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

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

INTERNATIONAL MARITIME ORGANIZATION

IMO 

# E

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

HARMFUL AQUATIC ORGANI SMS IN BALLAST WATER

Application for Basic Approval of the Blue Ocean Shield Ballast Water Management System

Submitted by China

SUMMARY

Executive summary: This document contains the non-co nfidential information regarding the application for Basic Approval of the Blue Ocean Shield Ballast Water Management System in acc ordance 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 dossier has been submitted to IMO for review by the GESAMP-Ballast Water Working Group.

Strategic direction: 7.1

High-level action: 7.1.2

Planned output: 7.1.2.4

Action to be taken: Paragraph 5

Related documents: BWM/CONF/36; MEPC 57/21; BW M.2/Circ.13 and BWM.2/Circ.15

Introduction

1 Regulation D-3.2 of the Inte rnational Convention for th e 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 IMO on the basis of the procedure de veloped by the Organization.

2 This document contains the non-confidentia l information related to the application for Basic Approval of the Blue Ocean Shield Ballast Water Management System in accordance with the “Procedure for approval of ballast water management systems that make use of Active Substances (G9)”.MEPC 59/2/2 - 2 -

I:\MEPC\59\2-2.doc 3 The competent authority of China has verified the appli cation dossier of the Blue Ocean Shield Ballast Water Management System, and believes it satisfies the data requirements of Procedure (G9).

4 Therefore, China submits the non-confidentia l part of the manufacturer’s application
dossier in the annex of this document to th e Organization for evaluation in accordance with 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

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

***MEPC 59/2/2

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

NON-CONFIDENTIAL INFORMATION ON THE BLUE OCEAN SHIELD BALLAST WATER MANAGEMENT SYSTEM (CHINA)

Table of Contents

1 INTRODUCTION

1.1 Working Principles of the Blue Ocean Shield Ballast Water Management System 1.2 Technology overview

2 DESCRIPTION OF THE BLUE OCEAN SHIELD SYSTEM

2.1 Description of the Blue Ocean Shield system and its components 2.2 Description of pilot scale test system used for Basic Approval

3 DEFINITIONS

4 ACTIVE SUBSTANCE AND OTHER CHEMICALS

4.1 Active Substance
4.2 Other Chemicals

5 RISK CHARACTERIZATIONS

5.1 Screening for persistency, bioaccumulation and toxicity 5.2 Acute toxicity testing of the treated ballast water 5.3 Risk characterization and analysis

6 RISK TO SAFETY OF SHIP AND HUMAN HEALTH

6.1 Safety Instructions 6.2 Regulation of the use of Active Substances 6.3 Risks for safety of ship

7 ASSESSMENT REPORT

8 CONCLUSIONS

REFERENCES

APPENDIX

− ACUTE TOXICITY TESTING DATA OF THE TREATED BALLAST WATERMEPC 59/2/2

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I:\MEPC\59\2-2.doc This application is prepared in accordance w ith the “Procedure for Approval of Ballast Water Management systems that make use of Ac tive Substances (G9)” and the Methodology for information gathering and the conduc t of work of the GESAMP-BWWG.

1 INTRODUCTION

1.1 Working Principles of the Blue Ocea n Shield Ballast Water Management System

China Ocean Shipping (Group) Company (COSCO) ha s joined forces with Tsinghua University to develop a modular ballast water management sy stem (Blue Ocean Shield ) that operates in-line during the uptake and discharge of ballast wate r. Prior to UV treatment, a filter system specifically designed for ballast water applications will significantly reduce the sediment load of the ballast water, as well as remove some micro- organisms. The filtration system is installed on the discharge side of the ballast water pumps and is fully automatic in terms of its operation in cleaning. This does not, however, af fect the treatment process and the flushing water is returned to the sea. The UV unit employs low-pressure, hi gh output ultra violet (L PUV) lamps to destroy living micro-organisms present in the ballast water.

Ballast water is treated at intake and once agai n at discharge. The treatment on intake ensures that a minimal amount of viable organisms ente r the ballast water tank s and reduces sediment built-up in the tanks, which is a potential area for the survival of organisms. The water is treated again at discharge only by the UV system to ensure that the potential re-growth of organisms in
the ballast water tanks is decr eased as much as possible.

1.2 Technology overview

UV technologies have become attractive options fo r water disinfection proc esses as they address increasing concerns regarding the inactivation of Cryptosporidium parvum and Giardia lamblia ( Clancy et al. , 2000). UV disinfection effec tively deactivates and dest roys both bacteria and viruses. Moreover, it does not form any disinf ection by-products under regul ar disinfection doses (Chang, J.C.H. et al. 1985; Hijnen, W. A. M. et al. 2006). Therefore, UV disinfection is a feasible technique for ballast water treatment. However, the chemicals in seawater are more complex than those in municipal drinking water and wastewater. UV irradi ation also plays a key role in effectively decomposing the micro-polluta nts in waters in advanced oxidation process, such as NDMA (Carstenk et al. , 2008), Metolachlor (Ruth et al. , 2000), naphthalene (Beltran, 1995), atrazine (Beltran et al. , 1997), diazinon (Doong and Chang, 1998), and carbaryl (Patterson et al. , 1998). Accordingly, concerns have emerged regarding UV irradiation’s production of by-products in ballast water disinfection.

Irradiation with UV light is highly effective and ha s been used for decades to reduce or eliminate various micro-organisms. The inactivation mech anism involves absorption of ultraviolet light by DNA or RNA pyrimidine bases thymine or cyto sine in DNA and uracil or cytosine in RNA causing a photochemical reaction in which a chemical dimmer is formed between the two bases.
The dimmer inhibits the formation of new DNA or RNA chains in the process of cell replication mycosis, thus resulting in the a ffected micro-organism’s inactiva tion of the abilit y to replicate (Bolton et al. , 2003).MEPC 59/2/2

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I:\MEPC\59\2-2.doc For ballast water, UV light tec hnologies have been successful in the laboratory and on a larger scale. However, if the improperly “treated wate r” stays in the open air tank, the water’s state must be considered as re-growth has been report ed after UV treatments. To solve this problem, the ballast water is treated by the UV system ag ain during deballasting. A nother critical problem with LPUV is photorepair afte r exposure to LPUV (Sanz et al. , 2007); no significant photorepair has been reported from using LPUV in a dark environment. Treating the ballast water again during deballasting can eliminat e the problem of photorepair.

A summary of the specific advantages of th e LPUV-based ballast water management is as
follows:

.1 UV is the most environmentally friend ly way to reduce the number of viable micro-organisms without polluti ng the local seawater ecology.

.2 No by-products are formed under regular disinfection doses.

.3 The process requires little main tenance and is easy to handle.

.4 Involves minimum operating cost s and maximum operating safety.

.5 The process do not increase the corrosion rate of ballast tank.

2 DESCRIPTION OF THE BLU E OCEAN SHIELD SYSTEM

2.1 Description of the Blue Ocean Shield system and its components

The Blue Ocean Shield system is a complete system, composing of four main functions.

Hydrocyclone : removes most of larger or heavier particles.

Hydrocyclone is a device used to separate particles in a liquid suspension based on the density and size of the partic les. Hydrocyclones have a cylindrical section at the top, where liquid enters the unit, and a conical base. The particular Blue Ocean Shield hydrocyclone units have three exits: a sm all one on the bottom (weighty particles, underflow), a smaller exit at the top (lighter pa rticles, overflow) and a larger exit in the middle (middle flow). In the treatment pro cess, centrifugal force moves larger, weighty particles to the bottom exit a nd light particles to the top.

Parameters of hydrocyclone unit:

Flow rate: 250 m 3 /hr

Working pressure: 0.8 bar

Maximum working pressure: 10 bar

Material: SS 316LMEPC 59/2/2

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I:\MEPC\59\2-2.doc Figure 1: Picture of Hydrocyclone system

Filter :

The filter is a device used to separate solid particles by size. In the Blue Ocean Shield system, multiple element tubular filter units with accessorial filtration are used. The ship’s high-pressure gas can be automa tically used by filter s on cleaning function,
which had more than two filter units installed at the same time in order to meet with uninterrupted water supply. Filter impurities fr om the ship arise through the discharge pipe into the water at the original port.

Parameters of filter unit:

Flow rate: 250 m 3 /hr

Filtration degree: 50 micron

Working pressure: 2.0 bar

Maximum working pressure: 10 bar

Automatic cleaning

Material

- Filter housing: SS 316L

- Filter screen: seawater-fast materialMEPC 59/2/2

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I:\MEPC\59\2-2.doc Figure 2: Picture of Filter system

UV disinfection :

No substances are added to the process. Removes most micro-organisms and algae smaller than 50 μm.

Flow rate: 250 m 3 /hr

Low pressure UV lamps

Material: SS 316L

Maximum dose: 300 mJ/cm 2

Automatic washing wiper for quartz sleeves

Figure 3: Picture of UV systemMEPC 59/2/2

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I:\MEPC\59\2-2.doc Control and auxiliary equipment : including sampling points.

The control system and transformer control the system and supply all components with power. The auxiliary equipment controls the flow and measures di fferent alarm levels.

Figure 4: Picture of control system

The Blue Ocean Shield system may be run in di fferent configurations depending on the level of treatment required and the particular propert ies of the ballast water. For example:

- Hydrocyclone /Filter / UV

- Filter / UV

The Blue Ocean Shield can be viewed as flexib le and modular, and can be applied in different configurations for different end user requirements.

This application will focus on the UV treatment un it, as this is the only component involving the
use of Active Substances.

Figure 5: Flow diagram of Blue Ocean shield systemMEPC 59/2/2

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I:\MEPC\59\2-2.doc 2.2 Description of pilot scale test system used for Basic Approval

In order to confirm and justify this system, the applicant has developed a pilot scale system and systematic experiments were performed us ing “treated water” and raw seawater.

The UV unit employs low-pressure, high-output ul tra violet (LPUV) lamps to destroy living micro-organisms present in the liquid being tr eated. During deballasting, the ballast water is treated again by the UV unit to de stroy any organisms which may have re-grown in the tanks during the voyage. The balla st water management system used fo r the pilot test consists of a UV unit and a monitoring and control panel. The maximum flow rate designed for the pilot system
is 2 m 3 /hr. The UV doses used for acute and mutagenicity toxicity are 100 mJ/cm 2

and 300 mJ/cm 2 . For other tests, the UV dose range is from 37 to 1990 mJ/cm 2

.

The test strategy is as follows:

- Basic Characteristics Testing: to investig ate any change in the seawater before and after treatment, the basic characteristic s (i.e., ions, TOC, UV absorbance scanning, and SUVA) of seawater are compar ed with the “treated water”.

- By-products formation testing: to inves tigate the possib ility of the formation of harmful halogenated organics and inorganics.

- Toxicity Testing: to investigate the acute toxicity for sea water before and after UV system.

The seawater (DOC=8.1mg/L; SS=7.0 mg/L) transpor ted to the laboratory wi ll be treated twice by the model Blue Ocean Shield ballast water tr eatment system. The control sample will not be treated by the water treatment system. Part of control sample and treated water will be used for the test immediately.

The results of biological efficacy testing of the Ballast Water Management System showed that the system has met the standard in regulation D-2 of the C onvention in all test cycles.

3 DEFINITIONS

3.1 In the Blue Ocean Shield ballast water management system, the UV process produces a “photon” as the only “Active Substance”, which is responsible for inactivating all harmful aquatic micro-organisms and pathogens present in the ballast water.

3.2 For the Blue Ocean Shield system, “ballast water discharge” is the treated ballast water that has passed the UV unit twice, duri ng ballasting and deba llasting, respectively.

3.3 The Blue Ocean Shield ballast water manage ment system does not intentionally add any “preparation” besides UV light.

3.4 The Blue Ocean Shield ballast water management system does not produce any
“relevant chemical”.

LPUV lamps are traditionally used in UV disi nfection and emit monochromatic UV radiation at 254 nm, which is close to the optimum germicidal wavelength of 260 nm. Medium-pressure UV (MPUV) lamps were deve loped in the last decade and emit a broadMEPC 59/2/2

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I:\MEPC\59\2-2.doc spectrum of wavelengths in the UV radiation region ranging from 200 to 400 nm. Puay et al., 2008) Therefore, LPUV cannot form any “relevant chemical,” such as hydroxyl radical, for the hydroxyl radical only form under some wavelengths not including 254 nm (Pamela et al. , 1998).

4 ACTIVE SUBSTANCE AND OTHER CHEMICALS

4.1 Active Substance

The LPUV-based system deems photons the only Active Substa nce available to kill and inactivate micro-organisms. The de finition of “photon” is a partic le of electromagnetic radiation that travels at the speed of light, used to ex plain phenomena that requir e light to behave as particles rather than as waves. As the photons are only available upon turning on the LPUV lamp, there must be no residual photons in both the “b allast water” and “bal last water discharge”.

As there is no current, the photon has no chance of being exposed to aquatic plants, invertebrates, fish, and other biota, in cluding sensitive and representative mi cro-organisms. Therefore, all tests for effects on aquatic plants, invertebrates, fish, and other biota, including sensitive and representative micro-organisms, ar e “not applicable” due to the non-residual characteristics of the photon.

Since the photons generated in the LPUV reactor are never exposed to the mammalian, all tests for effects on mammalian are “not applicable”.

A photon reacts with organics at a relatively slow rate and the re action rate is de pendant on the chemical properties of matter, su ch as quantum yield, molar extin ction coefficient, and photolysis fraction (Bolton, 2001). For the cas e of DOC, a significantly high UV dose is required for its reduction (Buchanan et al. , 2006).

The applied UV dose in the LPUV system is 300 mJ/cm 2 in the maximum condition, as it is too small to break down any dissolved organics. Buchanan et al. (2006) reported that more than 10,000 mJ/cm 2 is required for just a 5% reduction of DOC.

The physical and chemical properties of photon are showed in Table 1.MEPC 59/2/2

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I:\MEPC\59\2-2.doc Table 1: Physical and chemical properties for the Active Substance, Preparations and treated ballast water

Physical property Active Substance (Photon)

CAS number

–

Molecular weight (g/Mol)

–

Melting point (°C) N.A.

Boiling point (°C) N.A.

Flash point (°C) N.A.

Density (g/mL at 20°C) N.A.

Vapour pressure (Pa at 20°C) N.A.

Vapour Density (air=1) N.A.

Water solubility/dissociation N.A.

constant (pKa) N.A.

pH

–

Octanol/water partition coefficient(log Pow) N.A.

Oxidation/reduction potential (V) N.A.

Corrosivity to the materials N.A.

Autoignition temperature (°C) N.A.

Explosive properties N.A.

Oxidizing properties N.A.

Surface tension (N/mm at -183°C) N.A.

Viscosity (Pa.s at -183°C) N.A.

Thermal stability and identity of relevant breakdown products N.A.

Other known relevant physical or chemical hazards N.A.

N.A.: Not applicable.

4.2 Other Chemicals

According to Procedure (G9), when the proces ses may produce by-products not deemed to be “Relevant Chemicals” by the applicant, a justif ication for such a conclusion should be provided.

Of the DBPs (disinfection by-pr oducts) directly formed in UV irradiation processes, aldehydes and carboxylic acids are two classe s of organic oxidation by-products that have been observed in several studies pertaining to water treatment . Individual aldehydes of interest include formaldehyde, acetaldehyde, glyoxal, and methyl-gl yoxal. Carboxylic acids of interest includeMEPC 59/2/2

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I:\MEPC\59\2-2.doc formic acid (as formate), acetic acid (as acetat e), and oxalate acid (as oxalate). These compounds have typically been observed in the highest concentrations relative to other aldehyde and carboxylic acid by-products (Liu et al. , 2002).

If the dose is high enough, the UV-based system may produce other chemicals such as aldehydes and carboxylic acids, THMs, HAAs, a nd other halogenated organics. The results of the chemical
test for the model Blue Ocean Shield ballast water treatment system showed no concentration changes before or after UV irradiati on when the doses were under 300mJ/cm 2 , confirming literature stating chemicals might be produced by UV.

Pilot testing results indicated that UV did not have a signifi cant impact on most chemicals (Table 2). For CHCl 3 and TTHMs (CHCl 3 is a composition of TTHMs), there was little increase after UV (from undetectable to 3 μg /l when the UV dose is 406 mJ/cm 2 ), but is a safety value for the EPA drinking water regulation which sugge sts 80 μg/L (USEPA, 20 03) and WHO drinking water regulation which suggests 300 μg/L (WHO, 2006).MEPC 59/2/2

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I:\MEPC\59\2-2.doc Table 2: The impact of UV on the chemical in seawater

Parameter/UV

dose mJ/cm 2 0 60 97 156 252 406 1234 1990 LOD *

F- mg/L 0.67 0.65 0.68 0.73 0.68 0.68 0.68 0.68 0.01

Cl- g/L 14.5 14.6 14.5 14.6 14.5 14.7 14.6 14.7 0.1

Nitrate (as N) mg/L 4 5 4 5 5 5 5 4 1

SO 4 2- g/L 1.69 1.7 1.69 1.67 1.68 1.68 1.67 1.7 0.01

Br- mg/L 60.8 61 60.8 61.2 60.7 60.9 61.1 61.4 0.1

CO 3 2- mg/L 7.48 6.23 6.23 6.23 6.23 8.1 7.48 6.23 0.01

HCO 3 - mg/L 151 152 149 152 146 148 152 146 1

NH 3 -N mg/L 0.41 0.35 0.3 0.33 0.37 0.4 0.39 0.27 0.01

Nitrite mg/L 0.04 0.044 0.049 0.046 0.038 0.043 0.037 0.051 0.001

PO 4 3- mg/L 0.028 0.069 0.11 0.11 0.04 0.14 0.12 0.042 0.001

CN - mg/L UD UD UD UD UD UD UD UD 0.001

S 2- mg/L UD UD UD UD UD UD UD UD 0.001

TP mg/L 0.18 0.19 0.18 0.18 0.34 0.2 0.2 0.28 0.01

Organic nitrogen mg/L 0.28 0.35 0.38 0.32 0.3 0.27 0.24 0.47 0.01

Total nitrogen mg/L 4.5 6.24 4.94 5.66 6.1 5.48 5.6 5.16 0.01

chlorite mg/L 0.4 0.4 0.35 0.24 0.3 0.43 0.42 0.41 0.01

chlorate mg/L 3.19 3.67 2.76 2.68 2.79 3.16 2.7 2.87 0.01

Formaldehyde mg/L UD UD UD UD UD UD UD UD 0.01

Aldehyde mg/L 2.85 4.38 3.5 2.28 2.72 1.88 1.62 2.01 0.01

CHCl 3 μg/l UD UD 2 2 2 3 5 6 1

CHBr 2 Cl μg/l UD UD UD UD UD UD UD UD 1

CHBrCl 2 μg/l UD UD UD UD UD UD UD UD 1

CHBr 3 μg/l UD UD UD UD UD UD UD UD 1

TTHMs μg/l UD UD 2 2 2 3 5 6 1

MCAA μg/l UD UD UD UD UD UD UD UD 2

DCAA μg/l 2 2 2 2 2 2 2 8 2

MBAA μg/l 2 2 UD UD UD UD UD 4 2

TCAA μg/l 2 2 UD UD UD UD UD 4 2

BCAA μg/l 8 8 8 10 10 8 12 12 2

BDCAA μg/l 2 2 2 UD UD UD UD 4 2

DBAA μg/l UD UD UD UD UD UD UD UD 2

CDBAA μg/l UD UD UD UD UD UD UD UD 2

* UD means undetected

* LOD: Limit of Detection (SD*3.14, n=7) = MDL (method detection limit)MEPC 59/2/2

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

Internationally recognized associations, such as the International UV Association (IUVA), guarantee that water treatment by UV irradiation is a clean pro cess. The IUVA describes the UV technology as shown below:

Since UV is light, it travels through air and water at the speed of light, and when the UV source is turned off, the UV is gone. There are no residu als and the water that has been exposed to UV is in the same state as before exposure, and ther efore not radioactive. UV water disinfection units are designed to provide enough of a UV dose so that any pathogenic micro-organisms in the
water are rendered inactive. The UV is absorbed by the DNA in micro-organisms and the DNA is damaged so that the organisms cannot reprod uce. Cells that cannot reproduce cannot cause
disease. The most noted benefit of UV is that it purifies while the wa ter is passing through the unit, but after the water is disinfected, the quality does not changed. ( http://www.iuva.org/public/faqs.php )

5.1 Screening for persistency, bioaccumulation and toxicity

.1 Persistence tests

The half-life of the “Active Substance” (phot on) is extremely short. As referred to
in the criteria for identification of PBT substances (see the table in section 6.4.1 of Procedure (G9)), the “Active Substanc e” (photon) produced from the LPUV are not regarded as the PBT substance. Ther efore, the assessme nt of PBT does not

seem necessary.

.2 Bioaccumulation tests

The potential for bioaccumulation of the treated water is assessed by the measurement of possible changes in the octanol/water partition values of the
treated water. The LPUV did not cha nge the physical a nd chemical quality of seawater (refer to section 4.2) . Therefore, the assessment of bioaccumulation/biomagnification/ bioc oncentration does not seem necessary.

.3 Toxicity tests

No significant toxic effects have been detected, even using 100% treated ballast water. Solely physical ba llast water treatment met hods such as filtration, centrifugation, ultravio let irradiation, and oxygen stripping are assumed to not require toxicity testing.

Through Ames testing and a complete analys is of the organic matter, the effluent would not be expected to be toxic to aqua tic organisms or have negative effects on ecological communities at environmentally relevant concentrations.MEPC 59/2/2

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I:\MEPC\59\2-2.doc 5.2 Acute toxicity testing of the treated ballast water

Premnas biaculeatus, Artemia Salina and Skeletonema costatum were chosen as the challenge organisms for acute toxicity testing. The results s how that no acute toxicity was observed in the 100% treated ballast water (Table 3 and appendix).

Premnas biaculeatus , distributed widely in the Indian Ocean and the Pacific Ocean, is the preferred species for toxicity testing to assess possible risks for the environment since it is a sensitive indicator specie s and the bodyweight of Premnas biaculeatus is <3.0 g, which meets the requirement of USEPA test guideline.

Artemia Salina belongs to Arthropoda-Crustacea-Bran chiopoda-Anostraca, and is distributed widely in high salt water areas of all over the world. Artemia Salina feeds primarily on zooplankton and phytoplankton and is also consumed by many other aquatic organisms, such as fish. Therefore, Artemia Salina plays an important role in the food chain of high salt water areas, as well as belonging to the second trophic leve l animal, a requirement of Procedure (G9).

Species of algae recommended by USEPA as test or ganisms for the algae acute toxicity test are the freshwater green alga, S.capricornutum (or R. subcapitata ), the marine diatom, S. costatum, the freshwater diatom, N. pelliculosa , and the blue-green alga or cyanobacterium. In the ballast water acute toxicity test, S. costatum was selected for the test system, meeting the requirement of Procedure (G9) and USEPA test guidelines.

Table 3: The acute toxicity testing of the treated ballast water

Results Trophic

level Species method endpoint 100
mJ/cm 2 300
mJ/cm 2 Reference

Fish Premnas
biaculeatus OECD 202 NOEC/96h 100% 100% (PSEC 2008 report E083420068)

Invertebrates Artemia
Salina OECD 203 NOEC/96h 100% 100% (PSEC 2008 report E083490078)

Algae Skeletonem

a costatum OECD 201 IrC 50 /96h 100% 100% (PSEC 2008 report E085480018)

5.3 Risk characterization and analysis

This process does not involve the addition of a ny chemicals. The potential for bioaccumulation of the treated water was assessed by the measur ement of possible (if any) changes in the octanol/water partition values of the treated wa ter. The LPUV did not change the physical and chemical quality of seawater (sectio n 4.2). Therefore, the assessment of bioaccumulation/biomagnification/biocon centration does not seem necessary.

As shown in the chemical and t oxicity testing, there will be no significant residuals or effects directly after using the LPUV unit and therefore, discharge concentrations at different time
intervals is not relevant.MEPC 59/2/2

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I:\MEPC\59\2-2.doc Internationally recognized associations, such as International UV Association (IUVA) and the USEPA, guarantee that water treatment by UV irradiation is a clean process. The treated water does not contain any toxic matter. This fact was confirmed by measuring several halogenated chemicals, which cause harmful eff ects on marine ecosystems and human health, in
the “treated water”.

As a physical treatment process, the trea ted water has no bioaccumulation potential. The assessment of sediment species is re dundant for the physical treatment process.

Since no carcinogenic, mutagenic and endocrine disruptive substances were found in the analyzed water after the treatment and the mutagenic toxicity results showed no toxicity in the treated water, the assessment is not relevant.

As shown in the chemical and t oxicity testing, there will be no significant residuals or effects directly after using the Blue O cean Shield unit and therefore mon itoring of “Active Substances” or “Preparations” in the di scharge is not relevant.

6 RISK TO SAFETY OF SHIP AND HUMAN HEALTH

6.1 Safety Instructions

To prevent injury, basic safety precautions sh ould be observed by all personnel, including the following:

.1 Read and follow all safety instructions.

.2 Avoid possible electric shock, special care should be taken since water is employed in the use of this system. Do not attempt to repair yourself. No user serviceable parts. Return the system to an authorized service facility for service or discard the system.

.3 Do not operate the system if it has a damaged cord or plug, or if it is malfunctioning or has been droppe d or damaged in any manner.

.4 Always unplug the system from an outle t before servicing or cleaning. Never yank the cord to pull the plug from the outle t. Always grasp the plug and pull to
disconnect.

.5 To prevent risk of electrical shock, connect this system only to a properly grounded, grounding type power supply re ceptacle that is protected by a Ground Fault Circuit Interrupter (GFCI). Inspect performance of the GFCI as per manufacturer’s suggested maintenance schedule.

.6 Visually inspect this system prior to inst allation. If the quartz sleeve or lamp is broken, cracked or damaged in any way, do not use it. Contact COSCO Client Services for replacement parts.

.7 To reduce the risk of el ectrocution, keep all connec tions dry and off the ground. Do not touch the plug with wet hands.MEPC 59/2/2

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I:\MEPC\59\2-2.doc .8 The light emitted by the lamp will cause serious eye damage and will burn unprotected skin. Do not plug the unit into an electri cal outlet wit hout properly securing the lamp/sleeve into the reaction chamber. Disconnect the lamp harness before removing the lamp from the reactor.

.9 Always shut off the water flow and re lease water pressure before cleaning or maintaining unit.

.10 Installation of this sy stem must be in accordance with local plumbing and electrical codes, as well as any and all applicable regul ations and laws.

6.2 Regulation of the use of Active Substances

One potential risk present in the Blue Ocean Shie ld system is related to the UV process, which involves the UV-irradiation from the UV-lamps a nd overheating in the UV treatment unit. If the flow is cut off, the lamps will automatically shut-off and there will be no risk of overheating.

Several independent actions ensure that the shut-off occurs. The lamps are completely enclosed in the UV chambers and cannot be operated outside the chamber. Therefore, there is no risk that any personnel are exposed to the UV-irradiation.

The light emitted by the lamp will cause serious eye damage and will burn unprotected skin. If the emergency shut switch is set on the cover of reactor, the lamps will be shut down automatically when someone opens the reactor.

6.3 Risks for safety of ship

.1 UV does not change the physical and ch emical quality of ballast water
within 300 mJ/cm 2 (section 4.2), so it could not in crease the corrosion rate of BW.

.2 The automatic shut-off switch prevents overheating of the UV reactor (section 6.2). Also, all material is fireproof ed so the risk of fire is very low.

.3 No noise pollution from the Blue Ocean Shield ballast water management system.

.4 The Blue Ocean Shield system meet s the related regulations of SOLAS.

7 ASSESSMENT REPORT

In this proposal, the test results found no signifi cant levels of potentially toxic substances and no significant mutation effects of the full strengt h effluent on aquatic organisms. The results showed that all properties of the “treated water” were almost id entical to those of the “pre-treated
water”. This indicates that the “treated water” does not contain any residual oxidants, including “Active Substance,” “Relevant Chemicals,” any residual by-products or any toxicity.

The acute toxicity testing was performed by the Presentation of Supervis ion and Test Center for Pesticide Safety Evaluation and Quality Cont rol (PSEC), the testing site owner and testing organization. PSEC was established in 1982 under a cooperative program supported by UNDP, UNIDO, and China’s form er Ministry of Chemical Industry. The Centre conducts toxicological safety eval uations of drugs, pesticid es, and other fine chemicals. The Centre has designed its organizational st ructure around GLP (Good Laborat ory Practice). All data and reports issued by the Centre have been approved by relevant government agencies.MEPC 59/2/2

ANNEX Page 16

I:\MEPC\59\2-2.doc In 2004, PSEC received Ministry of Agriculture accr editation for agrochemical ecotoxicological safety evaluation. At the same time, PSEC also was accredited for the testing of new chemicals. Later, in 2006, PSEC was also accredited according to ISO/IEC 17025 by China National Laboratory Accreditation Board. This accredita tion provides the customer with certainty that PSEC’s laboratories use testing procedur es according to internationally acknowledged quality systems (ISO/IEC 17025).

PSEC now performs ecological testing based on OECD Principles of Good Laboratory Practice and according to international standards. PSEC is registered as a GLP laboratory in China and is regularly inspected by the State Food and Drug Administration and the Mi nistry of Agriculture of China. The ecotoxicological laboratory perf orms standardized tests (e.g., in accordance with OECD, USEPA guidelines or ISO standards) as well as special services concerning toxicity, biodegradability and bioaccumulation of chemical substances, products and complex mixtures.

The chemical testing was performed by PONY TEST, which is qualified by China National Acceditation Service for Conformity Assessmen t (CNAS) and China Metrology Accreditation (CMA) and has recognized agreements with58 other countries a nd regions, including the United States, the United Kingdom and Ge rmany. As a large comprehensive testing organization based on ISO/IEC 17025, the repor ts provided by PONY TEST reflect its international approval and inte rnational notarization credit.

All chemical analyses were conduc ted according to standard methods.

All samples for chemical analysis were obtai ned from the pilot-scale system developed by COSCO and Tsinghua University.

All data on quality assura nce are provided in each test report. The tests were performed in the pilot scale system using natural seawater accord ing to the QAPP in the confidential documents.

Further testes on a full-scale system will be also performed according to the QAPP.

8 CONCLUSIONS

The Blue Ocean Shield Ballast Water Management System uses the LPUV process to inactivate all harmful aquatic micro-organisms and pathogens present in seawater.

In this system, photon is defined as an “Active Substance.” The chemical testing done before and after the treatment did not indicate any significan t residual substances. The results from acute and mutagenicity toxicity tests show that there was no toxic effect detected in the treated water. Also, this UV-based system is deemed a clean proc ess by internationally r ecognized associations (i.e., the USEPA and IUVA), as it does not use a ny added chemicals or produce any toxic matter.

The system placed on a ship will not require the handling of any chemicals on board, nor will it compromise the safety of the ship or the crew. As shown in the chemical tests, the properties/reactivity of the water is not changed, in comparison with the inlet seawater, and did
not affect the corrosion rate in the BW tanks.

The pilot testing results clearly show that th ere is no potential for acute toxicity in the “treated water.” Therefore, it was determined that the Blue Ocean Shield Ballast Water Management System can absolute ly produce safe “ballast water” in the marine aquatic environment, as well as for relevant ships and crews.MEPC 59/2/2

ANNEX Page 17

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

Beltran, F. J, Intermedias of the oxidation of naphthalene in water with the combination of hydrogen peroxide and UV radiation. Chemos phere, Vol. 30, No. 8, pp. 1463-1475 (1995).

Beltran, F. J., Gonzalez, M., Riva s, J. F. Alvarez, P. Industria l wastewater advanced oxidation. Part 2. Ozone combined with hydrogen peroxide or UV radiation. Environmental Toxicology and Chemistry. 15(6), 868-872 (1997).

Bolton, J.R., Linden, K.G., Standard ization of methods for fluen ce (UV dose) determination in bench-scale UV experiments. J Envi ron ENG-ASCE 129 (3): 209-215 (2003).

Bolton J.R. Ultraviole t applications handbook. Bo lton Photosciences Inc, Canada, pp 5, 12, 15, 19, 27-28 (2001).

Buchanan W., Roddick F. Porter N. and Drikas M. Formation of hazardous by-products resulting
from the irradiation of natura l organic matter: Comparison betw een UV and VUV irradiation. Chemosphere. 63, 1130-1141 (2006).

Carstenk K, Schmidt, and Heinz N, N- Dimethylsulfamide as Precursor for N-Nitrosodimethylamine (NDMA) formation upon ozonation and its fate during drinking water treatment. Environ. Sci. Technol. 42, 6340–6346 (2008).

Chang, J.C.H., Ossoff, S.F., Lobe, D.C., Dorfma n, M.H., Dumais, C.M., Qualls, R.G., Johnson, J.D.,. UV inactivation of pa thogenic and indicator micro- organisms. Appl. Environ. Microbiol. 49 (6), 1361–1365 (1985).

Clancy, L. J., Bukhari, Z., Hargy, M. T., Bolton, R. J., Dussert, B. W., Marshall, M. M. Using UV to inactivate cryptosporidium. J. AWWA, 97(9), 97-104 (2000).

Doong, R., Chang, W. Photoassisted iron comp ound catalytic degradation of organophosphorous pesticides with hydrogen peroxide . Chemosphere, 37(13), 2563-2572 (1998).

Hijnen, W.A.M., Beerendonk, E.F. Medema, G.J .,. Inactivation credit of UV radiation for viruses, bacteria and protozoan (oo)cysts in water: A review. Water Res 22(3):3-4 (2006).

Kang J.W. and Hoffmann M.R. Kinetics and Mechan ism of the sonolytic de struction of methyl tert-butyl ether by ultrasonic irradiation in the presence of ozone. Envrion. Sci. Technol, 32, 3194-3199 (1998).

Letterman R.D. Water quality & treatmen t, A handbook of community water supplies: Chapter 12 Chemical oxidation Fifth Ed. AWWA, McGraw Hill Inc. (1999).

Liu W., Andrews S.A., Bolton J.R., Linden K.G., Sharpless C., Stefan Mihaela., Comparison of DBP Formation from Differ ent UV Technologies at Bench Scale,
Conference Information: 3 rd World Water Congress of the In ternational-Water-Association, 2, 515-521 (2002).MEPC 59/2/2

ANNEX Page 18

I:\MEPC\59\2-2.doc National Research Council. St emming the Tide: Controlling Introductions of Nonindigenous Species by Ships’ Ballast Water. Nationa l Academy Press, Washington D.C. (1996).

Patterson, H. H., Bachman, J., Kanan, S. Kinetics a nd the influences of dissolved organic matter on the photodecomposition of the carbonate pestic ides carbofuran, carbaryl and aldicarb. ACS National Meeting, Am. Chem. Soc., Div. Environ. Chem. 38(2), 105-106 (1998).

Ruth I. Wilson and Scott A. Mabury, Photodegrada tion of Metolachlor: Is olation, Identification, and Quantification of Monochloroacetic Ac id, J. Agric. Food Chem., 48, 944-950 (2000).

Sanz E.N., Davila I.S., Andrade Balao J.A. and Quiroga Alonso J.M. Modelling of
reactivationafter UV disinfection: Effect of UV- C dose on subsequent phot oreactivation and dark repair. Water Res. 41, 3141-3151 (2007).

P.L.C. Drinking Water Standards.

USEPA Drinking Water Standards.

WHO Guidelines for Drinking-water Quality.MEPC 59/2/2

ANNEX Page 19

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

ACUTE TOXICITY TESTING DATA OF THE TREATED BALLAST WATER

Premnas biaculeatus, Artemia Salina and Skeletonema costatum were chosen as the challenge organisms for acute toxicity testing. No acute to xicity was observed in the 100% treated water.

The fish treated with the two kinds of 100% treated ballast water showed no visibly toxic signs or mortality during the test periods. Results ar e presented in Table 5. The NOEC (no observed effect concentration) is greater than 100% treated ballast water.

Table 5: Cumulative mortality data of fish ( Premnas biaculeatus )

Test
Concentration Initial Population Time

(hr) Cumulative Mortality Abnormalities

6 0

24 0

48 0

72 0 Control 7

96 0 No observed toxic signs

6 0

24 0

48 0

72 0 T-1

(100%
100mJ/cm 2 ) 7

96 0 No observed toxic signs

6 0

24 0

48 0

72 0 T-2

(100%
300mJ/cm 2 ) 7

96 0 No observed toxic signs

During the 48-hour exposure period, no toxic signs or deaths were observed in the two kinds of 100% active ingredients of ballast wa ters. Results are presented in Table 6.

The test results indicate that EC50 of two kinds of 100% treated ballast water with the UV dose
of 100 mJ/cm 2 and 300 mJ/cm 2 to Artemia Salina were: NOEC > 100% treated ballast water.MEPC 59/2/2

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I:\MEPC\59\2-2.doc Table 6: Cumulative mortal ity data of invertebrates ( Artemia Salina )

Test
Concentration Parallel Initial Population 24h
Cumulative

Mortality 48h
Cumulative

Mortality Abnormalities

1 5 0 0 No observed toxic signs

2 5 0 0 No observed toxic signs

3 5 0 0 No observed toxic signs Control

4 5 0 0 No observed toxic signs

1 5 0 0 No observed toxic signs

2 5 0 0 No observed toxic signs

3 5 0 0 No observed toxic signs 100%

100mJ/cm 2

4 5 0 0 No observed toxic signs

1 5 0 0 No observed toxic signs

2 5 0 0 No observed toxic signs

3 5 0 0 No observed toxic signs 100%

300mJ/cm 2

4 5 0 0 No observed toxic signs

During the 96-hour exposure period, growth inhibition and other toxic signs were not observed in
the two kinds of 100% treated ba llast water. In addition, the re sults of calculations met the requirements of the test validity. See Table 7.

The test results indicate that IrC 50 (96hr) and IyC 50 (96hr) of 100 mJ/cm 2 and 300 mJ/cm 2 to Skeletonema costatum were more than 100% content.MEPC 59/2/2

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I:\MEPC\59\2-2.doc Table 7: Cumulative mortality data of algae ( Skeletonema costatum )

Algae concentration (×10 4 /mL) Test Concentration Parallel 0h 24h 48h 72h 96h State

1 7.7 10.8 17.3 31.3 48.8 Normal

2 7.7 10.5 17.0 34.0 49.8 Normal

3 7.7 11.3 17.5 30.5 50.5 Normal

4 7.7 11.8 15.8 32.3 48.3 Normal

5 7.7 10.8 17.8 29.8 50.5 Normal Control

6 7.7 10.8 18.8 31.0 50.8 Normal

Average - 7.7 11.0 17.3 31.5 49.8 -

1 7.7 11.3 17.5 31.3 51.0 Normal

2 7.7 11.0 19.0 31.8 53.3 Normal

3 7.7 11.0 18.0 34.3 51.0 Normal

4 7.7 11.5 16.5 32.0 48.0 Normal

5 7.7 10.8 19.0 29.8 52.8 Normal 100% 100 mJ/cm 2

6 7.7 10.5 18.3 32.3 50.0 Normal

Average - 7.7 11.0 18.0 31.9 51.0 -

1 7.7 9.8 16.5 29.5 54.0 Normal

2 7.7 11.3 20.8 31.3 50.8 Normal

3 7.7 11.0 18.5 30.8 48.8 Normal

4 7.7 11.5 19.8 30.0 48.3 Normal

5 7.7 11.3 19.0 31.8 51.3 Normal 100% 300 mJ/cm 2

6 7.7 11.3 17.0 32.8 52.3 Normal

Average - 7.7 11.0 18.6 31.0 50.9 -

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