1



# Washington State Dept. of Fish and Wildlife

Application Package Ballast Water Treatment System

Severn Trent DeNora
1110 Industrial Blvd. Sugar Land, Texas 77478
281

- 240

- 6770
www.severntrentdenora.com sales@severntrentdenora.com

CONTACT: Rudy Matousek Technology Manager
281

- 274

- 8493 rmatousek@severntrentservices.com

NAME:
BalPure TM

– Chemical classification as sodium hypochlorite

MODEL:
BP

- 1000

AVAILABLE DATE: Nov 1, 2005

SUBMITTED: August 8, 20052 

## Table of Contents

SECTION I: V endor Letter of Intent SECTION II: Vessel Owner Letter of Intent SECTION III: Resume of Principal Investigator SECTION IV: Shore Based System (not applicable) SECTION V: System Description

+ General Background + Chemistry + Operating Environments and Conditions + Operating and Maintenance Manual + Installation + Equipmen t and Operation + Maintenance and Consumables + Costs SECTION VI: Discharge Validation SECTION VII: Land Based Experiments SECTION VIII: Performance Capabilities SECTION IX: Shipboard Test Plan SECTION X: Ancillary Documentation

+ Ope rating Manual + Nautilus Toxicity Report + September U of W Report + October U of W Report + December U of W Report + EJR Technology

– Literature Review + ISO 2001 Certificate3



### SECTION I Vendor Letter of Intent

Se e next page4



### Memorandum

Date: August 8, 2005

To: Scott Smith

From: Rudy Matousek Subject: Application for Approval to Conduct

Shipboard Testing of the BalPure BWT System in Washington State Waters STSDN 1110 Industrial Blvd. Sugar Land, TX 77478

Tel 281 240 6770 Fax 281 240 6762

Dear Mr. Smith,

Severn Trent DeNora wishes to conduct shipboard testing of its BalPure TM Ballast Water Treatment System on a Marine Transport Corporation vessel. T he chosen vessel ballasts and de

- ballasts in Washington State waters. This letter serves as a request for approval to conduct such ballast water tests. Also enclosed is the accompanying documentation required by the State of Washington as part of the rev iew and approval process. The document list is identified in the table of contents of this submittal titled “Washington State Dept. of Fish and Wildlife Application Package Ballast Water Treatment System”.

Severn Trent DeNora understands and agrees to th e terms and conditions set forth by Washington Department of Fish and Wildlife for this approval process.5



### SECTION II Vessel Owner Letter of Intent

See next page.67



### SECTION III Principal Investigator

See next five pages.8 

## RESUME
NAME: Russell P . Herwig TITLE: Research Associate Professor and Marine Ballast Water Specialist DEPARTMENT: School of Aquatic and Fishery Sciences and Washington Sea Grant Program INSTITUTION: University of Washington DAY TELEPHONE: 206 685

- 2163 FAX: 206 685

- 7471 E

- MAIL: herwig@u.washington.edu

EDUCATION Ph.D. University of Washington, Seattle, Washington (Fisheries, concentration in Marine Microbiology). Chairperson: Dr. John Liston. Dissertation: Ecology and Properties of Marine Bdellovibrios. 1989. M.A. College of William & Mary, Williamsburg, Virginia (Marine Sciences). Chairperson: Dr. Howard I. Kator. Thesis: Bacterial Response to Crude Oil Spillage in a Salt Marsh. 1978. B.S. Muhlenberg College, Allentown, Pennsylvania (Honors in Biology). 1974

.

HONORS AND AWARDS College of Ocean and Fishery Sciences, University of Washington

– Award for Outstanding Undergraduate Teaching, 1999 Navy

- ASEE Summer Faculty Research Program, Summer Faculty Research Associateship, 1994 J.V. Shankweiler Award, for out standing graduating Biology student, Muhlenberg College, 1974 East Coast Athletic Conference Merit (Scholar

- Athlete) Award, Muhlenberg College, 1974 Graduated with Honors in Biology, cum laude , Muhlenberg College, 1974

POSITIONS HELD (1991 to present) Mar ine Water Ballast Specialist, Marine Advisory Service, Washington Sea Grant. 2002

- present Research Associate Professor, School of Aquatic and Fishery Sciences, University of Washington. 1998

- present Adjunct Research Associate Professor, Department of Microbiology, University of Washington. 1998

- present. Adjunct Research Assistant Professor, Department of Microbiology, University of Washington. 1996

- 1998. Research Assistant Professor, School of Fisheries, University of Washington. 1995

- 1998. Research A ssistant Professor, Department of Microbiology, University of Washington. 1991

- 1995

PROFESSIONAL MEMBERSHIPS American Society for Microbiology, International Society for Microbial Ecology, American Association for the Advancement of Science

PROFESSIONAL AND OUTSIDE SERVICES Editorial Board, Journal of Food Protection, 1/1998

- present9

Graduate Fellowship Review Panel: EPA Terrestrial Ecology and Ecosystems, 2000, 2001; EPA Microbiology, 2005 Grant Proposal Review Panel: EPA Exploratory Research in Envir onmental Biology, 1998 Ad Hoc Journal Reviewer: Aquaculture, Applied and Environmental Microbiology, Organic Geochemistry, Water Environment Research, International Journal of Systematic and Evolutionary Microbiology Ad Hoc Grant Proposal Reviewer: Univers ity of Washington Royalty Research Fund, Washington Sea Grant, Maryland Sea Grant, Michigan Sea Grant, Oregon Sea Grant, Illinois/Indiana Sea Grant Program, National Science Foundation, Cooperative Institute for Coastal and Estuarine Environmental Technolo gy

SELECTED PUBLICATIONS Estes, R.M., C.S. Friedman, R.A. Elston, and R.P. Herwig. 2004. Pathogenicity testing of shellfish hatchery bacterial isolates on Pacific oyster Crassostrea gigas larvae. Dis. Aquat. Organisms 58:223

- 230. Lee, S.B., S.E. Strand , H.D. Stensel, and R.P. Herwig. 2004. Pseudonocardia chloroethenivorans sp. nov., a chloroethene

- degrading actinomycete. Int. J. Syst. Evol. Microbiol. 54:131

- 139. Dong, F.M. A.R. Cook, and R.P. Herwig. 2003. High hydrostatic pressure treatment of f infish to inactivate Anisakis sp. J. Food Prot. 66: 1924

- 1926. Herwig, R.P. 2002. Role of bacteria in the nutrition of bivalve molluscs: intriguing results and research possibilities, p. 31

- 60. In C.

- S. Lee and P. O'Bryen (ed.), Microbial Approaches to Aquatic Nutrition within Environmentally Sound Aquaculture Production Systems. The World Aquaculture Soc.: Baton Rouge, Louisiana. Sun, T, G.M. Pigott, and R.P. Herwig. 2002. Lipase

- assisted concentration of n

- 3 polyunsaturated fatty acids from the vis cera of farmed Atlantic salmon ( Salmo salar L.) viscera. J. Food Sci. 67: 130

- 136. Herwig, R.P. 2000. Pathogens transmitted by seafoods, p. 109

- 182. Y.H. Hui, D. Kitts, and P.S. Standfield (ed.), Foodborne Disease Handbook: volume 4, Seafood and Environ mental Toxins. Marcel Dekker: New York. Shaw, T.R., R.P. Herwig, and J. Wakeman. 1999. Microbial degradation of intertidal creosote

Wyckoff/Eagle Harbor Superfund Site, p. 315

- 319. Bioremediation technologies for polycyclic aromatic hydrocarbon compoun ds: proceedings from the Fifth International In Situ and On

- Site Bioremediation Symposium, San Diego, April 19

- 22, 1999. Rockne, K.J., H.D. Stensel, R.P. Herwig, and S.E. Strand. 1998. Cometabolic enhancement of PAH degradation by marine methanotrophic e nrichment cultures. Bioremediation J. 1: 209

- 222. Herwig, R.P., and J.P. Gray. 1997. Microbial response to antibacterial treatment in marine microcosms. Aquaculture 152: 139

- 154. Herwig, R.P., J.P. Gray, and D.P. Weston. 1997. Antibacterial resistan t bacteria in surficial sediments near salmon net

- cage farms in Puget Sound, Washington. Aquaculture 149: 263

- 283. Ederer, M.M., R.L. Crawford, R.P. Herwig, and C.S. Orser. 1997. PCP degradation is mediated by closely related species of the genus Sphing omonas . Molecular Ecology 6: 39

- 49.10

Gray, J.P., and R.P. Herwig. 1996. Phylogenetic analysis of the bacterial communities in marine sediments. Appl. Environ. Microbiol. 62:4049

- 4059. Geiselbrecht, A.D., R.P. Herwig, J.W. Deming, and J.T. Staley. 1996. Enumeration and phylogenetic analysis of polycyclic aromatic hydrocarbon

- degrading marine bacteria from Puget Sound sediments. Appl. Environ. Microbiol. 62: 3344

- 3349. Dyksterhouse, S.E., J.P. Gray, R.P. Herwig, J.C. Lara, and J.T. Staley. 1995. Cycl oclasticus pugetii , gen. nov., sp. nov., an aromatic hydrocarbon

- degrading bacterium from marine sediments. Int. J. System. Bacteriol. 45: 116

- 123.

RECENT MEETING PRESENTATIONS Lawrence, D., and R.P. Herwig. March 2005. Enumerating phytoplankton abunda nce in ballast water treatment experiments. 2005 Puget Sound Georgia Basin Research Conference. (Seattle, WA). Perrins, J., and R.P. Herwig. March 2005. Analysis of ozone and chlorine disinfectant by

- products concerning ballast water treatment. 2005 Pu get Sound Georgia Basin Research Conference. (Seattle, WA). Nielsen, B., and R.P. Herwig. March 2005. Efficacy of an on

- site filtration and chlorination ballast water treatment system. 2005 Puget Sound Georgia Basin Research Conference. (Seattle, WA). Herwig, R.P., and J.R. Cordell. March 2005. Defending Our Shores: Ballast Water Treatment Technologies. 2005 Puget Sound Georgia Basin Research Conference. (Seattle, WA). Herwig , R.P., J.C. Perrins, J.R. Cordell, N.C. Ferm, P.A. Dinnel, G.M. Ruiz, R.W

. Gensemer, W. J. Cooper. November 2004. Shipboard testing of a prototype ballast water treatment system: experiments on the West Coast with ozone. Fourth SETAC World Congress. Society for Environmental Toxicology and Chemistry (SETAC). (Portland, OR). Herwig , R.P., J.R. Cordell, J.C. Perrins, N.C. Ferm, J.L. Grocock, E.R. Blatchley III. November 2004. Mesocosm experiments for evaluating potential ballast water treatment systems. Fourth SETAC World Congress. Society for Environmental Toxicology an d Chemistry (SETAC). (Portland, OR). Cordell , J.R., N.C. Ferm, J.L. Grocock, J.C. Perrins, R.P. Herwig. November 2004. Examination of mesozooplankton present in ballast water of ships entering Puget Sound, Washington. Fourth SETAC World Congress. Soci ety for Environmental Toxicology and Chemistry (SETAC). (Portland, OR). Perrins , J.C., R.P. Herwig. November 2004. Flow cytometry versus other methods for enumerating microorganisms present in ballast water. Fourth SETAC World Congress. Society for E nvironmental Toxicology and Chemistry (SETAC). (Portland, OR).11

RESUME
NAME: Jeffery R. Cordell TITLE: Principal Research Scientist DEPARTMENT: School of Aquatic and Fishery Sciences INSTITUTION: University of Washington DAY TELEPHONE: 206 543

- 7532 F AX: 206 685

- 7471 E

- MAIL: jcordell@u.washington.edu

EDUCATION M.S. University of Washington, Seattle, Washington (Fisheries). Chairperson: Dr. David Armstrong. Thesis: Structure and Dynamics of an Epibenthic Harpacticoid Assemblage and the Role of Predation by Juvenile Salmon. 1986. B.S. Huxley College of Environmental Studies, Bellingham, WA. 1976.

POSITIONS HELD Fisheries Biologist, School of Fisheries, University of Washington, 1977

- 2002 Principal Research Scientist, School of Aquatic and Fis hery Sciences, University of

Washington, 2002

- present

PROFESSIONAL MEMBERSHIPS Crustacean Society, Estuarine Research Federation, International Association of Meiobenthologists, Pacific Estuarine Research Society, Western Society of Naturalists, World S ociety of Copepodologists.

SELECTED PUBLICATIONS Dean, A.F., S.M. Bollens, C.A. Simenstad, and J.R. Cordell. 2005. Marshes as sources or sinks of an estuarine mysid: demographic patterns and tidal flux of Neomysis kadiakensis at China Camp marsh, San Fr ancisco estuary. Est. Coast. Shelf Sci. 63: 1

- 11. Levings, C.D., J.R. Cordell, S. Ong, and G.E. Piercey. 2004. The origin of invertebrate organisms being transported to Canada’s Pacific coast by ballast water. Can. J. Fish. 61(1): 1

- 11. Toft, J.D., C.A . Simenstad, J.R. Cordell, and L.F. Grimaldo. 2003. The effects of introduced water hyacinth on habitat structure, invertebrate assemblages, and fish diets. Estuaries 26(3): 746

- 758. Tanner, C.D., J.R. Cordell, J. Rubey and L.M. Tear. 2002. Restoratio n of freshwater intertidal habitat functions at Spencer Island, Everett, Washington. Rest. Ecol. 10(3): 564

- 576 Bollens, S.M., J.R. Cordell, S. Avent, and R. Hooff. 2002. Occurrences, causes and consequences of zooplankton invasions: a brief review, plus t wo case studies from the northeast Pacific Ocean. Hydrobiologia 480: 87

- 110. Toft, J.D, J.R. Cordell, and W.C. Fields. 2002. New records of crustaceans (Amphipoda, Isopoda) in the Sacramento/San Joaquin Delta, California, and application of criteria for i ntroduced species. J. Crust. Biol. 22(1): 190

- 200. Simenstad, C.A. and J.R. Cordell. 2000. Ecological assessment criteria for restoring anadromous salmonid habitat in Pacific Northwest estuaries. Ecol. Eng, 15:283

- 302. Giles, S.L. and J.R. Cordell. 1999. Zooplankton composition and abundance in Budd Inlet, Washington. Pages 634

- 642. In: Puget Sound Research '98: From Basic12

Science to Resource Management, Puget Sound Water Quality Action Team, Olympia, Washington. Prahl, F.G., L.F. Small, B.A. Sullivan, J.R. Cordell, C.A. Simenstad, B.C. Crump, and J.A. Baross. 1998. Biogeochemical gradients in the lower Columbia River. Hydrobiologica. 361: 37

- 52. Cohen, A, C. Mills, H. Berry, M. Wonham, B. Bingham, B. Bookheim, J. Carlton, J. Chapman, J. Cordell, L. H arris, T. Klinger, A. Kohn, C. Lambert, G. Lambert, K. Li, D. Secord, and J. Toft. 1998. Puget Sound expedition, a rapid assessment survey of

non

- indigenous species in the shallow waters of Puget Sound. Nearshore Habitat Program, Aquatic Resources Divis ion, Wash. State Department of Natural Resources, Olympia, WA. 37 pp. Morgan, C. A., J. R. Cordell, and C. A. Simenstad. 1997. Sink or Swim? Copepod population maintenance in the Columbia River estuarine turbidity maxima region. Mar. Ecol. Progr. Ser. 1 29: 309

- 317. Cordell, J.R. and S.M. Morrison. 1996 The invasive Asian copepod Pseudodiaptomus inopinus in Oregon, Washington, and British Columbia estuaries. Estuaries 16 (3): 629

- 638. Bollens, S.M., B.W. Frost and J.R. Cordell. 1994. Chemical, mechan ical, and visual cues in the vertical migration behavior of the marine planktonic copepod Acartia hudsonica . J. Plankton Res. 16 (5): 555

- 564. Cordell, J.R., C.A. Morgan, and C.A. Simenstad. 1992. Occurrence of the Asian calanoid copepod Pseudodiaptomu s inopinus in the zooplankton of the Columbia River estuary. J. Crust. Biol. 12(2): 260

- 269.13

SECTION V System Description

General Background

The BalPure TM System that will be used by MTC for this test is a scaled up version of the
system that has bee n tested by the University of Washington at the Marrowstone Island
USGS facility. The BalPure TM process is a patent pending system to generate, control,
and optimize hypochlorite use for the treatment of ballast water. It is proven high
capacity, compact , and modular technology, which can handle in excess of 3,000 cubic
meters of ballast per hour. The system also neutralizes all the chlorine before de

ballasting. Several system variables including key ones, residual chlorine to the ballast

tank and sulf

ite in the deballast, are recorded in a data logger to document proper system
operation.

The BalPure TM system as proposed for the MTC shipboard test program is designed to
treat a ballast flow of 5000 gpm. Based upon the STDN experience with the treatm ent of
seawater in cooling water applications, the typical dosage is 1

- 2 ppm. Port water used for
ballast has a higher chlorine demand, so greater chlorine dosage is required. The field
tests carried out on behalf of STDN and work done at the University of Washington show
that 5 ppm chlorine is a maximum dosage required for the kill necessary to meet the
Washington State and recent IMO proposed regulations. A more typical dosage ranges

from 3.0

- 3.5 ppm of hypochlorite for typical seawater with < 5 ppm TOC . The installed

BalPure TM system will have the capability to reach 5 ppm hypochlorite or 320 pounds per
day. Adjusting the current applied to the BalPure TM generator will increase or reduce the
amount of oxidant generated within the design conditions of the system. Therefore
hypochlorite production can be tailored to meet both organic and aquatic life content of
the ballast water. This adjustment can be done both automatically or manually through

the PLC.

The main BalPure TM system will be delivered fu lly contained on an epoxy painted (meets
marine requirements) steel skid with dimensions of 144 inches long by 72 inches wide by
96 inches high. Lifting lugs are provided to facilitate movement and installation (shown
in Dwg. D006711

- P

- 01). All equipment is provided in NEMA 4 enclosures or rated for14

full wash down service. Total weight of the skid is projected to be 7800 pounds. In cases
where space is a constraint the various components can be installed separately to
bulkheads or as space permits and f ield connected to operate as a fully skid mounted
integrated system. This will be done with this project as shown in Dwg. D006711

- P

- 50.
Major components on the skid, hung on the room walls, and method of operation are
listed in the following sections.

Th e BalPure TM system is sold and built by Severn Trent DeNora (STDN) a leader in

water treatment and marine sanitation devices. Severn Trent DeNora has been
manufacturing like equipment for the offshore industry since 1974. It has an installed

base of thes e systems producing over 1 million pounds of hypochlorite per day. STDN
accounts for 65% of the worldwide operating on

- site hypochlorite capacity with over 400
systems operating in 59 countries. For Offshore applications STDN offers 21 different
size sys tems capable of producing from 3 to 2400 pounds per day of hypochlorite. Our
manufacturing facility is ISO

- 9001

- 2000 certified and we manufacture NSF 61 certified
products. We also have received the ABS certificate of Product Design Assessment for

our SC

- 96, which is the precursor to our BalPure TM BP

- 500 model. All these
certifications are provided in the Ancillary Documentation Section.

Chemistry
Chlorination is now established as an integral part of water and wastewater treatment
practice in the Unite d States. Several hundred technical articles have been written on the
subject. It is the consensus that the primary use of chlorine is for disinfection.
Disinfection practices are governed by the chlorine residual

- contact time envelope. The
major facto rs affecting the germicidal efficiency of the free residual process are: chlorine
residual concentration, contact time, pH, and water temperature. Increasing the chlorine
residual, the contact time, or the water temperature increases the germicidal effici ency. Since seawater has a relatively constant pH and volumes are large, this is assumed to be a
constant. Contact time for ballast water treatment is the length of the voyage, but the

BalPure TM system is based on contact times of less than 4 hours. Thi s therefore sets the
chlorine to be added based on the chlorine (oxidant) demand of the seawater.15

Seawater (normally between 15 and 35 grams/liter NaCl) or other water containing NaCl
may be used to generate a disinfecting solution containing chlorine by p assing a direct
electrical current through the solution. On

- site generation of hypochlorite from seawater
has been used for over 25 years. These systems can be purchased as completely skid
mounted systems that generate sodium hypochlorite from seawater. These systems are
used in refining, petrochemical power plants, offshore drilling production, and marine
applications around the world. Systems can be scaled to the appropriate size depending
on the quantity of hypochlorite required.

The type of elect rolytic cell commonly used in these marine and offshore applications is a “tube within a tube.” Due to the high chlorine demands for ballast water applications the
cells offered in this design are the dense pack monopolar / bipolar electrolyzers. This

all ows high chlorine production in a relatively small space. The anode surface is coated
with proprietary precious metal oxides, primarily ruthenium and iridium. Seawater enters
one end of the electrolyzer and passes between the cathodes and the anodes. Th e hypochlorite solution, depleted seawater, and hydrogen exit out of the opposite end of
each electrolyzer. Up to three horizontal electrolyzers can be stacked vertically on top of
one another and flow serpentines through all three to increase pounds per hour production
rate linearly by the number of electrolyzers. Electrolyzer size may vary and can produce
up to 220 pounds/hour per electrolyzer.

In some applications, such as ballast water treatment, a dechlorination step can be added
to the process. T his requires adding a reducing agent such as sodium sulfite to the end of
the system to neutralize any residual chlorine at the point of discharge. The end result is

a non

- toxic stream with no free chlorine.

The process is based on the partial electrolys is of NaCl present in seawater as it flows
through an unseparated electrolytic cell. The resulting solution exiting the cell is a
mixture of seawater, sodium hypochlorite (hypo), hydrogen gas and hypochlorous acid.
Electrolysis of sodium chloride solutio n (seawater in this application) is the passage of
direct current between an anode (positive pole) and a cathode (negative pole) to separate
salt and water into their basic elements. Chlorine generated at the anode immediately16

goes through chemical reacti ons to form sodium hypochlorite and hypochlorous acid.

Reactions are shown below:

Eq. 1 Cl -  Cl 2 (aq) + 2e Eo = 1.396 V

Which is hydrolyzed in solution to form hypochlorous acid:

Eq. 2 Cl 2 + 2H 2 O  2HOCl + 2H +

Hypochlorous acid dissociat es to hypochlorite at alkaline pH levels:

Eq. 3 HOCl  OCl - + H + pKa = 7.5

In seawater bromide ions are present, together with a range of inorganic cations as well as
possibly ammonia and a variety of organic compounds. The reaction of molecular

c hlorine or hypochlorite ions with ammonia or amino compounds leads to the
disinfectants and react to destroy bacteria and microorganisms in the water just as do
chlorine, hypochlorous acid and hypochlorite ions. The rapid oxidation of bromide ions

will al so occur and (as with chlorine) in the aqueous environment form hypobromous
acid (HOBr) and hypobromite ions (OBr - ). These reactions will also be equilibrium
processes, dependent upon temperature and pH. Note also that brominated species will

react with ammonia and/or amino compounds if present in the water, just like the
chlorine analogues.

Hydrogen and hydroxides are formed at the cathode, the hydrogen forms a gas and is
vented and the hydroxide aids in the formation of sodium hypobromite and increas es the
exit stream pH to approximately 8.5. This reaction is shown below:

Eq. 4 2H 2 O + 2e -  H 2 (g) + 2OH Eo =

- 0.828 V17

Because the electrolytic cell used for this application is unseparated the reactants at both

anode and cathode can further r eact to form the respective end products shown in the

overall electrochemical and chemical reaction below:

Eq. 5 NaCl + H + + Br - + 2e  NaOBr + H 2 + Cl Salt + Water + Energy  Sodium Hypochlorite + Hydrogen

In some applications, such a s ballast water treatment, a dechlorination step can be added
to the process. This requires adding a reducing agent such as sodium sulfite to the end of
the system to neutralize any residual chlorine at the point of discharge. The end result is

a non

- tox ic stream with no free chlorine. The neutralization of the free halogen
(hypochlorite and hypobromite) between the discharge point and the ballast tanks.
Sodium sulfite is used and the simplified reaction is shown below to form sodium sulfate.

As shown in the equation, neutralization occurs at one to one molar ratio but two to one
(sulfite to halogen) as a weight ratio.

Eq. 6 Na 2 SO 3 + Cl 2 + H 2 O

– > Na 2 SO 4 + 2HCl

Sodium Sulfite + Chlorine + Water

– > Sodium Sulfate + Hydrochloric Acid

Typically ther e are 4 g/L sulfate in seawater and based on the concentrations of halogen
required only 10 mg of sulfate will be added to the discharge ballast water. Also the
amount of HCl generated is negligible and will not change the pH of the discharge ballast

wate r.

Operating Environments and Conditions

Ballast water turbidity: At this time STDN does not limit the turbidity of the incoming

ballast water.

Ballast water pressure: A nominal 10 PSIG is required to pass through the inlet strainers,

otherwise there are no requirements on minimum pressure because the provided system18

has booster pumps to increase pressure through the BWT system. Due to the
construction of the cells STDN does limit the line pressure from the shipboard ballast
pump to 50 psig.

Ballas t water temperature: The inlet temperature to the electrolytic cells must be above
38 degrees F. The split in ballast flow and portion to the generator is 220 to 1 so a small
heat exchanger can be added in applications where ambient ballast water tempera ture will
be below 38 degrees F. Maximum ambient temperature up to 120 degree F is acceptable.

Ballast Water Flow: The system that is being provided in this proposal can treat 5000
gpm flow at an organic loading of 5 ppm. STDN has provided offshore sys tems to treat 40,000 gpm at 5 ppm. Therefore we do not restrict flow rate but require matching the
hypochlorite production unit to standard ship rate of ballast.

Electrical Requirement: The proposed BalPure TM unit will require 54 kVA at 480 volts,
3 ph ase, 60 HZ.

Air: There are no process air requirements.

Weight: Approximately 7800 pounds

Dimensions: 144 inches long X 72 inches wide X 96 inches high

Environment: All equipment is provided in NEMA 4 boxes or with full wash down
capabilities. Equ ipment can be provided to meet class 1 div. 1 hazardous zones.
Therefore selective environment is not required.

Treatment Limitations: STDN does not know of any at this time. The amount of
disinfection by

- products will be proportional to the amount of TOC in the ballast water.19

Operating and Maintenance Manual

See Ancillary Document One.

Installation

Installation instructions are listed in the O&M Manual. STDN is committed to a
successful installation and operation of any equipment we provide to M TC. STDN will
provide on

- site service during the installation and commissioning phase of this project by
at least one field service engineer. Those available for field service are listed below:

Harold Childers

– 281

- 274

- 8459
Rudy Matousek

– 281

- 274

- 8493

Lucette Falcon

- 281

- 274

- 8460
STDN will also make available for phone consultation the following individuals:

Vince Wedlich

– 281

- 274

- 8488 Electrical Engineering Supervisor

Sean McMillan

– 281

- 274

- 8492 Instrument and Electrical Engineer
Larry Knight

– 2 81

- 274

- 8402 PE Mechanical Engineer

James Moore

– 281

- 274

- 8452 Mechanical Engineer

Hydraulic and Mechanical Connections:

Please refer to drawings D006711

- F

- 01, D006711

- F

- 02, D006711

- P

- 01 and the

O & M manual sections 11 and 12.

Electrical Connections:
Please refer to drawing D006711

- EP

- 01, D006711

- E

- 21, D006711

- E

- 01.

Operation and Equipment
Operation: 1.1 The BalPure System is a safe and simple electrolytic process for on

- site generation of sodium hypochlorite solutions via the electrolysis of

seaw ater. Seawater will be supplied by the customer at a minimum pressure and will be fed to the system inlet via a booster pump. Seawater passes through the electrolyzer where it is subjected to a DC current. The20 current passing through the seawater soluti on causes the disassociation of NaCl (salt) and H 2 O (water), which then allows for the formation of sodium hypochlorite. The proposed system is designed to produce 320 lb/day (13.75 pounds/hour) maximum capacity. Lower outputs can be achieved by reducing the current to the electrolyzer.

1.2 Optimum performance of the BalPure System is obtained by maintaining a constant seawater flow through the electrolyzer. Varying the DC amperage applied to the cell then controls the produc tion of hypochlorite. 1.3 The BalPure System, as proposed, will control and pass the seawater through the electrolyzer at a constant value using an orifice

- type flow controller. An inlet flow transmitter protects the system. This tra nsmitter will shut down the electrical current to the electrolyzer should seawater flow through the electrolyzer stop. The inlet seawater temperature should be at least 5 C and have a chloride conce ntration of at least 19,000 ppm for optimum performance. The BalPure system will be tied into the ballast water pump. The system will not operate in automatic mode if the ballast water pump is not operating. The BalPure system must also be set to the “Ballast” mode of operation. With the unit in the ballast mode the automatic valve on the inlet side will open as well as the valve on the discharge side permitting the flow of seawater.

1.4 An inline booster pump will feed a slip stream from the main ballast water line at a feed rate of 32 gpm. A duplex strainer will filter the water with a DP alarm (based on actual field experience with sea water) to

remov e any particles larger than 800 microns.

1.5 The BalPure System, as proposed, is designed to operate automatically. After the unit is energized, the system will sense that adequate seawater flow is available. After the unit is purg ed, the transformer/rectifier will supply DC current to the electrolyzer to produce hypochlorite. Again, for the ballast water treatment mode of operation, the system will be designed to operate when the ballast pumps are activated. The sodium hypochlorite will be injected into the discharge stream of the ballast pumps. The system may also be activated during voyage if required in manual mode.

1.6 The system is arranged and designed to provide flexi bility of the operation in terms of solution and dosing strength.

1.7 In the Ballast Water mode, there is a continuous chlorine analyzer that will measure the oxidant concentration of the treated ballast water after the in jection of the hypochlorite into the main ballast water stream. This analyzer will feed the results to the system PLC and data logger to automatically adjust the DC current to the generator in order to maintain the oxidant level at the desired set point in the ballast water feeding the ballast water tanks21 1.8 In the deballast mode of operation, liquid sodium sulfite will be metered into the inlet of the deballast water pump. With the mixing effect of the deballast water pump and the 39’ of pipe to overboard, the sulfite will easily react with any free oxidants. A sensor in the deballast line will monitor the level of sulfite and feed back a signal to the sulfite meter ing pump to insure the proper dosage of sodium sulfite. We will plan to supply a drum manifold line (suction side of metering pump), metering pump, sulfite analyzer, and of course PLC control and data logger.

1.9 All mea sured hypochlorite levels during system operation will be recorded with date and time in the date logger. All measured sulfite levels during deballasiting will be recorded with date and time in the data logger.

1.10 The BalPure System needs seawater to operate. If the vessel is going to be ballasting in water that has less than 10,000 ppm of chlorides in it, the normal operation of the BalPure TM system will have to change and an automatic brine r system using bulk salt will be activated. The briner system is automatic except for adding salt. The hold tank also serves as the briner and holds 4,900 pounds of salt. Based on ballast tank data there are 12 tanks each requiring 180,000 gallons. This will require approximately 2,000 pounds of salt if the ballast is fresh water. The metering pump attached to the tank will be electrically tied to the conductivity of the brine through cel l voltage. When the voltage rises above a pre

- set value the metering pump will turn on and have a variable frequency drive to allow for fine adjustments of the flow to maintain proper salinity for the electrolytic cell. T he brine tank and pump will be mounted within the shop building and the discharge line from the pump will inject into the BalPure system just before the booster pumps. The salt will be added manually and should be purchased in 2, 000 pound “super

- sacs”. The sack is designed to release full contents from a nozzle at its bottom. A small jib crane will be required to lift the bag over the tank to empty the contents. This is a semi manual job required of the operato r and can be done anytime prior to the ballasting operation.

1.11 Hydrogen gas is generated at the cathode of the BalPure unit. Immediately upon exiting the electrolytic cell the gas liquid mixture will be separated in the Hydrogen Degas Separator. Hydrogen is removed and immediately diluted with ambient air from a blower to less than 1%. The (LEL) lower explosive limit of a hydrogen / air mixture is 4% hydrogen.

1.12 The ballast water tanks use an Ameron coating. According to Ameron, there will be no problems with the coating as long as the oxidants are less than 10 ppm. (see Ancillary Documents

– Coating Letter)

Equipment:22

The major items of equipment are listed as follows:

2.1 Seawater Booster Pump : Vertical multistag e, inline pump, all stainless, with stainless steel impeller, diffusers, shaft, chamber and head, with 2” x 2” grooved end connections. The pump is equipped with a cartridge type mechanical seal, with silicon carbide faces and EPDM elastomers. Pumps are rigid coupled to a 7.5 HP, 3450 RPM, TEFC enclosure, standard efficient, 230/460V, 3ph, 60Hz, 1.15SF vertical 56C motor. Pump is 36.5” tall.

2.2 Transformer/Rectifier: The transformer/rectifier is NEMA 3R rated, and constructed of painted carbon steel. The transformer/rectifier is shipped loose and connected to the generator panel by the interconnecting cable. The control panel converts 480 VAC to 800 ADC @ 47VDC. The internal electrical items consist of a current adjust switch, a set of diodes, fuses an d required relays. The panel has the following local indications and controls:

- Ammeter

– DC

- meter

- Voltmeter

– DC

- meter

- Current adjust DC pot Power On / flow is OK

– lamp The control panel/transformer/rectifier dimensions are 20” Deep x 84” high x 72” wide. The control panel contains the Operator Interface Panel, which is used to control the overall operations of the BalPure system. The OIT provides a visual display of the status of the various system components, and alarm messages are used to i ndicate malfunctions in critical areas. The following control devices are necessary to protect the BalPure System. The PLC uses the output from the flow transmitter to monitor the flow of the seawater at the inlet to the electrolyzer, and will shut the s ystem down if the flow rate drops to 30 gpm. Temperature switches in the transformer will cut the power to the rectifier if the internal temperature is above 350 F. DC over

- current will cause the circuit breaker to trip. Displayed on the control panel:

- Electrolyzer voltage and current meters: Actual DC Current (Amps) to the electrolyzers is displayed on the cell current meter. These meters are provided to ensure that the power supplied to the cells is at the proper amperage. An increase in voltage indi cates a possible decrease in salinity (due to fresh water) or a dirty electrolyzer.

- Current Adjust Knob: In the manual mode, this knob allows the operator to manually adjust the current to the required value. In the feedback mode the current is adjusted automatically.

- Power on/Flow OK Light: This is a light to indicate that the unit is running, the transformer temperature is acceptable, and there is sufficient seawater flow, sensed from the flow meter.23 In the event of an electrical trip or low

- flow actu ation, the unit will turn off and the light will turn off. If the unit turns off due excess transformer temperature or insufficient seawater flow, there will be a time delay until the unit and the light turn off and an external alarm could be indicated. When the light is off and an alarm actuated, the unit will require operator investigation and correction of system valves, flow, or electric
power

- Power On/Off Knob: Allows the operator to start or stop the unit. There is a time delay from switching th e Knob to “On” and the Power On/Flow OK light turning on, indicating that the rectifier is energized.

2.3 Generator Panel: The generator panel converts seawater to sodium Hypochlorite. The generator panel assembly consists of an inlet automatic electric valve , a flow meter (with visual indication and a switch), one electrolyzer, and an outlet automatic valve used for isolation and flow control.

2.4 BalPure Electrolyzer: The Balpure electrolyzer consists of 8 bipolar cells with an electrode area of 0.8 squa re meters. One end of the electrolyzer is an anode (+) and the other end a cathode (

- ). The bipolar plates are inserted in each of the electrolyzer’s terminal electrodes. The seawater flow is channeled between the electrode plates. The main body of the el ectrolyzer is about 8.5 feet long with an overall length of 10.5 feet long when the electrical connections are included. The electrolyzer is about 2 feet in diameter. There is a 3 inch seawater inlet and a 3 inch outlet even though we are using 2” pipe t o and from. The electrolytic cell is stable under all normal operating conditions and has a guaranteed life of 5 years.

2.5 Continuous On

- Line Analyzers: The chlorine analytical instrument can measure free oxidants on a continuous basis. The sulfite an alyzer measures the sulfite level in the deballast water stream. The oxidant results are fed to the PLC where when in ballast mode, the current from the transformer/rectifier will be adjusted to maintain the generated oxidants at the proper set point. In the deballast mode, the sulfite analyzer will feed a signal back to the PLC to adjust the metering pump to dose the correct amount of 42% liquid sodium sulfite into the inlet of the deballast pump to remove any free oxidants in the deballast water.

2.6 Sulfite Addition System: The sulfite addition system is comprised of two metering pumps, one on

- line and the other an in

- line spare. They will be mounted on an exterior wall inside the present shop building. The suction line will run from the sulfite storage tank to the metering pumps. The pump is supplied to meter the sodium sulfite into the inlet of the deballast pump. The pump will be PLC controlled based upon the BalPure system in the deballast mode, and a signal from the analyzer (2.5) that there is sulfite in the deballast water. The sodium sulfite will be pumped from 55 gallon drums.24 The operator will have to check tank volume before each deballasiting operation to insure sufficient material.

2.7 PLC and Data Logger: A PLC is supplied to control the BalPure system. A data logger is supplied to collect and store the data for future down loading and record of ballast water treatment and dechlorination. Data s uch as run time, amperage, voltage, oxidant levels, sulfite levels, etc. will be recorded and logged. The Solid State Data Recorder is a Paperless Recording instrument. Data is stored
on either an internal floppy disk, a removable PCMCIA memory card or a Zip
Drive. All data is stored in MSDOS format and may be archived or analyzed on
any IBM compatible PC running Microsoft Windows 3.1 or Windows 95/98 using

the available Companion Software . The instrument retains all the features of a
traditional Pap er Chart Recorder by virtue of its large STN monochrome or TFT
color Liquid Crystal Display (LCD), which presents the data in the traditional
chart mode as well as in bar graph or digital numeric form. The unit has many
features and functions, which ar e unique and cannot be performed on traditional
paper recorders, such as data compression and historic data browsing. The
recorder is programmed via a touch screen keypad on the display. The recorder
will measure and process up to six direct inputs, ca lculated, conditional, or
external points for logging, trending, or data manipulation. If direct inputs are not
desired, the Data Recorder will accept up to fifteen points from a combination of
calculated, conditional, or external point types.

2.8 Sam ple Station : There will not be a master sample station. STDN requires the MTC vessel operators to sample and analyze the available chlorine content of each ballast tank 24 to 48 hours prior to de

- ballasting. The sampling and analysis procedures will be detailed in the operating and maintenance manual provided with the equipment. This task is estimated to take 15 minutes per ballast tank.

2.9 Hydrogen Dilution: The electrolyzer output enters the Hydrogen Degas Separator where the hydrogen is separated from the Sodium Hypochlorite solution. In the Hydrogen Degas Separator, H2 that is being generated is removed from the two

- phase (liquid/gas) solution and safely routed to the vent stack. The hydrogen in the vent stack is diluted to less than 1% by one (1) of the two (2) dilution air blowers. The lower explosive limit (LEL) of a hydrogen/air mixture is 4% hydrogen. Two 100% blowers are provided to ensure an automatic standby to the operator selected lead blower. Inlet filter screens prevent unwanted d ust/debris from being admitted to the vent system. Each blower line is provided with an individual airflow switch to provide logic feedback for the standby blower startup. Dampers prevent backflow through the standby blower during operation.25 After the h ydrogen is diluted to below the lower flammability limit, it is safely vented. The Sodium Hypochlorite solution flow from the degas separator is routed to the required injection points.

2.10 Briner System: Seawater will enter the brine tank through a side feed chamber. Liquid lever control maintains water at 30% from the bottom to ensure full saturation. Flow requirements will be approximately 1.5gpm to achieve the required brine concentration to the electrolyzer. The brine tank is sized for a working volume of 4,900 pounds to facilitate additions via 2000 pound super sacks. The brine tank will be installed inside next to the generator. It will be made of HDPE with bulkhead fittings. Brine addition to the electrolyzer will be controlled by salinity of the incoming seawater.

2.11 Alarms: Various alarms will display through the control panel PLC for proper operation of hypochlorite generator, sulfite addition, hypo addition, and concentrated brine addition. There will also be a general purpose audible and visual alarm on deck outside of the room housing the generator.

Maintenance and Consumables
Refer to the O & M manual; section 14 regarding maintenance and appendix A for spare

parts.

Sodium bisulfite is the other consumable material used during de

- ballasting for chlorine

neutralization. The stoichiometric ratio of sulfite to chlorine is 1.6 to 1. To be safe
assume 2:1 by weight and assume a 2 ppm residual chlorine that must be neutralized with
a 2 ppm sulfite excess. Therefore the worst

- case c onsumption rate for the MTC test
protocol for a 5,000 gallon (18,925 liters) per minute would be:

18,925 kg X 2 ppm = .0378 kg (.083 lb.) of chlorine to neutralize
At 2:1 ratio .0378 kg X 2 = .0757 kg sodium bisulfite
At 2ppm excess 18,925 kg X 2 ppm = .0378 kg of bisulfite extra
Therefore total sulfite per 5,000 gallon discharge would be .15 kg (.33lb) of bisulfite per
minute. The MTC total ballast is 2.6 million gallons or 173 pounds of sulfite per full de

ballast.26

Costs

The purchase price for the BP

- 1000 unit as delivered for this proposal will be less than $500,000. This price covers all hypochlorite generating equipment, gas separation, all
instrumentation, all analyzers, brine supplement system, and data logger.

Operating costs are projected to be $0.03 per cubic meter of treated ballast water. The
only consumables in operating the system (assuming proper salinity seawater is
available) are electricity and sodium sulfite. Breakdown would be as follows: At power costs of $0.15 p er Kwh, electricity would be $0.02 per cubic meter of ballast treated. Sulfite costs are $0.004 per cubic meter of ballast treated. The other major
replacement item is the electrodes in the electrolytic cell. Operating life is 3000 hours

with a contribu ting cost of $0.003 per cubic meter of ballast treated. Other miscellaneous operating costs for reagents, pump seals, etc. would be another $0.003 per

cubic meter of treated ballast water.27



### SECTION VI: Discharge Validation

We at Severn Trent DeNora be lieve that the de

- ballasted water from any ship using our

BalPure TM ballast water treatment system, when operated as designed, will meet all
regulatory requirements. This belief is based on the following land based testing, clinical
toxicity testing, and input from Federal agencies.

Toxicity
Nautilus Environmental Northwest Laboratory conducted tests per the guidelines published by the Washington Department of Ecology titled “Toxicity Testing to Establish
the Environmental Safety of Proposed Ballast Wate r Biocides”. The more aggressive 7

- day survival tests were conducted. Water environments were prepared following the full
cycle of our electrolytic ballast water treatment system. Puget Sound water was treated
with chlorine using the BalPure TM chlorinat or. That seawater was then neutralized with
varying amounts of sodium sulfite to establish a safety factor for commercial operation.
Standard treatment will require a residual of 1

- 2 ppm sulfite during normal operation.

Results indicate no adverse effec t on Mysid (M. bahia and M. beryllina), bivalve larval,
kelp germination, and herring embryo up to 16 ppm residual sulfite. The summary report
is attached in the Ancillary Documents.

The University of Washington also did toxicity tests following a simila r test protocol
with systems of 75 gallons, which indicate no adverse effects on bacteria, phytoplankton,
and mesozooplankton. This work is summarized in the December 2004 report, also
attached in the Ancillary Documents.

Disinfection By

- Products

Disinfe cting agents such as chlorine, ozone, chlorine dioxide, and chloramines react with
natural organic material present in water to produce disinfection byproducts (DBPs).
Most of the research and interest in DBPs has been with drinking water. DBPs have been
known since 1974, when chloroform was identified as DBP resulting from the
chlorination of tap water. Since then, hundreds of DBPs have been identified in drinking28

water. The benefit of disinfecting drinking water is obvious as thousands of people died
from waterborne disease before municipalities began to disinfect drinking water, but it is
also generally recognized that it is important to minimize the formation of DBPs in
drinking water. Several DBPs have been linked to cancer in laboratory animals, a nd as a
result, the U.S. EPA has regulated some DBPs.

While we anticipate that most people will not be drinking ballast water and other treated
seawater, we have evaluated the formation of selected DBPs that may be formed
following the generation of hypoc hlorite in seawater. Seawater is significantly different
than freshwater, not just because of the relatively high concentration of Na + and Cl and
oftentimes higher levels of natural organic material, but also because of the presence of

Br - (bromide). Th e presence of this ion may lead to the formation of bromate (BrO 3 - ), a
compound that is considered a possible human carcinogen. In the U.S., bromate is
regulated at 10 μ g/L (10 parts per billion) in drinking water. Seawater contains a typical

bromide con centration of 65 mg/L so the concentration in seawater is significant.
Therefore, bromate was one of the DBPs measured in our research. In addition, the
presence of haloacetic acids (HAAs) and trihalomethanes (THMs) are a concern and were
measured as par t of the overall study.

Results are provided in the December 2004 University of Washington Report.
Indications were that when treating Puget Sound water spiked with 50% more
zooplankton and phytoplankton than normal concentrations, result in de

- ballasted water that meets drinking water standards for THM, HAA5, and Bromate.

Permitting and Certifications

Chemicals that are involved in the BalPure TM process are: 0.1 wt% hypochlorite solution
or 50 times weaker than household bleach is not subject to the same regulations that
govern strong hypochlorite greater than 1.0 wt%. In fact we do not know any regulations
that pertain to this hypochlorite concentration. Sodium bisulfite, either 42 wt% liquid or29

dry powder made to 42 wt%. Both are only classified as irritants. The MSDS sheets are
attached in the ancillary documents.

STDN spoke with Dennis Edwards of the EPA in Washington D.C. pertaining to the
BalPureTM system and how it would be classified as a pesticide generation device. We
presently have o ur manufacturing site registered and all our pesticide devices built on this
site are covered by Establishment Number 048482

- TX

- 001. We submit documentation
annually and will include our BalPureTM in the future. Mr. Edwards mentioned that this

documentat ion was more than adequate to cover any regulations pertaining to a chemical
Ballast Water Treatment System. No other FIFRA laws pertain to our situation at this

time.

A literature review by Dr. E. Rudd (PHD in Electrochemistry) from ElectroTechnologies
is included in the Ancillary Documentation. The review concludes that hypochlorite /
chlorine concentrations as low as 0.1 ppm can be effective as a disinfectant to kill living
marine organisms. The review also indicates sodium sulfite is a non

- toxic and non

hazardous chemical. The report is included in the Ancillary Documentation.30

SECTION VII: Land Based Experiments

Discharge Water Quality

Per the work of Russ Herwig at Marrowstone Island, the BalPure TM unit can treat

seawater to meet the Wash ington State interim ballast water discharge standards:
Inactivation of ninety

- five percent of Zooplankton organisms
Inactivation of ninety

- nine percent of Phytoplankton Inactivation of ninety

- nine percent of Bacteria

Per the work of Russ Herwig at Mar rowstone Island, the BalPure TM unit can treat

seawater to meet IMO standards:
< 10 Viable Organisms per cubic meter at > 50 micron
< 10 Viable Organisms per milliliter at < 50 micron
Eliminate bacteria to < 250 colony forming units per 100 ml

Please re fer to the three summary reports by Russ Herwig for the work done by the
University of Washington at the Marrowstone Island USGS site. The work is contained
in the Ancillary Documents

- Marrowstone Sodium Hypochlorite Mesocosm September
2004, Marrowstone Sodium Hypochlorite Mesocosm October 2004, Marrowstone
Sodium Hypochlorite Mesocosm December 2004.31



### SECTION VIII: Performance Capabilities

As outlined above in the ballast flow section, STDN has provided offshore seawater
treatment systems up to 40,000 gpm at 5 ppm available hypochlorite. STDN is proposing
a system to handle 5000 gpm at 5 ppm available hypochlorite. All results should be
scalable up or down in production capacity. Please see the table below for various

available BalPure TM Systems. STDN is marketing six different size BWT systems based
on ballast water flow rates in increments of 500 cubic meters per hour.

MODEL SEAWATER TO BE

TREATED @ 5 ppm SYSTEM OUTPUT REQUIREMENTS AC POWER

REQUIRED 

### DC POWER

M 3 /H GPM kg/H Lbs/Day AC KVA AMPS V OLTS BP

- 500 400

- 825 2200 2.5 132 35 500 48 BP

- 1000 826

- 1250 4400 5.0 264 52 500 72

BP

- 1500 1251

-

1800 6600 7.5 396 78 500 108

BP

- 2000 1801

-

2200 8800 10.0 528 103 500 144

BP

- 2500 2201

-

2600 11000 12.5 660 110 800 96

BP

- 3000 2601

-

3600 13200 15. 0 792 165 800 14432



### SECTION IX: Shipboard Test Plan

Objectives

Demonstrate operational efficacy and reliability of the BalPure system. + Hypochlorite Generation + Chlorine monitor and control + Sulfite monitor and control + Data logger oper ation Characterize geochemical and biological composition of ballasted and de

- ballasted treated and un

- treated seawater.

Introduction

The BalPure system is divided into hypochlorite generation, chlorine monitoring and
control, sulfite monitoring and co ntrol, sulfite dosing, and data logging. Only the
monitoring systems will require some operator attention. The analyzers operate with pre

packaged reagents with somewhat short shelf life and should be changed (once opened)
every 14 days. The rest of the system is relatively free of maintenance and has a 20

- year proven history in power plants and offshore applications.

The intent of the sampling and analysis program is to provide initial start

- up, training,
and commissioning assistance to the Crowley staf f. Once the mechanical system
operation is verified a second phase would be to execute a detailed sampling and analysis
program with a team from University of Washington and STDN. This program would
establish the efficacy of the BalPure unit with ballast water from various ports. This
program would be conducted over the first three voyages. The sampling and analysis
sequence would follow that listed in Table 1. To provide a control for this test, we will

fill one ballast tank with un

- treated seawater a nd the rest with treated seawater. This will
aid in determining efficacy of the system with the same quality seawater and characterize
both types of ballast water with time. Accommodations will be required for the sampling
and test team of two people to do analyses at the prescribed intervals.33

The demonstration portion of the test program follows the intense one month period
described above. This portion of the overall program will cover the next two months.
This period is required to demonstrate relia bility of the equipment and provide logged
data to demonstrate system control and meeting operating parameters.

The final portion of the program is a six

- month maintenance period to establish
maintenance cycles and further demonstrate robustness of the system. If all critical validation points are met during the first six months it would be Marine Transport’s
decision to continue the elevated monitoring program or pursue the STEP program.

Test Procedure

– Every Ballasting Operation

Four hours prior to Ballasting, turn on power to chlorine analyzer to warm up, move sensor from holding tube to unit. Replace sample line filter and reagent bottle if required.

1. Once ballast pump(s) begin pumping and BalPure unit is making chlorine, collect sample balla st water after the mix point. Do chlorine analysis using Hach Colorimeter and adjust BalPure Chlorine analyzer (see manual) to match test kit value. (Should be infrequent and minimal adjustment). 2. Set BalPure unit to desired chlorine residual, to be deter mined (3.0

– 5.0 ppm range) based on initial efficacy tests during the first two weeks of operation. Allow BalPure unit to control residual chlorine concentration. 3. When system is fully commissioned, take samples per sampling Table 1 for three bal lasting operations during the next month. 4. Once per month (for the next two months) collect two ballast water samples from the none treated tank and two ballast water samples from a treated ballast tank right after tank is full. Send samples immediately to laboratory (to be determined) for analysis. Sampling could be scheduled through University of Washington or STDN to minimize time spent by Marine Transport personnel. 5. Once per month (for the next two months) collect two ballast water samples from the n one treated tank and two ballast water samples from a treated ballast tank right before de

- ballasting.

Test Procedure

– Every De

- ballasting Operation

Two hours before de

- ballasting, install sensor and then turn on power to the sulfite analyzer. Confirm there is at least 30 gallons of sulfite solution in the dosing34

drum. Turn on power to the chlorine analyzer to confirm there is residual chlorine in the ballast tanks just prior to de

- ballasting.

1. Once ballast pumps b egin pumping, confirm de

- chlorination unit is working. 2. Sample overboard discharge and check for chlorine with Hach test kit to confirm no chlorine is present. Match hand held reading with analyzer. 3. Confirm sulfite analyzer is work ing and if required, adjust sulfite analyzer per manual. Maintain 1

- 2 ppm sulfite in the exit stream. 4. Once de

- ballasting operation is completed, shutoff power to sulfite analyzer. Record sensor sensitivity, rinse, remove sensor and affix storage cap. 4. When system is fully commissioned, follow intense sampling sequence in Table 1 for three de

- ballasting operations that match like ballasting cycles. 5. Once per month (for the next two months) collect two samples after dechlorination sy stem that match those taken in item 5 under ballasting. Send samples to laboratory (to be determined). Sampling could be scheduled through University of Washington or STDN to minimize time spent by Marine Transport personnel.

Sample Analysis All retur ned samples will be analyzed to characterize the geochemical and
biological composition of the seawater. The data will include the following:

1. Salinity 2. Dissolved Organic Carbon 3. Live organisms greater than 50 micron and smaller than 50 micron 4. Chlorophyll a 5. Bacteria 6. Disinfectant By

- Products 7. Sulfite and Sulfate Conc. 8. Toxicity35 Table 1. Data collected during ballast water treatment and voyage of Crowley vessel with STDN BalPure system installed. The number of intermediate samples collected will depend on the length of the voyage. Data Collected Ballast Tank

After Filling Ballast Tank

24 h Ballast Tank

48 h Ballast Tank Before

Discharge Discharge

Chemistry Data Salinity X Temperature X X X X X Organic carbon X

Total residual oxidant (TRO) X X X X X

Disinfection byproducts X X X X X

Sulfite X

Biology Data Zooplankton X X X X Chlorophyll a X X X X X Cu lturable phytoplankton X X X X X

Bacteria X X X X X36



### SECTION X: Ancillary Documentation