0.5 nd nd <0.5 <0.5 <0.5 <0.5dichloroacetic acidμg/l 5.4 4 3.2 5.1 5.6 1.9 1.4 1.5 0.5trichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromochloroacetic acidμg/l nd nd nd nd nd nd nd nd nddibromoacetic acidμg/l 0.7 1.3 1.9 1 1.9 0.9 <0.5 1 0.8bromodichloroacetic acidμg/l nd <0.5 nd <0.5 <0.5 nd nd nd ndchlorodibromoacetic acidμg/l nd nd nd nd nd nd nd nd ndtribromoacetic acidμg/l nd nd nd nd nd nd nd nd ndGESAMP-BWWG 10/6ANNEX 7Page 43I:\MEPC\60\2-11.docChemicalTest 1ControlBH01Test 1TreatBH04Test 1FilterBH07Test 2ControlBH02Test 2TreatBH05Test 2FilterBH08Test 3ControlBH03Test 3TreatBH06Test 3FilterBH09dVolatile organic compoundsm + p-xylenesμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromoformμg/l 2 2 3 3 2 1 <1 1 <1Styreneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1o-Xyleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Isopropylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Propylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3,5-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1tert-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1sec-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,4-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Isopropyltolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromo-3-chloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Naphthaleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Hexachlorobutadieneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichlorofluoromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 44I:\MEPC\60\2-11.docChemicalTest 1ControlBH01Test 1TreatBH04Test 1FilterBH07Test 2ControlBH02Test 2TreatBH05Test 2FilterBH08Test 3ControlBH03Test 3TreatBH06Test 3FilterBH091,1-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trans-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromochloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chloroformμg/l 17 20 24 32 27 12 8 10 71,1,1-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Carbon Tetrachlorideμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Benzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Fluorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromomethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromodichloromethaneμg/l 4 5 6 8 6 3 2 2 2Trans-1,3,-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,3-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Tolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromochloromethaneμg/l 2 2 5 4 3 1 <1 1 <11,2-Dibromoethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Tetrachloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,1,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Ethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 45I:\MEPC\60\2-11.docTable A5: Chemical analysis of municipal drinking water treatedwith the RBT reactor (Treat), as well as samples collected whenthe filter unit was backwashed(Filter), and control samples collected prior to treatment (Control).Municipal drinking water was filtered through an 40 micron spun-wound filterprior to testing and treatment in an effort to reduce pre-existing background levels of chlorine breakdown products. Three replicate samples of eachtype were collected approximately 30 minutes apart and analysedimmediately on site (Salinity, TRO, FRO) or submitted to accredited laboratories foranalysis in South Africa (DOC, TSS, POM –CSIR Analytical Laboratories; Haloacetic acids – Naosep Laboratories; VOC – ERWAT LaboratoryServices) and Switzerland (Bromate – EAWAG). Samples analysed for VOCs were preserved with the reducing reagent ascorbic acid(625 mg/L).Certificates of analysis are included in appendix 13 (aCSIR 009P,bNanoSep 0810370,cEAWAG 01,dERWAT 2008/11/169).ChemicalTest 1ControlFL01Test 1TreatFL04Test 1FilterFL07Test 2ControlFL02Test 2TreatFL05Test 2FilterFL08Test 3ControlFL03Test 3TreatFL06Test 3FilterFL09Salinity PSU 0.3 0.3 0.4 0.3 0.2 0.2 0.2 0.3 0.2TRO mg Cl/l 0.02 0.09 0.07 nd 0.06 0.06 0.06 0.05 0.09FRO mg Cl/l 0.04 0.07 0.02 nd 0.03 0.02 0.02 0.03 0.07DOC (filtered)amg/L 1.09 1.13 1.17 1.09 1.09 1.34 1 1.17 1.51DOC (unfiltered)amg/L 1.38 1.52 1.76 1.57 1.38 1.48 1.38 1.67 1.76TSSamg/L 5.3 2.4 4.7 3.2 2.8 3.2 2.3 2.5 1.7POMaμg/l <5 <5 <5 <5 <5 <5 <5 <5 <5Bromatebchloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromoacetic acidμg/l nd nd nd nd nd nd nd nd nddichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndtrichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromochloroacetic acidμg/l nd nd nd nd nd nd nd nd nddibromoacetic acidμg/l <0.5 1 3.4 <0.05 2.6 2 <0.5 3.6 1.3bromodichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndchlorodibromoacetic acidμg/l nd nd nd nd nd nd nd nd ndtribromoacetic acidμg/l nd nd nd nd nd nd nd nd nddVolatile organic compoundsGESAMP-BWWG 10/6ANNEX 7Page 46I:\MEPC\60\2-11.docChemicalTest 1ControlFL01Test 1TreatFL04Test 1FilterFL07Test 2ControlFL02Test 2TreatFL05Test 2FilterFL08Test 3ControlFL03Test 3TreatFL06Test 3FilterFL09m+p-xylenesμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromoformμg/l 3 <1 <1 <1 <1 <1 <1 <1 <1Styreneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1o-Xyleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Isopropylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Propylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3,5-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1tert-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1sec-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,4-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Isopropyltolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromo-3-chloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Naphthaleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Hexachlorobutadieneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichlorofluoromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 47I:\MEPC\60\2-11.docChemicalTest 1ControlFL01Test 1TreatFL04Test 1FilterFL07Test 2ControlFL02Test 2TreatFL05Test 2FilterFL08Test 3ControlFL03Test 3TreatFL06Test 3FilterFL091,1-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trans-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromochloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chloroformμg/l 41 3 7 <1 8 6 6 41,1,1-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Carbon Tetrachlorideμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Benzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Fluorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromomethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromodichloromethaneμg/l 10 1 2 <1 2 2 2 2Trans-1,3,-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,3-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Tolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromochloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromoethaneμg/l 3 <1 <1 <1 <1 <1 <1 <1 <1Tetrachloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 48I:\MEPC\60\2-11.docChemicalTest 1ControlFL01Test 1TreatFL04Test 1FilterFL07Test 2ControlFL02Test 2TreatFL05Test 2FilterFL08Test 3ControlFL03Test 3TreatFL06Test 3FilterFL091,1,1,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Ethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 49I:\MEPC\60\2-11.docTable A6: Chemical analysis of municipaldrinking water, supplemented with barley malt to increase the dissolved organic carbon(DOC) and particulate organicmatter (POM) content, and treated with the RBT reactor (Treat), as well as samples collected when the filter unit was backwashed (Filter), and controlsamples collected prior to treatment (Control). Municipaldrinking water was filtered through an 40 micron spun-wound filter prior to testing andtreatment in an effort to reduce pre-existing background levels ofchlorine breakdown products.Three replicate samples of each type were collectedapproximately 30 minutes apart and analysedimmediately on site (Salinity, TRO, FRO) orsubmitted to accredited laboratories for analysis in SouthAfrica (DOC, TSS, POM – CSIR Analytical Laboratories; Haloacetic acids – Naosep Laboratories; VOC – ERWAT Laboratory Services)andSwitzerland (Bromate – EAWAG). Samples analysed for VOCs were preserved with the reducing reagent ascorbicacid (625 mg/L). Certificates ofanalysis are included in appendix 13 (aCSIR 100,bNanoSep 0810370,cEAWAG 01,dERWAT 2008/11/169).ChemicalTest 1ControlFH01Test 1TreatFH04Test 1FilterFH07Test 2ControlFH02Test 2TreatFH05Test 2FilterFH08Test 3ControlFH03Test 3TreatFH06Test 3FilterFH09Sample IDSalinity PSU 0.12 1.01 2.84 4.15 0.5 1.95 0.12 0.54 0.3TROmgCl/l nd 0.07 0.07 nd 0.05 0.06 0.02 0.08 0.1FROmgCl/l nd 0.02 0.07 nd 0.05 0.03 0.03 0.07 0.01DOC (filtered)amg/L 187 225 222 215 338 178 311 173 8DOC (unfiltered)amg/L 315 355 320 415 415 375 445 335 77TSSa% 69 84 74 68 68 97 73 56 74POMamg/L 34 39 55 83 36 52 33 46 34Bromatebμg/l <5 <5 <5 <5 <5 <5 <5 <5 <5Haloacetic acidscchloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromoacetic acidμg/l nd nd nd nd nd nd nd nd nddichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndtrichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndbromochloroacetic acidμg/l nd nd nd nd nd nd nd nd nddibromoacetic acidμg/l nd 1.7 2.1 nd nd 1.4 nd 1.8 1.7bromodichloroacetic acidμg/l nd nd nd nd nd nd nd nd ndGESAMP-BWWG 10/6ANNEX 7Page 50I:\MEPC\60\2-11.docChemicalTest 1ControlFH01Test 1TreatFH04Test 1FilterFH07Test 2ControlFH02Test 2TreatFH05Test 2FilterFH08Test 3ControlFH03Test 3TreatFH06Test 3FilterFH09chlorodibromoacetic acidμg/l nd nd nd nd nd nd nd nd ndtribromoacetic acidμg/l nd nd nd nd nd nd nd nd nddVolatile organic compoundsm+p-xylenesμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromoformμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Styreneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1o-Xyleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Isopropylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Propylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Chlorotolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3,5-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1tert-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trimethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1sec-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,4-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <14-Isopropyltolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1n-Butylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromo-3-chloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,4-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Naphthaleneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2,3-Trichlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 51I:\MEPC\60\2-11.docChemicalTest 1ControlFH01Test 1TreatFH04Test 1FilterFH07Test 2ControlFH02Test 2TreatFH05Test 2FilterFH08Test 3ControlFH03Test 3TreatFH06Test 3FilterFH09Hexachlorobutadieneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichlorofluoromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trans-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,2-Dichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <12,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromochloromethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Chloroformμg/l 10 3 2 8 7 8 10 18 151,1,1-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Carbon Tetrachlorideμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Benzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Fluorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Trichloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromomethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Bromodichloromethaneμg/l 2 <1 <1 2 2 2 2 4 4Trans-1,3,-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Cis-1,3-Dichloropropeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Tolueneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,2-Trichloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,3-Dichloropropaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Dibromochloromethaneμg/l 1 <1 <1 <1 <1 <1 <1 <1 <11,2-Dibromoethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Tetrachloroetheneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 52I:\MEPC\60\2-11.docChemicalTest 1ControlFH01Test 1TreatFH04Test 1FilterFH07Test 2ControlFH02Test 2TreatFH05Test 2FilterFH08Test 3ControlFH03Test 3TreatFH06Test 3FilterFH09Chlorobenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <11,1,1,2-Tetrachloroethaneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1Ethylbenzeneμg/l <1 <1 <1 <1 <1 <1 <1 <1 <1GESAMP-BWWG 10/6ANNEX 7Page 53I:\MEPC\60\2-11.docTable A7: Chemical analysis of natural seawater samples treatedwith the RBT reactor (Treat), aswell as samples collected whenthe filter unit was backwashed(Filter), and control samples collected prior to treatment (Control). Three replicate samples ofeach type were collected approximately 30 minutesapart and analysed immediately on site (Salinity, TRO, FRO) or submitted to accreditedlaboratories for analysis in South Africa (DOC, TSS, POM –CSIR Analytical Laboratories; THMs – Rand Water Analytical Services). Samples analysed for THMs were preserved with ascorbic acid (5.2 g/l asprescribed by Rand Water) after 3 hours to allow TROs present inthe treated water to breakdown and react with organic matter to produce to relevantdisinfection by-products. Duplicate samples werekept for 5 days in the dark after which they were preserved with ascorbic acid(5.2 g/l) andsubmitted to Rand Water for analysis. Certificates of analysis are included in appendix 13 (aCSIR 198,bRand Water2008/814,cRand Water 2008/853).ChemicalTest 1ControlSL01Test 1TreatSL04Test 1FilterSL07Test 2ControlSL02Test 2TreatSL05Test 2FilterSL08Test 3ControlSL03Test 3TreatSL06Test 3FilterSL09Salinity PSU 35.5 34.6 35.2 35.5 35.1 35.2 35.5 35 34.7TRO mg Cl/l 0.01 0.57 0.3 nd 0.65 0.15 0.02 0.58 0.36FRO mg Cl/l 0.02 0.5 0.41 nd 0.46 0.21 0.02 0.42 0.26DOC (filtered)amg/L <1 <1 <1 <1 <1 <1 <1 <1 <1DOC (unfiltered)amg/L <1 <1 <1 <1 <1 <1 <1 <1 <1TSSamg/L 6 70 20 5 37 12 4 12 16POMa% 100 30 41 100 40 57 94 52 50Trihalomethanesbbromodichloromethaneμg/l <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558bromoformμg/l <0.543 6.2 8.2 <0.543 7.2 7.6 <0.543 6.7 10chloroformμg/l <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328dibromochloromethaneμg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168GESAMP-BWWG 10/6ANNEX 7Page 54I:\MEPC\60\2-11.doc5-Day Old samplescTest 1ControlSL16Test 1TreatSL10Test 1FilterSL13Test 2ControlSL17Test 2TreatSL11Test 2FilterSL14Test 3ControlSL18Test 3TreatSL12Test 3FilterSL15dibromochloromethaneμg/l <1.168 <1.168 <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 <0.558 <0.558Percentage increase/decrease ofTHMs in 5-day old samples5-Day Old samplescTest 1ControlSL16Test 1TreatSL10Test 1FilterSL13Test 2ControlSL17Test 2TreatSL11Test 2FilterSL14Test 3ControlSL18Test 3TreatSL12Test 3FilterSL15dibromochloromethaneμg/l <1.168 <1.168 <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 <0.558 <0.558Percentage increase/decreaseof THMs in 5-day old samplesbromodichloromethane% 0 0 0 0 0 0 0 0 0bromoform% 0 54.8 22.0 0.0 - 15.8 0.0 -22.4 0.0chloroform% 0 0 0 0 0 0 0 0 0dibromochloromethane% 0 0 0 0 0 0 0 0 0GESAMP-BWWG 10/6ANNEX 7Page 55I:\MEPC\60\2-11.docTable A8: Chemical analysis of natural seawater, supplemented with barley malt to increase thedissolved organic carbon (DOC) and particulate organic matter(POM) content, and treated with the RBT reactor (Treat), as well as samples collected when the filter unit was backwashed (Filter), and controlsamples collected prior to treatment (Control). Three replicate samples of each typewere collected approximately 30 minutes apart and analysedimmediately on site (Salinity, TRO, FRO) or submitted to accredited laboratories for analysis in South Africa (DOC, TSS, POM –CSIR AnalyticalLaboratories; THMs – Rand Water Analytical Services). Samples analysed for THMs werepreserved with ascorbic acid (5.2 g/l asprescribedby Rand Water) after 3 hours to allow TROs present in the treated waterto breakdown and react with organic matter to produce to relevantdisinfection by-products. Duplicate samples werekept for 5 days in the dark after which they were preserved with ascorbic acid(5.2 g/l) andsubmitted to Rand Water for analysis. Certificates of analysis are included in appendix 13 (aCSIR 198,bRand Water2008/844,cRand Water 2008/857).ChemicalTest 1ControlSH01Test 1TreatSH04Test 1FilterSH07Test 2ControlSH02Test 2TreatSH05Test 2FilterSH08Test 3ControlSH03Test 3TreatSH06Test 3FilterSH09Salinity PSU 34.9 34.4 35.7 34.4 35.2 35.2 35.2 34.8 35.2TRO mg Cl/l nd 0.11 0.18 nd 0.28 0.19 nd 0.21 0.18FRO mg Cl/l 0.03 0.04 0.16 0.02 0.1 0.09 0.03 0.14 0.14DOC (filtered)amg/L 92 567 58 416 394 401 117 274 284DOC (unfiltered)amg/L 1594 367 79 575 472 283 199 278 107TSSamg/L 223 207 293 140 142 324 243 121 343POMa% 100 100 100 81 100 100 94 100 100Trihalomethanesbbromodichloromethaneμg/l <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558bromoformμg/l <0.543 2.2 12 <0.543 10 3.8 <0.543 <0.543 6.5chloroformμg/l <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328dibromochloromethaneμg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168GESAMP-BWWG 10/6ANNEX 7Page 56I:\MEPC\60\2-11.doc5-Day Old samplesTest 1ControlSH16Test 1TreatSH10Test 1FilterSH13Test 2ControlSH17Test 2TreatSH11Test 2FilterSH14Test 3ControlSH18Test 3TreatSH12Test 3FilterSH15bromodichloromethaneμg/l <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558bromoformμg/l <0.543 0.83 11 <0.543 9.9 1.1 <0.543 <0.543 5chloroformμg/l <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328 <0.328dibromochloromethaneμg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168Percentage increase/decreaseof THMs in 5-day old samplesbromodichloromethane% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0bromoform% 0.0 -62.3 -8.3 0.0 -1.0 -71.1 0.0 0.0 -23.1chloroform% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0dibromochloromethane% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0GESAMP-BWWG 10/6ANNEX 7Page 57I:\MEPC\60\2-11.docTable A9: Chemical analysis of a mixture natural seawater withmunicipal drinking water treated with the RBT reactor (Treat), as well as samples collectedwhen the filter unit was backwashed (Filter), and control samples collected prior totreatment (Control). Municipal drinking water was filteredthrough a 40 micron spun-wound filter prior to testing and treatment in an effort to reduce pre-existing background levels of chlorine breakdownproducts. Three replicate samples of each type were collected approximately 30 minutes apart and analysed immediately on site(Salinity, TRO, FRO) or submitted to accredited laboratories foranalysis in South Africa (DOC, TSS, POM – CSIR Analytical Laboratories; THMs –Rand Water Analytical Services). Samples analysed for THMs werepreserved with ascorbic acid(5.2 g/l as prescribed by Rand Water)after 3 hours to allow TROs present in the treated water to breakdown and react with organic matter to produce to relevant disinfection by-products.Duplicate samples were kept for 5 days inthe dark after which they were preserved with ascorbic acid (5.2 g/l) and submitted to Rand Water foranalysis. Certificates of analysis are included in appendix 13 (aCSIR 198,bRand Water2008/841,cRand Water 2008/853).ChemicalTest 1ControlBL01Test 1TreatBL04Test 1FilterBL07Test 2ControlBL02Test 2TreatBL05Test 2FilterBL08Test 3ControlBL03Test 3TreatBL06Test 3FilterBL09Salinity PSU 19.85 19.62 20.23 22.3 22.2 20.15 20.64 20.49 21.31TRO mg Cl/l nd 0.43 0.24 nd 0.27 0.19 nd 0.4 0.27FRO mg Cl/l 0.02 0.43 0.17 nd 0.16 0.13 nd 0.28 0.2DOC (filtered)amg/L <1 <1 <1 <1 <1 <1 <1 <1 <1DOC (unfiltered)amg/L <1 <1 <1 <1 <1 <1 <1 <1 <1TSSamg/L 45 10 17 15 12 37 21 13 45POaM % 89 62 54 66 60 37 36 60 38Trihalomethanesbbromodichloromethaneμg/l 2.6 3 2.9 2 2.6 2.9 2.7 2.9 2.7bromoformμg/l <0.543 8.6 8.9 <0.543 8.4 10 <0.543 8.8 11chloroformμg/l 14 16 14 10 13 15 14 15 14dibromochloromethaneμg/l 1.8 2.5 2.4 1.5 2.2 2.6 1.7 2.5 2.4GESAMP-BWWG 10/6ANNEX 7Page 58I:\MEPC\60\2-11.docTHMs in samples produced viaRBT treatment (treat/filter –control)Test 1ControlBL01Test 1TreatBL04Test 1FilterBL07Test 2ControlBL02Test 2TreatBL05Test 2FilterBL08Test 3ControlBL03Test 3TreatBL06Test 3FilterBL09bromodichloromethaneμg/l - 0.4 0.3 - 0.6 0.9 - 0.2 0bromoformμg/l - 8.6 8.9 - 8.4 10 - 8.8 11chloroformμg/l - 2 0 - 3 5 - 1 0dibromochloromethaneμg/l - 0.7 0.6 - 0.7 1.1 - 0.8 0.75-Day Old samplescTest 1ControlBL16Test 1TreatBL10Test 1FilterBL13Test 2ControlBL17Test 2TreatBL11Test 2FilterBL14Test 3ControlBL18Test 3TreatBL12Test 3FilterBL15bromodichloromethaneμg/l 3.1 3.5 3.4 2.7 2.9 md md md 2.7bromoformμg/l 0.8 12 11 0.59 7 md md md 11chloroformμg/l 17 18 17 16 15 md md md 16dibromochloromethaneμg/l 2.2 3.4 3.1 1.9 2.6 md md md 2.8Percentage increase/decreaseof THMs in 5-day old samplesbromodichloromethane% 19.23 16.67 17.24 35.00 11.54 - 0.00bromoform% 47.33 39.53 23.60 8.66 -16.67 - 0.00chloroform% 21.43 12.50 21.43 60.00 15.38 - 14.29dibromochloromethane% 22.22 36.00 29.17 26.67 18.18 16.67Note: md denotes missing data due to incomplete laboratory report supplied by Rand WaterGESAMP-BWWG 10/6ANNEX 7Page 59I:\MEPC\60\2-11.docTable A10: Chemical analysis of a mixturenatural seawater with municipal drinking water, supplemented with barley malt to increase the dissolved organiccarbon (DOC) and particulate organic matter (POM) content, and treated with the RBT reactor (Treat), as well as samples collected when the filterunit was backwashed (Filter), and control samples collected priorto treatment (Control). Municipal drinking water was filtered through a 40 micronspun-wound filter prior to testingand treatment in an effort to reduce pre-existing background levels of chlorine breakdown products. Three replicatesamples of each type were collected approximately 30 minutes apart and analysed immediately on site (Salinity, TRO, FRO) or submitted toaccredited laboratories for analysis in SouthAfrica (DOC, TSS, POM – CSIR AnalyticalLaboratories; THMs – Rand Water Analytical Services).Samples analysed for THMs were preserved with ascorbic acid (5.2 g/l asprescribed by Rand Water) after 3 hours to allow TROs present in thetreated water to breakdown and react with organic matter to produce to relevant disinfection by-products. Duplicate samples were keptfor 5 days in the dark after which they were preserved with ascorbic acid (5.2 g/l)and submitted to Rand Water for analysis.Certificates of analysisare included in appendix 13 (aCSIR 198,bRand Water2008/844,cRand Water 2008/857.ChemicalTest 1ControlBH01Test 1TreatBH04Test 1FilterBH07Test 2ControlBH02Test 2TreatBH05Test 2FilterBH08Test 3ControlBH03Test 3TreatBH06Test 3FilterBH09Salinity PSU 19.6 19.5 19.6 19.9 19.5 19.5 19.9 19.7 19.5TRO mg Cl/l 0.03 0.16 0.14 0.02 0.1 0.13 0.01 0.08 0.13FRO mg Cl/l nd 0.08 0.1 nd nd 0.09 nd 0.05 0.06DOC (filtered)amg/L 232 260 264 218 241 274 254 230 241DOC (unfiltered)amg/L 261 311 300 233 267 322 289 267 278TSSamg/L 147 96 434 109 124 306 129 144 60POMamg/L 98 97 87 100 100 85 100 88 82Trihalomethanesbbromodichloromethane<0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558bromoform<0.543 <0.543 <0.543 <0.543 <0.543 0.63 <0.543 <0.543 0.83chloroform11 13 12 11 13 13 12 12 13dibromochloromethane<1.168 <1.169 <1.170 <1.171 <1.172 <1.173 <1.174 <1.175 <1.176GESAMP-BWWG 10/6ANNEX 7Page 60I:\MEPC\60\2-11.docTHMs in samples produced viaRBT treatment (treat/filter –control)Test 1ControlBH01Test 1TreatBH04Test 1FilterBH07Test 2ControlBH02Test 2TreatBH05Test 2FilterBH08Test 3ControlBH03Test 3TreatBH06Test 3FilterBH09bromodichloromethaneμg/l - 0 0 - 0 0 - 0 0bromoformμg/l - 0 0 - 0 0 - 0 0chloroformμg/l - 2 1 - 2 2 - 0 1dibromochloromethaneμg/l - 0 0 - 0 0 - 0 05-Day Old samplescTest 1ControlBH16Test 1TreatBH10Test 1FilterBH13Test 2ControlBH17Test 2TreatBH11Test 2FilterBH14Test 3ControlBH18Test 3TreatBH12Test 3FilterBH15bromodichloromethaneμg/l <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558 <0.558bromoformμg/l <0.543 <0.543 <0.543 <0.543 <0.543 0.63 <0.543 <0.543 0.83chloroformμg/l 14 14 14 0 16 15 14 16 15dibromochloromethaneμg/l <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168 <1.168Percentage increase/decreaseof THMs in 5-day old samplesbromodichloromethane% 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00bromoform% 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00chloroform% 27.27 7.69 16.67 -100.00 23.08 15.38 16.67 33.33 15.38dibromochloromethane% 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00GESAMP-BWWG 10/6ANNEX 7Page 61I:\MEPC\60\2-11.docTable A11: Chemical analysis of municipal drinking water treatedwith the RBT reactor (Treat), as well as samples collected when the filter unit was backwashed(Filter), and control samples collected prior to treatment (Control). Municipal drinking water was filtered through a 40 micron spun-wound filter priorto testing and treatmentin an effort to reduce pre-existing background levelsof chlorine breakdown products. Three replicatesamples of each typewere collected approximately 30 minutes apart and analysed immediately on site (Salinity, TRO, FRO) or submitted to accreditedlaboratories foranalysis in South Africa (DOC, TSS, POC –CSIR Analytical Laboratories; THMs – Rand Water Analytical Services). Samples analysed for THMswere preserved with ascorbic acid (5.2 g/l as prescribed by Rand Water) after 3hours to allow TROs present in the treated water to breakdown andreact with organic matter to produce to relevant disinfection by-products. Duplicate samples were kept for 5 days in the dark after which they werepreserved with ascorbic acid (5.2 g/l) and submitted to Rand Water for analysis. Certificates of analysis are included in appendix 13(aCSIR 198,bRand Water2008/841,cRand Water 2008/853).ChemicalTest 1ControlFL01Test 1TreatFL04Test 1FilterFL07Test 2ControlFL02Test 2TreatFL05Test 2FilterFL08Test 3ControlFL03Test 3TreatFL06Test 3FilterFL09Salinity PSU 0.18 0.2 0.24 0.24 0.1 0.15 0.1 0.1 0.13TRO mg Cl/l nd nd nd 0.01 0.01 0.1 nd 0.06 0.04FRO mg Cl/l nd 0.02 nd 0.03 0.02 0.04 0.02 0.02 0.05DOC (filtered)amg/L <1 <1 <1 <1 <1 <1 <1 <1 <1DOC (unfiltered)amg/L 2 2 2 2 2 3 2 2 2TSSamg/L 14 7 5 11 7 6 7 6 22POMa% 48 104 86 75 100 100 100 100 87Trihalomethanesbbromodichloromethaneμg/l 6.5 8.7 7.8 7.2 7.7 7.3 5.7 7.6 7.6bromoformμg/l 1.8 2.8 2.6 1.4 2.1 2.6 1.1 2.4 2.4chloroformμg/l 32 38 35 34 35 36 28 35 34dibromochloromethaneμg/l 4 4.7 5 4 4.7 4.9 3.3 4.9 4.8GESAMP-BWWG 10/6ANNEX 7Page 62I:\MEPC\60\2-11.docTHMs in samples produced viaRBT treatment (treat/filter –control)Test 1ControlFL01Test 1TreatFL04Test 1FilterFL07Test 2ControlFL02Test 2TreatFL05Test 2FilterFL08Test 3ControlFL03Test 3TreatFL06Test 3FilterFL09bromodichloromethaneμg/l - 2.2 1.3 - 0.5 0.1 - 1.9 1.9bromoformμg/l - 2.8 2.6 - 2.1 2.6 - 2.4 2.4chloroformμg/l - 6 3 - 1 2 - 7 6dibromochloromethaneμg/l - 0.7 1 - 0.7 0.9 - 1.6 1.55-Day Old samplescTest 1ControlFL16Test 1TreatFL10Test 1FilterFL13Test 2ControlFL17Test 2TreatFL11Test 2FilterFL14Test 3ControlFL18Test 3TreatFL12Test 3FilterFL15bromodichloromethaneμg/l Md 8.6 8.5 7.3 9.2 7.6 8.1 7.8 8.1bromoformμg/l Md 2.7 2.7 1.9 2.6 2.8 2.1 2.5 2.8chloroformμg/l md 41 39 37 41 37 39 39 35dibromochloromethaneμg/l md 5.7 5.4 4.5 5.7 5.3 4.8 5.2 5.3Percentage increase/decreaseof THMs in 5-day old samplesbromodichloromethane% Md -1.15 8.97 1.39 19.48 4.11 42.11 2.63 6.58bromoform% Md -3.57 3.85 35.71 23.81 7.69 90.91 4.17 16.67chloroform% md 7.89 11.43 8.82 17.14 2.78 39.29 11.43 2.94dibromochloromethane% md 21.28 8.00 12.50 21.28 8.16 45.45 6.12 10.42GESAMP-BWWG 10/6ANNEX 7Page 63I:\MEPC\60\2-11.docTable A12: Chemical analysis of a mixturenatural seawater with municipal drinking water, supplemented with barley malt to increase the dissolvedorganic carbon(DOC) and particulate organic matter (POM) content, and treated with the RBT reactor (Treat), as well as samples collected whenthe filter unit wasbackwashed (Filter), and control samples collected prior to treatment (Control). Municipal drinking water was filtered througha 40 micronspun-wound filter prior to testing and treatment in an effort to reduce pre-existingbackground levels of chlorine breakdown products. Three replicatesamples of each type were collected approximately 30 minutes apart and analysed immediately on site (Salinity, TRO, FRO) or submitted to accreditedlaboratories for analysis in South Africa (DOC, TSS, POM – CSIRAnalytical Laboratories; THMs –Rand Water Analytical Services). Samplesanalysed for THMs were preserved with ascorbic acid (5.2 g/l as prescribed by Rand Water) after 3 hours to allow TROs present in the treated water tobreakdown and react with organic matter to produce to relevantdisinfection by-products. Duplicate samples were kept for 5 daysin the dark afterwhich they were preserved with ascorbic acid (5.2 g/l) and submitted to Rand Water for analysis. Certificates of analysis areincluded in appendix 13(aCSIR 198,bRand Water2008/844,cRand Water 2008/857).ChemicalTest 1ControlFH01Test 1TreatFH04Test 1FilterFH07Test 2ControlFH02Test 2TreatFH05Test 2FilterFH08Test 3ControlFH03Test 3TreatFH06Test 3FilterFH09Salinity PSU 0.22 0.23 0.26 0.17 0.2 0.18 0.37 0.17 0.25TRO mg Cl/l nd nd 0.08 0.02 0.04 0.01 nd nd 0.02FRO mg Cl/l 0.03 0.04 nd 0.03 0.03 nd 0.03 0.04 ndDOC (filtered)amg/L 416 394 401 117 274 284 567 58 123DOC (unfiltered)amg/L 416 394 417 117 274 289 675 58 136TSSamg/L 214 151 237 93 137 202 209 70 77POMa% 45 54 38 56 75 82 40 82 81Trihalomethanesbbromodichloromethaneμg/l 4 4.2 4.6 3.8 4.6 4.2 4.4 4.1 4.4bromoformμg/l 0.67 0.8 0.8 <0.543 0.75 0.8 0.69 0.69 0.72chloroformμg/l 30 31 33 32 33 32 31 33 32dibromochloromethaneμg/l 1.2 1.5 1.5 <1.168 1.5 1.5 1.4 1.4 1.4GESAMP-BWWG 10/6ANNEX 7Page 64I:\MEPC\60\2-11.docTHMs in samples produced viaRBT treatment (treat/filter –control)Test 1ControlFH01Test 1TreatFH04Test 1FilterFH07Test 2ControlFH02Test 2TreatFH05Test 2FilterFH08Test 3ControlFH03Test 3TreatFH06Test 3FilterFH09bromodichloromethaneμg/l - 0.2 0.6 - 0.8 0.4 - -0.3 0bromoformμg/l - 0.13 0.13 - 0.75 0.8 - 0 0.03chloroformμg/l - 1 3 - 1 0 - 2 1dibromochloromethaneμg/l - 0.3 0.3 - 1.5 1.5 - 0 05-Day Old samplescTest 1ControlFH16Test 1TreatFH10Test 1FilterFH13Test 2ControlFH17Test 2TreatFH11Test 2FilterFH14Test 3ControlFH18Test 3TreatFH12Test 3FilterFH15bromodichloromethaneμg/l 6 5.4 5.5 5.8 5.8 5.5 6 2.8 4.4bromoformμg/l <0.543 <0.543 <0.543 0.6 <0.543 <0.543 <0.543 <0.543 <0.543chloroformμg/l 30 28 27 30 29 31 30 32 32dibromochloromethaneμg/l 2.5 2.4 2.3 2.6 2.4 2.2 2.5 1.3 1.9Percentage increase/decreaseof THMs in 5-day old samplesbromodichloromethane% 50.0 28.6 19.6 52.6 26.1 31.0 36.4 -31.7 0.0bromoform% 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0chloroform% 0.0 -9.7 -18.2 -6.3 -12.1 -3.1 -3.2 -3.0 0.0dibromochloromethane% 108.3 60.0 53.3 122.6 60.0 46.7 78.6 -7.1 35.7___________