I:\MEPC\61\2-4.doc 

E

MARINE ENVIRONMENT PROTECTION 

COMMITTEE 

61st session 

Agenda item 2 

MEPC 61/2/4

22 March 2010

 Original: ENGLISH

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER 

Application for Final Approval of BalClorTM ballast water management system 

Submitted by China 

SUMMARY 

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

Final Approval of BalClorTM Ballast Water Management System in 

accordance with the "Procedure for approval of ballast water 

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

adopted by resolution MEPC.169(57). The complete application 

dossier will be submitted to the Marine Environment Division 

of IMO for review by the GESAMP-Ballast Water Working Group in 

accordance with Procedure (G9). 

Strategic direction: 7.1 

High-level action: 7.1.2 

Planned output: 7.1.2.4 

Action to be taken: Paragraph 7 

Related documents: BWM/CONF/36; MEPC 57/21/Add.1; BWM.2/Circ.13, BWM.2/Circ.24; 

MEPC 60/2/3 and MEPC 60/2/12 

Introduction

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

Ships' Ballast Water and Sediments stipulates that ballast water management systems that 

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

Organization.

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

of Active Substances (G9) contains the information that should be included into a proposal 

for approval (MEPC 57/21/Add.1, annex 1, paragraph 4.2.1) and provisions for risk 

characterization and analysis (MEPC 57/21/Add.1, annex 1, paragraph 5.3). According to 

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

application. 
MEPC 61/2/4 

Page 2 

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3 Sunrui Corrosion and Fouling Control Company, Qingdao (China) has developed 

a ballast water management system to treat ballast water using electrolysis. The name 

of "Sunrui BWMS" was used in the application for Basic Approval (MEPC 60/2/3). After that, 

the applicant decided to register its ballast water management system under the name of 

"BalClorTM BWMS" and to apply for Final Approval under the new name. 

4 According to BWM.2/Circ.24, a document on the proposal for approval containing all 

the non-confidential data related to the respective ballast water management systems that 

make use of Active Substances shall be submitted to MEPC 61. 

5 The competent authority in China has verified the application dossier and believes it 

satisfies the data requirements of Procedure (G9) adopted by resolution MEPC.169(57). 

6 China therefore submits the non-confidential part of the manufacturer's application 

dossier in the annex of this document to the Organization for evaluation according 

to Procedure (G9). The complete dossier will be made available to the experts of 

the GESAMP-BWWG with the understanding of confidential treatment. 

Action requested of the Committee 

7 The Committee is invited to consider the proposal for approval and decide as 

appropriate. 

*** 
MEPC 61/2/4 

Annex, page 1 

I:\MEPC\61\2-4.doc 

ANNEX 

NON-CONFIDENTIAL INFORMATION ON BALCLORTM BALLAST WATER 

MANAGEMENT SYSTEM (CHINA) 

This information related to the application for Final Approval of BalClorTM BWMS 

(the name of "Sunrui BWMS" was previously used in the application for Basic Approval 

(MEPC 60/2/3)) is prepared in accordance with the Procedure for approval of ballast water 

management systems that make use of Active Substances (G9) (MEPC.169(57)) and the 

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

(BWM.2/Circ.13). 

1 INTRODUCTION

1.1 Background

1.2 Response to the GESAMP-BWWG's review of the application for Basic Approval 

2 DESCRIPTION OF BALCLORTM BALLAST WATER MANAGEMENT SYSTEM

2.1 Overview 

2.2 Principle of chlorine disinfection

2.3 BalClorTM BWMS configuration and characters

3 LAND-BASED TYPE APPROVAL TESTS OF BALCLORTM BWMS 

3.1 Introduction

3.2 Test facility

3.3 Test cycles and test water

3.4 Test results

4 IDENTIFICATION OF THE SUBSTANCE, RELEVANT CHEMICALS AND 

OTHER CHEMICALS (G9: 4.1) 

4.1 Active Substances

4.2 Relevant Chemicals

4.3 Other Chemicals

4.4 Chemical analysis results 

5 DATA SET FOR ACTIVE SUBSTANCE AND PREPARATION (G9: 4.2) 

5.1 Data on effects on aquatic plants, invertebrates and fish, and other biota, including 

sensitive and representative organisms (G9: 4.2.1.1) 

5.1.1 Acute aquatic toxicity 

5.1.2 Chronic aquatic toxicity 

5.1.3 Endocrine disruption 

5.1.4 Sediment toxicity 

5.1.5 Bioavailability/biomagnification/bioconcentration 

5.1.6 Food web/population effects 
MEPC 61/2/4 

Annex, page 2 

I:\MEPC\61\2-4.doc 

5.2 Data on mammalian toxicity (G9: 4.2.1.2)

5.2.1 Acute mammalian toxicity 

5.2.2 Effects on skin and eye, and sensitization effects 

5.2.3 Repeated-dose toxicity 

5.2.4 Chronic toxicity 

5.2.5 Developmental and reproductive toxicity 

5.2.6 Carcinogenicity 

5.2.7 Mutagenicity/genotoxicity 

5.2.8 Toxicokinetics 

5.3 Data on environmental fate and effect under aerobic and anaerobic conditions 

(G9: 4.2.1.3) 

5.3.1 Modes of degradation (biotic; abiotic) 

5.3.2 Bioaccumulation, partition coefficient, octanol/water partition coefficient 

5.3.3 Persistence and identification of the main metabolites in the relevant media 

(ballast water, marine and fresh waters) 

5.3.4 Reaction with organic matter 

5.3.5 Potential physical effects on wildlife and benthic habitats 

5.3.6 Potential residues in seafood 

5.3.7 Any known interactive effects 

5.4 Physical and chemical properties for the Active Substances, Relevant Chemicals 

and treated ballast water (G9: 4.2.1.4) 

5.5 Analytical methods at environmentally relevant concentrations (G9: 4.2.1.5)

6 USE OF THE ACTIVE SUBSTANCE (G9: 4.2.6)

6.1 Manner of application

6.2 TRO dosage monitoring and control 

6.3 Neutralizing unit and TRO monitoring at discharge

6.4 Retention time

7 MATERIAL SAFETY DATA SHEETS (G9: 4.2.7) 

8 RISK CHARACTERIZATION 

8.1 Screening for persistence, bioaccumulation and toxicity (G9: 5.1)

8.1.1 PBT criteria for Active Substance (G9: 5.1.1.1) 

8.1.2 Assessment of Persistence (P), Bioaccumulation (B) and toxicity (T) (G9: 5.1.1.2) 

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

8.2.1 Toxicity test of the treated ballast water 

8.2.2 Determination of holding time (G9:5.2.7) 

8.3 Risk characterization and analysis (G9: 5.3) 

8.3.1 Reaction with organic matter (G9: 4.2.1.3) 

8.3.2 Characterization of degradation route and rate (G9: 5.3.5) 

8.3.3 Prediction of discharge and environmental concentrations (G9: 5.3.8) 

8.3.4 Assessment of potential for bioaccumulation (G9: 5.3.7) 

8.3.5 Effects assessment 

8.3.6 Effects on aquatic organisms 

8.3.7 Effects on sediment 

8.3.8 Comparison of effect assessment with discharge toxicity 
MEPC 61/2/4 

Annex, page 3 

I:\MEPC\61\2-4.doc 

9 RISK ASSESSMENT 

9.1 Risk to safety of ship 

9.1.1 Flooding 

9.1.2 Corrosion 

9.1.3 Fire and explosion 

9.1.4 Hydrogen gas and chlorine gas 

9.1.5 Storage and handling of the substances 

9.1.6 Noise 

9.2 Risks to human health

9.3 Risks to the aquatic environment

10 ASSESSMENT REPORT (G9: 4.3) 

10.1 Test report and data quality

REFERENCES 
MEPC 61/2/4 

Annex, page 4 

I:\MEPC\61\2-4.doc 

1 INTRODUCTION 

1.1 Background 

Sunrui Corrosion and Fouling Control Company ( ) Sunrui CFCC has developed a ballast 

water management system (BalClorTM BWMS) to treat ballast water on board through 

pre-filtration followed by disinfection with Active Substances (AS) produced by an electrolytic 

process during ballasting, and neutralization at de-ballasting. In applying for Basic Approval, 

the name of "Sunrui BWMS" was used (MEPC 60/2/3). After that, the applicant decided to 

register its ballast water management system in the name of "BalClorTM BWMS" and to apply 

for Final Approval of BalClorTM BWMS. 

BalClorTM BWMS has been developed on the basis of land-based electrolytic technology 

applied by Sunrui CFCC for many years, and the core technique is to electrolyze seawater 

on board directly to produce sodium hypochlorite solution for sterilization. Sunrui CFCC owns 

the proprietary rights of core components, such as cell design, electrode material etc. 

Application for Basic Approval of the BalClorTM BWMS (in the name of "Sunrui BWMS") was 

submitted to IMO in August 2009 and reviewed by the GESAMP-BWWG at its eleventh 

meeting held at IMO Headquarters from 19 to 24 October 2009. Based on the 

recommendation by the GESAMP-BWWG (MEPC 60/2/12), Basic Approval has been 

granted to the BWMS by the Marine Environment Protection Committee at MEPC 60. 

The system has run the land-based type approval testing in accordance with the 

IMO Guidelines (G8) from September to December 2009. The results of land-based tests 

showed that the biological efficacy of BalClorTM BWMS meet the performance standards of 

Regulation D-2. Meanwhile, as part of land-based type approval process, the discharge 

toxicity tests, on the samples drawn from the land-based test set-up were conducted 

according to Procedure (G9). The results of the Procedure (G9) tests, including the toxicity 

and chemical testing required for Final Approval, are reported in the application dossier. 

1.2 Response to the GESAMP-BWWG's review of the application for Basic Approval 

All the comments and recommendations made by the GESAMP-BWWG at its eleventh 

meeting have been carefully considered and addressed by the applicant. The response to 

individual recommendations is given below: 

1.2.1 Human Exposure Assessment (MEPC 60/2/12, annex 6, paragraph 9.4) 

The Group recommended that the Human Exposure Scenario (HES) general public via 

aggregated exposure (oral, skin and inhalation) when bathing in the areas close to the 

discharged ballast water should be provided by the applicant if the system is to be reviewed 

for Final Approval. The applicant should also identify and describe the unit operations 

associated with this system and information regarding the Human Exposure Scenario 

(MEPC 56/2/2, annex 9). 

Response: 

Assessment on potential risk of treated ballast water by the BWMS to human health has 

been conducted in accordance with the Methodology for information gathering and conduct 

of work of the GESAMP-BWWG contained in BWM.2/Circ.13. The full assessment report is 

contained in appendix 10 of the confidential dossier. 
MEPC 61/2/4 

Annex, page 5 

I:\MEPC\61\2-4.doc 

In the assessment, identification/description of the unit operations associated with the BWMS 

was carried out as a basic step to identify which individual system component is likely to lead 

to human exposure to the BWMS related chemicals. The Human Exposure Scenarios were 

developed according to the guidance in annex 2 of BWM.2/Circ.13. The descriptions on unit 

operations and the information regarding the HES are included in the assessment report. 

Regarding the general public/human exposure via environment, in addition to the food chain 

that was addressed in Basic Approval, the HES general public via aggregated exposure 

(oral, skin and inhalation) when bathing in the areas close to the discharged ballast water 

was included in the risk assessment. 

1.2.2 Corrosion Tests (MEPC 60/2/12, annex 6, paragraph 9.5) 

The Group recommended that the comprehensive corrosion testing be conducted in 

accordance with the guidance provided in section 5.1 of the "Report of the eighth meeting of 

the GESAMP-BWWG" contained in MEPC 59/2/16. Where intermittent exposures are utilized 

to predict long-term corrosion rates, as proposed by the applicant, the TRO in the sample 

containers should be recorded and reported over the period of the exposure. In addition, the 

Group recommended that some indication, with supporting data, of the long-term corrosion 

rates under a constant level of TRO at the maximum allowable dosage concentration should 

be provided to allow the potential impact on exposed ship systems to be assessed. 

Response: 

The comprehensive corrosion testing has been conducted in accordance with the guidance 

provided in section 5.1 of the "Report of the eighth meeting of the GESAMP-BWWG" 

contained in document MEPC 59/2/16. The testing includes two kinds of low carbon steel, 

i.e. stainless steel and Cu alloy, respectively, and one non-metal. In addition, corrosion of 

marine epoxy-coated steel and the coating properties of the specimens exposed to the 

treated water were also tested. The test duration lasted for six months. 

Corrosion tests are described in section 9.1.2. The full reports are provided in appendix 5 of 

the confidential dossier. 

1.2.3 Monitor and control of TRO in discharge (MEPC 60/2/12, annex 6, paragraph 9.6) 

The Group recommended that the neutralization system should include appropriate 

monitoring and control to ensure efficient reduction of TRO in the ballast water discharge and 

this should be fully described in an application for Final Approval. 

Response: 

The neutralization system has included two sets of TRO analysers to monitor and control the 

residual TRO in the ballast water discharge. The full description of the monitoring and control 

system is presented in section 6.3. 
MEPC 61/2/4 

Annex, page 6 

I:\MEPC\61\2-4.doc 

2 DESCRIPTION OF BALCLORTM BALLAST WATER MANAGEMENT SYSTEM 

2.1 Overview 

The BalClorTM BWMS is a complete ballast water management system composing of the 

following main functional components: 

.1 self-cleaning filter with 50 μm screen to remove large plankton and solid 

particles; 

.2 electrolytic unit (including electrolytic cells and accessory dosing and 

degassing units) to produce sodium hypochlorite solution which is injected 

back into the main ballast pipe to the ballast tanks to kill the residual 

planktons, pathogens, larva or spores; 

.3 neutralizing unit to add sodium thiosulfate solution into the treated ballast 

water at de-ballasting to neutralize the residual TRO; and 

.4 control and auxiliary equipment. 

The flow chart of treatment of BalClorTM BWMS is shown in Figure 2-1. 

When ballasting, seawater is filtrated by self-cleaning filter with precision of 50 μm, then a 

side stream of seawater is pumped into an electrolytic unit to generate sodium hypochlorite 

solution, which is injected back into the main ballast stream after degas, making a complete 

mixture with the main stream. The TRO level is measured by a TRO analyser 

(TRO analyser 1) and controlled at a pre-set concentration value (ranging from 7.5 mg/L 

to 9.5 mg/L). 

On discharge of the treated ballast water, the BalClorTM system monitors the levels of TRO in 

ballast water. Discharge does not start until the sensors are operational and the neutralizer 

feed system is in operation. The neutralization system is activated with the neutralizer dose, 

which is calculated based on the concentration of TRO measured at the location just in front 

of the neutralizer injection point, to offset all TRO residuals. The sodium thiosulfate solution 

is injected into the suction of the ballast pump by a metering pump. Another TRO sensor is 

installed after the neutralizer injection point to monitor the TRO level to ensure that during 

discharge TRO concentration does not exceed 0.1 mg/L at any time. 
MEPC 61/2/4 

Annex, page 7 

I:\MEPC\61\2-4.doc 

(a) Ballasting 

(b) De-ballasting 

Figure 2-1: Flow chart of BalClorTM BWMS 

2.2 Principle of chlorine disinfection 

Chlorination is a mature technique for water treatment and has been widely used for the 

sterilizations of potable water, waste water and swimming pools for many years. 

The chlorination technique applied in BalClorTM BWMS is to directly electrolyze seawater to 

produce the sodium hypochlorite solution in situ. The principle of electrolysing seawater is: 

when a certain amount of seawater flows through the electrolytic cells, decomposition 

reactions take place on the electrode surfaces, with chlorine produced at the anode and 

hydrogen gas at the cathode. The reaction mechanism is as follows: 

Anode: 2Cl- → Cl2 + 2e 

Cathode: 2H2O + 2e → 2OH-

 + H2↑
MEPC 61/2/4 

Annex, page 8 

I:\MEPC\61\2-4.doc 

Chlorine dissolves into water and produces hypochlorous acid (HOCl) in equilibrium with 

hypochlorite ion (OCl-

); and a part of HOCl reacts with bromine ion in seawater and 

generates hypobromous acid (HOBr) in equilibrium with hypobromous ion (OBr-

). HOCl/OCland HOBr/OBr-

 are usually called free available halogen (FAH). 

Both HOCl and HOBr are strong oxidizers and halogenation agents, which react with 

nitrogen compounds such as ammonia, urea, aminoacids, etc., present in fresh water or 

seawater, generating chloramines and/or bromamines, collectively called haloamines. 

All the substances mentioned above are biocide, including HClO/ClO-

/Cl2, HOBr/OBr-/Br2, 

chloramines and bromamines, which are called by a joint name Total Residual Oxidants 

(TRO) in this document. 

2.3 BalClorTM BWMS configuration and characters 

BalClorTM BWMS consists of the following functional modules: 

- Self-cleaning filter; 

- Electrolytic unit (including electrolytic cells and accessory dosing and degassing units); 

- Rectifier; 

- Controller; 

- TRO analyser; 

- Neutralizing unit; 

- Sampling unit; and 

- Hydrogen gas/chlorine gas alarm. 

Accessory units include flow-meters, pumps and valves, etc. Figure 2-2 shows a typical 

BalClorTM BWMS. 

Figure 2-2: BalClorTM BWMS 

The functional modules of the system can be installed either as an integrated system in one 

space or installed separately in different places on the ship. The integrated BWMS is more 

suitable for new buildings, while different factional modules installed in different place may be 

more practicable for existing ships. 
MEPC 61/2/4 

Annex, page 9 

I:\MEPC\61\2-4.doc 

The BalClorTM BWMS has some special characters, in particular, in the following aspects: 

Friendly to environment 

No wastes like fume and dust that may pollute the environment are produced when 

the system operates. The substances produced by the system leave no harmful 

influences on natural environment. 

Safe for ships and crew 

The system does not produce any substances that do harm to the crew. All electrical 

and electronic sections that crew shall operate are safe. Adequate alarm system is 

designed, so that protective action could be taken in time to eliminate potential 

dangers for ships and crew. 

Easy operation 

 The calibration and setting of the system have been completed in the factory and 

the operation of the system can be performed in fully automatic mode. It is easy for 

operators to monitor the operational status of the system on the Human-Machine 

Interface (HMI) on the touch screen. 

Low cost for operating and maintenance 

For the operation of the system, only power consumption and a small amount of 

inexpensive reagent is needed. 

The ballast water with salinity above 3 PSU can be directly electrolyzed to produce Active 

Substances as disinfecting agents. When ship is ballasting in fresh water areas with salinity 

below 3 PSU, there are two options: one is to add salt to increase the salinity in the water for 

electrolysis; the other option is that the ship in question retain a certain amount of seawater 

in the ballast tanks from her previous voyage (about 1%-2% of the ballast water needed for 

the voyage), which can be used as the electrolytic water. For either option, specific design 

can be tailored to the particular ship according to shipowner's choice. 

3 LAND-BASED TYPE APPROVAL TESTS OF BALCLORTM BWMS 

3.1 Introduction 

Land-based type approval tests were conducted from September to December 2009 at the 

test site located in Qingdao, China. The full-scale BalClorTM BWMS tested during the 

land-based testing was manufactured and installed in accordance with the requirements 

of Guidelines (G8) and the relevant class requirements. Its rated treatment 

capacity is 250 m3

/h. According to the requirements of Guidelines (G8), pre-test evaluation of 

the system was carried out and approved by China Classification Society (CCS) prior to the 

land-based type approval testing. The tests were attended and verified by the CCS. 

3.2 Test facility 

The test facility was built in 2008. It was arranged and established in accordance with the 

requirements of Guidelines (G8) and was also used for the tests for Basic Approval of 

BalClorTM BWMS. The facility includes two feed tanks (Culture tanks) used for preparing the 

inlet water to be tested, one control tank (Control ballast tank) for keeping control water and 
MEPC 61/2/4 

Annex, page 10 

I:\MEPC\61\2-4.doc 

one treated ballast tank (Treated ballast tank) for storing treated water before discharge, 

each tank with a capacity of 250 m3

. Rated flow rate of the land-based set-up is 250 m3/h.

3.3 Test cycles and test waters 

According to section 2.3.17, part 2 of Guidelines (G8), the tests of five cycles with high 

salinity and five cycles with medium salinity were performed. Each cycle lasted for a period of 

at least 5 days. In one test cycle for each salinity range, treated waters were also sampled 

for the toxicity tests and chemical analysis required in Procedure (G9). In addition, one test 

cycle (TC20) on fresh water (salinity< 3PSU) was conducted to analyse the chemicals in the 

water treated by electrolyzing artificial saltwater. 

Test water was prepared in the culture tanks for two different sets of test cycles. The test 

water fulfilled the influent water criteria in sections 2.3.17 to 2.3.20 of Guidelines (G8). 

Detailed information is provided in appendix 1 "Testing plans and QAPPs" and appendix 2 

"Test reports for biological efficacy analysis and physical and chemical properties test of 

treated water in land-based testing" to the confidential dossier.

3.4 Test results 

Biological efficacy 

The biological analysis results of ten valid land-based test cycles proved that the biological 

efficacy of BalClorTM BWMS met the performance standards of Regulation D-2. The full 

reports of biological analysis results of test cycles TC07 (with high salinity) and TC08 

(medium salinity) are provided in appendix 2 of the confidential dossier. 

Chemical analysis 

Samples for chemical analysis were taken from the treated water in test cycles TC07, TC08 

and TC20 (fresh water). The test results and analysis are reported in sections 4.4 and 4.5 

and appendix 3 of the confidential dossier. 

Toxicity tests 

In test cycles TC07 and TC08, the discharge water was sampled immediately after treatment 

(after neutralizing) and after storage in tank for 48 hours (after neutralizing) for acute and 

chronic toxicity tests. The results and analysis of toxicity tests are reported in section 8.2.1 

and appendix 4 of the confidential dossier. 
MEPC 61/2/4 

Annex, page 11 

I:\MEPC\61\2-4.doc 

TRO concentration in treated tanks 

The concentration of TRO in treated tank were measured and recorded daily. The data 

collected in the test cycles TC07, TC08 and TC20 are presented in Figure 3-1. 

0 12 24 36 48 60 72 84 96 108 120

0

2

4

6

8

TRO (mg/L) 

Time (h)

 Test Cycle 07 

 Test Cycle 08

 Test Cycle 20

Figure 3-1: TRO concentration in treated ballast water of test 

cycles TC07, TC08 and TC20 

4 IDENTIFICATION OF THE SUBSTANCE, RELEVANT CHEMICALS AND 

OTHER CHEMICALS (G9: 4.1) 

4.1 Active Substances 

BalClorTM BWMS utilizes the technology of electrolyzing seawater directly to generate 

biocides in situ on board. In the disinfection step, a side stream of filtered seawater flows 

through the electrolytic cells, in which electrochemical reactions take place at the anode and 

cathode, with chlorine and certain short-life oxygenated chemical compounds and oxygen 

gas at the anode, and hydrogen gas generated at the cathode. Chlorine dissolves into water 

and results in the formation of hypochlorous acid (HOCl) in equilibrium with hypochlorite ion 

(OCl-

); and a part of HOCl reacts with bromine ion in seawater and generates hypobromous 

acid (HOBr) in equilibrium with hypobromous ion (OBr-

). Both HOCl/OCl- and HOBr/OBr- are 

effective biocides, usually called free available halogen (FAH). 

Hydrogen gas and oxygen gas are completely removed in the degas tank, therefore, they are 

considered as by-products and not Relevant Chemicals. The short-life oxygenated chemical 

species, possibly including hydrogen peroxide and ozone, present in the side-stream will 

decompose. For example, hydrogen peroxide will be reduced to water by free available 

chlorine and ozone will decompose into oxygen gas with chlorine acting as a catalyst. 

Therefore, these oxygenated species will not be considered as either Active Substances or 

Relevant Chemicals. 

Both HOCl and HOBr are strong oxidizers and halogenation agents, which react with 

nitrogen compounds such as ammonia, urea, aminoacids, etc., present in fresh water or 

seawater, generating chloramines and/or bromamines, collectively called haloamines. Both 

chloramines and bromamines are also biocides. Although the germicide efficiency of 
MEPC 61/2/4 

Annex, page 12 

I:\MEPC\61\2-4.doc 

haloamines are much weaker than that of FAH, it becomes evident that those haloamines 

also have biocide effect, especially on certain pathogens, and have longer term effect. 

Chlorine and bromine based compounds are typically analysed together and reported as 

Free Available Halogen (FAH) for total HOCl/OCl- and HOBr/OBr- or as Total Residual 

Oxidant (TRO) for total HOCl/OCl-, HOBr/OBr-, chloramines and bromamines. It is virtually 

impossible to provide a further breakdown for the concentration of chloramines and 

bromamines in TRO, as these are unstable compounds and there are no calibration 

standards available to ensure their reliable analysis. 

Based on the above, for this application, HOCl/OCl- , HOBr/OBr-, chloramines together with 

bromamines, regarded as TRO, are defined as Active Substances. 

4.2 Relevant Chemicals 

During the process of disinfection by chlorine in seawater, trihalomethanes (THM), haloacetic 

acids (HAA), haloacetonitriles (HAN) and bromate ion are considered as main potential 

chemicals , therefore are defined as Relevant Chemicals. 

4.3 Other Chemicals 

On discharge of the treated ballast water, the TRO in ballast water is neutralized with sodium 

thiosulphate, which is defined as Other Chemical. 

4.4 Chemical analysis results 

The potential by-products in the seawater treated by BalClorTM BWMS have been tested and 

analysed. Based on the analysis results, the Active Substance, Relevant Chemicals and 

Other Chemicals identified are listed in Table 4-1. From the test results, it was observed that 

the chemicals detected in the treated water in land-based type approval testing are the same 

as those found in the previous tests for Basic Approval, and the quantity of each substance is 

at the similar level, some are slightly lower than the previous test results. 

The full chemical analysis report is provided in appendix 3 of the confidential application 

dossier. 

Table 4-1: Identified Active Substances, Relevant Chemicals and Other Chemicals 

Chemicals CAS No. Molecular

weight 

Formula AS/RC/

OC 

(bio)degradation 

rate or half-life 

Hypochlorous acid/ 

hypochlorite 

7681-52-9 74.44 NaOCl AS 1.4 hour 

(at pH 8) 

Hypobromous acid/ 

hypobromite 

13824-96-9 118.89 NaOBr AS 

Biodegrades fast 

Chloramines/Bromamines Not available 51.48 NH2Cl AS 9 to 420 hours 

(as Monochloramine) 

Dibromochloromethane 124-48-1 208.28 CHBr2Cl RC Water: 38 days 

Soil: 75 days 

Sediment: 

340 days 

Air: 280 days 
MEPC 61/2/4 

Annex, page 13 

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Chemicals CAS No. Molecular

weight 

Formula AS/RC/

OC 

(bio)degradation 

rate or half-life 

Tribromomethane 75-25-2 252.73 CHBr3 RC 1.7 years 

(Fresh water, at 

an aqueous 

concentration 

of 1X10-17 mole/l 

hydroxyl radicals) 

Monobromoacetic acid 79-08-3 167.01 CH2BrC

OOH 

RC Half-life: 

Water: 8.7 days 

Soil: 17 days 

Sediment: 

78 days 

Air: 22 days 

Bromochloroacetic acid 5589-96-8 138.95 CHBrClC

OOH 

RC Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 

140 days 

Air: 24 days 

Dibromoacetic acid 631-64-1 217.86 CHBr2C

OOH 

RC Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 

140 days 

Air: 25 days 

Dibromochloroacetic 

acid 

5278-95-5 252.36 CClBr2C

OOH 

RC 

No data available 

Tribromoacetic acid 75-96-7 296.74 CBr3CO

OH 

RC Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 

140 days 

Air: 31 days 

Dibromoacetonitrile 3252-43-5 198.86 CHBr2C

N 

RC Half-life: 

Water: 38 days 

Soil: 75 days 

Sediment: 

340 days 

Air: 540 days 

Bromate 7758-01-2 167.01 KBrO3 RC Half-life: 

Seawater: 

12 hours 

Sodium thiosulfate 7772-98-7 158.09 Na2S2O3 OC 

Biodegrades fast 

5 DATA SET FOR ACTIVE SUBSTANCE AND PREPARATION (G9: 4.2) 

Note: The data sets of the substances listed in Table 4-1 were provided in the forms in 

accordance with the requirements of Procedure (G9) and BWM.2/Circ.13 in the application 

for Basic Approval (MEPC 60/2/3). Since the information for this section (from 5.1 to 5.5) is 

the same as those in section 4 of document MEPC 60/2/3, it was not reproduced. 
MEPC 61/2/4 

Annex, page 14 

I:\MEPC\61\2-4.doc 

6 USE OF THE ACTIVE SUBSTANCE OR PREPARATION (G9: 4.2.6) 

6.1 Manner of application 

As reported in section 2, in disinfection process, the BalClorTM BWMS utilizes the technology 

of electrolyzing seawater directly to generate Active Substances as biocides in situ on board. 

A side stream of filtered seawater flows through the electrolytic cells, in which 

electrochemical reactions take place to generate Active Substances, including HClO/ClO-

, 

HOBr/OBr-

, chloramines and bromamines, which are called by a joint name Total Residual 

Oxidants (TRO). After degas, the TRO solution is injected back into the main ballast pipe and 

mixed with incoming ballast water in the pipe. The initial TRO concentration value in the 

treated ballast water is pre-set in the system, and the dose range in the BalClorTM BWMS is 

between 7.5 mg/L and 9.5mg/L. 

The production of TRO is determined by the magnitude of DC current of the electrolytic cells 

and the salinity of ballast water. The salinity of ballast water is measured by sensors prior to 

the electrolytic cells, and the signal is transmitted to controller. Because the production of 

TRO is a function of electrolytic current and the salinity of water, controller will determine the 

current output of rectifier to generate required amount of TRO, according to preset value of 

TRO concentration and the salinity of water. 

The actual TRO concentration in ballast water is continuously monitored by an online 

TRO analyser when ballasting. After the TRO solution is injected into the main ballast water 

stream from electrolytic unit and fully mixed, water samples will be taken to the TRO analyser 

to measure the TRO concentration, and the signals will be transmitted back to the controller, 

which will regulate the current output of the rectifier to maintain the TRO concentration at the 

preset level (7.5 mg/L – 9.5 mg/L), according to the difference between the measured 

concentration and preset value. The flow chart of treatment of BalClorTM BWMS is shown in 

Figure 2-1(a). 

During electrolysis, hydrogen gas is produced, which is a hazard to safety of ships. In the 

system, hydrogen gas is fully separated and diluted in a degas tank, and then discharged to 

atmosphere outside ships. Risk management measures in this regard are described in detail 

in section 9.1.4. 

6.2 TRO dosage monitoring and control during ballasting 

There are two TRO analysers in the BalClorTM BWMS. During ballasting operation, 

TRO analyser 1 is responsible for measuring the TRO concentration in the treated ballast 

water in main pipe. As mentioned above, the signal from the TRO analyser is transmitted to 

the controller, which will compare the TRO concentrations measured by TRO analyser with 

the preset values and regulate the current output of rectifier to maintain the TRO 

concentration at the preset value. 

6.3 Neutralizing unit and TRO monitoring and control at discharge 

When de-ballasting, neutralizer (sodium thiosulfate solution) is added into the treated ballast 

water to neutralize the residual TRO. The chemical reaction equation is as follows: 

Na2S2O3 + 4NaCl O + 2NaOH → 4NaCl + 2Na2SO4 + H2O 

NaCl and Na2SO4 produced in the neutralization reaction are the substances already existing 

in seawater, they will not cause any risk to the marine environment. 
MEPC 61/2/4 

Annex, page 15 

I:\MEPC\61\2-4.doc 

The neutralization step will be always employed prior to discharge to ensure the safety of the 

marine environment in receiving water. The dosage of the neutralizer depends on the TRO 

concentration in the ballast water for discharge and ballast water flow rate, and is controlled 

automatically. Flow chart of neutralization at discharge is shown in Figure 6-1. 

In neutralization process, filter and electrolytic unit are bypassed. At discharge, two 

TRO analysers (No.1 and No.2) are used to control and monitor the residual TRO in ballast 

water during neutralizing process; first one (TRO analyser 1) measures the residual TRO in 

treated ballast water before neutralization in order to calculate the amount of sodium 

thiosulfate solution needed to offset all remaining TRO, while second one (TRO analyser 2), 

which is located at downstream of the dosing point of the neutralizer, monitors the residual 

TRO in the discharge water after neutralization to ensure that during discharge TRO does 

not exceed 0.1 mg/L at any time. 

Figure 6-1: Flow chart of neutralization when discharging 

The BalClorTM BWMS is interlocked with the ballast system of the ship, and ballast water 

discharge will not start until the TRO analysers and the neutralization system are in 

operation. During deballasting, if the TRO concentration detected by TRO analyser 2 

exceeds 0.1 mg/L, an audible and visual alarm will be triggered, and the controller will send 

signals to ship ballast system to stop de-ballasting process. Instructions on how to carry out 

the inspection and take remedy actions will be shown on human-machine interface (HMI) at 

control station (see Technical Specification and Manual in appendix 11 of the confidential 

dossier). Discharge will not restart until the malfunction has been corrected. 

6.4 Retention time 

Retention time in the BalClorTM BWMS was determined based on the biological efficacy tests. 

According to the test results, 24 hours of storing of ballast water in the ballast tanks after 

treatment can ensure effective disinfection to the Regulation D-2 and no re-growth of 

organisms were found in the treated water after 10 days. 
MEPC 61/2/4 

Annex, page 16 

I:\MEPC\61\2-4.doc 

In conclusion, in order to meet the requirements in Regulation D-2, the treated ballast water 

should be kept in ballast tanks for 24 hours before de-ballasting. 

7 MATERIAL SAFETY DATA SHEETS (G9: 4.2.7)

Material Safety Data Sheets (MSDS) for Active Substances, Relevant Chemicals and Other 

Chemical are provided in appendix 7 of the confidential dossier. 

8 RISK CHARACTERIZATION 

8.1 Screening for persistence, bioaccumulation and toxicity (G9: 5.1) 

8.1.1 PBT criteria for Active Substance (G9: Table 1) 

Table 8-1 shows the criteria for identification of PBT substances. 

Table 8-1: Criteria for identification of PBT substances 

Criterion PBT criteria 

Persistence Half-life: 

 > 60 days in marine water, or 

> 40 days in freshwater, or 

> 180 days in marine sediment, or 

> 120 days in freshwater sediment 

Bioaccumulation BCF > 2,000 or 

LogPoctanol/water ≥3 

Toxicity Chronic NOEC < 0.01 mg/l 

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

Table 8-2 shows Persistence (P), bioaccumulation (B), and toxicity (T) data for the 

Active Substances, Relevant Chemicals and Other Chemicals. According to PBT evaluation, 

all of the Active Substances, Relevant Chemicals and Other Chemicals are not considered to 

be PBT substances. 

Table 8-2: Persistence (P), bioaccumulation (B), and toxicity (T) data for the Active 

Substances, Relevant Chemicals and Other Chemicals 

Chemical Persistence(Y/N) Bioaccumulation(Y/N) Toxicity(Y/N) 

HOCl(NaClO) No 

Half-life:1.4 hour 

(at pH 8) 

No 

BCF: 3.162 

Log Pow: -3.42 

Yes 

NOEC:0.003 

mg/l 

HOBr(NaBrO) No 

Biodegrades fast 

No 

BCF: 1.24 

Log Pow: -1.03 

N. A. 

Monochloramine No 

Abiotic Degradation: 

Chloramine half-lives 

ranging from 9 

to 420 hours 

N. A. N. A. 
MEPC 61/2/4 

Annex, page 17 

I:\MEPC\61\2-4.doc 

Chemical Persistence(Y/N) Bioaccumulation(Y/N) Toxicity(Y/N) 

Tribromomethane Yes 

Fresh water, Half-life: 

1.7 years (at an 

aqueous concentration 

of 1X10-17 mole/l 

hydroxyl radicals) 

No 

BCF: 14 

Log Pow: 2.4 

No 

NOEC: 4.8 

mg/l/28d 

Dibromochloromethane Yes 

Half-life: 

Watetr: 38 days 

Soil: 75 days 

Sediment: 340 days 

Air: 280 days 

No 

BCF: 0.74-1.47 L/kg 

Log Pow: 2.24 

No 

NOEC: 3.2 

mg/L/21day 

Bromoacetic acid No 

Half-life: 

Watetr: 8.7 days 

Soil: 17 days 

Sediment: 78 days 

Air: 22 days 

No 

BCF: 3.2 

Log Pow: 0.41 

No 

NOEC: 1.6 

mg/l/21days 

Dibromoacetic acid No 

Half-life: 

Watetr: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 25 days 

No 

BCF: 0.17 

Log Pow: 0.70 

No 

PBT Profiler 

Tribromoacetic acid No 

Half-life: 

Watetr: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 31 days 

No 

BCF: 0.63 

Log Pow: 1.71 

No 

PBT Profiler 

Bromochloroacetic acid No 

Half-life: 

Watetr: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 24 days 

No 

BCF: 3.2 

Log Pow: 0.61 

No 

PBT Profiler 

Dibromochloroacetic 

acid 

No 

Activated sludge: 

100%(aerobic), 28 days 

No 

Log Pow: 1.62 

N. A. 

Dibromoacetonitrile No 

Half-life: 

Watetr: 38 days 

Soil: 75 days 

Sediment: 340 days 

Air: 540 days 

No 

BCF: 3 

Log Pow: 0.47 

No 

PBT Profiler 

Bromate No 

Half-life: 

Seawater: 12 hours 

No 

BCF: 3.7×10-7

Log Pow: -7.18 

No 

NOEC:8 

mg/l/7d 

Sodium thiosulfate No 

Biodegrades fast 

No 

BCF: 3.162 

Log Pow: -4.53 

No 

NOEC: 600 

mg/l/18month 
MEPC 61/2/4 

Annex, page 18 

I:\MEPC\61\2-4.doc 

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

8.2.1 Toxicity test of the treated ballast water 

According to the requirements of Procedure (G9) and BWM.2/Circ.13, the aquatic toxicity 

tests of three trophic levels using the treated ballast waters sampled from the land-based 

type approval testing of BalClorTM BWMS were performed by Supervision and Test Center 

for Pesticide Safety Evaluation and Quality Control. 

The aquatic toxicity tests results are summarized in Table 8-3, and the complete report of the 

aquatic toxicity tests is provided in appendix 4 of the confidential dossier. 

Table 8-3: Aquatic toxicity test results 

Samples Tests Organisms Results 

Algae Growth inhibition Test Skeleonema 

costatum 

NOAEC > 100% 

Marine Invertebrate Acute Toxicity 

Test 

NOAEC > 100% 

Marine Invertebrate Chronic 

Toxicity Test 

Neomysis 

awatschenis NOEC > 100% 

LOEC > 100% 

Marine Fish Acute Toxicity Test NOAEC > 100% 

20091101- 

TC07T-0h-N 

Marine Fish Chronic Toxicity Test Ctenogobius 

gymnauchen 

NOEC > 100% 

LOEC > 100% 

Algae Growth inhibition Test Skeleonema 

costatum 

NOAEC > 100% 

Marine Invertebrate Acute Toxicity 

Test 

NOAEC > 100% 

Marine Invertebrate Chronic 

Toxicity Test 

Neomysis 

awatschenis NOEC > 100% 

LOEC > 100% 

Marine Fish Acute Toxicity Test NOAEC > 100% 

20091103- 

TC07T-48h-N 

Marine Fish Chronic Toxicity Test Ctenogobius 

gymnauchen NOEC > 100% 

LOEC > 100% 

Algae Growth inhibition Test Skeleonema 

costatum 

NOAEC > 100% 

Marine Invertebrate Acute Toxicity 

Test 

NOAEC > 100% 

Marine Invertebrate Chronic 

Toxicity Test 

Neomysis 

awatschenis NOEC > 100% 

LOEC > 100% 

Marine Fish Acute Toxicity Test NOAEC > 100% 

20091109- 

TC08T-0h-N 

Marine Fish Chronic Toxicity Test Ctenogobius 

gymnauchen NOEC > 100% 

LOEC > 100% 

Algae Growth inhibition Test Skeleonema 

costatum 

NOAEC > 100% 

Marine Invertebrate Acute Toxicity 

Test 

NOAEC > 100% 

Marine Invertebrate Chronic 

Toxicity Test 

Neomysis 

awatschenis NOEC > 100% 

LOEC > 100% 

Marine Fish Acute Toxicity Test NOAEC > 100% 

20091111- 

TC08T-48h-N 

Marine Fish Chronic Toxicity Test Ctenogobius 

gymnauchen NOEC > 100% 

LOEC > 100% 
MEPC 61/2/4 

Annex, page 19 

I:\MEPC\61\2-4.doc 

From the results of aquatic toxicity tests, it is concluded that all the ecotoxicity of discharged 

ballast water is acceptable. 

8.2.2 Determination of holding time (G9:5.2.7) 

The holding time is the time that the treated ballast water has to be retained in the tanks to 

ensure there is no adverse effect concentration upon discharge. Since the neutralization step 

will be always employed in BalClorTM BWMS treatment process prior to discharge, treated 

water can be discharged anytime as long as the required disinfection level is achieved. 

For the BalClorTM BWMS, whether that level is achieved is determined by the contact time 

between Active Substances and organisms. According to a series of biological efficacy tests, 

the retention time of 24 hours is considered to be adequate to meet Regulation D-2. 

8.3 Risk characterization and analysis (G9: 5.3) 

8.3.1 Reaction with organic matter (G9: 4.2.1.3) 

Major reactions of chlorine with organic matter in polluted water were described in 

section 5.3.4. THM and HAA identified as the major by-products of these reactions are 

directly related to the total organic carbon in the water being treated and the chlorine dose 

level used for disinfection. As these by-products may bring risk to the environment, they 

should be reduced to the minimum. 

8.3.2 Characterization of degradation route and rate (G9: 5.3.5) 

Degradation of TRO has two major routes: (1) through a quick consumption or 

decomposition by the chlorine demand in the polluted water (organic and nitrogen 

compounds, ions of Fe, Ni, Co that decompose TRO); and (2) through a slow decay via 

photolytic or heat decomposition. 

Chlorine and all of its derived species are oxidative and very reactive compounds. Chlorine 

gas is a more efficient oxidizer than hypochlorous acid (HOCl), and hypochlorous acid is 

more efficient than the hypochlorite ion (ClO-

). The balance between HOCl and ClO- can be 

studied in polluted water with pH between 4 and 10. In this case, the kinetic of the reactions 

and the final products obtained depend, to a large extent, on the percentage of each of the 

two species (HOCl, ClO-). The main reaction routes can be described as follows: 

.1 chlorination with amines R-NH2 or ammonium NH4

+

 is very rapid and 

explains the very fast disappearance of available chlorine in waste water; 

 .2 oxidation reactions occur with many inorganic or organic compounds; and 

 .3 chlorination of C atoms from organic molecules is easier for molecules with 

a shorter carbon skeleton. 

Three typical reactions are: Reaction with phenol giving monochlorophenols; Reaction with 

molecules containing two carbon atoms: acetaldehyde, acetonitrile, and acetic acid, which 

are chlorinated on the CH3, and give chloroacetaldehydes, chloroacetonitriles and 

chloroacetic acids; Reaction with final degradation of the carbon chain giving THMs. 

HOBr/OBr-

 is removed from seawater by several mechanisms. HOBr/OBr- reacts with natural 

organic matter to form tribromomethane by the haloform reaction. In fact, a number of 

disinfection products and other halogen containing compounds are reported when bromide is 

present in natural waters. Therefore, organic matter in ballast water could lead to the 
MEPC 61/2/4 

Annex, page 20 

I:\MEPC\61\2-4.doc 

disappearance of the TRO. Sunlight can reduce HOBr/OBr- to Br- through a complex series 

of photochemical reactions. In some cases, where high concentrations of Cl-

 are present, 

it may be that sunlight-mediated photolysis of HOBr/OBr- leads to the formation of bromate 

ion. Therefore, photolysis may also lead to the loss of TRO. After the neutralization and 

before the discharging, the concentrations of Active Substances and the bromate 

were 0 μg/L. 

THMs are extensively removed in sewage treatment, probably primarily by volatilization as 

well as by degradation. All trihalomethanes are volatile, the volatility decreasing in the order 

CHCl3 > CHBrCl2 > CHBr2Cl > CHBr3. Brominated acetic acids are generally more 

biodegradable than their chlorinated counterparts. Relevant Chemicals and Other Chemicals 

are expected to be naturally degradable by natural biotic or abiotic paths. 

8.3.3 Prediction of discharge and environmental concentrations (G9: 5.3.8) 

8.3.3.1 Introduction 

The MAMPEC Model of version 2.0 was used to calculate the PEC of Relevant Chemicals 

and Other Chemicals in the port. MAMPEC was originally programmed to calculate 

environmental concentrations of anti-fouling biocides released from ship coatings. 

In a modified way it can be used to calculate the concentrations that are released constantly 

into the water by other processes like for example ballast water treatment. The applicability 

of the model to any chemical substance made it a useful tool for environmental impact 

studies. 

8.3.3.2 Parameterization of the model 

To calculate the environmental concentration of the released compound in the harbour water 

and the sediment, several parameters are necessary. These parameters define the harbour 

and its characteristics, the compound that is being released and the amount of the specified 

compound released by ships. In the calculation, the OECD-EU commercial harbour was 

chosen with the default setting given by MAMPEC. Physico-chemical property data for 

Relevant Chemicals and Other Chemicals were taken from Key Data Summary or calculation 

of the EPI suit. The input parameters were the same as those of EUSES 2.1 which was used 

for human exposure assessment. The emission load was calculated from ballast water 

concentration for Relative chemicals and Other Chemical and average amount of ballast 

water in the OECD-EU commercial harbour. 

According to information contained in document BLG 13/INF.4, the daily ballast water 

discharge in port of Rotterdam (twice the size of the OECD-EU commercial harbour) is 

about 100,000 m3

.

 

8.3.3.3 Half-life 

Within MAMPEC, it was not possible to include the decay of the compound of interest during 

emptying the ballast water tank. In this case, a worst case scenario was used assuming that 

the water released from the ballast tanks has the same concentration at the start and at the 

end of discharge. 

The ballast water was treated by filter and electrolytic unit, and held in simulated tank for 

several days and then neutralized by sodium thiosulfate. After the neutralization the 

concentration of Active Substances and the Bromate measured was 0 μg/L in the ballast 

water, so the PEC of Active Substances and the Bromate in the harbour are 0 μg/L. 
MEPC 61/2/4 

Annex, page 21 

I:\MEPC\61\2-4.doc 

In the calculation of this dossier, using the worst-case scenario, it is assumed that all 

chemicals will not decay in water of the harbour after discharging. Predicted environmental 

concentrations (PEC) of the chemicals calculated by the MAMPEC model is based on the 

worst-case scenario of 100,000 m3 ballast water discharge. 

The concentrations of Active Substances, Relevant Chemicals and Other Chemicals after the 

neutralization were measured during the analytic testing, as shown in Table 8-4. 

Table 8-4: Maximum concentration of chemicals detected 

in treated water at discharge 

Chemicals Concentration, μg/L 

HOCl(NaOCl) 0 

HOBr(NaOBr) 0 

Chloramine 0 

Tribromomethane 42.21 

Dibromochloromethane 2.15 

Monobromoacetic acid 2.89 

Dibromoacetic acid 8.98 

Tribromoacetic acid 4.09 

Bromochloroacetic acid 0.46 

Dibromochloroacetic acid 2.96 

Dibromoacetonitrile 5.58 

Bromate 0 

Sodium thiosulphate 870 

8.3.3.4 Harbour definitions 

For all runs, the OECD-EU commercial harbour was chosen with the default settings given 

by MAMPEC. The modelling of the harbour is shown in Figure 8-1. 

Figure 8-1: The modelling of the OECD-EU commercial harbour 

Where: 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 
MEPC 61/2/4 

Annex, page 22 

I:\MEPC\61\2-4.doc 

8.3.3.5 Background concentration 

The background concentration of HOCl(NaOCl), HOBr(NaOBr), Chloramine, 

Monobromoacetic acid, Tribromoacetic acid, Dibromochloroacetic acid, Dibromoacetonitrile, 

Bromate, Sodium thiosulphate were measured to be 0 μg/L and Tribromomethane, 

Dibromochloromethane, Dibromoacetic acid, Bromochloroacetic acid were measured to 

be 0.16 μg/L, 0.04 μg/L, 0.22 μg/L and 0.12 μg/L, respectively. 

8.3.3.6 Results of Modelling 

The PEC results from the MAMPEC calculation are shown in Table 8-5. Maximum 

concentration was used in PEC/PNEC calculation. The data sheets are provided in the 

relevant parts of appendix 8 in the confidential application dossier. 

Table 8-5: Estimated total concentrations for Active Substance and Relevant Chemicals 

by MAMPEC (VER. 2.0 model) 

Chemical name Maximum 

Concentration 

(μg/L) 

95% 

Concentration 

(μg/L) 

Average 

Concentration 

(μg/L) 

Median 

Concentration 

(μg/L) 

Minimum 

Concentration 

(μg/L) 

HOCl(NaOCl) 0 0 0 0 0 

HOBr(NaOBr) 0 0 0 0 0 

Chloramine 0 0 0 0 0 

Tribromomethane 3.48E-01 3.40E-01 2.28E-01 1.83E-01 1.63E-01 

Dibromochloromethane 3.99E-02 3.98E-02 3.73E-02 3.91E-03 3.25E-04 

Monobromoacetic acid 2.65E-02 2.59E-02 9.22E-03 2.42E-03 3.25E-04 

Dibromoacetic acid 3.02E-01 3.01E-01 2.49E-01 2.28E-01 2.21E-01 

Tribromoacetic acid 3.74E-02 3.67E-02 1.31E-02 3.43E-03 4.60E-04 

Bromochloroacetic acid 1.24E-01 1.24E-01 1.21E-01 1.20E-01 1.20E-01 

Dibromochloroacetic 

acid 2.71E-02 2.66E-02 9.44E-03 2.48E-03 3.33E-04 

Dibromoacetonitrile 5.10E-02 5.00E-02 1.78E-02 4.67E-03 6.28E-04 

Bromate 0 0 0 0 0 

Sodium thiosulphate 7.96E+00 7.81E+00 2.78E+00 7.30E-01 9.79E-02 

8.3.4 Assessment of potential for bioaccumulation (G9:5.3.7) 

As the logarithm octanol/water partition coefficients (log Pow) of all Active Substances, 

Relevant Chemicals and Other Chemicals in the treated ballast water by BalClorTM BWMS 

are <3 and the BCFs of all chemicals are below 500 L/kg, the potential for bioaccumulation is 

not accessed in marine or freshwater organisms in accordance with G9:5.3.7. 

8.3.5 Effects assessment 

The toxicity data sets indicate that the risk of the Active Substances of HOCl is significant for 

most fresh water and saltwater predators (fish) and primary producer (alga) based on a 

chronic NOEC <0.01 mg/L. 

The ecological risk of the Relevant Chemicals to aquatic organisms is less than the risk from 

the Active Substances because much less chronic NOEC toxicity data are available. Chronic 

data of two trophic levels used in this dossier are available for tribromomethane and bromate 

to conclude that the compounds would not bring risk to predators and alga because all of 

the NOECs are 2-3 orders of magnitude above 0.01 mg/L. Likewise, one chronic crustaceans 
MEPC 61/2/4 

Annex, page 23 

I:\MEPC\61\2-4.doc 

value (1.6 mg/L) is available for monobromoacetic acid. An NOEC of 600 mg/L was found for 

fish exposed to sodium thiosulphate which indicates that the risk of sodium thiosulphate is 

negative. Because of the lack of a complete chronic database (i.e. one or more of the three 

chronic trophic levels used in this dossier are not available), a great deal of uncertainty exists 

for some of the THMs and HAAs. In addition, one must also consider the fact that it is 

unlikely that only one chemical will be discharged in the ballast water. Additional risks are 

likely when a mixture of the relevant chemicals is discharged. 

8.3.6 Effects on aquatic organisms 

In chemical testing, no potential ecotoxic substance was found in the treated water. 

Predicted No-Effect Concentrations (PNEC) values were calculated using the aquatic toxicity 

data set endpoints and the appropriate assessment factor. The calculation results are shown 

in Table 8-6. 

Table 8-6: PNEC for the Active Substances and Relevant Chemicals in fresh water 

and saltwater according to data set endpoint 

Chemical name Toxicity 

(mg/L) 

Information Assessment 

factor 

PNEC 

(mg/L) 

HOCl(NaOCl) 0.003 Lowest L(E)C50 from a fish, 

crustacean and alga and lowest 

NOEC from a algae, 

crustaceans and fish 

100 0.00003 

Chloramine 0.012 Lowest LC50 from a fish and 

crustacean 

1000 0.000012

Tribromomethane 4.8 Lowest L(E)C50 from a fish, 

crustacean and alga and Lowest 

NOEC from a algae and fish 

100 0.048 

Dibromochloromethane 3.2 Lowest L(E)C50 from a fish, 

crustacean and alga and Lowest 

NOEC from fish 

100 0.032 

Monobromoacetic acid 0.2 Lowest L(E)C50 from a 

crustacean and alga and Lowest 

NOEC from crustacean 

1000 0.0002 

Dibromoacetic acid 6.9 Lowest LC50 from a fish 1000 0.0069 

Tribromoacetic acid 6.9 PNEC was assumed to be the 

same value as that for 

dibromoacetic acid 

1000 0.0069 

Bromochloroacetic acid 6.9 PNEC was assumed to be the 

same value as that for 

dibromoacetic acid 

1000 0.0069 

Dibromochloroacetic acid 6.9 PNEC was assumed to be the 

same value as that for 

dibromoacetic acid 

1000 0.0069 

Dibromoacetonitrile 0.55 Lowest L(E)C50 from a fish, 

crustacean and alga 

1000 0.00055 

Bromate 8 Lowest L(E)C50 from a fish, 

crustacean and alga and Lowest 

NOEC from fish and alga 

100 0.08 

Sodium thiosulphate 64 Lowest L(E)C50 from a fish and 

alga and Lowest NOEC from 

fish 

1000 0.064 
MEPC 61/2/4 

Annex, page 24 

I:\MEPC\61\2-4.doc 

Risk to aquatic environment by chemicals in ballast water was carried out by calculating 

PEC/PNEC ratio. If PEC/PNEC ratio is less than or equal to 1, the chemical is of no 

immediate concern. In PEC/PNEC ratio is greater than 1, the substance should be of 

concern. Active Substances were not detected in treated ballast water so that risk 

assessment to aquatic environment for Active Substance was not considered. PNEC values 

are normally derived from short-term and/or long-term aquatic toxicity results for relevant 

aquatic species by dividing the lowest available effect concentration with an appropriate 

assessment factor. 

The PEC/PNEC calculated for chemicals are all less than 1, so the ballast water treated by 

BalClorTM BWMS has low potential risk for aquatic environment. Risk assessment results for 

aquatic environment are summarized in Table 8-7. 

Table 8-7: Risk assessment results for aquatic environment 

Chemicals PEC/PNEC 

Tribromomethane 0.00725 

Dibromochloromethane 0.00125 

Monobromoacetic acid 0.13250 

Dibromoacetic acid 0.04377 

Tribromoacetic acid 0.00542 

Bromochloroacetic acid 0.01800 

Dibromochloroacetic acid 0.00393 

Dibromoacetonitrile 0.09270 

Sodium thiosulphate 0.12440 

8.3.7 Effects on sediment 

As stated in section 5.1.4, the Koc values of all chemicals range from 2.7×10-8 to 468, which 

are smaller than 500 l/kg, which indicate that the chemicals will not readily partition to 

sediment and thus be of concern to benthic organisms residing in the sediment, so the risk to 

infaunal sediment organisms is low. 

8.3.8 Comparison of effect assessment with discharge toxicity 

The concentration of Active Substance, Relevant Chemicals and Other Chemicals in the 

ballast water were measured by analytical methods and the aquatic toxicity tests were 

conducted using the same ballast water. From the toxicity test results, no mortality and 

adverse effects were observed, so the toxic effects of the ballast water treated 

by BalClorTM BWMS to aquatic organisms would be low. 
MEPC 61/2/4 

Annex, page 25 

I:\MEPC\61\2-4.doc 

9 RISK ASSESSMENT 

9.1 Risk to safety of ship 

9.1.1 Flooding 

The BalClorTM BWMS is connected to the ship ballast piping system by hard rubber lined 

steel pipes, together with a number of electromagnetic and manual valves. The piping to 

connect the BWMS with ship ballast piping system is designed and arranged in accordance 

with the classification rules. The BWMS is so designed that in case of any failure of the 

components or function module, the system will be stopped automatically to isolate the 

BWMS from the ship ballast piping. Manual valves are also fitted in the system so that the 

BWMS can be closed by the manual valves if there is a failure of the automatic valves. 

9.1.2 Corrosion 

Further to the corrosion test on two kinds of low carbon steels, as reported in the application 

for Basic Approval, comprehensive corrosion testing has been conducted in accordance with 

the guidance provided in section 5.1 of the "Report of the eighth meeting of the 

GESAMP-BWWG" contained in document MEPC 59/2/16. 

The corrosion tests include two kinds of low carbon steels, i.e. stainless steel and Cu alloy 

respectively, and the test on one non-metal. In addition, corrosion of marine epoxy-coated 

steel and the coating properties of the specimens exposed to the treated water were also 

tested. The test duration was six months. All the tests have completed except the long-term 

test on stainless steel and Cu alloy. The full corrosion testing reports are provided in 

appendix 5 to the confidential dossier. Based on these tests the following conclusions were 

obtained: 

- For uncoated steel exposure, the corrosion rates of bare steels were tested 

using the method of mass loss. No localized corrosion was found on the 

samples of 360 steel and CCS B steel both in the treated water and in the 

control water. The corrosion tests show that the corrosion morphology of the 

bare samples subjected to the treated water are same with those subjected to 

natural seawater, i.e. all are uniform corrosion. The results of corrosion rate 

calculation indicate that the corrosion rate of the bare steels in the ballast water 

treated by BalClorTM BWMS is at the similar level with that of the steels in 

nature seawater. 

- Regarding coated steel, the corrosion rating of coated specimens was 

evaluated in accordance with the rule of ASTM D1654-08. While the corrosion 

rating of the specimen exposed in natural seawater was rating 7, the rating of 

the specimen in the treated seawater was rating 8. That implies that the 

corrosion on the coated specimens exposed in the treated water is lighter than 

that in natural seawater. 

- The effect of the treated water on the epoxy painted specimens was tested, 

and no significant difference was found in coating properties compared to 

natural seawater. 

- The effect of the treated water on non-metal was evaluated, and Nitrile 

butadiene rubber (NBR, gasket material) was used for testing. The results 

show that the main properties of NBR immersed in treated water for six months 

was at the similar level to that immersed in natural seawater. 
MEPC 61/2/4 

Annex, page 26 

I:\MEPC\61\2-4.doc 

- For steel and Cu alloy, the interim report on corrosion testing was included in 

the application dossier based on the results of two months exposure. 

Long-term testing was still ongoing at the time of submission for Final Approval, 

and the final report will be submitted as part of Type Approval requirements. 

9.1.3 Fire and explosion 

The only chemical carried on board is sodium thiosulfate for neutralizing residual TRO during 

de-ballasting. The solution is stored in a sealed PVC container, which is neither flammable 

nor explosive. 

9.1.4 Hydrogen gas and Chlorine gas 

Hydrogen gas 

Hydrogen gas is generated during the electrolytic process. Theoretically, under the condition 

of the TRO concentration of 9.5 mg/L (the maximum allowable dosage of TRO), 133.8 mol of 

hydrogen gas (H2) is generated in the electrolyzed water with concentrated TRO for 

treating 1,000 tonnes of ballast water, which equals 267.6 g. 

The electrolysed water entraining H2 gas flows into the degas tank. H2 gas is fully separated 

inside the tank, and diluted by air blowers to the level below Lower Explosive Limit (LEL). 

Then, the diluted gas is released overboard. A spark arrestor is fitted on the discharge end of 

vent pipe. 

Rated air flow of the blowers is calculated according to the relevant specifications to ensure 

that the volume of air provided is adequate to dilute H2 gas to the level below LEL. 

Considering it is important to supply air continuously, two air blowers are fitted in the degas 

unit. Should the one in operation fail, another will continue to operate automatically. As a 

further safety measure, an air pressure sensor is installed at the discharge side of the 

blowers, and the sensor will send an acousto-optic alarm if air supply is insufficient. The air 

blower will continue to work for 10 minutes after electrolytic process finishes. 

During the land-based type approval tests, H2 gas was monitored. No hydrogen gas was 

ever detected in the area around the electrolytic unit or in the headspace of treated tank 

throughout the electrolytic process. The concentration of hydrogen gas measured near the 

outlet of the vent pipe of degas tank was not higher than 0.28 v/v % during the whole 

electrolytic process, and then it went down to below 0.04 v/v % two hours after completion of 

the electrolytic process. 

The technology for venting hydrogen gas has been employed by Sunrui Company in the 

design and manufacture in relation to electrolytic process for several hundreds of the 

installations either on board (sewage water treatment system by electrolytic method) or in 

land-based systems (anti-fouling of seawater cooling system). These installations have been 

in operation safely and reliably for many years. 

Chlorine gas 

The chlorine gas produced by electrolysis dissolves into seawater rapidly, generating active 

substances (TRO). The short-term exposure limit of chlorine gas is known to be 1 mg/m3

(MSDS, approximately 0.78 ppm). Under normal operation, there is no leakage of chlorine 

gas from the BWMS. During land-based type approval tests, no chlorine gas was detected in 

the area around the electrolytic unit. The concentration of chlorine gas measured in the 
MEPC 61/2/4 

Annex, page 27 

I:\MEPC\61\2-4.doc 

headspace of treated tank was not higher than 0.3 mg/m3 during the whole electrolytic 

treatment, and after that it clears away rapidly. 

To monitor the accidental leakage of hydrogen gas and chlorine gas, sensors and alarms are 

included in the BWMS to detect any leakage online. Acousto-optic alarms will be sent when 

the concentrations of H2 and Cl2 exceed 2 v/v % and 0.4 ppm, respectively. If the 

concentrations of H2 and Cl2 exceed 3 v/v % and 0.55 ppm, respectively, the electrolytic units 

will be immediately shut down automatically. Meanwhile, air blowers will keep ventilation 

continuous to dilute H2 to the level below Lower Explosive Limit. 

When there is an alarm signal, relevant information and instructions on the remedy measures 

will be shown on the human-machine interface (HMI). 

9.1.5 Storage and handling of the substances 

The only chemical substance carried on board is sodium thiosulfate. The substance is widely 

used in dechlorination in water, such as halt bleaching in the paper-making industry. It is also 

used in smelting silver ore, in producing leather goods and to set dyes in textiles. Sodium 

thiosulfate is also used to fix black and white photography negatives after the developing 

stage. 

Sodium thiosulfate is kept in a tightly closed container, stored in a cool, dry, ventilated area; 

therefore, there is no any risk to the safety of ships during storage and handling. 

When the sodium thiosulfate is handled and mixed by crew, it is required that the operators 

should wear neoprene or rubber gloves and other protective clothing, wear safety glasses or 

chemical goggles with face shield and wear respirator. Safety procedure for handling of 

sodium thiosulfate is detailed in "Technical Specification and Manual", in appendix 11 of the 

confidential application dossier. 

9.1.6 Noise 

The BalClorTM BWMS operates in engine room of ships using standard pumps and valves 

that meet relevant specifications. The noise of BalClorTM BWMS in operation was tested in 

accordance with the relevant specifications of the Class, and confirmed to remain within the 

permitted levels. 

9.2 Risks to human health 

9.2.1 Introduction 

The assessment on potential risks of ballast water treated by the BalClorTM BWMS was 

carried out by China Classification Society (CCS) together with the applicant in accordance 

with the IMO Methodology for Information gathering and conduct of work of the 

GESAMP-BWWG contained in BWM.2/Circ.13. 

The human health risk assessment of the BalClorTM BWMS includes assessment of risks to 

human health due to potential exposure of crew, dock workers and PSC inspectors to 

chemicals associated with BalClorTM BWMS during normal operation and in accident 

situations, as well as general public exposure to the discharge treated ballast water. The full 

assessment report is provided in appendix 10 of the confidential dossier. 
MEPC 61/2/4 

Annex, page 28 

I:\MEPC\61\2-4.doc 

9.2.2 Occupational exposure (HES) and quantitative risk evaluation 

As recommended by the GESAMP-BWWG, identification/description of the unit operations 

associated with BalClorTM BWMS has been carried out as a basic step to identify which 

individual system component is likely to lead to human exposure to the BWMS related 

chemicals. Each unit was assessed for the potential risk of human exposure to the BWMS 

related chemical substances. 

The BalClorTM BWMS is designed to operate automatically, and under normal operating 

conditions, the system is to be considered as a closed system, therefore, the crew's 

exposure to the treated water is highly unlikely. 

During ballasting, the air in the empty ballast tanks will gradually be vented out of the tanks 

as the air is replaced by the rising water. The air can contain chemical substances found in 

the ballast water that could imply a health risk if inhaled. Crew on deck can be exposed to 

the vented tank air. To minimize the exposure to the vented tank air, crew should avoid 

staying in the area near to the vent heads when the BWMS is operating. 

Although it is considered to be highly unlikely, crew or dock workers could have contact with 

treated ballast water during maintenance and sediment cleaning in ballast tanks. Ship's crew 

and PSC officers could have contact with treated ballast water when sampling during 

discharge. 

Following the identification of operation units in BalClorTM BWMS, the occupational exposure 

to chemicals associated with the system was assessed for the following HES assumptions: 

 - carrying out work on deck near to the vent heads of ballast tanks; 

 - entering ballast tanks for cleaning or maintenance; and 

 - sampling from the BWMS at discharge. 

All routes of exposure were thoroughly evaluated based on very conservative assumptions, 

and the calculated results show that there is no unacceptable risk to human health, without 

consideration of wearing personal protective equipment (PPE). Therefore, it is not necessary 

for the crew to wear PPE as a routine when working on deck. Notwithstanding, to minimize 

the potential risk, PPE is recommended when people enter empty ballast tanks for cleaning, 

maintenance or sampling. 

Human risk in accident situations was also addressed. Though human exposure to TRO or 

neutralizer due to accidental leakage is considered to be highly unlikely, safety precautions 

and mitigating measures are provided to protect the crew in case of any incident (refer to the 

full assessment report in the confidential dossier). 

9.2.3 General public/human exposure via environment 

The following two scenarios are identified as possible scenarios of exposure to the general 

population through environment and food chain: 

- exposure to sea bathers in surrounding areas (oral, inhalational or dermal 

exposure by way of bathing in areas near the harbours); and 

- exposure to the general population through the food chain (oral intake by way 

of marine foods). 
MEPC 61/2/4 

Annex, page 29 

I:\MEPC\61\2-4.doc 

As worst scenarios, the calculation results for human health risk to general public via 

swimming near port (oral route) and through eating marine food from the ballast water 

discharge areas are listed in Tables 9-6 and 9-7. 

Table 9-6: MRR values for seawater ingestion during swimming 

Chemical MOS MOSref MRR(MOS/MOSref) 

Tribromomethane 1.724 E+05 100 1.724 E+03 

Dibromochloromethane 1.8 E+06 100 1.8 E+04 

Monobromoacetic acid 3.182 E+05 100 3.182 E+03 

Bromochloroacetic acid 2.51 E+05 100 2.51 E+03 

Dibromoacetic acid 3.18 E+04 100 3.18 E+02 

Dibromochloroacetic 

acid 

3.23 E+06 100 3.23 E+04 

Tribromoacetic acid 2.34 E+06 100 2.34 E+04 

Dibromoacetonitrile 5.22 E+04 100 5.22 E+02 

Sodium thiosulphate 1.206 E+05 100 1.206 E+03 

Table 9-7: Calculated MRR(MOS/MOSref) values 

(Human health risk via eating marine food from the ballast water discharge areas) 

Chemical MOS MOSref MRR(MOS/MOSref) 

Tribromomethane 2.68E+04 100 2.68 E+02 

Dibromochloromethane 2.67E+06 100 2.67E+04 

Monobromoacetic acid 2.15E+05 100 2.15E+03 

Bromochloroacetic acid 1.71E+05 100 1.71E+03 

Dibromoacetic acid 4.07E+05 100 4.07E+03 

Dibromochloroacetic acid 2.225E+06 100 2.225E+04 

Stribromoacetic acid 8.075E+06 100 8.075E+04 

Dibromoacetonitrile 4.44E+04 100 4.44E+02 

Sodium thiosulphate 8.28 E+04 100 8.28 E+02 

As shown in the above tables, all MRR values are much higher than 1, it can be judged that 

there is no unacceptable risk to the general public.

9.3 Risks to the aquatic environment 

Risk to aquatic environment by chemicals in ballast water was carried out by calculating 

PEC/PNEC ratio. If PEC/PNEC ratio is less than or equals to 1, the chemical is of no 

immediate concern. If PEC/PNEC ratio is greater than 1, the substance should be of 

concern. 

The PEC/PNEC calculated for chemicals are all less than 1, so the ballast water treated 

by BalClorTM BWMS of Sunrui Company has low potential risk for aquatic environment. 

Detailed results are shown in section 8.3.6. 
MEPC 61/2/4 

Annex, page 30 

I:\MEPC\61\2-4.doc 

10 ASSESSMENT REPORT (G9: 4.3) 

10.1 Test report data quality 

The ballast water treated by BalClorTM BWMS have been tested by the following 

organizations in accordance with the relevant international recognized guidelines, and the 

data obtained from the testing were used in the dossier for the application of Final Approval: 

.1 Aquatic toxicity tests were conducted by Supervision and Test Center 

for Pesticide Safety Evaluation and Quality Control (PSEC) in Shenyang. 

PSEC is accredited for toxicological safety evaluations of drugs, 

pesticides, and other fine chemicals by the Ministry of Agriculture of 

the People's Republic of China. 

.2 The chemical analysis was performed by PONY Testing International Group 

in Qingdao and Beijing laboratory (PONY TEST). 

.3 The measuring of environmental parameters of the seawater and the 

physical and chemical properties of the treated ballast water were carried 

out by the Centre of Marine Environmental Measurement, the First Institute 

of Oceanography, State Oceanic Administration. 

.4 The corrosion tests were conducted by Qingdao Laboratory, Xiamen 

Laboratory and Luoyang Laboratory of Testing and Verifying Centre 

for Ship Materials of China Shipbuilding Industry (TCSI), respectively. TCSI 

is a famous organization on corrosion test in China. In 2002, the TCSI 

obtained accreditation of China Class Society (CCS). 

The above four organizations are accredited by China National Accreditation Service 

for Conformity Assessment (CNAS, eqv. to ISO/IEC 17025) and China Metrology 

Accreditation (CMA). And PSEC is registered as a GLP laboratory in China and run in 

accordance with the requirements of GLP lab. 

These organizations are all qualified testing organizations, and have their own 

Quality Management Plan (QMP). The testing plans and QAPPs were developed and strictly 

followed through the testing. 
MEPC 61/2/4 

Annex, page 31 

I:\MEPC\61\2-4.doc 

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