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

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

INTERNATIONAL MARITIME ORGANIZATION

IMO 

# E

MARINE ENVIRONMENT PROTECTION COMMITTEE 60th session Agenda item 2 MEPC 60/2/1 20 August 2009 Original: ENGLISH

HARMFUL AQUATIC ORGANI SMS IN BALLAST WATER

Application for Final Approval of HHI Balla st Water Management System ìEcoBallastî

Submitted by the Republic of Korea

SUMMARY

Executive summary: This document contains the non-conf idential information related to the application for Final Approv al of the HHI Ballast Water Management System ìEcoBallastî, in accordance with the Procedure for approval of ballast water management systems that make use of Active Substances (G9) adopt ed by resolution MEPC.169(57)

Strategic direction: 7.1

High-level action: 7.1.2

Planned output: 7.1.2.4

Action to be taken: Paragraph 7

Related documents: BWM/CONF/36; MEPC 57/21; MEPC 58/23; MEPC 59/2/4; BWM.2/Circ.18; MEPC 59/2/16 and MEPC 59/24

Introduction

1 Ballast water management systems, which make use of Active Substan ces or Preparations containing one or more Active Substances, shall be approved by the Organization under regulation D-3.2 of the BWM Convention.

2 The Procedure for approval of ballast water management systems that make use of Active Substances (G9), adopted by resolution MEPC.169(57), defi nes the principal aspects to be documented by data or testing (MEPC 57/ 21, annex 1, paragraph 4.2.1) and some basic principles for risk evaluation (MEPC 57/21, annex 1, paragraph 5.3). According to section 6 of Procedure (G9), the Organization should evaluate the informati on provided in the application.MEPC 60/2/1 - 2 -

I:\MEPC\60\2-1.doc 3 According to BWM.2/Circ.18, proposals for approval of ballast water management systems that make use of Active Substances are to be submitted to the Marine Environment Division of the Organization to be reviewed by the GESAMP-Ba llast Water Working Group. In the meantime, a document on the proposal for a pproval containing all th e non-confidential data related to the respective ballast water management systems that make use of Active Substance needs to be submitted to MEPC 60.

4 Having granted Basic Approval to the HHI Ballast Water Management System ìEcoBallastî (MEPC 59/24, paragraph 2.5.2), the Committee noted the opinion of the GESAMP-BWWG that the application related to the above-mentioned system also fulfilled the requirements of Procedure (G9) for Final Approval.

5 The competent authority in the Republic of Korea has verified the application dossier for Final Approval prepared by Hyundai Heavy Industr ies Co., Ltd. (HHI) and be lieves it to satisfy the data requirements of Procedure (G9).

6 The Republic of Korea therefore submits th e non-confidential part of the applicantís dossier in the annex of this document to the Organization for evaluation according to Procedure (G9).

Action requested of the Committee

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

***MEPC 60/2/1

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

PROPOSAL FOR FINAL APPROVAL OF HHI BALLAST WATER MANAGEMENT SYSTEM ìEcoBallastî

Contents

0 SUMMARY OF REVIEW BY GESAMP-BWWG (MEPC 59/2/16)

1 INTRODUCTION

1.1 Working principles of the HHI Ballast Water Management System, ìEcoBallastî 1.2 Description of the ìEcoBallast î system and its components 1.3 Development of Helix type UV reactor 1.4 Description of the pilot scale test system of ìEcoBallastî 1.5 Operation of test facility 1.6 Sampling and Measurements 1.7 Full scale (200m 3 /hr) test results

2 DEFINITIONS

2.1 Terms and Definitions

2.2 Background for determining the ìActive Substanceî and ìRelevant Chemicalsî 2.2.1 Introduction 2.2.2 Direct Damage 2.2.3 Indirect Damage 2.2.3.1 Formation of hydroxyl radical (OHï) 2.2.4 Active Substances 2.2.5 Relevant chemicals (hydroxyl radical (OHï))

3 PRINCIPLES

4 GENERAL REQUIREMENTS

4.1 Identification 4.1.2 Active Substance 4.1.3 Relevant Chemicals 4.1.4 Discharge characteristics 4.1.4.1 Literature Reviews

4.2 Data-set for Active Substa nces and Preparations 4.2.1 Properties and actions of the Preparation 4.2.2.1 Acute and Chronic aquatic toxicity 4.2.2.2 Data on mammalian toxicity 4.2.2.3 Data on environmental fate and effect under aerobic and anaerobic conditions 4.2.2.4 Physical and chemical propertie s for the Active Substances and Preparations and the treated ba llast water, if applicable 4.2.2.5 Analytical methods at environmen tally relevant concentrations

4.3 Assessment reportMEPC 60/2/1
ANNEX Page 2

I:\MEPC\60\2-1.doc 5 RISK CHARACTERIZATION

5.1 Screening for persistency, bioaccumulation and toxicity 5.2 Toxicity testing of the treated Ballast Water 5.3 Risk characterization and analysis

6 EVALUATION CRITERIA

6.3 Ship and personnel safety 6.3.4 Hazard Identification (HAZID) study of ìEcoBallastî Management System 6.3.5 Managements in emergency conditions

6.4 Environmental protection

7 REGULATION OF THE USE OF ACT IVE SUBSTANCES AND PREPARATIONS

7.1 Handling of Active Substances and Preparations 7.2 Hazard documentation and labelling

8 APPROVAL

9 CONCLUSION

10 REFERENCES

11 APPENDICES

A ppendix 1 : QUALITY ASSURANCE PROJECT PLAN (QAPP) FOR TESTING HHI-BWM (ìEcoBallastî) SYSTEM FOR TYPE APPROVAL AND FULL SCALE (200 m 3 /hr) TEST REPORT
A ppendix 2 : QUALITY ASSURANCE PROJECT PLAN (QAPP) FOR HHI-BWM (ìEcoBallastî) SYSTEM AND TEST REPORT FOR CHEMICAL ANALYSIS
A ppendix 3 : AQUATIC TOXICITY TEST
A ppendix 4 : CORROSIVITY TEST FOR UV-TREATED BALLAST WATER
A ppendix 5 : HAZID STUDY ON ìEcoBallastî
A ppendix 6 : SYSTEM DESCRIPTION OF HHI BALLAST WATER MANAGEMENT SYSTEMMEPC 60/2/1
ANNEX

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I:\MEPC\60\2-1.doc PROPOSAL FOR FINAL APPROVAL OF HHI BALLAST WATER MANAGEM ENT SYSTEM ìEcoBallastî

This report is structured in accordance with th e headlines in the ìProcedure for approval of Ballast Water Management systems that make use of Active Substances (G9)î.

0 SUMMARY OF REVIEW BY GESAMP-BWWG

0.1 HHI ìEcoBallastî was submitted for Basic Appr oval and reviewed at the eighth meeting of the GESAMP-Ballast Water Working Group (GESAMP-BWWG). The following comments were received from the GESAMP-BWWG (MEPC 59/2/16).

0.2 Having reviewed all the information receiv ed from the applicant, the Group decided to recommend that Basic Approval be given to th e HHI EcoBallast Ballast Water Management System proposed by the Republic of Korea.

0.3 The Group noted that the HHI EcoBallast Ballast Water Management System uses a combination of Filtration and Medium Pressure UV Disinfection to treat the ballast water.

0.4 The Group was satisfied that, as the system does not involve the storage or generation of chemicals to treat ballast water, there were no associated storage safety problems.

0.5 The Group noted that the Medium Pressure UV technology in the HHI EcoBallast System makes use of electromagnetic radiation (photons) in order to treat ballast water. As such, the Group considered that it was neither necessa ry nor practical to provide the physical characteristics or toxicologi cal profiles of such photons.

0.6 However, it was recognized that the ra diation (photons) might react with naturally occurring organic molecules in seawater to fo rm by-products with safety and environmental concerns. Half-lives of the photons are expected to be in the order of micro- to milli-seconds.

0.7 Based on results from the chemical analyses of treated ballast wate r, the Group concurred with the views of the applicant that it was not necessary to provide toxicological and ecotoxicological data on these by-products and that the evalua tion of the possible effects of treated ballast water provided in the submitted dossier was sufficient.

0.8 The Group noted that the acute and chro nic aquatic ecotoxicity testing had been performed as a full-scale land-based test in acco rdance with the requiremen ts of Procedure (G9) for Final Approval (MEPC 57/21, annex 1, appendix).

0.9 The Group noted that the potential hazards fo r human health related to overheating of UV lamps and exposure to UV irradia tion resulting from operating this system were sufficiently addressed by the applicant by engineering control measures pu t in place and training of operators. Therefore, the Group concluded that the risks to the crew from exposure were sufficiently mitigated by the measures put in place.

0.10 In addition, the Group noted that all the disinfection by -products measured in the discharged ballast water were under LOD w ith exception of AOX (Adsorbable Organic Halogens) (0.29mg/L at day 5). The Group consid ered that these chemicals are short-lived and would not pose a toxicological concern toward s the general public swimming and eating fish from the area.MEPC 60/2/1
ANNEX Page 4

I:\MEPC\60\2-1.doc 0.11 Having reviewed all the information in th e non-confidential submi ssion and the information received from the applicant during the GE SAMP-BWWG meeting, th e Group decided to recommend that Basic Approval be given to the BWMS submitte d by the Republic of Korea.

0.12 Moreover, the Group was satisfied that the re quired tests had been performed correctly and that the results demonstrated that the syst em met the requirements of Procedure (G9) to allow it to be recommended for Final Approval. The Group is of the opinion that this application fulfilled the requirements for Final Approva l in accordance with Procedure (G9).

0.13 With regard to completeness, the Group did not have any concerns which it considered should be addressed for Final A pproval as the applica tion contained all the information required to allow it to be reviewed (M EPC 59/2/16, annex 8, paragraph 2.1).MEPC 60/2/1
ANNEX

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

1.1 Working principles of the HHI Ballas t Water Management System ìEcoBallastî

The ballast water is treated at intake (ballastin g) and again at discharg e (de-ballasting). The treatment during intake ensures th at a minimal amount of viable or ganisms enter in to the ballast water tanks and reduces sediment built-up in the ballast water tanks , which is a poten tial area for survival and growth of organisms. The water is treated again during discharge to ensure that any potential re-growth of organisms in the ballast wa ter tanks is prevented. The working principle is disinfection or destruction of organisms thr ough UV radiation without addition of chemical compounds, so the ìEcoBallastî system represen ts a chemical-free disinfection procedure.

HHI ìEcoBallastî has received a comment for its chemical-fre e disinfection procedure in MEPC 59/2/16, annex 8, paragraph 3.2.1.3, as follows:

ì3.2.1.3 The Group accepted that this system re presents a chemical-free disinfection procedure as no chemical compounds are added to the process.î

1.2 Description of the ìEcoBallast î system and its components

The ìEcoBallastî Water Management System is a complete system and its operation can be divided into three main functi ons: filtration; disinfection of marine organisms through UV radiation; and controls and auxiliary functions. Accordingly, the system is composed of three main units: 1) a filtration unit; 2) a UV reactor, and 3) a control and cleaning unit. The ìEcoBallastî system is illustrated schematically in Figure 1. The detailed description of ìEcoBallastî is prepared in appendix 6.

Figure 1: Schematic Process Diagram of the ìEcoBallastî Water Management SystemMEPC 60/2/1
ANNEX Page 6

I:\MEPC\60\2-1.doc .1 The filtration unit

This filter unit is composed of a 50 μm filter with automatic back flushing. This automatic back-flushing filter is a self-clean ing system for extracting particles from low viscosity fluids. Its robust construction a nd automatic back-flushing capability make a major contribution to operati onal reliability and reduce opera ting and maintenance costs.

The slotted tube filter elements ensure hi ghly effective filtration of contaminating particles from seawater. Automatic cleani ng starts as soon as the elements become contaminated when the pressure drop across the filter element reaches to the set-point.

Filter unit is installed after ballast pump discharge valve or common pipe and will be located before UV reactor to ensure water quality such as water transmittance and to remove large size organisms and sediment which could affect s ubsequent treatment.

The fluid to be filtered flows through the slotte d-tube filter elements of the back-flushing filter, passing from the inside to the outside. Contamination particles then collect on the smooth inside of the filter elements. As th e level of the contamination increases, the differential pressure between the contaminated and clean sides of the filter increases. When the differential pressure reaches its pre-set value, back-flushing operation starts automatically.

The filter removes larger particles and organisms from the seawater. This filtration reduces the sediment load of the ballast wate r and hence reduces sediment build-up in the ballast water tanks. The filter is fully automatic in terms of its operation and cleaning without affecting the filtration process, and ba ckwashing water is returned into the sea
in situ . The filter unit operates only during ballas ting; during de-ballasting, the filter unit is bypassed. The detailed description of filter unit is prepared in appendix 6.

.2 The UV Reactor

The ballast water is treated by UV radiati on both during ballastin g and again during de-ballasting to destro y any organism which might have re-grown or survived in the ballast water tanks during the voyage.

The Helix type UV reactor of the ìEcoBallastî system which has been specially designed for ballast water application to reduce spa ce and to maximize its efficiency employs a high-intensity, medium-pressure ultra-violet lamp. The helix UV reactor overcomes the limitation of previous UV systems for applica tion to ballast water treatment because the helical lamp structure decrea ses the probability that wate r volume segments, including micro-organisms, pass the UV chamber wit hout being exposed to sufficiently high UV-doses. Sectors with relatively high velo city and low irradia tion flow have been eliminated as far as possible. The helix lamp arrangement ( patent pending ) overcomes the need for additional chemical treatment due to a revolutionary lamp arrangement leading to an extremely uniform dose dist ribution at ideal hydraulic conditions. The applied UV dose is ideal and even organisms w ith very high resistance to UV light can be inactivated definitively. This system represents a chemical-free disinfection procedure as no chemical compounds are added to the process.MEPC 60/2/1
ANNEX

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I:\MEPC\60\2-1.doc .3 The control and cleaning system

The system control unit controls ìEcoBallast î management system and supplies power to all items, and the water flow meter and al arms are installed at different levels.

One method for gauging UV effectiveness is to compute UV dose. UV dose is the most important control variable in system to kill small organism and it depends on flow rate, water quality, lamp age and UV light outpu t from UV lamp. However, UV dose cannot be measured by direct measurement device. System controls only UV lamp output to adapt UV dose by controlling power of ballast de vice until system flow is in design range.

In system, UV dose will be controlled to op timize power efficiency, according to flow rate and water quality (appendix 6).

The system comprises also a ìcleaning in place î (CIP) unit, which is an automatic service device that cleans the quartz sl eeves covering the UV-lamps after each ballasting and de-ballasting operation. The operation is according to program by manual initiation during voyage period. CIP unit is installed adjacent to UV reactor and the line is connected to every UV reactors. After servi ce operation of UV reactors, reactors will be cleaned by CIP unit one by one.

Biodegradable acid solution could be used to solve the chemical deposits such as calcium carbonate, magnesium carbonate, and so on. Clean ing solution is reusable until its life time and all cleaning solution will be rec overed to CIP tank at the end of cleaning operation. The life time of clean ing solution can be detected by installed pH meter or cleaning performance after cleaning operation, wh ich can be estimated by comparing light intensity before and after cleaning. The deta iled description of clea ning unit is prepared in appendix 6.

The application for Final Approval will focus on the Helix type UV reactor. The filter and other components are not c onsidered to be relevant fo r Active Substance approval.

During the review of HHI ìEcoBallastî, Basic Approval application by the GESAMP-BWWG, HHI has received the qu estion about cleaning procedure of ìEcoBallastî, as follows:

ìThe Group recognized that this UV syst em has a complex design and lamp arrangement (the Helix) and we wonder what kind of cleaning device or cleaning solution you are foreseeing to use?, and how frequently would this need to be applied to ensure proper f unctioning of your system?î

The detailed descriptions of cleaning procedure are as follows:

CIP (Clean-In-Place) cleaning unit will be used to clean outside of quartz sleeve installed in UV reactor. Through circulation of cleani ng solution in UV reacto r after its operation, limescale deposits, such as calcium carbonate , magnesium hydroxide and so on, on the surface of quartz sleeve can be removed by aci dity. For acid cleaning, strong and weak acid can be used. But, for crew safety and e nvironmental risk, biodegr adable weak acid is desirable. In considering biodegradability a nd safety in handling, 5% citric acid solution was selected as a cleaning solution. Cl eaning performance could be monitored by comparing light intensity values before and after cleaning. As addressed in systemMEPC 60/2/1
ANNEX Page 8

I:\MEPC\60\2-1.doc description, it is recommended that during star t-up of treatment operation, operator checks the intensity value and compares historical values whether the cleaning operation is acceptable or not.

Cleaning requirements is function of water qua lity and operation time. Up to now, the operational recommendation is cleaning afte r every operation longer than 15 hours or after every 15 hours operation for short ballasting and deballasting time period.

Beside the question being addressed, our addi tional concern is life time of cleaning solution. Cleaning power of solution depends on acidity. Acidity can be decreased by alkalinity. Available acidity can be monitored by measuring pH of solution.

LS

T1 CIP Tank

to Bilge Holding Tank IV-R1

CIP Pump MV-T1 50A MV-T2 50A

25A MV-F-2 MV-F-1 UV Reactor

DV-R1 RV-R1 FV-R1 OV-R1

Fresh water AE

R1-1 AE

R1-2 LS

R1-H

LS

R1-L TE

R1 MV-R1-2

MV-R1-1 VV-R1

to Bilge Well

Drain line to Bilge Holding Tank, 40A Flow Out

25A to 40A MV-T3 25A Flow In

25A

LS

T2

Figure 2: Schematic connection diagram of CIP Unit and UV reactorMEPC 60/2/1
ANNEX

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I:\MEPC\60\2-1.doc 1.3 Development of Helix type UV reactor

UV technology

In principle two different UV-T echnologies (low pressure, LP, and medium pressure, MP) are available for disinfection. Essentially, a UV sp ectrum has to be applied, which inactivates microbial organisms, and the so-called germicid al range is at wavelengths between 200-300 nm. This value is usually approximated by the relative absorbance of DNA. Germicidal effectiveness of the 254 nm emission line by LP (low pressure) UV lamps is regarded as unity. Some basic differences between LP and MP UV-t echnology are summarized in Table 1.

Table 1: Summary of low pressure and medium pressure UV technologies

Parameter Low-Pressure LP (Amalgam) Medium-Pressure MP

Germicidal action spectrum Monochroma tic spectrum Polych romatic spectrum
Operating Temperature Optimal at 100°C 600 ñ 900°C
Electrical Input (W/cm) 2 50 ñ 250 Germicidal UV Output (W/cm) 0.7 5 ñ 30

Arc length (cm) 20 ñ 200 5 ñ 120
Relative Number of Lamps High Low
Lifetime (hrs) 8,000 ñ 12,000 3,000 ñ 5,000

Concerning the electrical effec tiveness, the LP technology appears the better choice. However, for application to ballast water treatment othe r parameters are also relevant. These are summarized in Table 2.

Table 2: Relevant parameters for ballast wate r treatment application of UV technologies

Technology Low-pressure LP Medium-pressure MP

Parameters Rating Reason Rating Reason

footprint Poor High number of lamps Good Low number of lamps pressure loss Poor High number of lamps Good Low number of lamps

Efficiency (Germicidal) Moderate Monochromatic action spectrum, 254 nm Good Polychromatic action spectrum, Each micro-organism has a unique action spectrum. Damage to other molecules than DNA,

e.g., enzymes

Reliability Good Low operating temperature. High lamp life. Moderate High operating temperature. Average lamp life.
Power consumption Low High UVC output at
254 nm Moderate High UVC output in the range of 200-300 nmMEPC 60/2/1
ANNEX Page 10

I:\MEPC\60\2-1.doc As a result of the comparisons in Table 1 and Ta ble 2, it is concluded that MP technology is most efficacious for ballast water application because of the polychromatic UV spectrum which will cause damage to a wide range of micro-organisms.

Standard UV treatment systems have been used successfully in drinking water and waste water applications during several decades, but there are not sufficient literature data available for ballast water application of such standard UV systems. Some literature data suggest that the UV dose for some marine species va ries from 200 to 300 mWs/cm 2 to reach a 3-log step reduction for ballast water application. However, the long experience of our co-developer, Wedeco AG Germany, as well-known manufacturer of UV-disinf ection systems for drinking water and waste water treatment plants, suggest that traditional UV systems are not capable producing sufficiently high UV-intensities required for appl ication in ballast water treatment.

Laboratory pre-tests with different types of algae

Laboratory pre-tests were conducte d to obtain spectra indicating the sensibility of different phytoplankton species exposed to di fferent types of UV radiation. Seven different species of algae were selected and their survival when exposed to UV-LP and/or UV-MP radiation was tested in the laboratory. The results are s hown in Figure 2. For the marine phytoplankton species, Symbiodinium sp ., a UV-MP dose of 60 mWs/cm 2 is needed to achieve a 1 log step mortality rate (Figure 3 (h)).

UV design in order to m eet shipboard requirements

Due to the fact that ships operate globally, a UV- system for ballast water treatment has to be designed so it can operate under wi de range of inlet water conditi ons. Different water qualities represent a considerable challenge to the perfor mance of the UV system. UV radiation does not spread homogenously in water; the spreading decr eases logarithmically with the distance from the point of radiation. In orde r to deal with the non-uniform sp reading of the UV radiation, the construction of the UV lamp and the reactor ch amber has been re-designed. The chamber has been changed so that water flow is in the dire ction along the quartz tubes rather than across the quartz tubes as in conventional UV systems. The change of water flow together with the new developed helical shape of the UV lamp ensures th at all organisms in the water will receive more or less the same high dose of radiation.

The following design has been developed to meet shipboard requirements:

! reduction of the number of lamps: UV-MP technology with high power lamps;

! a new developed UV-MP lamp with a helical structure to achieve high efficiency in the treatment of the seawater;

! a new design of the reactor chamber with a changed water flow resulting in more uniform and efficient exposure of th e seawater to UV radiation; and

! pipe shape designed to fit existing pipe works.MEPC 60/2/1
ANNEX Page 11

I:\MEPC\60\2-1.doc 0 1000 2000 3000 4000 5000Log(N/No)

-5 -4 -3 -2 -1 0

0 1000 2000 3000 4000 5000 -5 -4 -3 -2 -1 0

0 1000 2000 3000 4000 5000Log(N/No)

-5 -4 -3 -2 -1 0

0 1000 2000 3000 4000 5000 -5 -4 -3 -2 -1 0

0 1000 2000 3000 4000 5000Log(N/No)

-5 -4 -3 -2 -1 0

0 1000 2000 3000 4000 5000 -5 -4 -3 -2 -1 0 (a) (b)

(c) (d)

(e) (f)

UV Dose (J/m 2 ) 0 1000 2000 3000 4000 5000Log(N/No)

-5 -4 -3 -2 -1 0

UV Dose (J/m 2 ) 0 1000 2000 3000 4000 5000 -5 -4 -3 -2 -1 0

(g) (h)

Figure 3: Laboratory pre-test with 7 different algae with LP and MP UV radiation. N o means the initial concentration of alg ae and N means the final concentr ation of algae. (a) LP UV, Phaeodactylum , (b) LP UV, Diatom Cyclotella , (c) LP UV, Tetraselmis , (d) LP UV, Scrippsiella

, (e) LP UV, Symbiodinium , (f) LP UV, Scenedesmus , (g) LP UV, Haematococcus , (h) MP UV, Symbiodinium , UV dose has a unit of 1 mWs/cm 2 which is equal to 10 J/m 2

.MEPC 60/2/1
ANNEX Page 12

I:\MEPC\60\2-1.doc Reactor design

Based on the pre-test results and design princi ples mentioned above, a computational fluid dynamics (CFD) simulation had been carried out aiming at keeping the number of lamps and the process-related power consumption in a mode rate range but with a high UV efficiency.

(b)

(a)

(c)

(d)

Figure 4: CFD analysis and development of helix UV reactor:

(a) CFD analysis of helix UV reactor, (b) conceptual design of helix UV reactor, (c) first prototype helix UV reactor and test of its performance with Symbiodinium , and (d) final product of helix UV reactor.

The first prototype UV reactor (Figure 4) was designed and manuf actured based on CFD modelling. The efficiency of the helix UV reactor was calculated by CFD analysis and tested with Symbiodinium at different flow rates.

The hydraulic test and ca lculation up to 3,000 m 3 /hr flow rate (4.2 m/s of flow velocity) to see the stability of UV lamp arrangement was perfor med without any problem.MEPC 60/2/1
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I:\MEPC\60\2-1.doc 1.4 Description of the pilot scal e test system of ìEcoBallastî

The pilot scale test system is set up at Hyundai Heavy Industries Co. LTD, City of Ulsan, Korea in accordance with the IMO requirements (Figure 5), and is used for the toxicity test, performance test, corrosivity test and chemical water analysis.

Figure 5: Land based test facility at Hyundai H eavy Industries Co. LTD, Ulsan, Korea. The helix UV reactor was installed and its performance was tested.MEPC 60/2/1
ANNEX Page 14

I:\MEPC\60\2-1.doc The flow diagram of the test facility is shown in Figure 6. It has three 280 m 3 ballast tanks and
a 250 m 3 /hr ballast pump. All materials for the test faci lity such as pipes, valves, steel and paints are the same as used in ships.

Strainer Tank - 1

Tank - 2

Filter

UV Module Tank - 3 East Sea

Figure 6: Flow diagram of the test facility at Hyundai Heavy Industries Co. LTD.

All tanks have drain valves in the bottom of each tank and the water in each tank can be drained. The test facility has 5 sampling points in the pipes. To get representative samples from the sampling points, the sampling port is located in the centre of pipe and in the opposite direction of the water flow (Figure 7.)

Figure 7: Diagram of a sampling port installed in a pipeMEPC 60/2/1
ANNEX Page 15

I:\MEPC\60\2-1.doc HHI ìEcoBallastî has received a comment for full-scale perfor mance test in MEPC 59/2/16, annex 8, paragraph 3.2.2.3, as follows:

ì3.2.2.3 The Group noted that, according to the applicant the full-scale (200 m 3 /hr) performance test was done according to the IMO Guideline (G8). The test results showed that the EcoBallast system meet s the Ballast Water Performance Standard contained in regulation D-2 of the IMO Ballast Water Management Convention.î

1.5 Operation of test facility

Flow rate 210 ± 10 m 3 /h Treatments Two treatments, during ba llasting and during de-ballasting Power consumption 39 ± 1 kW for UV unit Less than 1 kW for Filter Unit Treated volume more than 200 m 3 Salinity 34 PSU (Seawater), 21 PSU (Brackish water)

Note : For test operation, UV transmittance of water was in range between 88 and 95%. In this operation, UV dose was in range between 190 and 350 mWs/cm 2

.

Intake of seawater, Figure 8

Through the intake pump, the seawater was pumpe d into tank-1(100A) and tank-2(100B) passing through the strainer to remove larger particle. Starch, gluc ose, phytoplankton, zooplankton, and heterotrophic bacteria were added to tank-1( 100A) and tank-2(100B) to meet the influent conditions of the IMO guidelines; POC, TSS, DOC, marine organisms and heterotrophic bacteria, respectively if needed.

For the brackish water tests, lake water suppl ied to Hyundai Heavy In dustries Co. Ltd. without any treatment was added to the seawater.

Strainer Tank - 1

Tank - 2

Filter

UV Module Tank - 3 East Sea

Figure 8: Flow diagram of the test facil ity during intake of seawaterMEPC 60/2/1
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I:\MEPC\60\2-1.doc Ballasting ñ Treatment Operation, Figure 9

The seawater which meets IMO influent guidel ine flows through the filter and the helix UV reactor to tank-3(400) to simulate ballasti ng treatment operation mode. The flow rate through UV reactor was cont rolled larger than 200m 3 /hr using a flow control valve and flow meter installed after UV reactor.

After ballasting-treatment operation, tank-1(100A) a nd all pipes were drained and flushed with seawater. The tank-1(100A) was cleaned with pre ssurized clean potable water and dried with air that was supplied to each tank.

Strainer Tank - 1

Tank - 2

Filter

UV Module Tank - 3 East Sea

Figure 9: Flow diagram of the test faci lity in ballasting operation mode.MEPC 60/2/1
ANNEX Page 17

I:\MEPC\60\2-1.doc Ballasting ñ Control Operation, Figure 10

During ballasting-control operation, the seawater of Tank-2(100B) was tr ansferred to Tank-1 (100A) bypassing both of the filter and the heli x UV reactor. During be ginning about 5 minutes, the seawater from Tank-2(100B) af ter bypassing both of th e filter and UV reac tor was discharged to sea to flush the pipe.

Strainer Tank - 1

Tank - 2

Filter

UV Module Tank - 3 East Sea

Figure 10: Flow diagram of the test facility during ballasting- control operation

Storage, Figure 11

The treated seawater in Tank-3( 400) and untreated cont rol seawater in Tank- 1(100A) were stored for 5 days. During the storage, the ballast tanks were completely shielded from light.

Strainer Tank - 1

Tank - 2

Filter

UV Module Tank - 3 East Sea

Figure 11: Diagram of the test facility during storageMEPC 60/2/1
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I:\MEPC\60\2-1.doc Deballasting ñ Treatment and Discharge Operation, Figure 12

The seawater which has been stor ed at Tank-3(400) for 5 days was discharged through the helix UV reactor, but bypassing the filter. During disc harge, seawater was sampled for discharged water toxicity tests, performance test and corrosivity test.

Strainer Tank - 1

Tank - 2

Filter

UV Module Tank - 3 East Sea

Figure 12: Flow diagram of the test facili ty in de-ballasting operation mode

Deballasting ñ Control and Discharge Operation, Figure 13

The seawater which has been stored at Tank-1( 100A) for 5 days was di scharged bypassing both of the filter and the helix UV reactor. During disc harge, seawater was sampled for the control of discharged toxicity test and pe rformance test. After finishing every one cycle experiment, all tanks and pipes were cleaned with natural seawat er and clean portable water and all tanks were dried with dry air.

Strainer Tank - 1

Tank - 2

Filter

UV Module Tank - 3 East Sea

Figure 13: Flow diagram of the test facility during de-ballasti ng-control operationMEPC 60/2/1
ANNEX Page 19

I:\MEPC\60\2-1.doc 1.6 Sampling and Measurements

Sampling locations (points) are indicated by P0-P 4 in Figure 14. All grab samples for chemical analysis and performance analysis (see Table 3) were collected in triplicates at beginning, middle, and end of ballasting and de-ballasting mode if necessary. P0 indicates the raw seawater to use as the control for corrosivity test. P1, P2 and P3 represent the sampling from each tank, Tank 1(100A), Tank 2(100B) and Tank 3(400A), respec tively. Sampling point P4 was used to sampling for corrosivity test, toxicity test, ch emical analysis, and performance analysis. Procedures for sampling and transfer are desc ribed in detail in a ppendix 1, section 1.3.

Seawater was sampled according to the guideline to test;

! whether the water quality in the initial test waters (Tank-1(100A), P1 and Tank-2(100B), (P2) is meeting the chemical and biological water quality criteria defined by IMO;

! the efficiency of the HHI ìEcoBallastî system in removing/inactivating target organisms during ballasting and deballa sting after 5 days storage (P4);

! the corrosivity of UV-treated seawater directly after treatment at the time of ballasting (P4);

! the water quality in the control tank (Tank-1( 100A)) as a reference to the water quality of control tank during discharg e after 5 days storage (P4);

! the acute and chronic environmental toxic ity after 5 days storage at the time of de-ballasting from Tank-3(400A ) and Tank-1(100A) (P4); and

! any by-products formation after ìEcoBallast î treatment at day 0 before ballasting (P1, P2), during ballasting (P4), at day 1( P1, P3), at day 5 before deballasting (P1, P3), and at the tim e of discharge (P4).

Detailed information for sampling is described in Table 3 and the required sample volume was followed according to IMO guideline as follows:

! 1 Litre :

- Marine organisms, ≥ 10 ñ 50 μ m for control

! 1 Litre x 4

- Bacteria group

! 1 Litre

- DOC/POC

! 1 Litre

- TSS

! 0.02 ñ 10 Litres :

- Quality of water (chemical analysis)

! 10 Litres :

- Marine organisms, ≥ 10 ñ 50 μ m for treated

! 20 Litres :

- Marine organisms, ≥ 50 μ m for control

! 1 m 3 :

- Marine organisms, ≥ 50 μ m for treatedMEPC 60/2/1
ANNEX Page 20

I:\MEPC\60\2-1.doc Sea Tank 1 (TK-100A)

Tank 2 (TK-100B) Tank 3 (TK-400A)

Seawater Intake Pump Transfer Pump Filter Unit UV Unit

Discharge to Sea P1

P2 P3

P4 2 0 0 A p i p e50A pipe

Sample Flow

P0

Figure 14: Test water flow diagram; Pos itions of sampling are as follows:

P0: Raw seawater; P1: IMO influent requirement for treatment on day 0 and control water on day 5; P2: IMO influent requirement for control water on day 0; P3: treated water on day 1 and day 5; P4: treated and control water during ballas ting on day 0 and de-ballasting on day 5.MEPC 60/2/1
ANNEX Page 21

I:\MEPC\60\2-1.doc Table 3: Grab sample information from ìEcoBallastî system

Sampling Location Sample for Control
water Treated
water On-site
measurements Off-site
measurement Sampling time *1)

Corrosivity P0 P4 - Corrosivity

Toxicity P4 P4 - Toxicity
Day 0 before

ballasting P2 P1

Day 0 during

ballasting P4 P4 B, M, E

Day 1 P1 P3 Day 5 before de-ballasting P1 P3 Chemical Analysis

Day 5 during de-ballasting P4 P4 - DO

- ORP

- pH

- Salinity

- TRO

- Turbidity

- Temperature - DOC, TOC, POC *2)

- Chemicals

B, M, E

IMO influent P2 P1 Day 0 during

ballasting P4 P4 B, M, E

Day 5 before de-ballasting P1 P3 Performance

Analysis

Day 5 during de-ballasting P4 P4 - DO

- ORP

- pH

- Salinity

- Turbidity

- Temperature - Organisms:
≥ 50 μ m, ≥ 10 ñ 50 μ m

- Bacteria

- TSS B, M, E

Note: 1) B means ìBeginning of the test; M means ìMi ddle of the testî; E means ìEnd of the testî. 2) POC is estimated value from difference between TOC and DOC.

1.7 Full-scale (200 m 3 /hr) test results

The full scale (200 m 3 /hr) performance test was done according to IMO Guidelines (G8). Test results show that the ìEcoBallastî system meets the Ballast Water Performance Standard contained in Regulation D-2 of the IMO Ball ast Water Management Convention. Detailed description was in appendix 2.

Table 3-1: Organism concentrations in influent water

Test period Organism classification Organism
concentration Minimum G8 requirement Assessment

≥ 50 μm (individuals/m 3 ) 4.62 × 10 5 ≥ 10 5

≥ 10-50 μm (individuals/mL) 1.28 × 10 3 ≥ 10 3 1-6 (> 32 PSU) Heterotrophic Bacteria (cells/mL) 2.60 × 10 4 ≥ 10 4 ACCEPTABLE

≥ 50 μm (individuals/m 3 ) 2.80 × 10 5 ≥ 10 5

≥ 10-50 μm (individuals/mL) 1.65 × 10 3 ≥ 10 3 2-5 (> 3-32

PSU) Heterotrophic Bacteria (cells/mL) 3.50 × 10 4 ≥ 10 4 ACCEPTABLEMEPC 60/2/1
ANNEX Page 22

I:\MEPC\60\2-1.doc Table 3-2: Organism identifications in influent water

Test period Organism classification Species composition of organism Minimum G8 requirement Assessment

≥ 50 μm 4 phylum 10 species 3 phylum 5 species 1-6 (> 32 PSU) ≥ 10-50 μm 3 division 13 species 3 division 5 species ACCEPTABLE

≥ 50 μm 6 phylum 10 species 3 phylum 5 species 2-5 (> 3-32

PSU) ≥ 10-50 μm 4 division 12 species 3 division 5 species ACCEPTABLE

Table 3-3: Measurement of DOC, POC, TSS and salinity in influent water

Test period Sample DOC (mg/L) POC (mg/L) TSS (mg/L) Salinity (PSU) Minimum G8 requirement Assessment

Treatment 4.55 2.20 31.83 1-6 (> 32 PSU) Control 4.62 2.12 32.50 33.95 1 mg/L DOC 1 mg/L POC 1 mg/L TSS ACCEPTABLE

Treatment 26.30 8.15 79.53 2-5 (> 3-32

PSU) Control 11.40 7.95 77.10 20.81 5 mg/L DOC 5 mg/L POC 50 mg/L TSS ACCEPTABLE

Table 3-4: Assessment of Regulation D-2 compliance

Viable organism Test period Organism classification

T5 D-2

Standard Assessment

≥ 50 μm (individuals/m 3 ) 0 < 10

≥ 10-50 μm (individuals/mL) 0 < 10

Escherichia coli (cfu/100 mL) 0 < 250

Intestinal Enterococci (cfu/100 mL) 0 < 100 1-6 (> 32 PSU)

Toxicogenic Vibrio cholerae (cfu/100 mL) ND < 1 ACCEPTABLE

≥ 50 μm (individuals/m 3 ) 0 < 10

≥ 10-50 μm (individuals/mL) 0 < 10

Escherichia coli (cfu/100 mL) 0 < 250

Intestinal Enterococci (cfu/100 mL) 0 < 100 2-5 (> 3-32

PSU)

Toxicogenic Vibrio cholerae (cfu/100 mL) ND < 1 ACCEPTABLE

Note: T5 means treated (deballasted) water after five days storage sampled at P4.MEPC 60/2/1
ANNEX Page 23

I:\MEPC\60\2-1.doc Table 3-5: Assessment of valid condition for land-based test

Viable organism Test period Organism size class C5 Minimum G8 requirement Assessment

≥ 50 μm (individuals/m 3 ) 1.10 × 10 5 ≥ 100 1-6 (> 32 PSU) ≥ 10-50 μm (individuals/ml) 1.32 × 10 2 ≥ 100 ACCEPTABLE

≥ 50 μm (individuals/m 3 ) 2.27 × 10 4 ≥ 100 2-5 (> 3-32

PSU) ≥ 10-50 μm (individuals/ml) 8.58 × 10 2 ≥ 100 ACCEPTABLE

Note: C5 means control (deballasted) water after five days sampled at P4.

2 DEFINITIONS

2.1 Terms and Definitions

2.1.1 ìEcoBallastî is the tentative commercial name of the Ballast Water Management System developed by ìHyundai Heavy Industries Co. LTD.î. The system is composed of a filtration unit followed by a helix UV reactor equipped with medium pressure UV lamps. ìEcoBallastî treats shipís ballast water during ballasting and de-ballasting. During ballasting, the seawater will be treated by filtration followed by treatment in th e helix UV reactor. The particles and marine organisms retained by the filter will be discharged back into the sea through back-washing of the filter. During de-ballasting, the ballast wate r will be treated again but only by the helix
UV reactor.

2.1.2 ìTreated Waterî means the seawater trea ted by the ìEcoBallastî Water Management System.

2.1.3 ìBallast Water Dischargeî means the ballast water discharged over board after treatment by the ìEcoBallastî Water Management System.

2.1.4 ìActive Substanceî ñ In the ìEcoBallast î system, direct an d indirect effects of UV irradiation have a general and spec ific action on or against harmful aquatic micro-organisms and pathogens. Therefore, the UV irradiation ìPhotonî can be defined here as the ìActive Substanceî.

2.1.5 ìPreparationî as defined in the Procedure (G 9) is not used by the ìEcoBallastî system.

2.1.6 ìRelevant Chemicalsî ñ The UV irradiation of ìEcoBallastî can be absorbed by certain molecules, such as nitrate and dissolved or ganic matter (DOM) in the seawater and cause photo-chemical reactions to pr oduce reactive oxygen species such as hydroxyl radical (OHï). Therefore, hydroxyl radical (OHï) can here be defined as ìRelevant Chemicalsî.MEPC 60/2/1
ANNEX Page 24

I:\MEPC\60\2-1.doc 2.2 Background for determining the ìActiv e Substanceî and ìRelevant Chemicalsî

2.2.1 Introduction

Natural and artificial UV li ght (wavelength of 190-400 nm) ma y damage living organisms by directly and indirectly altering bi ological molecules like nucleic ac ids and proteins. UV light can be divided into three differe nt types according to the wavelength. UV-A extends from 320 to 400 nm, UV-B extends from 290 to 320 nm, whereas UV-C, which is called short UV, extends from 100 to 290 nm (Figure 15). Dire ct effects of UV light on nucleic acids include photo-dimerizations between adjacent pyrimidine ba ses, photo-hydration of cytosine, inter- and intra-strand cross-links and prot ein-DNA cross-links. Indirect damages may occur when reactive oxygen species are generated; such compounds may react with DNA damaging bases, breaking strands, and cross-link DNA and proteins (Miller et al . 1999).

Figure 15: The spectral distribution of UV-light and visible light

2.2.2 Direct Damage

Direct damage is caused by changes in the biol ogical molecules (mainl y DNA and proteins) in the organisms when they absorb the UV light, resu lting in loss of reproductive capabilities of the organisms. This is mainly due to absorption of irradiation by DNA. DNA absorbance is high in the UV-C range (190-280 nm), but falls more than three orders of magnitude in the UV-B range (280-320 nm), and is negligible in the UV-A band (320-400 nm) (Miller et al . 1999). The DNA-damaging effect of UV-C is utilized in bactericidal lamps. The low-pressure mercury-vapour lamp emits approximately 85% of its energy output as m onochromatic light at a wavelength of 253.7 nm, which is within the optimum wavelengt h range of 250 to 270 nm for bactericidal effects (Figure 15) . Medium pressure lamps emit light in a broader spectrum of wavelengths (200-320 nm). Solar UV-B irradiation is responsible for both direct and indirect DNA damage, while UV-A produces only indirect damage. The direct UV-C damage is often due to dimerization of two pyrimidine molecules (Figure 16). Cyclobuta ne pyrimidine dimers and pyrimidine-pyrimidone (6-4) photoproducts ar e the two major classe s of photo-lesions formed by direct DNA absorption of UV-C i rradiation (Sage 1993). Once the pyrimidine residues are covalently bound together , replication of the nucleic ac id is blocked or results in mutant daughter cells unable to multiply.MEPC 60/2/1
ANNEX Page 25

I:\MEPC\60\2-1.doc Dimer

Dimer UV

- li g h t h

ï v

Dimer

Dime r UV

- li g h t h

ï v

Figure 15: UV-C-induced formation of pyrimidine dimers in a DNA-double strand

2.2.3 Indirect Damage

Like biological molecules, some organic and in organic molecules in water can absorb UV light, causing changes in the water qual ity. UV is absorbed by some phot osensitizing agents such as oxygen, nitrate and natural dissolved organic matter (DOM) in sea water either inside or outside the cells to produce reactive oxygen species. The resulting high energy oxidants such as hydrogen peroxide (H 2 O 2 ), superoxide (O 2 -· ) or hydroxyl radical (OHï) can then infuse and react with other cellular components with sites of damage that can be well away from the si te of photo-production.

Hydrogen peroxide (H 2 O 2 ) is produced photo-chemically by a variety of mechanisms both internally within the cells of aquatic organi sms and also externally in their surrounding environment. The main photochemical pathwa y is by the dismutation from superoxide:

O 2 + hv " O 2 -· " H 2 O 2

H 2 O 2 has long been used as an algici de and bactericide, at concentrations in the millimolar range (e.g., 0.25 ~ 1.5 mmol/Liter against filamentous cyanobacteria ; Barroin and Feu illade, 1986).
H 2 O 2 is a powerful oxidant capable of damaging nuc leic acids, proteins and pigments. Although this damage may be incurred by direct reaction between biomolecules and the H 2 O 2 , many of these effects are mediated by the Fenton reaction, whereby more reactive oxidants are generated, in particular hydroxyl radical (OHï):

H 2 O 2 + Fe 2+ " OH · +OH - + Fe 3+

The extreme reactivity of the hydroxyl radical (OHï) is indicated by its short half-life, typically nanoseconds. Hydroxyl radical (O Hï) attack nucleic acids, proteins and membranes and consequently few parts of the cell are immune fro m their effects; even catalases and peroxidases are attacked and degraded by this highly reactive oxygen species.

The detailed mechanisms by which hydroxyl ra dical (OHï) are formed by UV radiation are reviewed below.MEPC 60/2/1
ANNEX Page 26

I:\MEPC\60\2-1.doc 2.2.3.1 Formation of hydroxyl radical (OHï)

Formation of hydroxyl radical (OHï) by UV radiation is mainly from dissolved organic matter or from nitrate.

Dissolved organic matter

Dissolved organic matter (DOM) in seawater is pr esent at concentrations of about 0.5 - 2 mg/L (MacKinnon, 1981) and represents on e of the largest reservoirs of organic carbon on the surface of the earth (Mopper and Degens, 1979; Hedges, 1992). Despite the si ze of this carbon pool, only about 25% to 50% has been characterized. The uncharacterized fraction of DOM has often been referred to as marine humic substances. In natural waters, photochemical reactions are initiated by absorption of s unlight mainly by humic substances. The energy at the shorter wavelengths (UV and blue regions) is sufficientl y high to induce the formation of a variety of highly reactive transient chemi cal compounds, such as the hydroxyl radical (OHï). At present, little is known about th e photochemical reaction and reactive s ites within marine DOM that are responsible for production of reactiv e transients at the sea surface.

Solar exposure of dissolved organic matter (DOM) in comb ination with oxygen may produce reactive species (Figure 16). The overall proc ess of light absorption by DOM and subsequent energy dissipation is described by various mode ls for the photochemical oxidation of organic matter in natural waters (Mopper and Kieber, 2000). In these m odels, the absorption of light by DOM initially results in the formati on of singlet excited state species ( 1 DOM*) that subsequently decays through a series of photophysical and phot ochemical pathways, as shown in Figure 16. The singlet excited state can also undergo inters ystem crossing (ISC) to the triplet excited state ( 3 DOM*). A small fraction of the singlet and triplet excited states of DOM decays through energy transfer to acceptor molecules and through photochemical reactions in solution. In natural waters, an important decay pathway is energy transfer from 3 DOM* to singlet oxygen ( 1 O 2 * ). Other decay pathways for excited state DOM are molecular rea rrangement, fragmentati on and/or reaction with metal ions and oxygen (Figure 17). These pathways resu lt in the formation of an array of radical. Of these transient species, the hydroxyl radical is by far the most reactive (Table 4).

The photochemical production rate of radicals vari es substantially in se awater depending to a large degree on the absorbance of DOM.

Photochemically formed reactive transients play important roles in chemical and biological processes in aquatic environments. For exampl e, biologically and chemically recalcitrant components of DOM, e.g., humic substances a nd organic pollutants, are degraded by photochemical oxidation.

Nitrate

Nitrate (NO 3 - ) is a very strong ab sorber of UV radiation below 250 nm (Sharpless et al . 2003) and a characteristic photoreaction of th is compound is reduction to nitrite (NO 2 - ). Takeda et al

. (2004) reported that although mo st of the hydroxyl radical (OHï) found in river water and seawater were formed from unknown dissolved organic matter, a signifi cant fraction of the hydroxyl radical (OHï) was also formed due to the photolysis of nitrate and nitrite.MEPC 60/2/1
ANNEX Page 27

I:\MEPC\60\2-1.doc NO 3 - + hv " " OHï

Figure 16: General pathways for the photochemical oxidation of dissolved organic matter in natural water (Source: Mopper and Kieber, 2000)

Table 4: Reactive oxygen species and oxida nts ranking by oxidation potential

Chemicals/Compound Oxidation potential (V)

OH radical 2.80

Ozone 2.07 Hydrogen Peroxide 1.79 Permanganate 1.70 Hypochlorite 1.49

Chlorine 1.36

Chlorine dioxide 1.27 Oxygen molecule 1.23MEPC 60/2/1
ANNEX Page 28

I:\MEPC\60\2-1.doc 2.2.4 Active Substances

The mechanism of disinfection by UV light differs considerably from chemical disinfectants such as chlorine and ozone in that no chemical compounds are used or added to the ballast water for the purpose of disinfection; hence no chemical compounds are used as Active Substances and subsequently have not to be dealt with in te rms of handling, storage, and neutralization. As discussed above (see 2.1.4), the Active Substan ce in the ìEcoBallastî sy stem is regarded as the UV irradiation ìPhotonî. The disinfection pro cess is a physical-chemical interaction due to energy input. The active substance is electro magnetic waves (or photons ), carrying energy for partial DNA alteration resulting in loss of reprodu ctive capabilities of the ha rmful micro-organisms.

HHI ìEcoBallastî has received a comment for Active Substanc e in MEPC 59/2/16, annex 8, paragraph 3.4.1, as follows:

ì 3.4.1 Active Substance

3.4.1.1 In this MPUV-based system, the Group accepts that photons are the only Active Substance available to kill and inac tivate micro-organisms. The definition of photon is a particle of electromagnetic radiati on that travels at the speed of light, used to explain phenomena that require light to be have as particles rather than as waves. Accordingly, as the photons are only available upon turning on the MPUV lamp, there must be no residual photons in both the balla st water and ballast water discharge. Half-lives of the photons are expected to be in the order of micro- to milliseconds.

3.4.1.2 Therefore the Group accepted that the photon has no chance of exposing aquatic plants, invertebrates, fish, and other biota, including sensitive and representative micro-organisms. Therefore, all tests for effects on such biota, are ìnot applicableî due to the non-resi dual characteristics of the photon.

3.4.1.3 Likewise, since the photons genera ted in the MPUV reactor are never exposing mammals, all tests for effects on mammals are not applicable.î

2.2.5 Relevant chemicals (hydroxyl radical (OHï))

The only effect of the ìEcoBallastî system on th e ballast water is the potential formation of by-products. It is important to note that these by-products are formed also under natural conditions by photo-chemical reactions caused by sunlight.

Photosensitizing dissolved organi c matter (DOM) and nitrate may adsorb electromagnetic energy and small quantities of free radicals may be pro duced and these radicals will react immediately with other substances to crea te ìreaction productsî. Of these transient oxygen species, the hydroxyl radical (OHï) is by far the most reactive and both of hydrogen peroxide (H 2 O 2 ) and superoxide (O 2 -· ) can be converted to hydroxyl radical (OHï).

Since hydroxyl radical (OHï) react non-sel ectively with organic compounds (Andreozzi et al . 1999), the possible reaction products, so called ìby-productsî will be very diverse and difficult to be characterized.

Therefore, in this application, since the formati on of radicals is a prerequisite for creation of ìreaction productsî and hydroxyl radical (OHï) is by far the most reac tive among the produced radicals, hydroxyl radical (OHï) can be regarded as the represen tative and here regarded as ìrelevant chemicalsî in the sense of the Convention.MEPC 60/2/1
ANNEX Page 29

I:\MEPC\60\2-1.doc HHI ìEcoBallastî has received a comment for Re levant Chemicals in MEPC 59/2/16, annex 8, paragraph 3.4.2, as follows:

ì 3.4.2 Relevant Chemicals

3.4.2.1 The Group noted that the hydroxyl radical (OHï) is defined by the Applicant as a Relevant Chemical in th is BWMS. The Group concurred with the applicant that the extreme r eactivity of the hydroxyl radical (OHï) is indicated by its short half-life, typically nanoseconds. U nder these circumstances where the hydroxyl radical (OHï) can react non-selectively w ith organic compounds to give possible reaction products, the Group proposed that it was neither necessary nor practical to provide the physical characteris tics or toxicological profil es of the hydroxyl radical.î

3 PRINCIPLES

3.1 Active Substances and Preparations may be adde d to the ballast water or be generated on board ships by technology within the ballast water treatment system using an Active Substance to comply with the Convention.

3.2 Active Substances and Prepar ations accomplish their intended purpose through action on harmful aquatic organisms and pathogens in shipsí ballast water and sediments. However, if the ballast water is still toxic at the time of discha rge into the environment, the organisms in the receiving water may suffer unacceptable harm. Bo th the Active Substance or Preparation as well as the ballast water discharge s hould be subjected to toxicity testing in order to protect the receiving environment or human health from toxic effects due to the discharges. Toxicity testing is needed to determine if an Active Substa nce or Preparation can be used and under which conditions the potential of harmi ng the receiving environment or hum an health is acceptably low.

3.3 Any system which makes use of, or generate s Active Substances, Relevant Chemicals or free radicals during the treatment process to elim inate organisms in order to comply with the Convention should be subject to this Procedure.

3.4 Ballast water management systems that make use of Active Substan ces and Preparations must be safe in terms of the ship, its equipmen t and the personnel to comply with the Convention.

3.5 The approval of Active Substances and Preparatio ns using viruses or f ungi for use in ballast water management systems is not addressed in this procedure. The approval of such substances for ballast water management should require an additional consideration by the Organization in compliance with regulation D-3 of the Convention if the use of such substances is proposed.

3.6 Administrations should check the quality a nd completeness of any Basic Approval or Final Approval submission, against the latest version of the Methodology for information gathering and the conduct work of the Technica l Group agreed by the Organization, prior to its submission to the MEPC.

4 GENERAL REQUIREMENTS

4.1 Identification

4.1.1 The basic process in the ìEcoBallastî system operates without addition of chemicals.MEPC 60/2/1
ANNEX Page 30

I:\MEPC\60\2-1.doc 4.1.2 Active Substance

In the ìEcoBallastî Management System, direct and indirect effects of UV irradiation have a general and specific action on or against harmful aquatic micr o-organisms and pathogens. Therefore, the UV irradiation ìPhotonî is here de fined as the ìActive Subs tanceî. The information required in section 4.1.2.1 is not applicable to the ìActive Substanceî of the ìEcoBallastî system.

4.1.3 Relevant Chemicals

The UV irradiation of ìEcoBallastî can be abso rbed by some photosensitive compounds such as nitrate and natural dissolved organic matter (DOM) in seawater to produce reactive oxygen such as hydroxyl radical (OHï). Therefore, hydroxyl radical (OHï) is here defined as ìRelevant Chemicalsî.

4.1.3.1 The information required by IMO as listed belo w is applicable for Hy droxyl Radical (OHï) ( http://webbook.nist.gov/cgi /cbook.cgi?Name=hydroxyl +radical&Units=SI ):

.1 the Chemical (IUPAC) name: InChI=1/HO/h1H .2 the CAS number: 3352-57-6 .3 the Molar mass: 17.01 (g/mol) .4 the empirical formula: HO .5 the structural formula: O* H and .6 Other name: Hydroxyl.

4.1.4 Discharge characteristics

The basic process of the ìEcoBallastî manage ment system operates using the UV-photons and the produced hydroxyl radical (OHï ) to inactivate marine or ganisms without addition of chemicals. Since the hydroxyl radical (OHï) itself does not show significant presence in the treated water due to its very short life time (around 10 -7 seconds), the only environmental concern of the ìEcoBallastî management system might be possible reaction products, so called ìby-productsî and ìtheir residual toxicityî.

4.1.4.1 Literature reviews

Chemical changes of UV irradiated water

Parkingson et al . (2003) studied the effect of UV-C (254 nm) wavelengths on absorbance spectra, dissolved organic carbon (DOC) levels, molecu lar size distributions, bacterial re-growth potentials (BRP) and trihalomethane formation pot entials (THMFP) of aquatic natural dissolved organic matter (DOM) from a number of sources to investigate the use of photo-oxidation for the removal of DOM from drinking water. High UV doses (10 3 -10 5 mWs/cm 2 ) were used aiming at removal of DOM, not for disinfection. The following effects were found:

• reduction in absorbance at 254 nm and reduced DOC concentrations

• reduction in molecular size

• increased bacterial re-growth potentials (BRP)

• mixed effects on the trihalomethane formation potentials (THMFP).

Significant changes in DOM are in general not observed at UV doses used for drinking water disinfection (doses of 10 1 -10 2 mWs/cm 2 ) applying conventional water quality paramete rs such as UV absorbance at 254 nm, total organic carbon (T OC), biodegradable disso lved organic carbon (BDOC), assimilable organic carbon (AOC).MEPC 60/2/1
ANNEX Page 31

I:\MEPC\60\2-1.doc Changes in biodegradability and growth potential

At high doses, the microbial re-growth potential may incr ease as shown by Parkingson et al

. (2003) who demonstrated that the acetate/DOC ratio increased with increasing UV doses (10 3 -10 5 mWs/cm 2 ). Lehtola et al . (2003) studied whet her UV disinfection in creases the amount of microbially available forms of organic carbon and phosphorus in drinking waters with different characteristics, and whether these changes in water chemical quality could enhance the microbial growth in drinking water. They found a decrease in AOC and the sum of the molecular size fractions by LP-UV i rradiation at 15-50 mWs/cm 2 . They also reported an increase in microbial available phosphorus (MAP) at 204 mWs/cm 2

.

Shaw et al . (2000), however, concluded that at relatively lower UV doses (130 mWs/cm 2 ), there is no indication of increase in the contents of assimilable orga nic carbon (AOC), during a 5-day period and in biodegradable dissolved or ganic carbon (BDOC) during a 30-days period.

Changes in residual toxicity in the fish farming application

In general, low UV doses are required to modify the DNA and cause inac tivation of most fish pathogenic bacteria in the fish farming application. However, these doses are known to be too low to cause unwanted toxic by-products. Lo w to moderate UV-doses (20-30 mWs/cm 2 ) has been widely used for disinfection of influent water to land based fish farms, both sea water and fresh water. The method is valued due to its effectiveness to inactivate fish pa thogenic bacteria and some viruses. Liltved et al . (1995) reported that an UV dose of 2.7 mWs/cm 2 resulted in 99.999% (5 log) reduction in viable count fo r all three fish pa thogenic bacteria ( Vibrio anguillarum, Vibrio salmonicida and Yersinia ruckeri ) and an average UV dose of 122 mWs/cm 2 was required for 99.9% (3 log) reduction for virus ( Infectious pancreatic necrosis virus , IPNV).

The UV inactivation of the bacteria was consistent with other published investigations from laboratory batch systems. In ge neral, higher doses have been ap plied in flow through systems. Kimura et al. (1976) showed 99.99% inactivation of several fish pathogenic bacteria ( Aeromonas hydrophila, Aeromonas punctata, Aeromonas salmonicida, Pseudomonas fluorescens, and Escherichia coli ) in a continuous flow system at a dose of 22.1 mWs/cm 2

.
Bullock and Stuckey (1977) repor ted 97-100% inactivation of Aeromonas salmonicida, Aeromonas hydrophila, Pseudomonas fluorescens, Vibrio anguillarum and enteric redmouth bacterium at doses of 13-47.5 mWs/cm 2

.
Sako and Sorimachi (1985) found 99.9% inactiv ation of fish-pathogenic viruses ( Infectious pancreatic necrosis virus (INPV), Infectious hematopoietic necrosis virus (IHNV), Oncorhynchus masou virus (OMV)) and bacteria ( Aeromonas salmonicida

, Vibrio anguillarum

, and Vibrio ordalii ) in batch tests with doses in the range of 1.4-3.4 mWs/cm 2 except for IPNV which had low susceptibility to UV light. However, doses of 150-200 mWs/cm 2
in-activated 99.9% of IPNV.

Liltved et al . (2006) also reported the use of UV irradiation to inactiv e important fish pathogenic viruses, including IPNV, Atlantic Halibut Noda Virus (AHNV) and Infectious Salmon Anaemia
Virus (ISAV). In their studies, ozone was also tested and ozonation by- products (OBPs) were detected. Of the detected carcinogenic ozona tion by-products (OBPs), bromate was found in concentrations of 50-70 mg/L . Bromoform was the only trih alomethane (THM) found in the concentration of 16.4 mg/l. Unlike ozone, the UV irradiation has be en reported not to leave toxic residues behind in their study.MEPC 60/2/1
ANNEX Page 32

I:\MEPC\60\2-1.doc From the aquaculture industry, there are only few reports on the possible damage to fish caused by UV treated water. Bjˆrnsson (2004) found that seawater recently disinf ected with ultraviolet radiation (254 nm) can increase the frequency of cataract in juvenile cod. In a 5-month experiment where groups of cod were reared in a re-circulating system at two different densities (54 and 300 fish/m 3 ), the frequency of cataract increased af ter the fish were exposed to UV-treated water. The fishes in the tank with the water intake closest to the UV lamps (3 m) were most affected, 39% of the fish devel oped cataract, compared to 5% of the fishes in the tank located further away from the UV lamps (3 3 m). The effect was believed to be indirect, caused by chemical photoproducts from the UV irradiat ion since the UV lamps were pla ced inside an opaque steel box. It was hypothesized that photo by- products formed by UV radiation may cause cataract in fish.

Changes in residual toxicity in water ecosystem

De Veer et al . (1994) investigated whethe r UV-disinfection of natural and contaminated organic substances in surface and drinking water may gene rate a positive mutagenic effects. Selected organic pesticides (atrazine, simazine, metobr omurone, methabenzthiazur one, dichlorprop) and organic compounds naturally present in water ( phenylalanine, tyrosine, polysaccharides) were examined in Ames-test (bacterial strains TA 98 and TA 100) and sister chromatid exchange (SCE)-test (V79 cells) before and after UV-irradiat ion. Based on results in Ames- and SCE-test, mutagenic activity was found in none of the samp les, neither before nor after UV-irradiation.

However, it has been found that high intensity vi sible light or solar light may cause indirect photochemical damage to micro-organisms. Such da mage may occur when the light is absorbed by a sensitizer, which enters an excited state. In th e presence of oxygen, the ex ited sensitizer may form reactive species like singlet oxygen, superoxide , hydrogen peroxide, and hydroxyl radical (OHï).

Cooper and Zika (1983) found that the hydroge n peroxide present in water was mainly photo-chemically generated from organic constitu ents and, furthermore, that the accumulation rate of hydrogen peroxide was a function of TOC. These aut hors, in studies of TOC in freshwater ecosystems, detected formati on of hydrogen peroxide over a range of 10 -6 to 10 -5 M with only 2.5 h of e xposure to sunlight

Arana et al . (1992) found that visible light may act dire ctly on the cells or generate photoproducts with a negative effect on the cel ls. In non-illuminated microcos ms the addition of increasing concentrations of hydrogen peroxide, one of the photoproducts formed in natural aquatic systems, gave rise to the formation of non-culturable cell s and damaged culturable cells, and this negative effect depended on the concentration of peroxide. On the other hand, in illuminated microcosms the addition of compounds which eliminate hydr ogen peroxide (i.e., catalase, sodium pyruvate, and thioglycolate) had a protective effect on the E. coli cells, as the viable cell numbers on minimal medium and on recuperation medium were significantly higher than those detected in the absence of these compounds.

Curtis et al. (1992) and Reed (1997) concluded that the ability of light to damage bacteria was highly sensitive to, and completely dependent on the presence of oxygen and humic acid.

Bio-assays with the green alga Selenastrum capricornutum in heavily UV irradiated DOM-containing water showed inhibition of grow th lasting for several weeks (Gjessing and K‰llqvist 1991). The results showed that UV ra diation of humus water changed the chemical composition of water, including acid ity and charge density and also inhibited the growth of the alga Selenastrum capricornutum . Inhibition increases with increased UV dose from a mercury-lamp. The observed effects of UV treated DOC-containing wate r were explained byMEPC 60/2/1
ANNEX Page 33

I:\MEPC\60\2-1.doc photon-mediated interactions of humic substan ces and other chemicals in the water which resulted in the formation of oxidizing r eagents such as hydroxyl radical (OHï).

Lund and Ormerod (1994) found that UV irradiated water (dose 42 mWs/cm 2 ) showed considerably less production of bio- film compared to untreated water after 20 months pilot test. This leads to the assumption that production of ìtoxicî compounds during UV treatment resulted in an inhibitory effect. Similar observati ons were reported by Lund and Hongve (1994), who found that UV-irradiated water (42 mWs/cm 2 and 92 mWs/cm 2 ) inoculated with fresh bacteria resulting in reduced numbers of viable bacteria and reduced bacterial metabolism. This inhibitory effect seemed to last for at least 1 week. The observed effects were explained by the action of oxidizing reagents such as hydroxyl radical (OHï), produced by photo-chemical reactions mediated by UV radiation of humic substances in the water.

Alam and Ohgaki (2002) found a residual effect of UV irradiated synthetic water containing a photosensitizing element and ferric ion (Fe 3+ ) on Microcystis aeruginosa and E. coli at doses of about 400 mWs/cm 2 . No such effect was found in M. aeruginosa at 100 mWs/cm 2 , and only a small effect was observed at 200 mWs/cm 2 . No residual effect was observed in the absence of any photosensitizing element. A close relationshi p was observed between th e residual effect and the formation of hydrogen peroxide in the UV irra diated water. They s uggested that transition metals and hydrogen peroxide play a key role in producing the residual effect of UV radiation through the formation of r eactive species, includi ng hydroxyl radical (OHï).

Parkingson et al . (2001) tested the potenti al toxicity of UV treate d aquatic DOM (high doses

∼ 10 4 mWs/cm 2 ) in two spot samples from tw o Australian reservoirs using Vibrio fisheri in the MicrotoxTM test, African gr een monkey kidney cells, and Daphnia carinata in an acute immobilization test. Toxicity was not apparent for the Microtox procedure and cytotoxicity analyses, but acute toxicity to D. carinata was observed. The observed toxicity was attributed to photo-oxidative degradation of DOM-metal binding sites, which resulted in the release of bio-available copper ions, as ev idenced by higher concentrati ons of free copper ions in photo-oxidised water.

Effects on the formation of chlorination by-products

The effect of UV irradiation prior to traditiona l chlorination for drinking water disinfection has been investigated. Kashinkunti et al . (2004) exposed granular activ ated carbon filtered drinking water to UV light from low pressure (LP) a nd medium pressure (MP) UV bench systems at UV doses of 40 and 140 mWs/cm 2 , followed by adding 2 mg/L Cl 2 . They found no evidence of increase in disinfection by-produ cts (DBP) formation, assayed as the formation potential of trihalomethanes (THM), 9-haloacetic acids (HAA-9), carboxylic acids, aldehydes and total organic halogen (TOX)) or re-growth (measured as assimilable organic carbon (AOC)) after
UV-treatment.

Similarly, Bukhari et al . (2004) reported no significant change s in total haloacetic acids (HAA-5) and THMs after MP UV-irradiation at doses of approximately 40 mWs/cm 2 . Kruithof et al . (1992) also reported no production of biodegradable compounds, assayed by th e AOC method, and no mutagenic activity in the Ames test after tr eatment with LP UV li ght at about 20 mWs/cm 2

.
The UV doses used for drinking water disinfec tion are relatively low, normally 16 to 40 mWs/cm 2

. At these doses, subsequent formation of by-pr oducts from chlorination does not give rise to concern, at least not the by-produc ts that have been analysed in published investigations.MEPC 60/2/1
ANNEX Page 34

I:\MEPC\60\2-1.doc Potential effect on seawater salts and bromate

Seawater contains halogen anions (Cl - , Br - , I - ). Oxidation of these an ions by UV-irradiation to bioactive forms (chlorine, brom ine, iodine) has not been reported. Such oxidation is known to occur when seawater is ozonated or chlorinated. By ozonation of Br - containing water, also small amounts of bromate can be formed. Bromate is well known as a probable human carcinogen. The compound is of great concern in oz one treated drinking water. Peldszus et al . (2004) investigated the potential for bromate remo val from drinking water by irradiation with medium-pressure UV lamps. Bromate absorbs UV light well at low wa velengths and hence, photolysis of bromate may be expected when us ing medium-pressure UV lamps. However, they observed essentially no or only limited removal ( up to 19%) of bromate even at high UV doses (700 mWs/cm 2 ), probably due to competitive UV absorption by nitrate and DOC.

Summary and Conclusion

The potential of UV-irradiatio n to induce photo-chemical wate r quality changes, by-products formation and residual toxicity effects have been reviewed based on the available literature. Effects of various doses of UV-irradiation on different water qualities have been included.

At UV doses used for disinfection purposes (low to moderate doses), the following conclusions can be drawn:

• Small, if any, changes in conventiona l water quality parameters such as UV absorbance at 254 nm, colour, TOC, AOC and BDOC have be found.

• Residual effects like reduced bi o-film formation, inactivatio n of heterotrophic bacteria and reduced bacterial metabolism in UV-tr eated natural lake water have been reported. Weak, if any, or no increase in geno-toxic activity has been found.

• Except one case by Bjˆrnsson (2004), no pr actical negative effects have been identified by using UV irradiated natural water or seawater in land based aquacultural facilities.

• No evidence of increased disinfec tion by-product formation (THM, HAA-9, carboxylic acids, aldehydes, TOX) by s ubsequent chlorination has been found.

At high UV doses (about 10 4 mWs/cm 2 ), high concentrations of DOM can produce by-products, which can give residual toxic effects to the growth of several organisms.

At moderate UV doses (200 ~ 300 mWs/cm 2 ), which are applied in ballast water treatment, there is no available information abou t formation of by-products. Of pr imary interest here would be the possibility of formation of halogenated organics or toxic oxidation pro ducts in the discharged ballast water after UV-treatment.

It should be pointed out that the radicals produced in the helix UV reactor are not different from those naturally formed by sunlight in the surface layer of seawater. Howe ver, to elucidate any environmental effects of possibl e by-products in UV treated seawater, a series of chemical analyses and eco-toxicological tests of the UV treated seawater have been performed, with particular focus on:MEPC 60/2/1
ANNEX Page 35

I:\MEPC\60\2-1.doc - Bromate formation - THMs/VOCs - Halogenated Phenols - By-product of disinfection (HAAs, HANs) - General toxicity an alysis (acute and chronic toxicity).

4.2 Data-set for Active Substances and Preparations

All analyses were carried out according to standa rd methods. All tests were carried out under the supervision of the Korea Marine Equipment Re search Institute (KOMERI), Korea Testing & Research Institute (KTR) and Marine Eco-Technology Institute (MEI). KOMERI laboratory is accredited by KOLAS (Korea Laboratory Accr editation Scheme) for phytoplankton and micro-organism analysis (appendix 1). Thus, the study director of KOMERI is accredited by IOC-UNESCO for identification of phytoplankton (appendix 1). KTR laboratory is accredited by KOLAS for chemical analyses of environmen tal samples including DOC and POC analysis (appendix 1). Although MEI Institute is not accr edited specifically for toxicological testing (e.g., Good Laboratory Practice, GLP), the Institute has an ecotoxicological laboratory, personnel with a solid experience in toxicological research, and all tests were performed according to GLP. The data on quality assurance (QA) are pr ovided in each test report (appendix 3).

The Corrosivity test of UV-treated seawater wa s performed using the SWBT (Simulated Wave Ballast Tank) by Coating Performance Test La boratory in Protective Coatings & Corrosion Research Department, Hyundai Industrial Resear ch Institute (HIRI) located on Hyundai Heavy Industries Co. LTD. in Ulsan, Korea. Although this institute is not accr edited, two researchers involved in this project are accredited by NACE Certified Coa ting Inspector Level 2. The Institute has personnel with a so lid experience in protective coat ing and corrosion research, and all tests were performed according to IMO MSC 82/WP.3 (appendix 4).

4.2.1 Properties and actions of the Preparation

.1 Data on effects on aquatic plants, invertebrates, fish, and other biota, including sensitive and representative organisms:

Acute aquatic toxicity ñ No significant acute toxicity was observed; see report in appendix 3, section 3.1. The results ar e summarized in Tables 5 and 6.

Algae

ñ For the study to assess the effects of the UV-treated seawater on the diatom, Skeletonema costatum , during 72 hours

, NOEC and LOEC values from Hypothesis Test based on the cell densities at the end of the experiment were calculated for both 34 psu and 21 psu treated ballast water.

Crustacean

ñ For the study to assess the effects of the UV-treated seawater on the copepod, Tigriopus japonicus, during 48 hours, EC 25 , EC 50 , LC 25 and LC 50 values based on mobilization and survival da ta at the end of the expe riment were calculated for both 34 psu and 21 psu UV-tr eated ballast water.

Fish ñ For the study to assess th e effects of the UV- treated ballast wa ter on flounder, Paralichthys olivaceus , during 96 hours, LC 25 and LC 50 values based on survival data at the end of the experiment were calculate d for both 34 psu and 21 psu treated ballast

water.MEPC 60/2/1
ANNEX Page 36

I:\MEPC\60\2-1.doc Echinoderms ñ For the study to assess the effects of the UV-treated ballast water on sea urchin, Anthocidaris crassispina , during 48 hours, EC 25 , EC 50 , LC 25 and LC 50 values based on mobilization and survival data at th e end of the experiment were calculated for 34 psu treated ballast water.

Mollusc ñ For the study to assess the effects of the UV-treated ballast water on pacific oyster, Crassostrea gigas , during 48 hours, EC 25 , EC 50 , LC 25 and LC 50 values based on mobilization and survival data at the end of the experiment were calculated for 34 psu treated ballast water.

Table 5: Acute aquatic toxicity of 34 psu ballas t water treated by the HHI-BWM system

LC 50 and/or EC 50 Species End point Conc.(%) Reference/Comments/ justification for missing data

Algae Skeletonema costatum EC 50 72 h > 100 OECD 201

Crustacean Tigriopus japonicus EC 50 48 h LC 50 48 h > 100 > 100 OECD 202

Fish Paralichthys olivaceus LC 50 96 h > 100 OECD 203

Echinoderm Anthocidaris crassispina EC 50 48 h LC 50 48 h > 100 > 100 OECD 202

Mollusc Crassostrea gigas EC 50 48 h LC 50 48 h > 100 > 100 OECD 202

Table 6: Acute aquatic toxicity of 21 psu ballas t water treated by the HHI-BWM system

LC 50 and/or EC 50 Species End point Conc.(%) Reference/Comments/ justification for missing data

Algae Skeletonema costatum EC 50 72 h > 100 OECD 201

Crustacean Tigriopus japonicus EC 50 48 h LC 50 48 h > 100 > 100 OECD 202

Fish Paralichthys olivaceus LC 50 96 h > 100 OECD 203

Chronic aquatic toxicity ñ No chronic toxicity was obser ved in algae and fish, however, slight chronic toxicity was observed in echinoderm and mollu sc; see report in appendix 3, section 3.2. The results are su mmarized in Tables 7 and 8.

Algae ñ For the study to assess the e ffects of the UV-treated ba llast water on the diatom, Skeletonema costatum, during 96 hours, NOEC and LOEC values from Hypothesis Test based on cell densities at th e end of the experiment were calculated for both 34 psu and 21 psu treated ballast water.

Fish ñ For the study to assess the effects of the UV-treated ballast water on olive flounder, Paralichthys olivaceus , during 7 ~ 8 days, NOEC and LOEC values from result of Hypothesis Test based on number of the liv ing organism at the end of the experiment were calculated for 34 psu and 21 psu treated ballast water.MEPC 60/2/1
ANNEX Page 37

I:\MEPC\60\2-1.doc Echinoderms ñ For the study to assess the effects of the UV-treated ballast water on the sea urchin, Anthocidaris crassispina , during 14 days, NOEC and LOEC values from result of Hypothesis Test base d on the living organism at the end of the experiment were calculated for 34 psu treated ballast water.

Mollusc ñ For the study to assess the effects of the UV-treated ballast water on pacific oyster, Crassostrea gigas , during 10 days, NOEC and LOEC values from result of Hypothesis Test based on the living organism at the end of the experiment were calculated for 34 psu treated ballast water.

Table 7: Chronic aquatic toxicity of 34 psu ball ast water treated by the HHI-BWM system

LC 25 , LC 50 , LOEC, and/or NOEC Species End point Conc.(%) Reference/Comments/ justification for missing data

Algae Skeletonema costatum NOEC 96 h 100 OECD 201

Fish Paralichthys olivaceus NOEC 8 D 100 OECD 212

Echinoderm Anthocidaris crassispina NOEC 14 D LOEC 14 D LC 25 14 D LC 50 14 D 6.25 12.50 18.50 > 100 OECD 210

Mollusc Crassostrea gigas NOEC 10 D LOEC 10 D LC 25 10 D L C 50 10 D 12.50 25.00 49.10 > 100 OECD 210

Table 8: Chronic aquatic toxicity of 21 psu ball ast water treated by the HHI-BWM system

LC 25 , LC 50 and/or
NOEC Species End point Conc.(%) Reference/Comments/ justification for missing data

Algae Skeletonema costatum NOEC 96 h 100 OECD 201

Fish Paralichthys olivaceus NOEC 7 D 100 OECD 212

• Endocrine disruption . Not specifically tested, however th e acute toxicity test, the chronic toxicity test, and the chemical analyses of discha rged seawater sugg est that endocrine disruption is unlikely to occu r (see appendix 2 for Chemical Analysis Report and appendix 3 for Toxicity Test Report).

HHI ìEcoBallastî has received a comment for E ndocrine disruption in MEPC 59/2/16, annex 8, appendix, paragraph 3.3, as follows:MEPC 60/2/1
ANNEX Page 38

I:\MEPC\60\2-1.doc ì 3.3 Information on Endocrine Disruption

3.3.1 The Group noted that the endocrine disrup tion potential of treated ballast water had not been tested for specifically but the a pplicant reported that no potential endocrine disrupting chemicals had been identified in the treated water.

3.3.2 Based on this information, the Group agreed that the treated ballast water was unlikely to have any endocrine disrupting effects.î

• Sediment toxicity . As shown in the appendix 2 for Chemical Analysis Report and appendix 3 for Toxicity Test Report, there are no residuals resulting from the treatment. This means that ìEcoBallastî treatment will not cause sedimentation toxicity.

HHI ìEcoBallastî has received a comment for Sediment Toxic ity in MEPC 59/2/16, annex 8, appendix, paragraph 3.4, as follows:.

ì 3.4 Sediment Toxicity

3.4.1 The Group noted that the applicant had indicated that, based on the chemical analysis and toxicity tests of the treated ba llast water, there woul d not be any sediment toxicity associated with the treated ballast water. The Gr oup agrees with this view.î

• Bioavailability/biomagnification/bioconcentration . Not specifically tested; however, the chemical analyses of ìEcoBallastî treated s eawater (see appendix 2 for Chemical Analysis Report) do not show any significant changes of its components compared to ìControlî seawater, which suggests that changes in bioavailability/bio magnification/bioconcent ration do not occur.

HHI ìEcoBallastî has received a comment for Bioava ilability/Biomagnification/Bioconcentration in MEPC 59/2/16, annex 8, appendi x, paragraph 3.5, as follows:

ì 3.5 Bioavailability/Biomagnification/Bioconcentration

3.5.1 The Group noted that the applicant had indicated that, based on the chemical analysis of the treated ballast water, there was no indicati on of any chemical by-products that might be bioaccumulative. The Group agrees with this view.î

• Food web/population effects . Since the full strength (100%) treated seawater and brackish water did not have any deleterious effects on any of the test species including marine and brackish water organisms, discharg ed ballast water can be expect ed to be non-toxic to aquatic organisms and the ecosystem in general.

HHI ìEcoBallastî has received a comment for F ood Web/Population Effects in MEPC 59/2/16, annex 8, appendix, paragraph 3.6, as follows:

ì 3.6 Food Web/Population Effects

3.6.1 The Group noted that the applicant had indicated that, taking into account the 100% treated ballast water ha d been used to measure any effects on the test species, it would be unlikely for the diluted ballast wate r to have any significant negative effects on ecological communities at environmentally re levant concentrations. The Group agrees with this view.îMEPC 60/2/1
ANNEX Page 39

I:\MEPC\60\2-1.doc .2 Data on mammalian toxicity

Since the photon (defined as ìActive Substanceî) generated in the ìEcoBallastî Management System are never exposed to mammals, toxicity tests on mammalians are ìNot Applicableî.

Since the hydroxyl radical (OHï ) (defined as ìRelevant Su bstanceî) are short lived and will disappear before leaving the ìEcoBalla stî Management System, toxicity tests on mammalians are ìNot Applicableî.

Chemical Analysis (appendix 2) and Toxicity Test (appendix 3) also suggest that there will be no residuals resulting from the trea tment which will show mammalian toxicity.

HHI ìEcoBallastî has received a comment for Ma mmalian Toxicity in MEPC 59/2/16, annex 8, appendix, paragraph 2, as follows:

ì 2 MAMMALIAN TOXICITY

The Group noted that the applicant had indi cated that, as there were no measurable chemical by-products, there was no need to pr ovide any data with regards to mammalian toxicity. The Group agr ees with this view.î

.3 Data on environmental fate and effect under aerobic and anaerobic conditions

• Modes of degradation (biotic; abiotic). The free radicals resulting from the interactions between UV irradiation and some photosensitizi ng chemical compounds (such as nitrate and DOM) in the seawater will decay into stable non-radical chem ical compounds or will involve several oxidation reactions befo re leaving the ìEcoBallastî sy stem. In addition to the formation of stable non-radical species through decay processes, the decay of excited state DOM may also result in the direct form ation of non-radical species. Mopper and Kieber (2000) have reviewed the formation of non-radical species from the decay of excited state DOM. From their review, the net eff ects of these photo-chemical processes and transformations are the oxidation of DOM, cleavage of humic substances, oxidation of reduced sulphur, photo-bleaching of absorbance a nd fluorescence properties, loss of dissolved oxygen, photo-reduction of trace metals, releas e of complex-bound molecules such as phosphate, and production of relativ ely stable low molecular we ight (LMW) molecules such as hydrogen peroxide, NO and NO 2 , reduced iodine species , ammonium, hydrocarbons, organic acids, carbon dioxide, carbon monoxide, sulphide, and carbonyl compounds. It should be pointed out that the radicals produced in the helix UV reactor are not different from those naturally formed by sun light in the surface layer of seawater. Therefore all chemicals compounds formed by these reactio ns will be expected to follow natural decomposition processes by natural biotic or abiotic pathways

.

• Bioaccumulation, partition coefficient, octanol/water coefficient . Not specifically tested; however, the Chemical Analysis (appendix 2) and Toxicity Test (appendix 3) indicate that the treated water has not been changed.

• Persistence and identification of the main metabolites in the relevant media (ballast water, marine and fresh waters) . No significant quantities of by-products were measured by the Chemical Analysis (appendix 2).MEPC 60/2/1
ANNEX Page 40

I:\MEPC\60\2-1.doc • Reaction with organic matter . The free radicals resulting fr om the interactions between UV irradiation and some photosensitizing compounds such as nitrate and natural dissolved organic matter (DOM) in seawater will react with several types of orga nic matter as described in 2.2.3.1. These radicals are formed under natu ral conditions in surface seawater, so any decomposition compounds from ìEcoBallastî, if formed, can be expected to be similar to those produced during natural decompos ition of organic matter in seawater.

To identify products of concern to the environm ent from the reaction of radicals with organic matters, some halogenated hydrocarbons were anal ysed in brackish water and seawater tests (Tables 9 and 10). The detailed info rmation can be found in appendix 2.

Table 9: Concentrations of potential Re levant Chemicals in control and treated seawater samples in 21 PSU test

Time (day 0) Time (day 1) Time (day 5) Chemical compounds Unit MDL Control Treated Control Treated Control Treated

AOX mg/L 0.01 0.45 0.39 0.76 0.36 0.68 0.29

EOX mg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00

Bromate μ g/L 0.46 0.0 0.0 0.0 0.0 0.0 0.0

Trichloromethane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000

Dibromochloromethane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000

Bromoform μ g/L 0.001 0.003 0.002 0.003 0.000 0.004 0.000

Dibromomethane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000

Dichlorobromomethane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 1,2,3-Trichloropropane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 1,2-Dibrom-3- chloropropane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000

2-Chlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 3-Chlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 4-Chlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2,3-Dichlorophenol μ g/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00
2,4-Dichlorophenol+ 3,5-Dichlorophenol μ g/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00

2,5-Dichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2,6-Dichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 3,4-Dichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2,3,4-Trichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00
2,3,5-Trichlorophenol +2,4,5-Trichlorophenol μ g/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00

2,3,6-Trichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2,4,6-Trichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 3,4,5-Trichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00MEPC 60/2/1
ANNEX Page 41

I:\MEPC\60\2-1.doc Table 9: (continued)

Time (day 0) Time (day 1) Time (day 5) Chemical compounds Unit MDL Control Treated Control Treated Control Treated
2,3,4,5- Tetrachlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00

2,3,4,6- Tetrachlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00

2,3,5,6- Tetrachlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00

PCP μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2-Chlorotoluol μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 4-Chlorotoluol μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 1,2,4-Tribromobenzol μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 1,3,5-Tribromobenzol μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 Chloral hydrate μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 Dibromoacetonitrile μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Dichloroacetonitrile μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Trichloroacetonitrile μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 Monochloroacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Dichloroacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Trichloroacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Bromochloroacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Bromoacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Dibromoacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Density g/cm 3 0.00001 1.0238 1.0237 1.0237 1.0237 1.0237 1.0237 TRO mg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 DOC mg/L 0.005 11.40 26.30 POC mg/L 0.005 7.95 8.15 TSS mg/L 77.10 79.53 Salinity PSU 20.81MEPC 60/2/1
ANNEX Page 42

I:\MEPC\60\2-1.doc Table 10: Concentrations of potential Rele vant Chemicals in control and treated seawater samples in 34 PSU test

Time (day 0) Time (day 1) Time (day 5) Chemical compounds Unit MDL Control Treated Control Treated Control Treated

AOX mg/L 0.01 0.51 0.51 0.45 0.48 0.24 0.29

EOX mg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00

Bromate μ g /L 0.46 0.0 0.0 0.0 0.0 0.0 0.0

Trichloromethane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000

Dibromochloromethane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.001

Bromoform μ g/L 0.001 0.015 0.008 0.016 0.008 0.010 0.004

Dibromomethane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000

Dichlorobromomethane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 1,2,3-Trichloropropane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 1,2-Dibrom-3- chloropropane μ g/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000

2-Chlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 3-Chlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 4-Chlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2,3-Dichlorophenol μ g/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00
2,4-Dichlorophenol+ 3,5-Dichlorophenol μ g/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00

2,5-Dichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2,6-Dichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 3,4-Dichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2,3,4-Trichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00
2,3,5-Trichlorophenol +2,4,5-Trichlorophenol μ g/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00

2,3,6-Trichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2,4,6-Trichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 3,4,5-Trichlorophenol μ g/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00
2,3,4,5- Tetrachlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00

2,3,4,6- Tetrachlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00

2,3,5,6- Tetrachlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00

PCP μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 2-Chlorotoluol μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 4-Chlorotoluol μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 1,2,4-Tribromobenzol μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 1,3,5-Tribromobenzol μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000MEPC 60/2/1
ANNEX Page 43

I:\MEPC\60\2-1.doc Table 10: (continued)

Time (day 0) Time (day 1) Time (day 5) Chemical compounds Unit MDL Control Treated Control Treated Control Treated Chloral hydrate μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 Dibromoacetonitrile μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Dichloroacetonitrile μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Trichloroacetonitrile μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 Monochloroacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Dichloroacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Trichloroacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00

Bromochloroacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00

Bromoacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Dibromoacetic acid μg/L 0.01 0.00 0.00 0.00 0.00 0.00 0.00 Density g/cm 3 0.00001 1.0139 1.0138 1.0138 1.0138 1.0139 1.0137 TRO mg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 DOC mg/L 0.005 4.62 4.55 POC mg/L 0.005 2.12 2.20 TSS mg/L 32.50 31.83 Salinity PSU 33.95

• Potential physical effects on wildlife & benthic habitats. Not specifically tested. However, treatment does not seem to affect th e physical properties of the seawater and its habitats, as deduced from the chem ical analysis data in appendix 2.

• Potential residues in seafood . Bioaccumulation is not expect ed, and no potential residues in seafood resulting from ìEcoBallastî treatment are likely to occur.

• Any known interactive effects . There are no known or expected interactive effects.

HHI ìEcoBallastî has received a comment fo r Environmental Fate and Behaviour in MEPC 59/2/16, annex 8, appendix, paragraph 3.7, as follows:

ì 3.7 Environmental Fate and Behaviour

3.7.1 The Group recognized that there is no chemical Active Substance or any assessable Relevant Chemical produced by the system and so there was no need to consider their environmental fate any further.îMEPC 60/2/1
ANNEX Page 44

I:\MEPC\60\2-1.doc .4 Physical and chemical properties for th e Active Substances and Preparations and the treated ballast water, if applicable.

The ìEcoBallastî treatment technol ogy does not involve any additi on of chemicals. The free radicals which may be generated have very shor t-life time and are consumed inside the reactor, and may react with DOM in the seawater transf orming this into low molecular weight (LMW) carbon products. Only the redox potential, de nsity and corrosivity are tested here.

• Density . The density of controlled a nd treated seawater was measured. That values were not significantly different from thos e of the raw seawater (see appendix 2), which means any significant physical and chemical changes of the seawater have not been introduced. The results are summarized in Table 11.

Table 11 . Density in control and treated seawater (OECD Guide 109: 1996)

Time (day 0) Time (day 1) Time (day 5) Salinity Unit MDL Control Treated Control Treated Control Treated 21 PSU g/cm 3 0.00001 1.0238 1.0237 1.0237 1.0237 1.0237 1.0237 34 PSU g/cm 3 0.00001 1.0139 1.0138 1.0138 1.0138 1.0139 1.0137

• Oxidation/reduction potential . The oxidation and reduction pot ential was measured after ìEcoBallastî treatment. That values were not significantly different from those of the raw seawater (see appendix 1), whic h means any significant physical and chemical changes of the seawater have not been introduced. Th e results are summarized in Table 12.

Table 12 . Oxidation and Reduction Potential (O RP) in control and treated seawater

Influent water (immediately after ballasted water, day 0) Discharged water (after de-ballasted water, day 5)

Control(mV) Treated(mV) Control(mV) Treated(mV) Salinity (PSU)

B M E B M E B M E B M E

21 341 344 338 342 349 337 335 319 311 343 345 345
34 347 329 325 335 342 324 336 328 356 327 310 322

Note: B, beginning; M, middle; E, end.

• Corrosivity to the materials or equipm ent of normal ship construction. The corrosivity test has been performed with the discharged seawater from the ìEcoBallastî system during about 6 months. The test results showed no significant changes of the corrosivity of the discharged seawater compared to raw seawater (see appendix 4).

.5 Analytical methods at environm entally relevant concentrations

• All analytical methods follow Internati onally Recognized methods (see appendix 2, section 2.4).MEPC 60/2/1
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I:\MEPC\60\2-1.doc 4.2.2 A proposal for approval should include the above data set either for th e Preparation or for each component separately, and a list of the name and relative quantities (in volumetric percentages) of the components should be also attached. As described in section 8.1, all proprietary data should be treated as confidential.

• Not applicable.

4.2.3 The tests for Active Substances and Preparati ons should be carried out in accordance with internationally recognized guidelines.

4.2.4 The testing process should contain a rigorous quality control/quality assurance program consisting of:

.1 Both a Quality Management Plan (QMP) and a Quality Assurance Project Plan (QAPP). Guidance on preparation of th ese plans, along w ith other guidance documents and other general quality control information are available for download from the International Organiza tion for Standardization (ISO) ( www.iso.org ).

.2 The QMP addresses the quality control management structure and policies of the Test Organization (inclu ding subcontractors and outside laboratories).

.3 The QAPP is a project specific technical document reflecting the specifics of the system to be tested, the test facility, and other conditions a ffecting the actual design and implementation of the required experiments.

4.2.5 Dossiers already used for registration of ch emicals can be submitted by the applicant to satisfy the required data needed for the eval uation of Active Substances and Preparations according to this procedure.

4.2.6 The proposal should describe th e manner of application of the Preparation for ballast water management, including requir ed dosage and retention time.

4.2.7 A proposal for approval should include (Mat erial) Safety Data Sheets ((M)SDS).

Assessment report

4.3.1 A proposal for approval should include an assessment report. The assessment report should address the quality of the te st reports, the risk characteri zation and a consid eration of the uncertainty associated with the assessment.

• The analyses performed will be complemented with further tests both with regard to toxicity as well as chemical properties of th e treated ballast water if necessary.

• The preliminary test results reve aled no measurable levels of potentially toxic substances and no acute or chronic effects of the full strength effluent on aquatic orga nisms. Therefore, no apparent environmental ri sks could be identified.

• All analyses were carried out according to st andard methods as described in each appendix.MEPC 60/2/1
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I:\MEPC\60\2-1.doc 5 RISK CHARACTERIZATION

5.1 Screening for persistency, bioaccumulation and toxicity

5.1.1 An assessment on the intrinsic properties of the Active Substa nce and/or Preparation such as persistency, bioaccumulation and toxicity shou ld be conducted (see Table 1 in section 6).

.1 Persistence tests

• Not specially tested. According to the liter ature review, the half- life of hydroxyl radical (OHï) is very short, in the range of 10 -7 ~ 10 -9 seconds.

.2 Bioaccumulation tests

• Not specifically tested; however, the Chemical Analysis (appendix 2) and Toxicity Test (appendix 3) indicate that the tr eated water has not been changed.

.3 Toxicity tests

• Acute and chronic ecotoxicity tests of ìEco Ballastî treated seawater and brackish water covering multiple test species (a fish, an invertebrate and a plant) showed no effects on the tested organisms (appendix 3).

5.2 Toxicity testing of the treated Ballast Water

5.2.1 Toxicity testing is necessary for the Active Substance, or Prepara tions (see sections 4.2.1 and 5.3) and the treated Ballast Water Discharge as covered in this section. The advantage of conducting toxicity testing on the Ballast Water Disc harge is that it integr ates and addresses the potential for interactions of the Active Substances and Preparations with the possible by-products.

.1 For the Basic Approval process, the disc harge testing should be performed in a laboratory using techniques and equipment to simulate Ballast Water Discharge following treatment by the Preparation.

• Acute and chronic ecotoxicity tests w ith ìEcoBallastî treated seawater and brackish water covering multiple test species (a fish, an invertebrate and a plant) indicated no significant acute or chr onic toxicity to any test organisms. Only slight chronic toxicity effect was observed in echinoderm and mollusc. However, LC 50 values of the chronic toxicity effect to echinoderm and mollusc were greater than 100%. Even the full strength effluent (100%) did not show any deleterious effects on a ny of the test species. Consequently, the effluent can be expected to be non-toxic to aqua tic organisms as well as to the marine environment in general (appendix 3).

.2 For final approval, the discharge testi ng should be performed as part of the land-based type approval process using the treated ballast water discharge.

• Acute and chronic ecotoxicity tests w ith ìEcoBallastî treated seawater and brackish water covering multiple test species (a fish, an invertebrate and a plant) indicated no significant acute or chr onic toxicity to any test organisms.MEPC 60/2/1
ANNEX Page 47

I:\MEPC\60\2-1.doc Only slight chronic toxicity effect was observed in echinoderm and mollusc. However, LC 50 values of the chronic toxicity effect to echinoderm and mollusc were greater than 100%. Even the full strength effluent (100%) did not show any deleterious effects on a ny of the test species. Consequently, the effluent can be expected to be non-toxic to aqua tic organisms as well as to the marine environment in general (appendix 3).

5.2.2 The applicant should provide both acute and chr onic toxicity test data using standardized test procedures to determine the toxicity of th e Preparation and Relevant Chemicals as used in conjunction with the Ballast Water Management System. This testing approach should be performed on the treated Ballast Water Discharge, as the Ballast Water Management system could either mitigate or enhance the adverse effe cts of the Preparation or Relevant Chemicals.

5.2.3 The discharge toxicity tests should be c onducted on samples drawn from the land-based test set-up, which would be repres entative of the discharge from the Ballast Water Management system.

5.2.4 These toxicity tests should include chronic test methods with multiple test species (a fish, an invertebrate and a plant) that address the sensi tive life-stage. The preference is to include both a sub-lethal endpoint (growth) and a survival endpoint. Either fres hwater or marine test methods should be tested.

5.2.5 The test results to be provided include: acute 24-hour, 48-hour, 72-hour, and 96-hour Lethal Concentration at which x% of the test or ganisms die (LCx), No Observed Adverse Effect Concentrations (NOAECs), chronic No Observed Effect Concentration (NOEC) and/or Effect Concentration at which x% of test organisms s how effect (ECx), as appropriate based on the experimental design.

5.2.6 A dilution series including a 100% ballast wate r discharge would be tested to determine the no adverse effect level using the statistical endpoints (NOEC or ECx). An initial analysis could use a conservative approach where the dilution capacity would not be taken into consideration (no modelling or plumes analysis would be used). The rationale for taking a conservative approach is that th ere could be multiple discharges into one location (even though this is not necessarily the case).

• The actual NOEC of ìEcoBallastî treated seawater and brackish water was not measurable; the statistically determined NOEC was 100% (appendix 3).

5.2.7 The acute and chronic toxicity test data in conjunction with the information in Section 4.2.1 should be used to determine the hol ding time necessary to achieve the no adverse effect concentration upon discharge. Knowing the half-life (days), decay rate, dosage rate, volume of system and toxicity tests with time seri es, then a computational model can be used to determine the amount of time needed to hold th e treated ballast water before discharge.

• Since the free radicals have ve ry short life time and no signifi cant toxic effects to aquatic organisms have been observed, and the NOEC has been shown to be 100%, there should be no need for holding time in order to obser ve further adverse effects upon discharge.

5.2.8 Information on Total Residual Oxidants (T RO) and Total Residual Chlorine (TRC) should be provided as part of th e application for eval uation, for both the ba llast water treatment process and the ballast water discharge.MEPC 60/2/1
ANNEX Page 48

I:\MEPC\60\2-1.doc • The Total Residual Oxidants (TRO) was meas ured for the discharged seawater from ìEcoBallastî Management System (Table 13) . There was no difference between treated water and raw (control) seawat er. The detailed informati on can be found in appendix 2.

• The Total Residual Chlorine (TRC) was not meas ured specially. The definition of TRO and TRC is as follows (http: // hc-sc.gc.ca/ewh-semt/pubs/contaminants);

TRC includes both combined residu al chlorine (CRC) and free chlo rine. Free chlorine is also called free residual chlorine (FRC) or free available chlorine (F AC), and it includes hypochlorous acid and the hypochlorite ion. In the presence of brom ide, such as in seawater, reactive chlorine atoms can be completely or partially replaced by bromine atoms. The collection of reactive chlorine and bromine species is called chlorine-produced oxidants (CPO) or total residual oxidants (TRO).

• From the definition of TRO and TRC describe d above, some of reactive chlorine can be measured as TRO. By the fact that ìEcoBa llastî does not use any chlorine compound and the results of TRO measurement (Table 13), the re sult of TRC may be assumed to be almost same as the value of TRO in the ëìEcoBallastî system.

Table 13 . TRO in control and treated seawater (EPA method 330.5:1989)

Time (day 0) Time (day 1) Time (day 5) Salinity Unit MDL Control Treated Control Treated Control Treated 21 PSU mg/L 0.02 0.0 0.0 0.0 0.0 0.0 0.0 34 PSU mg/L 0.02 0.0 0.0 0.0 0.0 0.0 0.0

5.3 Risk characterization and analysis

5.3.1 For the Basic Approval proc ess, fate and effect testi ng should be performed in the laboratory with Active Substances and Preparations. This section lists information that could be useful for a preliminar y risk characterization.

5.3.2 Both the Active Substance or Preparation as well as the tr eated Ballast Water Discharge should be subject to toxicity te sting in order to protect the r eceiving environment from toxic effects due to discharges.

5.3.3 The reaction with organic matter of Active S ubstances and Preparations that produce free radicals should be addressed qu alitatively so as to identify products of concern to the environment.

5.3.4 The rate of abiotic and biotic degradation of the Active Subs tances and Preparations under aerobic and anaerobic conditions should be assessed, resulting in the identification of relevant metabolites in the relevant media (ballast water, marine and fresh waters).

5.3.5 The rate of abiotic and biotic degradation of the Active Subs tances and Preparations under aerobic and anaerobic conditions should be assesse d, resulting in the characterization of the persistence of the Active Substances, Preparat ions and Relevant Chemicals in terms of degradation rates under specified co nditions (e.g., pH, redox, temperature).MEPC 60/2/1
ANNEX Page 49

I:\MEPC\60\2-1.doc 5.3.6 The partition coefficients (solids-water pa rtition coefficient (Kd) and/or organic carbon normalized distribution coefficient (Koc)) of the Active Substances, Preparations and Relevant Chemicals should be determined.

5.3.7 For Active Substances and Preparations, the potential for bioaccumulation should be assessed in marine or freshwater organisms (fish or bivalves) if the logarithm octanol/water partition coefficient (logPow) is >3.

5.3.8 Based on the information on fate and behavior of Active Substances and Preparations, the discharge concentrations at selected time intervals should be predicted.

5.3.9 The effect assessment of the Active Substances, Preparations and Relevant Chemicals is initially based on a dataset of acute and/or chroni c ecotoxicity data for aquatic organisms, being primary producers (algae or sea grasses), consum ers (crustaceans), predators (fish), and should include secondary poisoning to ma mmalian and avian top-predators, as well as data for sediment species.

5.3.10 An assessment of secondary poisoning is redundant if the substance of concern demonstrates a lack of bioaccumulation potenti al (e.g., BCF <500 L/kg wet weight for the whole organism at 6% fat).

5.3.11 An assessment of sediment species is redund ant if the potential of the substance of concern to partition into the sedi ment is low (e.g., Koc <500 L/kg).

5.3.12 The effect assessment of the Active Substa nces, Preparations and Relevant Chemicals should include a screening on carcin ogenic, mutagenic and endocrine disruptive properties. If the screening results give rise to concerns, this s hould give rise to a further effect assessment.

5.3.13 An analytical method suitable for monitori ng Active Substances and Preparations in ballast water discharges should be available.

• The test results revealed no measurable levels of potentially toxic subs tances and no acute or chronic effects of the full strength effluent on aquatic organisms. Therefore, no apparent environmental risks could be identified.

• Acute and chronic eco-toxicity tests of the ìE coBallastî treated seawater and brackish water showed no effects on any of th e test organisms (appendix 3).

• The free radicals resulting from the interactions between UV irradiation and some photosensitizing agents such as nitrate and natura l dissolved organic matter (DOM) in the seawater will react with seve ral organic compounds as described in 2.2.3.1 (Formation of hydroxyl radical (OHï)) and 4.2.1.3 (mode of degrad ation). These radicals are also formed naturally in the surface of seawater so any products from ìEcoBallastî, if formed, can be expected to be of a similar chemical nature to those resulting from natural decomposition in the water, see also 2.2 ëBackground for determ ining the ìActive Substanceî and ìRelevant Chemicalsî and 4.1.4 ëDischarge characteristicsí.

• Since the free radicals have very short life time; no significant toxi c effects to aquatic organisms and the aquatic environments; and the toxicity test results showed that NOEC was 100%, there is no need for holding time as ar gued above, and therefore measurements of discharge concentrations at differe nt time intervals are not relevant.MEPC 60/2/1
ANNEX Page 50

I:\MEPC\60\2-1.doc • The partition coefficients (solids-water parti tion coefficient (Kd) a nd/or organic carbon normalized distribution coeffici ent (Koc)) of the Active S ubstances, Preparations and Relevant Chemicals as well as the logarithm octanol/water partitio n coefficient (logPow) have not been determined, however, the ëChe mical Analysisí (appendix 2) and ëToxicity Testí (appendix 3) indicate that the seawater treated by the ìEcoBallastî management system has not been changed.

• Secondary poisoning testing is here deemed not re levant as chemical analyses data indicate that bioaccumulation does not occur (appendix 2), and these da ta also indicate that the sediment in the ballast water tanks are non-toxic. Furthermore, no carcinogenic, mutagenic or endocrine disruptive substances were found in the analysed seawater.

• In conclusion, it should be noted that the analyses performe d and presented in this document are preliminary and will be complemented with further tests both with re gard to toxicity as well as chemical properties of the treated wate r, if necessary. The test results found no measurable levels of potentially toxic substanc es and no acute or chronic effects of the full strength effluent to aquatic organisms. Ther efore, no apparent envir onmental risks could be identified.

• All analyses were carried out in accordance wi th standard methods and toxicity testing was performed under supervision of the Korea Mari ne Equipment Research Institute (KOMERI), Korea Testing & Research Institute (KTR) and Marine Eco-Technology Institute (MEI). KOMERI laboratory is accredited by KOLAS fo r phytoplankton and micro-organism analyses (appendix 1). The study director of KOMERI is accredited by IOC-UNESCO for identification of harmful microalgae (appendix 1). KTR labor atory is accredited by KOLAS for chemical analysis of environmental samp les including DOC and POC anal ysis (appendix 2). Although MEI Institute is not accredited specifically for toxicological testing (e.g., Good Laboratory Practice, GLP), the Institute has an Ecotoxi cology laboratory, personnel with a solid experience in toxicological research, and all te sts were performed according to GLP. The data on quality assurance (QA) are provide d in each test re port (appendix 3).

6 EVALUATION CRITERIA

The Organization should evaluate the applicati on for approval based on the criteria in this section.

6.1 The information that has been provided should be complete, of sufficient quality and in accordance with this Procedure.

6.2 That this information does not indicate possible unacceptable adverse effects to environment, human health, property or resources.

6.3 Ship and personnel safety

6.3.1 In order to protect the ship and personnel safety the technical gr oup should evaluate the physical and chemical hazards (see paragraph 4.2.1.4) to ensure that potential hazardous properties of the Active Substances, Preparations or Relevant Chemicals formed in the treated ballast water should not create any unreasonable risk to the ship and personnel. Proposed procedures for the use and tec hnical equipment introduced needs to be taken into account.MEPC 60/2/1
ANNEX Page 51

I:\MEPC\60\2-1.doc 6.3.2 For the protection of personnel involved in the handling and storage of the Active Substances and Preparations, the proposal should incl ude relevant ((M)SDS) . The Organization should evaluate (M)SDS, mammalian toxicity da ta and chemical properties hazards (see paragraphs 4.2.1.2 and 4.2.1.4) and ensure that potential hazardous properties of the Active Substances, Preparations or Releva nt Chemicals should not create any unreasonable risk to the ship or personnel. This evaluation should take into account th e different circumstances th at a ship or personnel may face in its trade (e.g., ice, tropical, humidity, etc.).

6.3.3 A Human Exposure Scenario (H ES) should be provided by the applicant as part of the Risk Assessment procedure for ballast water management systems.

6.3.4 Hazard Identification (HAZID) study of ìEcoBallastî Management System

A HAZID study was conducted to id entify possible hazardous events and how to manage hazards to personnel and ship through the design and opera tional phase of the ìEcoBallastî management system. The HAZID workshop was organized incl uding experts with expe rience in mechanical and process design, manufacture, and ship trial te st, etc., in HHI. The workshop identified the following operations and issues as relevant in relation to ship and personnel safety:

• UV reactor

• Auto back flushing filter

• CIP unit

• Human safety.

All HAZID issues were included in the Risk Re gister with recommenda tions on corrective or preventive actions. A detailed report of HAZID is described in appendix 5. HAZID Identification Report.

The main HAZID issues are summarized as follows:

• Insufficient flow level and incomplete fil ling in the UV reactor were identified as a possible hazard event as this may cause overheating of the UV lamp. Preventive actions include installation of temperature se nsor and flow meter within the UV reactor to prevent critical conditions.

• The installation of an air vent line and le vel switch is recommended as a safeguard against the hazard in the event that UV la mps are not completely synchronized with the ballast water flow and therefore overheated.

• The quart sleeves protecting the UV lamps may break inside the UV reactor during the normal operation due to clashing against debris material in the sea water. Because an auto back flushing filter is installed, such an event is unlikely to cause hazards to ship, crew, or the water environment.

• The air vent line should be installed in the upper filter cover to avoid generating an air pocket inside the auto back flushing filter.

• For control of correct back flushing through the filter, a differential pressure sensor should be installed and monitored.MEPC 60/2/1
ANNEX Page 52

I:\MEPC\60\2-1.doc • The line (pipes) connecting the CIP unit and the UV reactor should be constructed to resist the corrosive characteristics of the cleaning solution in the CIP tank.

• During general maintenance, storage or di sposal procedures, the UV lamp may be broken by careless handling. This may lead to mercury (Hg) exposure with extremely serious impact on both human health and th e environment in general. As preventive actions, HHI shall establish guidelines and pr ocedures for the handling of such events including appropriate manner of packing and protective ma terials for the potential hazardous components.

• Crew members operating the UV reactor should receive special training in its operation including hazard s associated with exposure to UV radiation and exposure to mercury. Suitable protective gear identified by independent job safety analysis shall be provided to the handling crew.

6.3.5 Managements in emergency conditions

Emergency conditions are consid ered in the design of ìEcoBallastî management system especially during operation on board (Table 14).

Table 14. Emergency conditions and its mana gement in design of ìEcoBallastî

Emergency Conditions Emergency Management

Electric power failure In case of electric power failure of ship: ! All units will be stopped and go to safe positions. After recovery of power system, all units can be restarted with operator acknowledge.

! All hydraulic valves will be in position as it has before failure.

! All pneumatic valves will be closed because all pneumatic valves are fail-safe closed type. Hydraulic power failure Hydraulic power failure during operation by failure of hydraulic power pack ! All hydraulic valves will be in position as it has before failure. Therefore, for emergency operation, hydraulic hand pump is necessary. For emergency operation of hydraulic valve, emergency hand pump and accessories will be provided.

Instrument air failure Instrument air failure during CIP operation ! All pneumatic valves will be closed because all pneumatic valves are fail-safe closed type.

! CIP operation is not essential operation and crew can restart whenever cleaning operation is possible.
Instrument air failure In case of instrument air failure during filter operation

Instrument power failure Instrument power failure during filter operation ! Filter back-flushing valve could not be open or close and back-flushing cannot be accomplished and failure alarm will be generated. In this case, emergency operation bypass filter unit is possible, however, this operation may not meet IMO requirement and this event will be monitored by system control unit and recorded in data storage of operator station and system control unit with redundancy.

Heavy weather ballasting ! For heavy weather ballasting operation without treatment, system bypass valve is considered. However, this operation cannot meet IMO requirement and event will be monitored by system control unit and recorded in data stor age of operator station and system control unit with redundancy.MEPC 60/2/1
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I:\MEPC\60\2-1.doc 6.4 Environmental protection

6.4.1 In order to approve the a pplication, the Organization shou ld determine that the Active Substances, Preparations or Relevant Chemical s are not Persistent, Bioaccumulative and Toxic (PBT). Preparations that exceed all these criter ia (Persistence, Bioaccum ulation and Toxicity) in the table below are considered PBT.

Table 1. Criteria for identification of PBT substances

Criterion PBT criteria
Persistence Half-life: > 60 days in marine water, or > 40 days in freshwater, or > 180 days in marine sediment, or > 120 days in freshwater sediment Bioaccumulation BCF > 2,000 or LogPoctanol/water ≥ 3 Toxicity Chronic NOEC < 0.01 mg/l

Note : For the purpose of marine envir onmental risk assessment half-life data in freshwater and freshwater sediment can be overruled by data obtained under marine conditions.

6.4.2 The Organization should determine the overall acceptability of the risk the Preparation may pose in its use for ballast water management. It should do so by co mparing the information provided and the undertaken assessment of PBT a nd the discharge with scientific knowledge of the Active Substances, Preparations and Releva nt Chemicals concerned. The risk evaluation should qualitatively take into account cumulative effects that may occur due to the nature of shipping and port operations.

6.4.3 The risk evaluation should consider the uncertainties involved in the application for approval, and as appropriate, provide advice on how these uncertainties can be dealt with.

6.4.4 An Emission Scenario Document (ESD) should be provided by the applicant as part of the Risk Assessment procedure for ballast wate r management systems. The ESD should be based on the worst-case discharge scenario and should be regarded as the first stage of a stepped approach to the development of a full ESD, when more data on potential discharges and technologies becomes available.

• The chemical analyses (appendix 2) and the t oxicity tests (appendix 3) have lead to the conclusion that there are no potential risks to the aquatic environment. No potentially dangerous substances were identified in the wa ter and the discharge effluent (100%) did not have any harmful effects on any of the tested organisms.

• An Emission Scenario Document (ESD) has not been prepared as the ìEcoBallastî system does not use chemicals in the treatment of the water.

HHI ìEcoBallastî has received co mments of Risk assessments for Human Health, Ships, and Environment in MEPC 59/2/16, annex 8, paragraphs 4, 5 and 6.MEPC 60/2/1
ANNEX Page 54

I:\MEPC\60\2-1.doc ì 4 HUMAN HEALTH ASSESSMENT

4.1 The Group noted that the potential ha zards for human health related to overheating of UV lamps and exposure to UV irradiation resulting from operating this system were sufficiently addressed by the a pplicant by engineering control measures put in place and training of operators. Therefore the Group concluded that the risk of crew exposure was sufficiently mitigated by the measures put in place.

4.2 In addition the Group no ted that all the di sinfection by-products measured in the discharged ballast water we re under LOD with exception of AOX (A dsorbable Organic Halogens) (0.29mg/L at day 5). The Group considered that th ese chemicals are short-lived and would not pose a toxicolo gical concern towards the gene ral public swimming and eating fish from the area. The Grou p identified that the only potential for human health risk was related to exposure to UV irradi ation from the treatment unit and therefore recommends that appropriate risk mitigation measures be put in place.

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

5.1 The Group was satisfied that, as the sy stem does not involve the storage or generation of chemicals to treat ballast wate r, there were no associated storage safety problems or risks.

5.2 The Group noted that the submission identif ied the only potential risk to the ship and its crew present in the BWMS was relate d to UV irradiation a nd overheating in the treatment unit from the UV lamps. The submission confirmed that these identified risks had been addressed by system safety measur es that ensure that there is no risk of personnel exposure to UV-irradiation and that automatic shut down occurs, in a no-flow situation, in order to prevent overheating.

5.3 The Group noted that the corro sivity of UV-treated seawat er had been tested with the discharged ballast water from the EcoB allast BWMS during about six months. The test results showed no significan t changes of the corrosivity of the discharged seawater compared to raw seawater. The Group conclu ded the results indicated that UV-treated seawater, the effluent of EcoBallast, has ne gligible effect on coating performance of shipís ballast tank, when compared with na tural seawater and co ating performance will meet the IMO PSPC requirement.

5.4 The Group noted that the applicant had provided information (during the GESAMP-BWWG meeting) about normal maintena nce procedures to keep the surface of the quartz sleeve in the UV lamps clean. This procedure includes frequent cleaning (every 15 hours of operation) using clean ing solution of low concentration of biodegradable organic acid. The Group recomme nds that detailed information for safe use of the cleaning procedure on-board s hould be supplied during Type Approval and evaluated by the Administration in accordance with Procedure (G8).MEPC 60/2/1
ANNEX Page 55

I:\MEPC\60\2-1.doc 6 ENVIRONMENTAL RISK ASSESSMENT

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

6.1.1 The Group recognized that it was not possible to evaluate the persistence, bioaccumulation and toxicity of any chemical s within or produced by the system, as it does not use a chemical active substanc e or produce any relevant chemical for assessment. Assessment of the PBT-criteria is therefore considered not applicable.

6.2 Derivation of the Predicted No Effect Concentration (PNEC)

6.2.1 The Group noted that the applicant had provided some acute and chronic aquatic ecotoxicity data for the 100% treated ballast wa ter that demonstrated a complete lack of toxicity in all studies except the chronic te sts on Pacific Oyster ELS and Sea Urchin ELS with NOEC values of 12.5% and 6.25% respectively, and LC25 values of 49% and 18.5% respectively (both LC50 values were > 100%).

6.2.2 The Group noted that the slight effects s een in the two chroni c ecotoxicity tests had not been sufficiently described by the a pplicant in the non-conf idential dossier. In response to a request for further information, the Group was informed that slight chronic toxicity effects had been observed in echinoderm and mo llusc. However, the LC50 values of the chronic toxicity effect to ech inoderm and mollusc were greater than 100% of the UV-treated ballast wate r and there should be no need for holding time in order to prevent adverse effects to the environment upon discharge of the ballast water. The Group concurred with this view.

6.2.3 The Group agreed that the derivation of a PNEC is not possible as the nature of the system does not involve th e use of chemicals that make the derivation of a PNEC either possible or necessary. The Group noted th at full results of the ecotoxicity tests are provided in the appendix to this annex.

6.3 Calculation of the Predicted E nvironmental Concentration (PEC)

6.3.1 The Group agreed that ther e would be no point in ca lculating the PEC of the treated ballast water, in view of the absence of any PNEC values.

6.4 Calculation of the PEC/PNEC ratios

6.4.1 The Group noted that neither the PEC nor the PNEC had been derived. The Group agreed that it was not necessary to do so in the present assessment.î

7 REGULATION OF THE USE OF ACTIV E SUBSTANCES AND PREPARATIONS

7.1 Handling of Active Substances and Preparations

7.1.1 The proposal for approval of Active Substances and Preparations should include information on their intended use and applicati on. The quantity of Active Substances and Preparations to be added to the ballast water and the maximum allowabl e concentration of the Active Substances therein should be described in the instructions provided by the manufacture.MEPC 60/2/1
ANNEX Page 56

I:\MEPC\60\2-1.doc • The ìEcoBallastî management system is desi gned with a specified number of UV-lamps according to the maximum design flow rate of the ballast system. If the flow rate of ballast system decreases, the control system will detect this and decrease power of each lamp accordingly in order to minimize the power co nsumption and to prevent over-dosage of UV irradiation. Therefore the ìEcoBallastî ma nagement system will not produce higher quantities of ìActive Substancesî in case of fluctuating (decreasing) flow rate.

7.1.2 An assessment should be undertaken to ensure the safe on-board handling and storage of chemicals used to treat ballast water, using the existing IMO Conventions, Codes and guidance as a basis.

7.2 Hazard documentation and labelling

7.2.1 The proposal should include ((M)SDS) as required. The (M)S DS should describe appropriate storage and handling to gether with the effects of degr adation and chemical reactivity during storage and should be included in the instructions provided by the manufacturer.

• A ((M)SDS) is deemed not applicable for the ìEcoBallastî system.

7.2.2 Document ation of hazards or the (M)SDS should conform to the UN Globally Harmonized System of Classification and La belling of Chemicals (GHS) and the relevant IMO regulations (e.g., the IMDG Code) and guidelines (e.g., the GESAMP Hazard Evaluation Procedure). Where these regimes are not applicable, relevant na tional or regional regimes should be followed.

7.3 Procedures and use

7.3.1 Detailed procedures and information for safe application of Active Substances and Preparations on board should be developed and supplied, taki ng into consider ation existing IMO Conventions, Codes and guidance. The pr ocedures should comply with the approval conditions such as maximum allowa ble concentration and maximum di scharge concentr ation, if any.

8 APPROVAL

8.1 Basic approval

8.1.1 All proprietary data should be treated as conf idential by the Organization and its Technical Group, the Competent Authorities involved, and the evaluating regul atory scientists, if any. However, all information related to safety and environmental protection, including physical/ chemical properties, environmental fate and t oxicity, should be treate d as non-confidential.

8.1.2 Procedure to be followed:

.1 The manufacturer should evaluate the Ac tive Substances or Preparations and the potential discharge in accordance with th e approval criteria specified in this procedure.

.2 Upon completion, the manufacturer should prepare an Application on the Active Substances and Preparations and submit it to the Member of the Organization concerned. An application should only be made once the ballast water management system, Active Substance or Prepara tion has been sufficiently designed, progressed and tested to pr ovide the full data necessa ry for a Basic Approval.MEPC 60/2/1
ANNEX Page 57

I:\MEPC\60\2-1.doc .3 The Administration having received a satis factory application should as soon as possible propose an appr oval to the Organization.

.4 Members of the Organization may propose an approval.

.5 The Organization should announce and se t the time frame for the evaluation of Active Substances and Preparations.

.6 Parties, Members of the Organization, the United Nations and its Specialized Agencies, intergovernmental organiza tions having agreements with the Organization and non-governmental organizatio ns in consultative status with the Organization may submit in formation that is rele vant to the evaluation.

.7 The Organization should esta blish a Technical Group in accordance with its rules of procedure ensuring that proprietary da ta should be treated as confidential.

.8 The Technical Group should review the comprehensive proposal along with any additional data submitted and report to the Organization whether the proposal has demonstrated a potential for unreasonable risk for environment, human health, property or resources in accordance with th e criteria specified in this procedure.

.9 The Technical Groupís report should be in written form and circulated to the Parties, Members of the Organization, the United Nations and its Specialized Agencies, intergovernmental organiza tions having agreements with the Organization and non-governmental organizatio ns in consultative status with the Organization, prior to its consider ation by the competent Committee.

.10 The Committee of the Organization s hould decide whether to approve any proposal, introduce any modifica tions thereto, if appropr iate, taking into account the Technical Groupís report.

.11 The Member of the Organization that submitted the application to the Organization should inform in writing the applicant about the decision made with regard to the respective Active Substance or Preparation and their manner of application.

.12 Active Substances or Preparations r eceiving Basic Approval by the Organization may be used for prototype or type approval testing based on the guidelines developed by the Organization4. Subject to evaluation against the criteria developed by the Organization, an Active Substance or Preparation may be used for Prototype or Type Approval testi ng for the approval of different BWMS.

.13 An applicant seeking to take advantage of an Active Substan ce or Preparationís Basic Approval should provide in its app lication a written agreement from the applicant whose Active Substance or Prep aration has been granted the initial Basic Approval.

8.2 Final Approval

8.2.1 In accordance with regulation D-3.2, a ballast water management system using an Active Substance or Preparation to comp ly with the Convention (which received Basic Approval) must be approved by the Organization. For this purpos e, the Member of the Organization submitting an application should conduct the Type Approval tests in accordance with the Guidelines for approvalMEPC 60/2/1
ANNEX Page 58

I:\MEPC\60\2-1.doc of ballast water management systems (G8). The results should be conveyed to the Organization for confirmation that the residual toxicity of the discharge confor ms to the evaluation undertaken for Basic Approval. This would result in Final Approval of the ballast water management system in accordance with regulation D-3.2. Active Substances or Preparations that have received Basic Approval by the Organization may be used for ev aluation of ballast water management systems using Active Substances or Prep arations for Final Approval.

8.2.2 It is to be noted that from Guidelines (G 8) land-based testing on ly the results of the residual toxicity tests should be included in the proposal for Fi nal Approval in accordance with Procedure (G9). All other Guidelines (G8) tes ting remains for the assessment and attention of the Administration. Basic Approva l under Procedure (G9) should not be a pre-requis ite of Type Approval testing, as an Administ ration can regulate discharges from its own ships in its own jurisdiction. Basic Approval w ould still be required , and the specific t echnology could not be used in vessels in another juri sdiction without Basic Approval.

8.2.3 It should be noted that once a system has r eceived Final Approval under this Procedure, then the respective applicant shou ld not have to retrospectively submit new data if there is a change in the Methodology ag reed by the Organization.

8.3 Notification of approval

8.3.1 The Organization will record the Basic a nd Final Approval of Active Substances and Preparations and ballast water management syst ems that make use of Active Substances and circulate the list once a year including the following information:

• Name of ballast water management system that make use of Active Substances and Preparations;

• Date of approval;

• Name of manufacturer; and

• Any other specifications, if necessary.

8.4 Modification

8.4.1 Manufacturers should report any modifications in names, including trade and technical name, composition or use of the Active Substances and Preparations in the ballast water management systems approved by the Organizati on, to the Member of the Organization. The Member of the Organization should in form the Organization accordingly.

8.4.2 Manufacturers intending to sign ificantly change any part of a ballast water management System that has been approved by the Organizati on or the Active Substances and Preparations used in it should submit a new application.

8.5 Withdrawal of approval

8.5.1 The Organization may withdraw any appr oval in the following circumstances:

.1 If the Active Substances and Preparati ons or ballast water management system that make use of Active Substances no longer conforms to requirements due to amendments of the Convention.MEPC 60/2/1
ANNEX Page 59

I:\MEPC\60\2-1.doc .2 If any data or test reco rds differ materially from data relied upon at the time of approval and are deemed not to satisfy the approval condition.

.3 If a request for withdrawal of approval is made by the Member of the Organization on behalf of the manufacturer.

.4 If unreasonable harm to environment, human health, property or resources is demonstrated by any Member of the Organi zation or observer to have been caused by the approved ballast water management system that makes use of Active Substances or Preparations.

9 CONCLUSION

The ìEcoBallastî Management System uses filter and UV technology. The direct effect of UV irradiation will destroy DNA of the micro-organi sms causing their death. Also indirect effect of UV will produce radicals and attack cells, which is the same mechanism of the natural process that occurs when the sunlight hits the surface of the seawater. There are no chemicals added and there are no chemicals formed whic h can enter the ballast tanks.

The chemical analysis before and after the full scale (200 m 3 /hr) treatment has not indicated any residual substances. Toxic ity test results from acute and chr onic toxicity test s with seawater and brackish water show that there is no toxic effect det ected in the treated water.

HHI ìEcoBallastî has received comments fo r Conclusions and Recommendations in MEPC 59/2/16, annex 8, paragraph 7, as follows:

ì 7 CONCLUSIONS AND RECOMMENDATIONS

7.1 Risks to the safety of the ship

7.1.1 Based on the points expressed above in this Annex, the Group agreed that this system was not likely to cause any concern with regards to the safety of the ship.

7.2 Risk to the crew and the general public

7.2.1 The Group agreed that the potential hazards for human health related to overheating of UV lamps and exposure to UV irradiation resulting from operating this system were sufficiently addressed by the a pplicant by engineering control measures put in place and training of operato rs. Therefore the Group concl uded that the risk of crew exposure was sufficiently mitigated by the measures put in place.

7.2.2 In addition the Group noted that all the disinfection by-products measured in the discharged ballast water we re under LOD with exception of AOX (Adsorbable Organic Halogens) (0.29mg/L at day 5). The Group considered that these chemicals are short-lived and would not pose a toxicologi cal concern towards the general public swimming and eating fish from the area. Th e Group agreed that the only potential for human health risk was related to exposure to UV irradiation from the treatment unit and therefore recommends that appropriate ri sk mitigation measures be put in place.MEPC 60/2/1
ANNEX Page 60

I:\MEPC\60\2-1.doc 7.3 Risks to the environment

7.3.1 Based on the acute and chronic aquatic ecotoxicity tests carried out on the treated ballast water, the Group agreed that this sy stem was not likely to cause any concern with regard to the environment.

7.4 Recommendations

7.4.1 Having considered all of the data submitted for Basic Approval, the Group agreed to recommend that Basic Approval be given to this system.

7.4.2 Moreover, the Group was satisfied that the required tests had been performed correctly and that the results demonstrated that the system met the requirements of Procedure (G9) to allow it to be recommended for Final Appr oval. The Group was of the opinion that this application fulfils the requi rements for consideration for Final Approval.î

10 REFERENCES

Alam, M.Z.B. and Ohgaki, S. (2002). Role of hydrogen peroxide ra dical in producing the residual effect of u ltraviolet radiation. Water Environment Research . 74 (3), 248-255.

Andreozzi, R., Caprio, V., Insola, A., and Maro tta, R. (1999). Advanced oxidation process (AOP) for water purification and recovery. Catalysis Today . 53, 51-59.

Arana, I., Muela, A., Iriberri, J., Egea, L., and Ba rcina, I. (1992). Role of hydrogen peroxide in loss of culturability mediated by visible light in Escherichia coli in a freshwater ecosystem. Applied and Environmental Microbiology . 58, 3903-3907.

Barroin, G. and Feuillade, M. ( 1986). Hydrogen Peroxide as a poten tial algicide for Oscillatoria rubescens D.C. Water Research , 20, 619-623.

Bjˆrnsson, B. (2004). Can UV-treated seawater cause cataract in juve nile cod (Gadus morhua L.)? Aquaculture . 240, 187-199.

Bukhari, Z., Abram, F., and LeChevallier, M. ( 2004). Using ultraviolet light for disinfection of finished water. Water Science and Technology . 50 (1), 173-178.

Bullock, G.L. and Stuckey, H.M. (1977). Ultravio let treatment of water fo r destruction of five gram-negative bacteria pathogenic to fishes. Journal of the Fisheries Research Board of Canada . 34, 1244-1249.

Cooper, W.J. and Zika, R.G. (1983). Photochemical formation of hydrogen peroxide in surface and ground waters exposed to sunlight. Science . 220, 711-712.

Curtis, T.P., Mara, D.D., and Silva, S.A. (1992) . Influence of pH, oxygen, and humic substances on ability of sunlight to damage fecal co liforms in waste stabilization pond water. Applied and Environmental Microbiology . 58, 1335-1343.

de Veer, I., Moriske, H.J., and Ruden, H. (1994). Photochemical decomposition of organic compounds in water after U.V.-irradiation: i nvestigation of positive mutagenic effects. Toxicology Letters . 72, 113-119.MEPC 60/2/1
ANNEX Page 61

I:\MEPC\60\2-1.doc Gjessing, E.T. and K‰llqvist, T. (1991). Algicida l and chemical effect of UV radiation of water containing humic substances. Water Research . 25 (4), 491-494.

Hedges, J.I. (1992). Global biogeoche mical cycles: progress and problems. Marine Chemistry

. 39, 67-93.

Kashinkunti, R.D., Linden, K.G., Shin, G., Me tz, D.H., Sobsey, M.D., Moran, M.C., and Samuelson, A.M. (2004). Investigating multibarrier inactivation for Cincinnati-UV, by-products, and biostability. Journal American Wate r Works Association . 96 (6), 114-127.

Kimura, T., Yoshimizu, M., Tajima, K., Ezura, Y., and Sakai, M. ( 1976). Disinfection of hatchery water supply by ultrav iolet (U.V.) irradiati on ñ Susceptibility of some fish-pathogenic bacteria and micro-organisms inhabiting pond waters. Bulletin of the Japan Soc iety of Scientific Fisheries. 42, 207-211.

Kruithof, J.C., van der Leer, R.C., and Hijnen, W. A.M. (1992). Practical experiences with UV disinfection in the Netherlands . J Water SRT-Aqua . 41 (2), 88-94.

Lethola, M.J., Mittinen, I.T., Vartiainen, T., Ra ntakokko, P., Hirvonen, A., and Martikainen, P.J. (2003). Impact of UV disinfection on microbi ally available phosphoru s, organic carbon, and microbial growth in drinking water. Water research . 37, 1064-1070.

Liltved, H., Hektoen, H., and Efraimsen, H. (1995) . Inactivation of bacterial and viral fish pathogens by ozonation or UV irradiati on in water of different salinity. Aquacultural Engineering . 14, 107-122.

Liltved, H., Vogelsang, C., Modahl, I., and Dannevig, B. (2006). High resi stance of fish pathogenic viruses to UV irradiation and ozonated seawater. Aquacultural Engineering , 34, 72-82.

Lund, V. and Hongve, D. (1994). Ultraviolet i rradiated water containing humic substances inhibits bacterial metabolism. Water Research . 28 (5), 1111-1116.

Lund, V. and Ormerod, K. (1994). The influence of disinfection processe s on biofilm formation in water distribution system. Water Research . 29 (4), 1013-1021.

MacKinnon, M.D. (1981). The measurem ent of organic carbon n sea water. In Marine Organic Chemistry , Elsevier Oceanography Seri es, 31 ed. E.K. Duursma & R.Dawson, 415-443. Elsevier Scientific Publishing, Amsterdam.

Miller, R.V., Jeffrey, W., Mitchell, D., and Elasri, M. (1999). Bacterial responses to ultraviolet light. ASM News . 65, 535-541.

Mopper, K. and Degens, E.T. (1979). Organic carbon in the ocean: Natural and cycling. In The Global Carbon Cycle , ed. Bolin, B., Degens, E.T., Kemp e, S., and Ketner, P., 293-316, John Wiley & Sons, New York.

Mopper K. and Kieber D.J. (2000). Marine phot ochemistry and its impact on carbon cycling. In The effects of UV radiation in the marine environment , Cambridge environmental chemistry series, 10 ed. de Mora S., Demers S., and Vernet M. 101-129, Cambridge University Press, Cambridge.MEPC 60/2/1
ANNEX Page 62

I:\MEPC\60\2-1.doc Parkingson, A., Barry, M.J., Roddick, F.A., and Hobday, M.D. (2001). Preliminary toxicity assessment of water after treatment with UV-irradiation and UVC/H2O2. Water Research

. 35 (5), 3656-3664.

Parkingson, A., Roddick, F.A., and Hobday, M.D. (2003). UV photooxida tion of NOM: issues related to drinking water treatment. Journal of Water Supply and Technology-Aqua . 52 (8), 577-586.

Peldszus, S., Andrews, S.A., Souza, R., Smith, F., Douglas, I., Bolton, J., and Huck, P.M. (2004). Effect of medium-pressure UV irradiati on on bromate concentrations in drinking water, a pilot scale study. Water Research . 38 (1), 211-217.

Reed R.H. (1997). Solar inactiv ation of fecal bacteria in wate r: the critical role of oxygen. Letters in Applied Microbiology . 24, 276-280.

Sage E. (1993). Distribution and repair of photoles ions in DNA: genetic consequences and the role of sequence context. Photochemistry and Photobiology . 57, 163-174.

Sako, H. and Sorimachi, M. (1985). Susceptibili ty of fish pathogenic viruses, bacteria and fungus to ultraviolet irra diation and the disinfection effect of W- ozone water sterilizer on the pathogens in water. Bull. National Research Institute of Aquaculture . 8, 51-58.

Sharpless, C.M., Page, M.A., and Linden, K.G. (2003). Impact of hydrogen peroxide on nitrite formation during UV disinfection. Water Research . 37, 4730-4736.

Shaw, J.P., Malley, J.P., and Willough S.A. (2000) . Effects of UV irradiation on organic matter. Journal American Water Works Association . 92 (4), 157-167.

Takeda, K., Takedoi H., Yamaji S., Ohta K., and Sakugawa H. (2004). Determination of Hydroxy Radical Photoproduction Rates in Natural Waters. Analytical Sciences . 20, 153-158.

Cited Internet Addresses

webbook.nist.gov

- [ http://webbook.nist.gov/cgi /cbook.cgi?Name=hydroxyl +radical&Units=SI ]

Canada Environmental Protection Act, 1999

- [ http://hc-sc.gc.ca/ewh-semt/pubs/contaminants ]

* * *MEPC 60/2/1
ANNEX Page 63

I:\MEPC\60\2-1.doc APPENDIX 1



### EXTRACTION OF QAPP

Project Name: HHI-BWM System

System Developer: Hyundai Heavy Industry Co., Ltd 1, Jeongha-dong Dong-gu, Ulsan, Republic of Korea Tel. 82-52-202-2114 Fax. 82-52-202-3470 english.hhi.co.kr

Primary System Tester (Type Approval Test Organization) Korea Marine Equipment Research Institute 1125-22 Dongsam-dong, Youngdo-gu, Busan, Republic of
Korea
Tel. 82-51-400-5000 Fax. 82-51-400-5091 www.komeri.re.kr

1.

............................................................................................................................... ........ 2.

............................................................................................................................... ........ 3.

............................................................................................................................... ........ 4.

............................................................................................................................... ........ 5.

............................................................................................................................... ........ 6.

............................................................................................................................... ........ 7.

............................................................................................................................... ........ October 2008 

### Quality Assurance Project Plan (QAPP) for

testing of HHI-BWM (EcoBallast) System for Type Approval by the Ministry of Land, Transport and Maritime Affairs (MLTM), Republic of Korea in accordance with the Guidelines for A pp roval of Ballast Water Mana g ement S y stems (G8)MEPC 60/2/1
ANNEX Page 64

I:\MEPC\60\2-1.doc Contents

Introduction and background ...................................................................................................

......... Quality Management Plan (QMP) .................................................................................................

... 1. Hyundai Heavy Industries ...................................................................................................

... 2. Korea Marine Equipment Research Institute ......................................................................... Quality Assurance Proj ect Plan (QAPP) .........................................................................................

.. Quality St atement .............................................................................................................

........ Approval Sheet ................................................................................................................

......... Distribution List .............................................................................................................

.......... 1. PROJECT MANAGEMENT ................................................................................................ 1.1 Project Description .......................................................................................................

.. 1.1.1 Address of QAPP ................................................................................................. 1.2 Project Organization and Responsibilities ...................................................................... 1.3 Project and Task Description .......................................................................................... 1.3.1 Test Site ...............................................................................................................

. 1.3.2 The HHI-BWM System ....................................................................................... 1.3.3 Test Schedule ....................................................................................................... 1.3.4 Task ....................................................................................................................

.. 1.4 Quality Assurance Objectives ......................................................................................... 1.5 Training and Certification ............................................................................................... 1.5.1 Collection and Handling of Samples .................................................................... 1.5.2 Laboratory Testing and Analysis ......................................................................... 1.6 Document and Records ................................................................................................... 1.6.1 QAPP .................................................................................................................... 1.6.2 Field Sample Records............................................................................................ 1.6.3 Chain of Custody Records .................................................................................... 1.6.4 Laboratory Raw Data Records .............................................................................. 2. MEASUREMENT AND DATA ACQUISITION ................................................................ 2.1 Sampling Process Design .............................................................................................. 2.2 Sampling Methods ........................................................................................................ 2.2.1 Sample Collection, Preparation, Decontamination Procedure ............................. 2.2.2 Sampling Equipment, Preservation, and Holding Times ..................................... 2.2.3 Sampling/Measurement System Failure Response and Corrective Action Process 2.3 Sample Handling and Custody ...................................................................................... 2.4 Preparation of Samples and Analytical Methods .......................................................... 2.4.1 Analysis of Organisms in Water Samples ( ≥ 10 ñ 50 μm and ≥ 50 μm) ............. 2.4.2 Samples for Chemical Analyses (KTR) ............................................................... 2.4.3 Samples for Bacteriological Analysis .................................................................. 2.5 Quality Control Procedures ........................................................................................... 2.6 Data Acquisition ..........................................................................................................

.. 2.7 Data Management .......................................................................................................... 2.7.1 Data Recording ..................................................................................................... 2.7.2 Data Validation .................................................................................................... 2.7.3 Data Transformation ............................................................................................ 2.7.4 Data Transmittal ................................................................................................... 2.7.5 Data Reduction ..................................................................................................... 2.7.6 Data Analysis ....................................................................................................... 2.7.7 Data Tracking ....................................................................................................... 2.7.8 Data Storage and Retrieval ................................................................................... 2.7.9 Data Release .........................................................................................................MEPC 60/2/1
ANNEX Page 65

I:\MEPC\60\2-1.doc 3. ASSESSEMENT AND OVERSIGHT .................................................................................. 3.1 Assessment and Response Actions ................................................................................ 3.2 Reports to Management ................................................................................................. 4. DATA VALIDATION AND USABILITY ........................................................................... 4.1 Data Review, Validation, and Verification ................................................................... 4.1.1 Sampling Design .................................................................................................. 4.1.2 Calibration ............................................................................................................ 4.1.3 Data Reduction and Processing ............................................................................ 4.2 Validation and Verification Methods ............................................................................ 5. REFERENCES .................................................................................................................

..... 6. APPENDICES .................................................................................................................

...... Appendix 1 ....................................................................................................................

...... Appendix 2 ....................................................................................................................

...... Appendix 3 ....................................................................................................................

...... Appendix 4 ....................................................................................................................

...... Appendix 5 ....................................................................................................................

...... Appendix 6 ....................................................................................................................

...... Appendix 7 ....................................................................................................................

...... Appendix 8 Reference materials and papers ........................................................................ Appendix 9 Full-scale (200 ton/hr) Test Report ..................................................................

Appendix 1. Species identification of influent (ballast) water ( ≥ 50 μm, min. dimension)

Appendix 2. Pictures of organisms ( ≥ 50 μm, min. dimension)

Appendix 3. Species identification of influent (ballast) water ( ≥ 10-50 μm, min. dimension)

Appendix 4. Pictures of organisms ( ≥ 10-50 μm, min. dimension)

Appendix 5. Pictures of incubated bacteria

Appendix 6. Chain of custody record

* * *MEPC 60/2/1
ANNEX Page 66

I:\MEPC\60\2-1.doc APPENDIX 2



### TEST REPORTS OF CHEMICAL ANALYSIS

Quality Assurance Project Plan (QAPP)



### HHI-BWM (EcoBallast) System

Korea Testing & Research Institute

prepared by: Jae-Hong Kim Korea Testing & Research Institute 411 Daun-dong, Jung-gu, Ulsan, Republic of Korea www.ktr.or.kr

reviewed by: Mu-Sang Lyu Korea Testing & Research Institute 411 Daun-dong, Jung-gu, Ulsan, Republic of Korea www.ktr.or.kr

under contract to Ph.D. Kee-Yong Park Hyundai Heavy Industries Co., Ltd 1, Jeongha-dong Dong-gu, Ulsan, Republic of Korea english.hhi.co.kr

co-work to Young-Soo Kim Korean Marine Equipment Research Institute 1125-22 Dongsam-dong, Youngdo-gu, Busan, Republic of Korea eng.komeri.re.kr

October 2008

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I:\MEPC\60\2-1.doc APPENDIX 3



### TEST REPORTS OF AQUATIC TOXICITY

Test Report on Aquatic Organism Toxicity

No significant acute toxicity was observed in tr eated deballasting seawater compared to control seawater. But slightly low NOEC observed in chronic toxicity test on treated deballasting seawater of 34 PSU. Echinoderm and mollu sc show 6.25% of NOE C and 12.50% of NOEC, respectively. Besides of these two organisms, any other organisms do not show significant toxicity in chronic toxicity test on treated deballasting seawater.

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I:\MEPC\60\2-1.doc APPENDIX 4



### TEST REPORTS OF CORROSIVITY

Corrosivity tests were conducted to assess the effect of efflue nt from ìEcoBallastî system on protective coating of water ballast tank. For test , epoxy coating system which is the most widely used in shipís ballast tank coating was appl ied to Simulated Wave Ballast Tank (SWBT) according to IMO MSC 82/WP.3.

Following coating performances were eval uated for natural and treated seawater:

# Adhesion strength,

# Anti-corrosion resistance,

# Cathodic disbondment resistance,

# Colour change,

# Chemical molecular change on surf ace coating using FT-IR analysis.

The key results are as follows:

# Adhesion strength was little aff ected by seawater condition a nd coating adhe sion strength and coating failure mode satisfied the requirement of IMO PSPC.

# It was found that UV-treated wate r did not significantly affect corrosion creep of coating system comparing with natural seawater cond ition and corrosion creep of coating system well satisfied IMO PSPC criterion, below 8mm regardless of seawater condition.

# The cathodic disbondment difference between natu ral seawater condition and UV-treated condition is negligible level. In addition, coating system satisfied thoroughly cathodic disbondment criterion of IMO PSPC, <8mm, regardless of seawater condition. These observations confirmed that cathodic disbondment resistance was not affected by UV-treated

seawater.MEPC 60/2/1
ANNEX Page 69

I:\MEPC\60\2-1.doc # There was no remarkable colour difference between two exposed environments since all of the colour difference ( ∆ E) are below 1, which cannot be distinguished with naked eye.

# FT-IR analysis results show that there is negl igible chemical structure change or chemical aging even though the coating films were expos ed to UV-treated seawater environment.

As a conclusion, results clearly in dicated that UV-treated seawater , the effluent of ìEcoBallastî system, has negligible effect on coating performance of shipís ba llast tank, when compared with natural seawater and coating performance will meet the IMO PSPC requirement regardless of seawater condition.

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I:\MEPC\60\2-1.doc APPENDIX 5



### HAZID STUDY

Hazard identification (HAZID) study of ìEcoBa llastî to be installed on board ship was conducted. The objective of study is to identi fy and summarize all known hazardous events during the normal operation and maintenance pha ses. HAZID workshop was carried out by attendees who have a lot of experiences in mechanical and proce ss design, fabrication, installation, and sea trial test etc. in HHI. The scopes of HAZID study are as follows:

• UV reactor (UV unit)

• Auto back-flushing filter (Filter unit)

• CIP unit (Cleaning unit)

• Human safety (Crew)

As a result of HAZID workshop, a total of 15 h azards were identified for the normal operation and maintenance phases of ìEco ballastî. Among those identified, critical 12 hazards were compiled in the Hazard Register, and recommende d the corrective or preventive action plans.

The key summaries of HAZID workshop are as follows:

Hazard
No. Hazard System (or Sub-system) Mode

1 UV lamp goes out UV reactor Operation

2 UV lamp fails during the ope ration UV reactor Operation

3 UV lamp fails to start UV reactor Operation

4 UV radiation expose to personal UV reactor Operation

5 UV lamp breaks during the maintenance tasks Human safety Maintenance

6 UV lamp breaks during the storage or transport phase Human safety Storage

7 Used UV lamp breaks during the disposal phase Human safety Disposal

8 Geared motor fails Filter Operation

9 Too frequent back-flushing or continuous back-flushing occurs Filter Operation

10 The cleaning solution is flooded over the CIP tank CIP unit Cleaning

11 Leakage of chemical line and CIP tank CIP unit Cleaning

12 Too low level of solution in CIP tank CIP unit Operation

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I:\MEPC\60\2-1.doc APPENDIX 6



### SYSTEM DESCRIPTION OF ìECOBALLASTî

1 Introduction

2 System Overview

2.1 Process summary

2.2 System boundary

2.3 Electric power distribution for treatment system

2.4 System control

2.5 Safety functions of system

2.6 Equipment model line-up for ba llast water treatment system

2.7 Utilities

3 Equipment Unit

3.1 System Control Unit

3.2 Filter Unit

3.3 UV Unit

3.4 CIP Unit

4 System Operation

4.1 General

4.2 Modes of operation

4.3 Sequence of operations

4.4 Control functions in normal operation

5 Appendix

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