For reasons of economy, this document is printed in a limited number. Delegates are 

kindly asked to bring their copies to meetings 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 ORGANISMS IN BALLAST WATER 

Application for Final Approval of HHI Ballast Water Management System ìEcoBallastî 

Submitted by the Republic of Korea 

SUMMARY

Executive summary: This document contains the non-confidential information related to 

the application for Final Approval 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) adopted 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 Substances 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), defines 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 information 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-Ballast Water Working Group. In 

the meantime, a document on the proposal for approval containing all the non-confidential data 

related to the respective ballast water management systems that make use of Active 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 Industries Co., Ltd. (HHI) and believes it to satisfy 

the data requirements of Procedure (G9). 

6 The Republic of Korea therefore submits the 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 proposal 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 ìEcoBallastî 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 (200m3

/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 Substances 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 properties for the Active Substances and 

Preparations and the treated ballast water, if applicable 

4.2.2.5 Analytical methods at environmentally relevant concentrations 

4.3 Assessment report 
MEPC 60/2/1 

ANNEX 

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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 ACTIVE 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 

Appendix 1 : QUALITY ASSURANCE PROJECT PLAN (QAPP) FOR 

TESTING HHI-BWM (ìEcoBallastî) SYSTEM FOR 

TYPE APPROVAL AND FULL SCALE (200 m3

/hr) 

TEST REPORT 

Appendix 2 : QUALITY ASSURANCE PROJECT PLAN (QAPP) 

FOR HHI-BWM (ìEcoBallastî) SYSTEM AND TEST 

REPORT FOR CHEMICAL ANALYSIS 

Appendix 3 : AQUATIC TOXICITY TEST 

Appendix 4 : CORROSIVITY TEST FOR UV-TREATED BALLAST 

WATER 

Appendix 5 : HAZID STUDY ON ìEcoBallastî 

Appendix 6 : SYSTEM DESCRIPTION OF HHI BALLAST WATER 

MANAGEMENT SYSTEM 
MEPC 60/2/1 

ANNEX 

Page 3 

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PROPOSAL FOR FINAL APPROVAL OF 

HHI BALLAST WATER MANAGEMENT SYSTEM ìEcoBallastî

This report is structured in accordance with the 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 Approval 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 received from the applicant, the Group decided to 

recommend that Basic Approval be given to the 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 necessary nor practical to provide the physical 

characteristics or toxicological profiles of such photons. 

0.6 However, it was recognized that the radiation (photons) might react with naturally 

occurring organic molecules in seawater to form 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 water, 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 evaluation of the possible effects of 

treated ballast water provided in the submitted dossier was sufficient. 

0.8 The Group noted that the acute and chronic aquatic ecotoxicity testing had been 

performed as a full-scale land-based test in accordance with the requirements of Procedure (G9) 

for Final Approval (MEPC 57/21, annex 1, appendix). 

0.9 The Group noted 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 applicant by engineering control measures put 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 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 toxicological concern towards 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 the non-confidential submission and the information 

received from the applicant during the GESAMP-BWWG meeting, the Group decided to 

recommend that Basic Approval be given to the BWMS submitted by the Republic of Korea. 

0.12 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 Approval. The Group is of the opinion that this application 

fulfilled the requirements for Final Approval 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 Approval as the application contained all the information required 

to allow it to be reviewed (MEPC 59/2/16, annex 8, paragraph 2.1). 
MEPC 60/2/1 

ANNEX 

Page 5 

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

1 INTRODUCTION

1.1 Working principles of the HHI Ballast Water Management System ìEcoBallastî 

The ballast water is treated at intake (ballasting) and again at discharge (de-ballasting). The 

treatment during intake ensures that a minimal amount of viable organisms enter into the ballast 

water tanks and reduces sediment built-up in the ballast water tanks, which is a potential 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 water tanks is prevented. The working principle is 

disinfection or destruction of organisms through UV radiation without addition of chemical 

compounds, so the ìEcoBallastî system represents a chemical-free disinfection procedure. 

HHI ìEcoBallastî has received a comment for its chemical-free 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 represents a chemical-free disinfection 

procedure as no chemical compounds are added to the process.î 

1.2 Description of the ìEcoBallastî system and its components 

The ìEcoBallastî Water Management System is a complete system and its operation can be 

divided into three main functions: 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 System 
MEPC 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-cleaning system for extracting particles from low 

viscosity fluids. Its robust construction and automatic back-flushing capability make a 

major contribution to operational reliability and reduce operating and maintenance costs. 

The slotted tube filter elements ensure highly effective filtration of contaminating 

particles from seawater. Automatic cleaning 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 subsequent treatment. 

The fluid to be filtered flows through the slotted-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 the 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 water 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 backwashing water is returned into the sea 

in situ. The filter unit operates only during ballasting; 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 radiation both during ballasting and again during 

de-ballasting to destroy 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 space 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 application to ballast water treatment because the 

helical lamp structure decreases the probability that water volume segments, including 

micro-organisms, pass the UV chamber without being exposed to sufficiently high 

UV-doses. Sectors with relatively high velocity and low irradiation 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 distribution at ideal hydraulic conditions. The 

applied UV dose is ideal and even organisms with 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 

Page 7 

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

.3 The control and cleaning system 

The system control unit controls ìEcoBallastî management system and supplies power to 

all items, and the water flow meter and alarms 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 output 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 device until system flow is in design range. 

In system, UV dose will be controlled to optimize power efficiency, according to flow 

rate and water quality (appendix 6). 

The system comprises also a ìcleaning in placeî (CIP) unit, which is an automatic service 

device that cleans the quartz sleeves 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 service 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. Cleaning solution is reusable until its life 

time and all cleaning solution will be recovered to CIP tank at the end of cleaning 

operation. The life time of cleaning solution can be detected by installed pH meter or 

cleaning performance after cleaning operation, which can be estimated by comparing light 

intensity before and after cleaning. The detailed description of cleaning 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 considered to be relevant for Active Substance approval. 

During the review of HHI ìEcoBallastî, Basic Approval application by the 

GESAMP-BWWG, HHI has received the question about cleaning procedure of 

ìEcoBallastî, as follows: 

ìThe Group recognized that this UV system 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 functioning 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 cleaning solution in UV reactor after its operation, 

limescale deposits, such as calcium carbonate, magnesium hydroxide and so on, on the 

surface of quartz sleeve can be removed by acidity. For acid cleaning, strong and weak 

acid can be used. But, for crew safety and environmental risk, biodegradable weak acid is 

desirable. In considering biodegradability and safety in handling, 5% citric acid solution 

was selected as a cleaning solution. Cleaning performance could be monitored by 

comparing light intensity values before and after cleaning. As addressed in system 
MEPC 60/2/1 

ANNEX 

Page 8 

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

description, it is recommended that during start-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 quality and operation time. Up to now, the 

operational recommendation is cleaning after 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 additional 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 reactor
MEPC 60/2/1 

ANNEX 

Page 9 

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1.3 Development of Helix type UV reactor 

UV technology 

In principle two different UV-Technologies (low pressure, LP, and medium pressure, MP) are 

available for disinfection. Essentially, a UV spectrum has to be applied, which inactivates 

microbial organisms, and the so-called germicidal 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-technology 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 Monochromatic spectrum Polychromatic 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 effectiveness, the LP technology appears the better choice. However, 

for application to ballast water treatment other parameters are also relevant. These are 

summarized in Table 2. 

Table 2: Relevant parameters for ballast water 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 nm 
MEPC 60/2/1 

ANNEX 

Page 10 

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

As a result of the comparisons in Table 1 and Table 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 varies from 200 to 300 mWs/cm2 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-disinfection systems for drinking water and waste 

water treatment plants, suggest that traditional UV systems are not capable producing sufficiently 

high UV-intensities required for application in ballast water treatment. 

Laboratory pre-tests with different types of algae 

Laboratory pre-tests were conducted to obtain spectra indicating the sensibility of different 

phytoplankton species exposed to different 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 shown in Figure 2. For the marine phytoplankton 

species, Symbiodinium sp., a UV-MP dose of 60 mWs/cm2 is needed to achieve a 1 log step 

mortality rate (Figure 3 (h)). 

UV design in order to meet 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 wide range of inlet water conditions. Different water qualities 

represent a considerable challenge to the performance of the UV system. UV radiation does not 

spread homogenously in water; the spreading decreases logarithmically with the distance from 

the point of radiation. In order to deal with the non-uniform spreading of the UV radiation, the 

construction of the UV lamp and the reactor chamber has been re-designed. The chamber has 

been changed so that water flow is in the direction 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 that 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 the seawater to UV radiation; and 

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

ANNEX 

Page 11 

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0 1000 2000 3000 4000 5000

Log(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 5000

Log(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 5000

Log(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/m2)

0 1000 2000 3000 4000 5000

Log(N/No)

-5

-4

-3

-2

-1

0

UV Dose (J/m2)

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. No means 

the initial concentration of algae and N means the final concentration 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/cm2

 which is equal to 10 J/m2. 
MEPC 60/2/1 

ANNEX 

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Reactor design 

Based on the pre-test results and design principles 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 moderate 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 manufactured 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 calculation up to 3,000 m3

/hr flow rate (4.2 m/s of flow velocity) to see 

the stability of UV lamp arrangement was performed without any problem. 
MEPC 60/2/1 

ANNEX 

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1.4 Description of the pilot scale 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 Heavy Industries Co. LTD, Ulsan, Korea. 

The helix UV reactor was installed and its performance was tested. 
MEPC 60/2/1 

ANNEX 

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

The flow diagram of the test facility is shown in Figure 6. It has three 280 m3 ballast tanks and 

a 250 m3

/hr ballast pump. All materials for the test facility 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 pipe
MEPC 60/2/1 

ANNEX 

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HHI ìEcoBallastî has received a comment for full-scale performance 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 m3/hr) 

performance test was done according to the IMO Guideline (G8). The test results 

showed that the EcoBallast system meets 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 m3/h 

Treatments Two treatments, during ballasting and during de-ballasting 

Power consumption 39 ± 1 kW for UV unit 

 Less than 1 kW for Filter Unit 

Treated volume more than 200 m3

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/cm2. 

Intake of seawater, Figure 8 

Through the intake pump, the seawater was pumped into tank-1(100A) and tank-2(100B) passing 

through the strainer to remove larger particle. Starch, glucose, 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 supplied to Hyundai Heavy Industries 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 facility during intake of seawater 
MEPC 60/2/1 

ANNEX 

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Ballasting ñ Treatment Operation, Figure 9 

The seawater which meets IMO influent guideline flows through the filter and the helix 

UV reactor to tank-3(400) to simulate ballasting treatment operation mode. The flow rate 

through UV reactor was controlled larger than 200m3

/hr using a flow control valve and flow 

meter installed after UV reactor. 

After ballasting-treatment operation, tank-1(100A) and all pipes were drained and flushed with 

seawater. The tank-1(100A) was cleaned with pressurized 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 facility in ballasting operation mode. 
MEPC 60/2/1 

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Ballasting ñ Control Operation, Figure 10 

During ballasting-control operation, the seawater of Tank-2(100B) was transferred to Tank-1 

(100A) bypassing both of the filter and the helix UV reactor. During beginning about 5 minutes, 

the seawater from Tank-2(100B) after bypassing both of the filter and UV reactor 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 control 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 storage 
MEPC 60/2/1 

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Deballasting ñ Treatment and Discharge Operation, Figure 12 

The seawater which has been stored at Tank-3(400) for 5 days was discharged through the helix 

UV reactor, but bypassing the filter. During discharge, 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 facility 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 discharged bypassing both 

of the filter and the helix UV reactor. During discharge, seawater was sampled for the control of 

discharged toxicity test and performance test. After finishing every one cycle experiment, all 

tanks and pipes were cleaned with natural seawater 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-ballasting-control operation 
MEPC 60/2/1 

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1.6 Sampling and Measurements 

Sampling locations (points) are indicated by P0-P4 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), respectively. Sampling point P4 was used to 

sampling for corrosivity test, toxicity test, chemical analysis, and performance analysis. 

Procedures for sampling and transfer are described in detail in appendix 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 deballasting 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 discharge after 5 days storage (P4); 

! the acute and chronic environmental toxicity 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 ìEcoBallastî 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 time 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 μm 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 μm for treated 

! 20 Litres : - Marine organisms, ≥50 μm for control 

! 1 m3

 : - Marine organisms, ≥50 μm for treated 
MEPC 60/2/1 

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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

200A pipe

50A pipe

Sample

Flow

P0

Figure 14: Test water flow diagram; Positions 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 ballasting on day 0 and de-ballasting on day 5. 
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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 μm, 

≥ 10 ñ 50 μm 

- Bacteria 

- TSS 

B, M, E 

Note: 1) B means ìBeginning of the test; M means ìMiddle 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 m3/hr) test results 

The full scale (200 m3/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 Ballast 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/m3) 4.62 × 105 ≥ 105

≥ 10-50 μm (individuals/mL) 1.28 × 103 ≥ 103

1-6 

(> 32 

PSU) Heterotrophic Bacteria (cells/mL) 2.60 × 104 ≥ 104

ACCEPTABLE 

≥ 50 μm (individuals/m3) 2.80 × 105 ≥ 105

≥ 10-50 μm (individuals/mL) 1.65 × 103 ≥ 103

2-5 

(> 3-32 

PSU) Heterotrophic Bacteria (cells/mL) 3.50 × 104 ≥ 104

ACCEPTABLE 
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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 

2-5 ≥ 50 μm 6 phylum 10 species 3 phylum 5 species 

(> 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 

1-6 Treatment 4.55 2.20 31.83 

(> 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 

Test organism 

period Organism classification 

T5 

D-2 

Standard Assessment 

≥ 50 μm (individuals/m3) 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/m3) 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 

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Table 3-5: Assessment of valid condition for land-based test 

Test Viable organism 

period Organism size class C5 

Minimum G8 

requirement Assessment 

≥ 50 μm (individuals/m3) 1.10 × 105 1-6 ≥ 100 

(> 32 

PSU) ≥ 10-50 μm (individuals/ml) 1.32 × 102 ≥ 100 

ACCEPTABLE 

≥ 50 μm (individuals/m3) 2.27 × 104 2-5 ≥ 100 

(> 3-32 

PSU) ≥ 10-50 μm (individuals/ml) 8.58 × 102 ≥ 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 the 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 water will be treated again but only by the helix 

UV reactor. 

2.1.2 ìTreated Waterî means the seawater treated by the ìEcoBallastî Water Management 

System. 

2.1.3 ìBallast Water Dischargeî means the ballast water discharged overboard after treatment 

by the ìEcoBallastî Water Management System. 

2.1.4 ìActive Substanceî ñ In the ìEcoBallastî system, direct and indirect effects 

of UV irradiation have a general and specific 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 (G9) 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 organic matter (DOM) in the seawater and cause 

photo-chemical reactions to produce reactive oxygen species such as hydroxyl radical (OHï). 

Therefore, hydroxyl radical (OHï) can here be defined as ìRelevant Chemicalsî. 
MEPC 60/2/1 

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2.2 Background for determining the ìActive Substanceî and ìRelevant Chemicalsî 

2.2.1 Introduction 

Natural and artificial UV light (wavelength of 190-400 nm) may damage living organisms by 

directly and indirectly altering biological molecules like nucleic acids and proteins. UV light can 

be divided into three different 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). Direct effects of UV light on nucleic acids include 

photo-dimerizations between adjacent pyrimidine bases, photo-hydration of cytosine, inter- and 

intra-strand cross-links and protein-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 biological molecules (mainly DNA and proteins) in 

the organisms when they absorb the UV light, resulting 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 monochromatic light at a 

wavelength of 253.7 nm, which is within the optimum wavelength 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). Cyclobutane pyrimidine dimers 

and pyrimidine-pyrimidone (6-4) photoproducts are the two major classes of photo-lesions 

formed by direct DNA absorption of UV-C irradiation (Sage 1993). Once the pyrimidine 

residues are covalently bound together, replication of the nucleic acid is blocked or results in 

mutant daughter cells unable to multiply. 
MEPC 60/2/1 

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Dimer

Dimer

UV-light hïv

Dimer

Dimer

UV-light hïv

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 inorganic molecules in water can absorb UV light, 

causing changes in the water quality. UV is absorbed by some photosensitizing 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 (H2O2), superoxide (O2

-·) or hydroxyl radical (OHï) can then infuse and react with other 

cellular components with sites of damage that can be well away from the site of photo-production. 

Hydrogen peroxide (H2O2) is produced photo-chemically by a variety of mechanisms both 

internally within the cells of aquatic organisms and also externally in their surrounding 

environment. The main photochemical pathway is by the dismutation from superoxide: 

O2 +hv " O2

-· " H2O2

H2O2 has long been used as an algicide and bactericide, at concentrations in the millimolar range 

(e.g., 0.25 ~ 1.5 mmol/Liter against filamentous cyanobacteria; Barroin and Feuillade, 1986). 

H2O2 is a powerful oxidant capable of damaging nucleic acids, proteins and pigments. Although 

this damage may be incurred by direct reaction between biomolecules and the H2O2, many of 

these effects are mediated by the Fenton reaction, whereby more reactive oxidants are generated, 

in particular hydroxyl radical (OHï): 

H2O2 + Fe2+ " OH·

+OH- + Fe3+ 

The extreme reactivity of the hydroxyl radical (OHï) is indicated by its short half-life, typically 

nanoseconds. Hydroxyl radical (OHï) attack nucleic acids, proteins and membranes and 

consequently few parts of the cell are immune from their effects; even catalases and peroxidases 

are attacked and degraded by this highly reactive oxygen species. 

The detailed mechanisms by which hydroxyl radical (OHï) are formed by UV radiation are

reviewed below. 
MEPC 60/2/1 

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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 present at concentrations of about 0.5 - 2 mg/L 

(MacKinnon, 1981) and represents one of the largest reservoirs of organic carbon on the surface 

of the earth (Mopper and Degens, 1979; Hedges, 1992). Despite the size 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 sunlight mainly by humic substances. The energy at the shorter 

wavelengths (UV and blue regions) is sufficiently high to induce the formation of a variety of 

highly reactive transient chemical compounds, such as the hydroxyl radical (OHï). At present, 

little is known about the photochemical reaction and reactive sites within marine DOM that are 

responsible for production of reactive transients at the sea surface. 

Solar exposure of dissolved organic matter (DOM) in combination with oxygen may produce 

reactive species (Figure 16). The overall process of light absorption by DOM and subsequent 

energy dissipation is described by various models for the photochemical oxidation of organic 

matter in natural waters (Mopper and Kieber, 2000). In these models, the absorption of light by 

DOM initially results in the formation of singlet excited state species (1

DOM*) that subsequently 

decays through a series of photophysical and photochemical pathways, as shown in Figure 16. 

The singlet excited state can also undergo intersystem 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 3DOM* to singlet oxygen (1O2

*

). Other decay 

pathways for excited state DOM are molecular rearrangement, fragmentation and/or reaction with 

metal ions and oxygen (Figure 17). These pathways result 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 varies substantially in seawater 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 example, biologically and chemically recalcitrant 

components of DOM, e.g., humic substances and organic pollutants, are degraded by 

photochemical oxidation. 

Nitrate 

Nitrate (NO3

-

) is a very strong absorber of UV radiation below 250 nm (Sharpless et al. 2003) 

and a characteristic photoreaction of this compound is reduction to nitrite (NO2

-

). Takeda et al. 

(2004) reported that although most of the hydroxyl radical (OHï) found in river water and 

seawater were formed from unknown dissolved organic matter, a significant fraction of the 

hydroxyl radical (OHï) was also formed due to the photolysis of nitrate and nitrite. 
MEPC 60/2/1 

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NO3

-

 + 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 oxidants 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 1.23 
MEPC 60/2/1 

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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 terms of handling, storage, and neutralization. 

As discussed above (see 2.1.4), the Active Substance in the ìEcoBallastî system is regarded as 

the UV irradiation ìPhotonî. The disinfection process is a physical-chemical interaction due to 

energy input. The active substance is electromagnetic waves (or photons), carrying energy for 

partial DNA alteration resulting in loss of reproductive capabilities of the harmful micro-organisms. 

HHI ìEcoBallastî has received a comment for Active Substance in MEPC 59/2/16, annex 8, 

paragraph 3.4.1, as follows: 

ì3.4.1 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 inactivate micro-organisms. The definition of 

photon is a particle of electromagnetic radiation that travels at the speed of light, used 

to explain phenomena that require light to behave 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 ballast 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-residual characteristics of the photon. 

3.4.1.3 Likewise, since the photons generated 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 the 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 organic matter (DOM) and nitrate may adsorb electromagnetic energy 

and small quantities of free radicals may be produced and these radicals will react immediately 

with other substances to create ìreaction productsî. Of these transient oxygen species, the 

hydroxyl radical (OHï) is by far the most reactive and both of hydrogen peroxide (H2O2) and 

superoxide (O2

-·) can be converted to hydroxyl radical (OHï). 

Since hydroxyl radical (OHï) react non-selectively 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 formation of radicals is a prerequisite for creation of 

ìreaction productsî and hydroxyl radical (OHï) is by far the most reactive among the produced 

radicals, hydroxyl radical (OHï) can be regarded as the representative and here regarded as 

ìrelevant chemicalsî in the sense of the Convention. 
MEPC 60/2/1 

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HHI ìEcoBallastî has received a comment for Relevant Chemicals in MEPC 59/2/16, annex 8, 

paragraph 3.4.2, as follows: 

ì3.4.2 Relevant Chemicals

3.4.2.1 The Group noted that the hydroxyl radical (OHï) is defined by the 

Applicant as a Relevant Chemical in this BWMS. The Group concurred with the 

applicant that the extreme reactivity of the hydroxyl radical (OHï) is indicated by its 

short half-life, typically nanoseconds. Under these circumstances where the hydroxyl 

radical (OHï) can react non-selectively with organic compounds to give possible 

reaction products, the Group proposed that it was neither necessary nor practical to 

provide the physical characteristics or toxicological profiles of the hydroxyl radical.î 

3 PRINCIPLES

3.1 Active Substances and Preparations may be added 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 Preparations 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 discharge into the environment, the organisms in the 

receiving water may suffer unacceptable harm. Both the Active Substance or Preparation as well 

as the ballast water discharge should 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 Substance or Preparation can be used and under which 

conditions the potential of harming the receiving environment or human health is acceptably low. 

3.3 Any system which makes use of, or generates Active Substances, Relevant Chemicals or 

free radicals during the treatment process to eliminate 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 Substances and Preparations 

must be safe in terms of the ship, its equipment and the personnel to comply with the Convention. 

3.5 The approval of Active Substances and Preparations using viruses or fungi 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 and 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 Technical 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 

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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 micro-organisms and pathogens. 

Therefore, the UV irradiation ìPhotonî is here defined as the ìActive Substanceî. 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 absorbed 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 below is applicable for Hydroxyl 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 management system operates using the UV-photons and 

the produced hydroxyl radical (OHï) to inactivate marine organisms 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, molecular size distributions, bacterial re-growth 

potentials (BRP) and trihalomethane formation potentials (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 (103

-105 mWs/cm2) 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 101

-102 mWs/cm2) applying conventional water quality parameters such as 

UV absorbance at 254 nm, total organic carbon (TOC), biodegradable dissolved organic carbon 

(BDOC), assimilable organic carbon (AOC). 
MEPC 60/2/1 

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Changes in biodegradability and growth potential 

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

(2003) who demonstrated that the acetate/DOC ratio increased with increasing UV doses 

(103

-105 mWs/cm2). Lehtola et al. (2003) studied whether UV disinfection increases 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 irradiation at 15-50 mWs/cm2. They also reported an increase in 

microbial available phosphorus (MAP) at 204 mWs/cm2. 

Shaw et al. (2000), however, concluded that at relatively lower UV doses (130 mWs/cm2), there 

is no indication of increase in the contents of assimilable organic carbon (AOC), during a 5-day 

period and in biodegradable dissolved organic 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 inactivation 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. Low to moderate UV-doses (20-30 mWs/cm2

) 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 pathogenic bacteria and 

some viruses. Liltved et al. (1995) reported that an UV dose of 2.7 mWs/cm2 resulted in 99.999% 

(5 log) reduction in viable count for all three fish pathogenic bacteria (Vibrio anguillarum, 

Vibrio salmonicida and Yersinia ruckeri) and an average UV dose of 122 mWs/cm2 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 general, higher doses have been applied 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/cm2

. 

Bullock and Stuckey (1977) reported 97-100% inactivation of Aeromonas salmonicida, 

Aeromonas hydrophila, Pseudomonas fluorescens, Vibrio anguillarum and enteric redmouth 

bacterium at doses of 13-47.5 mWs/cm2

. 

Sako and Sorimachi (1985) found 99.9% inactivation 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/cm2 except for IPNV 

which had low susceptibility to UV light. However, doses of 150-200 mWs/cm2

in-activated 99.9% of IPNV. 

Liltved et al. (2006) also reported the use of UV irradiation to inactive 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 ozonation by-products (OBPs), bromate was found in 

concentrations of 50-70 mg/L. Bromoform was the only trihalomethane (THM) found in the 

concentration of 16.4 mg/l. Unlike ozone, the UV irradiation has been reported not to leave toxic 

residues behind in their study. 
MEPC 60/2/1 

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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 disinfected 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/m3), the frequency of cataract increased after 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 developed cataract, compared to 5% of the fishes in the tank located 

further away from the UV lamps (33 m). The effect was believed to be indirect, caused by chemical 

photoproducts from the UV irradiation since the UV lamps were placed 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 whether UV-disinfection of natural and contaminated organic 

substances in surface and drinking water may generate a positive mutagenic effects. Selected 

organic pesticides (atrazine, simazine, metobromurone, methabenzthiazurone, 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-irradiation. Based on results in Ames- and SCE-test, 

mutagenic activity was found in none of the samples, neither before nor after UV-irradiation. 

However, it has been found that high intensity visible light or solar light may cause indirect 

photochemical damage to micro-organisms. Such damage may occur when the light is absorbed by a 

sensitizer, which enters an excited state. In the presence of oxygen, the exited sensitizer may form 

reactive species like singlet oxygen, superoxide, hydrogen peroxide, and hydroxyl radical (OHï). 

Cooper and Zika (1983) found that the hydrogen peroxide present in water was mainly 

photo-chemically generated from organic constituents and, furthermore, that the accumulation 

rate of hydrogen peroxide was a function of TOC. These authors, in studies of TOC in 

freshwater ecosystems, detected formation of hydrogen peroxide over a range of 10-6 to 10-5 M 

with only 2.5 h of exposure to sunlight 

Arana et al. (1992) found that visible light may act directly on the cells or generate photoproducts 

with a negative effect on the cells. In non-illuminated microcosms 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 cells 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 hydrogen 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 growth lasting for several weeks (Gjessing and 

K‰llqvist 1991). The results showed that UV radiation of humus water changed the chemical 

composition of water, including acidity 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 water were explained by 
MEPC 60/2/1 

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photon-mediated interactions of humic substances and other chemicals in the water which 

resulted in the formation of oxidizing reagents such as hydroxyl radical (OHï). 

Lund and Ormerod (1994) found that UV irradiated water (dose 42 mWs/cm2) 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 observations were reported by Lund and Hongve (1994), who 

found that UV-irradiated water (42 mWs/cm2

 and 92 mWs/cm2) 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 (Fe3+) on Microcystis aeruginosa and E. coli at doses of 

about 400 mWs/cm2. No such effect was found in M. aeruginosa at 100 mWs/cm2, and only a 

small effect was observed at 200 mWs/cm2

. No residual effect was observed in the absence of 

any photosensitizing element. A close relationship was observed between the residual effect and 

the formation of hydrogen peroxide in the UV irradiated water. They suggested that transition 

metals and hydrogen peroxide play a key role in producing the residual effect of UV radiation 

through the formation of reactive species, including hydroxyl radical (OHï). 

Parkingson et al. (2001) tested the potential toxicity of UV treated aquatic DOM (high doses 

∼104 mWs/cm2

) in two spot samples from two Australian reservoirs using Vibrio fisheri in the 

MicrotoxTM test, African green 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 evidenced by higher concentrations of free copper ions in 

photo-oxidised water. 

Effects on the formation of chlorination by-products 

The effect of UV irradiation prior to traditional chlorination for drinking water disinfection has 

been investigated. Kashinkunti et al. (2004) exposed granular activated carbon filtered drinking 

water to UV light from low pressure (LP) and medium pressure (MP) UV bench systems at 

UV doses of 40 and 140 mWs/cm2, followed by adding 2 mg/L Cl2. They found no evidence of 

increase in disinfection by-products (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 changes in total haloacetic acids (HAA-5) 

and THMs after MP UV-irradiation at doses of approximately 40 mWs/cm2. Kruithof et al. (1992) 

also reported no production of biodegradable compounds, assayed by the AOC method, and no 

mutagenic activity in the Ames test after treatment with LP UV light at about 20 mWs/cm2

. 

The UV doses used for drinking water disinfection are relatively low, normally 16 to 40 mWs/cm2. 

At these doses, subsequent formation of by-products from chlorination does not give rise to 

concern, at least not the by-products that have been analysed in published investigations. 
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Potential effect on seawater salts and bromate 

Seawater contains halogen anions (Cl-, Br-, I-). Oxidation of these anions by UV-irradiation to 

bioactive forms (chlorine, bromine, 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 ozone treated drinking water. Peldszus et al. (2004) 

investigated the potential for bromate removal from drinking water by irradiation with 

medium-pressure UV lamps. Bromate absorbs UV light well at low wavelengths and hence, 

photolysis of bromate may be expected when using 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/cm2), probably due to competitive UV absorption by nitrate and DOC. 

Summary and Conclusion 

The potential of UV-irradiation to induce photo-chemical water 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 conventional water quality parameters such as 

UV absorbance at 254 nm, colour, TOC, AOC and BDOC have be found. 

• Residual effects like reduced bio-film formation, inactivation of heterotrophic bacteria 

and reduced bacterial metabolism in UV-treated 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 practical negative effects have been 

identified by using UV irradiated natural water or seawater in land based aquacultural 

facilities. 

• No evidence of increased disinfection by-product formation (THM, HAA-9, 

carboxylic acids, aldehydes, TOX) by subsequent chlorination has been found. 

At high UV doses (about 104 mWs/cm2), 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/cm2), which are applied in ballast water treatment, there 

is no available information about formation of by-products. Of primary interest here would be 

the possibility of formation of halogenated organics or toxic oxidation products 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. However, to elucidate any 

environmental effects of possible 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 

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- Bromate formation 

- THMs/VOCs 

- Halogenated Phenols 

- By-product of disinfection (HAAs, HANs) 

- General toxicity analysis (acute and chronic toxicity). 

4.2 Data-set for Active Substances and Preparations 

All analyses were carried out according to standard methods. All tests were carried out under the 

supervision of the Korea Marine Equipment Research Institute (KOMERI), Korea Testing & 

Research Institute (KTR) and Marine Eco-Technology Institute (MEI). KOMERI laboratory is 

accredited by KOLAS (Korea Laboratory Accreditation 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 environmental samples including DOC and POC analysis 

(appendix 1). Although MEI Institute is not accredited 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 provided in each test report (appendix 3). 

The Corrosivity test of UV-treated seawater was performed using the SWBT (Simulated Wave 

Ballast Tank) by Coating Performance Test Laboratory in Protective Coatings & Corrosion 

Research Department, Hyundai Industrial Research Institute (HIRI) located on Hyundai Heavy 

Industries Co. LTD. in Ulsan, Korea. Although this institute is not accredited, two researchers 

involved in this project are accredited by NACE Certified Coating Inspector Level 2. The 

Institute has personnel with a solid experience in protective coating 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 are 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, EC25, EC50, LC25 and LC50 values based 

on mobilization and survival data at the end of the experiment were calculated for 

both 34 psu and 21 psu UV-treated ballast water. 

Fish ñ For the study to assess the effects of the UV-treated ballast water on flounder, 

Paralichthys olivaceus, during 96 hours, LC25 and LC50 values based on survival data at 

the end of the experiment were calculated for both 34 psu and 21 psu treated ballast 

water. 
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Echinoderms ñ For the study to assess the effects of the UV-treated ballast water on sea 

urchin, Anthocidaris crassispina, during 48 hours, EC25, EC50, LC25 and LC50 values 

based on mobilization and survival data 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 48 hours, EC25, EC50, LC25 and LC50 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 ballast water treated by the HHI-BWM system 

LC50 and/or EC 50 Species End point Conc.(%)

Reference/Comments/ 

justification for missing data

Algae Skeletonema costatum EC50 72 h > 100 OECD 201

Crustacean Tigriopus japonicus EC50 48 h

LC50 48 h

> 100

> 100 OECD 202

Fish Paralichthys olivaceus LC50 96 h > 100 OECD 203

Echinoderm Anthocidaris crassispina EC50 48 h

LC50 48 h

> 100

> 100 OECD 202

Mollusc Crassostrea gigas EC50 48 h

LC50 48 h

> 100

> 100 OECD 202

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

LC50 and/or EC 50 Species End point Conc.(%)Reference/Comments/ 

justification for missing data

Algae Skeletonema costatum EC50 72 h > 100 OECD 201

Crustacean Tigriopus japonicus EC50 48 h

LC50 48 h

> 100

> 100 OECD 202

Fish Paralichthys olivaceus LC50 96 h > 100 OECD 203

Chronic aquatic toxicity ñ No chronic toxicity was observed in algae and fish, however, 

slight chronic toxicity was observed in echinoderm and mollusc; see report in appendix 3, 

section 3.2. The results are summarized in Tables 7 and 8. 

Algae ñ For the study to assess the effects of the UV-treated ballast water on the diatom, 

Skeletonema costatum, during 96 hours, NOEC and LOEC values from Hypothesis Test 

based on cell densities at the 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 living organism at the end of the experiment 

were calculated for 34 psu and 21 psu treated ballast water. 
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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 based 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 ballast water treated by the HHI-BWM system 

LC25, LC50, LOEC, 

Species and/or NOEC

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

LC25 14 D

LC50 14 D

6.25

12.50

18.50

> 100

OECD 210

Mollusc Crassostrea gigas

NOEC 10 D

LOEC 10 D

LC25 10 D

L C50 10 D

12.50

25.00

49.10

> 100

OECD 210

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

LC25, LC 50 and/or 

Species NOEC

End point Conc.(%)

Reference/Comments/ 

justification for missing data

Algae Skeletonema costatum NOEC 96 h 100 OECD 201

Fish Paralichthys olivaceus NOEC7 D 100 OECD 212

• Endocrine disruption. Not specifically tested, however the acute toxicity test, the chronic 

toxicity test, and the chemical analyses of discharged seawater suggest that endocrine 

disruption is unlikely to occur (see appendix 2 for Chemical Analysis Report and appendix 3 

for Toxicity Test Report). 

HHI ìEcoBallastî has received a comment for Endocrine disruption in MEPC 59/2/16, annex 8, 

appendix, paragraph 3.3, as follows: 
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ì3.3 Information on Endocrine Disruption 

3.3.1 The Group noted that the endocrine disruption potential of treated ballast water 

had not been tested for specifically but the applicant 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 Toxicity in MEPC 59/2/16, annex 8, 

appendix, paragraph 3.4, as follows:. 

ì3.4 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 ballast water, there would not be any sediment 

toxicity associated with the treated ballast water. The Group agrees with this view.î 

• Bioavailability/biomagnification/bioconcentration. Not specifically tested; however, the 

chemical analyses of ìEcoBallastî treated seawater (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/biomagnification/bioconcentration do not occur. 

HHI ìEcoBallastî has received a comment for Bioavailability/Biomagnification/Bioconcentration 

in MEPC 59/2/16, annex 8, appendix, paragraph 3.5, as follows: 

ì3.5 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 indication 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, discharged ballast water can be expected to be non-toxic to aquatic 

organisms and the ecosystem in general. 

HHI ìEcoBallastî has received a comment for Food Web/Population Effects in MEPC 59/2/16, 

annex 8, appendix, paragraph 3.6, as follows: 

ì3.6 Food Web/Population Effects 

3.6.1 The Group noted that the applicant had indicated that, taking into account 

the 100% treated ballast water had been used to measure any effects on the test species, it 

would be unlikely for the diluted ballast water to have any significant negative effects on 

ecological communities at environmentally relevant concentrations. The Group agrees 

with this view.î 
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.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 Substanceî) are short lived and 

will disappear before leaving the ìEcoBallastî 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 treatment which will show mammalian toxicity. 

HHI ìEcoBallastî has received a comment for Mammalian Toxicity in MEPC 59/2/16, annex 8, 

appendix, paragraph 2, as follows: 

ì2 MAMMALIAN TOXICITY 

The Group noted that the applicant had indicated that, as there were no measurable 

chemical by-products, there was no need to provide any data with regards to mammalian 

toxicity. The Group agrees 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 photosensitizing chemical compounds (such as nitrate and 

DOM) in the seawater will decay into stable non-radical chemical compounds or will involve 

several oxidation reactions before leaving the ìEcoBallastî system. 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 formation 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 effects of these photo-chemical processes and 

transformations are the oxidation of DOM, cleavage of humic substances, oxidation of 

reduced sulphur, photo-bleaching of absorbance and fluorescence properties, loss of dissolved 

oxygen, photo-reduction of trace metals, release of complex-bound molecules such as 

phosphate, and production of relatively stable low molecular weight (LMW) molecules such 

as hydrogen peroxide, NO and NO2, 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 reactions 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). 
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• Reaction with organic matter. The free radicals resulting from 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 organic matter as described 

in 2.2.3.1. These radicals are formed under natural conditions in surface seawater, so any 

decomposition compounds from ìEcoBallastî, if formed, can be expected to be similar to 

those produced during natural decomposition of organic matter in seawater. 

To identify products of concern to the environment from the reaction of radicals with organic 

matters, some halogenated hydrocarbons were analysed in brackish water and seawater tests 

(Tables 9 and 10). The detailed information can be found in appendix 2. 

Table 9: Concentrations of potential Relevant 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 μg/L 0.46 0.0 0.0 0.0 0.0 0.0 0.0 

Trichloromethane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

Dibromochloromethane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

Bromoform μg/L 0.001 0.003 0.002 0.003 0.000 0.004 0.000 

Dibromomethane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

Dichlorobromomethane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

1,2,3-Trichloropropane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

1,2-Dibrom-3-

chloropropane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

2-Chlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

3-Chlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

4-Chlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,3-Dichlorophenol μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 

2,4-Dichlorophenol+ 

3,5-Dichlorophenol μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 

2,5-Dichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,6-Dichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

3,4-Dichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,3,4-Trichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,3,5-Trichlorophenol 

+2,4,5-Trichlorophenol μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 

2,3,6-Trichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,4,6-Trichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

3,4,5-Trichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 
MEPC 60/2/1 

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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/cm3 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 20.81 
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Table 10: Concentrations of potential Relevant 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 μg /L 0.46 0.0 0.0 0.0 0.0 0.0 0.0 

Trichloromethane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

Dibromochloromethane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.001 

Bromoform μg/L 0.001 0.015 0.008 0.016 0.008 0.010 0.004 

Dibromomethane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

Dichlorobromomethane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

1,2,3-Trichloropropane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

1,2-Dibrom-3-

chloropropane μg/L 0.001 0.000 0.000 0.000 0.000 0.000 0.000 

2-Chlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

3-Chlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

4-Chlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,3-Dichlorophenol μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 

2,4-Dichlorophenol+ 

3,5-Dichlorophenol μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 

2,5-Dichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,6-Dichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

3,4-Dichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,3,4-Trichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,3,5-Trichlorophenol 

+2,4,5-Trichlorophenol μg/L 0.02 0.00 0.00 0.00 0.00 0.00 0.00 

2,3,6-Trichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

2,4,6-Trichlorophenol μg/L 0.03 0.00 0.00 0.00 0.00 0.00 0.00 

3,4,5-Trichlorophenol μg/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 0.000 
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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/cm3 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 the physical properties of the seawater and its 

habitats, as deduced from the chemical analysis data in appendix 2. 

• Potential residues in seafood. Bioaccumulation is not expected, 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 for Environmental Fate and Behaviour in 

MEPC 59/2/16, annex 8, appendix, paragraph 3.7, as follows: 

ì3.7 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.î 
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.4 Physical and chemical properties for the Active Substances and Preparations 

and the treated ballast water, if applicable. 

The ìEcoBallastî treatment technology does not involve any addition of chemicals. The free 

radicals which may be generated have very short-life time and are consumed inside the reactor, 

and may react with DOM in the seawater transforming this into low molecular weight (LMW) 

carbon products. Only the redox potential, density and corrosivity are tested here. 

• Density. The density of controlled and treated seawater was measured. That values were not 

significantly different from those 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/cm3 0.00001 1.0238 1.0237 1.0237 1.0237 1.0237 1.0237 

34 PSU g/cm3 0.00001 1.0139 1.0138 1.0138 1.0138 1.0139 1.0137 

• Oxidation/reduction potential. The oxidation and reduction potential was measured after 

ìEcoBallastî treatment. That values were not significantly different from those of the raw 

seawater (see appendix 1), which means any significant physical and chemical changes of the 

seawater have not been introduced. The results are summarized in Table 12.

Table 12. Oxidation and Reduction Potential (ORP) 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 equipment 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 environmentally relevant concentrations 

• All analytical methods follow Internationally Recognized methods (see appendix 2, 

section 2.4). 
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4.2.2 A proposal for approval should include the above data set either for the 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 Preparations 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 these plans, along with other guidance 

documents and other general quality control information are available for download 

from the International Organization for Standardization (ISO) (www.iso.org). 

.2 The QMP addresses the quality control management structure and policies of the 

Test Organization (including 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 affecting the actual 

design and implementation of the required experiments. 

4.2.5 Dossiers already used for registration of chemicals can be submitted by the applicant to 

satisfy the required data needed for the evaluation of Active Substances and Preparations 

according to this procedure. 

4.2.6 The proposal should describe the manner of application of the Preparation for ballast 

water management, including required dosage and retention time. 

4.2.7 A proposal for approval should include (Material) 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 test reports, the risk characterization and a consideration 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 the treated ballast water if necessary. 

• The preliminary test results revealed no measurable levels of potentially toxic substances and 

no acute or chronic effects of the full strength effluent on aquatic organisms. Therefore, no 

apparent environmental risks could be identified. 

• All analyses were carried out according to standard methods as described in each appendix.
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5 RISK CHARACTERIZATION 

5.1 Screening for persistency, bioaccumulation and toxicity

5.1.1 An assessment on the intrinsic properties of the Active Substance and/or Preparation such 

as persistency, bioaccumulation and toxicity should be conducted (see Table 1 in section 6). 

.1 Persistence tests 

• Not specially tested. According to the literature 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 treated water has not been changed. 

 .3 Toxicity tests 

• Acute and chronic ecotoxicity tests of ìEcoBallastî 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 Preparations (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 Discharge is that it integrates and addresses the 

potential for interactions of the Active Substances and Preparations with the possible by-products. 

.1 For the Basic Approval process, the discharge 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 with ìEcoBallastî treated seawater and 

brackish water covering multiple test species (a fish, an invertebrate and a 

plant) indicated no significant acute or chronic toxicity to any test organisms. 

Only slight chronic toxicity effect was observed in echinoderm and mollusc. 

However, LC50 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 any of the test species. Consequently, the effluent 

can be expected to be non-toxic to aquatic organisms as well as to the marine 

environment in general (appendix 3). 

.2 For final approval, the discharge testing should be performed as part of the 

land-based type approval process using the treated ballast water discharge. 

• Acute and chronic ecotoxicity tests with ìEcoBallastî treated seawater and 

brackish water covering multiple test species (a fish, an invertebrate and a 

plant) indicated no significant acute or chronic toxicity to any test organisms. 
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Only slight chronic toxicity effect was observed in echinoderm and mollusc. 

However, LC50 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 any of the test species. Consequently, the effluent 

can be expected to be non-toxic to aquatic organisms as well as to the marine 

environment in general (appendix 3). 

5.2.2 The applicant should provide both acute and chronic toxicity test data using standardized 

test procedures to determine the toxicity of the 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 effects of the Preparation or Relevant Chemicals. 

5.2.3 The discharge toxicity tests should be conducted on samples drawn from the land-based 

test set-up, which would be representative 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 sensitive life-stage. The preference is to include both 

a sub-lethal endpoint (growth) and a survival endpoint. Either freshwater 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 organisms die (LCx), No Observed Adverse Effect 

Concentrations (NOAECs), chronic No Observed Effect Concentration (NOEC) and/or Effect 

Concentration at which x% of test organisms show effect (ECx), as appropriate based on the 

experimental design. 

5.2.6 A dilution series including a 100% ballast water 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 there 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 holding 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 series, then a computational model can be used to 

determine the amount of time needed to hold the treated ballast water before discharge. 

• Since the free radicals have very short life time and no significant 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 observe further adverse effects upon discharge. 

5.2.8 Information on Total Residual Oxidants (TRO) and Total Residual Chlorine (TRC) 

should be provided as part of the application for evaluation, for both the ballast water treatment 

process and the ballast water discharge. 
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• The Total Residual Oxidants (TRO) was measured for the discharged seawater from 

ìEcoBallastî Management System (Table 13). There was no difference between treated 

water and raw (control) seawater. The detailed information can be found in appendix 2. 

• The Total Residual Chlorine (TRC) was not measured specially. The definition of TRO and 

TRC is as follows (http://hc-sc.gc.ca/ewh-semt/pubs/contaminants); 

TRC includes both combined residual chlorine (CRC) and free chlorine. Free chlorine is also 

called free residual chlorine (FRC) or free available chlorine (FAC), and it includes 

hypochlorous acid and the hypochlorite ion. In the presence of bromide, 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 described above, some of reactive chlorine can be 

measured as TRO. By the fact that ìEcoBallastî does not use any chlorine compound and the 

results of TRO measurement (Table 13), the result 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 process, fate and effect testing should be performed in the 

laboratory with Active Substances and Preparations. This section lists information that could be 

useful for a preliminary risk characterization. 

5.3.2 Both the Active Substance or Preparation as well as the treated Ballast Water Discharge 

should be subject to toxicity testing in order to protect the receiving environment from toxic 

effects due to discharges. 

5.3.3 The reaction with organic matter of Active Substances and Preparations that produce free 

radicals should be addressed qualitatively so as to identify products of concern to the 

environment. 

5.3.4 The rate of abiotic and biotic degradation of the Active Substances 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 Substances and Preparations under 

aerobic and anaerobic conditions should be assessed, resulting in the characterization of the 

persistence of the Active Substances, Preparations and Relevant Chemicals in terms of 

degradation rates under specified conditions (e.g., pH, redox, temperature). 
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5.3.6 The partition coefficients (solids-water partition 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 chronic ecotoxicity data for aquatic organisms, being 

primary producers (algae or sea grasses), consumers (crustaceans), predators (fish), and should 

include secondary poisoning to mammalian 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 potential (e.g., BCF <500 L/kg wet weight for the whole 

organism at 6% fat). 

5.3.11 An assessment of sediment species is redundant if the potential of the substance of 

concern to partition into the sediment is low (e.g., Koc <500 L/kg). 

5.3.12 The effect assessment of the Active Substances, Preparations and Relevant Chemicals 

should include a screening on carcinogenic, mutagenic and endocrine disruptive properties. If the 

screening results give rise to concerns, this should give rise to a further effect assessment. 

5.3.13 An analytical method suitable for monitoring Active Substances and Preparations in 

ballast water discharges should be available. 

• The test results revealed no measurable levels of potentially toxic substances 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 ìEcoBallastî treated seawater and brackish water 

showed no effects on any of the test organisms (appendix 3). 

• The free radicals resulting from the interactions between UV irradiation and some 

photosensitizing agents such as nitrate and natural dissolved organic matter (DOM) in the 

seawater will react with several organic compounds as described in 2.2.3.1 (Formation of 

hydroxyl radical (OHï)) and 4.2.1.3 (mode of degradation). 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 determining the ìActive Substanceî and ìRelevant 

Chemicalsî and 4.1.4 ëDischarge characteristicsí. 

• Since the free radicals have very short life time; no significant toxic 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 argued above, and therefore measurements of 

discharge concentrations at different time intervals are not relevant. 
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• The partition coefficients (solids-water partition coefficient (Kd) and/or organic carbon 

normalized distribution coefficient (Koc)) of the Active Substances, Preparations and 

Relevant Chemicals as well as the logarithm octanol/water partition coefficient (logPow) 

have not been determined, however, the ëChemical 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 relevant as chemical analyses data indicate 

that bioaccumulation does not occur (appendix 2), and these data 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 performed and presented in this document 

are preliminary and will be complemented with further tests both with regard to toxicity as 

well as chemical properties of the treated water, if necessary. The test results found no 

measurable levels of potentially toxic substances and no acute or chronic effects of the full 

strength effluent to aquatic organisms. Therefore, no apparent environmental risks could be 

identified. 

• All analyses were carried out in accordance with standard methods and toxicity testing was 

performed under supervision of the Korea Marine Equipment Research Institute (KOMERI), 

Korea Testing & Research Institute (KTR) and Marine Eco-Technology Institute (MEI). 

KOMERI laboratory is accredited by KOLAS for 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 laboratory is accredited by KOLAS for chemical 

analysis of environmental samples including DOC and POC analysis (appendix 2). Although 

MEI Institute is not accredited specifically for toxicological testing (e.g., Good Laboratory 

Practice, GLP), the Institute has an Ecotoxicology laboratory, personnel with a solid 

experience in toxicological research, and all tests were performed according to GLP. The 

data on quality assurance (QA) are provided in each test report (appendix 3). 

6 EVALUATION CRITERIA

The Organization should evaluate the application 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 group 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 technical equipment introduced needs to be taken into account. 
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6.3.2 For the protection of personnel involved in the handling and storage of the Active 

Substances and Preparations, the proposal should include relevant ((M)SDS). The Organization 

should evaluate (M)SDS, mammalian toxicity data 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 Relevant Chemicals should not create any unreasonable risk to the ship or 

personnel. This evaluation should take into account the different circumstances that a ship or personnel 

may face in its trade (e.g., ice, tropical, humidity, etc.). 

6.3.3 A Human Exposure Scenario (HES) 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 identify possible hazardous events and how to manage hazards 

to personnel and ship through the design and operational phase of the ìEcoBallastî management 

system. The HAZID workshop was organized including experts with experience in mechanical 

and process design, manufacture, and ship trial test, 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 Register with recommendations 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 filling 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 sensor and flow meter within the UV reactor 

to prevent critical conditions. 

• The installation of an air vent line and level switch is recommended as a safeguard 

against the hazard in the event that UV lamps 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. 
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• 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 disposal 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 the environment in general. As preventive 

actions, HHI shall establish guidelines and procedures for the handling of such events 

including appropriate manner of packing and protective materials for the potential 

hazardous components. 

• Crew members operating the UV reactor should receive special training in its 

operation including hazards 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 considered in the design of ìEcoBallastî management system 

especially during operation on board (Table 14). 

Table 14. Emergency conditions and its management 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 storage of operator 

station and system control unit with redundancy. 
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6.4 Environmental protection

6.4.1 In order to approve the application, the Organization should determine that the Active 

Substances, Preparations or Relevant Chemicals are not Persistent, Bioaccumulative and Toxic 

(PBT). Preparations that exceed all these criteria (Persistence, Bioaccumulation 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 environmental 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 comparing the information 

provided and the undertaken assessment of PBT and the discharge with scientific knowledge of 

the Active Substances, Preparations and Relevant 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 water 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 toxicity 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 water 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 comments of Risk assessments for Human Health, Ships, and 

Environment in MEPC 59/2/16, annex 8, paragraphs 4, 5 and 6. 
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ì4 HUMAN HEALTH ASSESSMENT 

4.1 The Group noted 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 applicant 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 noted that all the disinfection by-products measured in the 

discharged ballast water were 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 toxicological concern towards the general public swimming and eating 

fish from the area. The Group identified that the only potential for human health risk was 

related to exposure to UV irradiation from the treatment unit and therefore recommends that 

appropriate risk mitigation measures be put in place. 

5 RISKS TO SAFETY OF THE SHIP, ITS CREW AND THE GENERAL 

PUBLIC 

5.1 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 or risks. 

5.2 The Group noted that the submission identified the only potential risk to the ship 

and its crew present in the BWMS was related to UV irradiation and overheating in the 

treatment unit from the UV lamps. The submission confirmed that these identified risks 

had been addressed by system safety measures 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 corrosivity of UV-treated seawater had been tested with 

the discharged ballast water from the EcoBallast BWMS during about six months. The 

test results showed no significant changes of the corrosivity of the discharged seawater 

compared to raw seawater. The Group concluded the results indicated that UV-treated 

seawater, the effluent of EcoBallast, has negligible effect on coating performance of 

shipís ballast tank, when compared with natural seawater and coating 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 maintenance 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 cleaning solution of low concentration of 

biodegradable organic acid. The Group recommends that detailed information for safe 

use of the cleaning procedure on-board should be supplied during Type Approval and 

evaluated by the Administration in accordance with Procedure (G8). 
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6 ENVIRONMENTAL RISK ASSESSMENT 

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

6.1.1 The Group recognized that it was not possible to evaluate the persistence, 

bioaccumulation and toxicity of any chemicals within or produced by the system, as it 

does not use a chemical active substance 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 water that demonstrated a complete lack of 

toxicity in all studies except the chronic tests 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 seen in the two chronic ecotoxicity tests 

had not been sufficiently described by the applicant in the non-confidential dossier. In 

response to a request for further information, the Group was informed that slight chronic 

toxicity effects had been observed in echinoderm and mollusc. However, the LC50 

values of the chronic toxicity effect to echinoderm and mollusc were greater than 100% 

of the UV-treated ballast water 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 the use of chemicals that make the derivation of a PNEC 

either possible or necessary. The Group noted that full results of the ecotoxicity tests are 

provided in the appendix to this annex. 

6.3 Calculation of the Predicted Environmental Concentration (PEC) 

6.3.1 The Group agreed that there would be no point in calculating 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 ACTIVE 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 application. The quantity of Active Substances and 

Preparations to be added to the ballast water and the maximum allowable concentration of the 

Active Substances therein should be described in the instructions provided by the manufacture. 
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• The ìEcoBallastî management system is designed 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 consumption and to prevent over-dosage of UV 

irradiation. Therefore the ìEcoBallastî management 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)SDS should describe 

appropriate storage and handling together with the effects of degradation 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 Documentation of hazards or the (M)SDS should conform to the UN Globally Harmonized 

System of Classification and Labelling 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 national 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, taking into consideration existing 

IMO Conventions, Codes and guidance. The procedures should comply with the approval 

conditions such as maximum allowable concentration and maximum discharge concentration, if any. 

8 APPROVAL

8.1 Basic approval 

8.1.1 All proprietary data should be treated as confidential by the Organization and its Technical 

Group, the Competent Authorities involved, and the evaluating regulatory scientists, if any. 

However, all information related to safety and environmental protection, including physical/ 

chemical properties, environmental fate and toxicity, should be treated as non-confidential. 

8.1.2 Procedure to be followed: 

.1 The manufacturer should evaluate the Active Substances or Preparations and the 

potential discharge in accordance with the 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 Preparation has been sufficiently designed, 

progressed and tested to provide the full data necessary for a Basic Approval. 
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.3 The Administration having received a satisfactory application should as soon as 

possible propose an approval to the Organization. 

.4 Members of the Organization may propose an approval. 

.5 The Organization should announce and set 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 organizations having agreements with the 

Organization and non-governmental organizations in consultative status with the 

Organization may submit information that is relevant to the evaluation. 

.7 The Organization should establish a Technical Group in accordance with its rules 

of procedure ensuring that proprietary data 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 the 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 organizations having agreements with the 

Organization and non-governmental organizations in consultative status with the 

Organization, prior to its consideration by the competent Committee. 

.10 The Committee of the Organization should decide whether to approve any 

proposal, introduce any modifications thereto, if appropriate, 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 receiving 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 testing for the approval of different BWMS. 

.13 An applicant seeking to take advantage of an Active Substance or Preparationís 

Basic Approval should provide in its application a written agreement from the 

applicant whose Active Substance or Preparation 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 comply with the Convention (which received Basic Approval) must 

be approved by the Organization. For this purpose, the Member of the Organization submitting an 

application should conduct the Type Approval tests in accordance with the Guidelines for approval 
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of ballast water management systems (G8). The results should be conveyed to the Organization 

for confirmation that the residual toxicity of the discharge conforms 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 evaluation of ballast water management systems 

using Active Substances or Preparations for Final Approval. 

8.2.2 It is to be noted that from Guidelines (G8) land-based testing only the results of the 

residual toxicity tests should be included in the proposal for Final Approval in accordance with 

Procedure (G9). All other Guidelines (G8) testing remains for the assessment and attention of 

the Administration. Basic Approval under Procedure (G9) should not be a pre-requisite of Type 

Approval testing, as an Administration can regulate discharges from its own ships in its own 

jurisdiction. Basic Approval would still be required, and the specific technology could not be 

used in vessels in another jurisdiction without Basic Approval. 

8.2.3 It should be noted that once a system has received Final Approval under this Procedure, 

then the respective applicant should not have to retrospectively submit new data if there is a 

change in the Methodology agreed by the Organization. 

8.3 Notification of approval

8.3.1 The Organization will record the Basic and Final Approval of Active Substances and 

Preparations and ballast water management systems 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 Organization, to the Member of the Organization. The 

Member of the Organization should inform the Organization accordingly. 

8.4.2 Manufacturers intending to significantly change any part of a ballast water management 

System that has been approved by the Organization 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 approval in the following circumstances: 

.1 If the Active Substances and Preparations or ballast water management system 

that make use of Active Substances no longer conforms to requirements due to 

amendments of the Convention. 
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.2 If any data or test records 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 Organization 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-organisms 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 which can enter the ballast tanks. 

The chemical analysis before and after the full scale (200 m3

/hr) treatment has not indicated 

any residual substances. Toxicity test results from acute and chronic toxicity tests with seawater 

and brackish water show that there is no toxic effect detected in the treated water. 

HHI ìEcoBallastî has received comments for Conclusions and Recommendations in 

MEPC 59/2/16, annex 8, paragraph 7, as follows: 

ì7 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 applicant 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. 

7.2.2 In addition the Group noted that all the disinfection by-products measured in the 

discharged ballast water were 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 toxicological concern towards the general public 

swimming and eating fish from the area. The 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 risk mitigation measures be put in place. 
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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 system 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 Approval. The Group was of the 

opinion that this application fulfils the requirements for consideration for Final Approval.î 

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Gjessing, E.T. and K‰llqvist, T. (1991). Algicidal and chemical effect of UV radiation of water 

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webbook.nist.gov 

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* * * 
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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 Approval of Ballast Water Management Systems (G8)
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Contents 

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

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

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

2. Korea Marine Equipment Research Institute ......................................................................... 

Quality Assurance Project Plan (QAPP) ........................................................................................... 

Quality Statement ..................................................................................................................... 

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 ......................................................................................................... 
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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 

* * * 
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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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APPENDIX 3 

TEST REPORTS OF AQUATIC TOXICITY

Test Report on Aquatic Organism Toxicity 

No significant acute toxicity was observed in treated deballasting seawater compared to control 

seawater. But slightly low NOEC observed in chronic toxicity test on treated deballasting 

seawater of 34 PSU. Echinoderm and mollusc show 6.25% of NOEC 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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APPENDIX 4

TEST REPORTS OF CORROSIVITY

Corrosivity tests were conducted to assess the effect of effluent 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 applied to Simulated Wave Ballast Tank (SWBT) 

according to IMO MSC 82/WP.3. 

Following coating performances were evaluated for natural and treated seawater: 

# Adhesion strength, 

# Anti-corrosion resistance, 

# Cathodic disbondment resistance, 

# Colour change, 

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

The key results are as follows: 

# Adhesion strength was little affected by seawater condition and coating adhesion strength 

and coating failure mode satisfied the requirement of IMO PSPC. 

# It was found that UV-treated water did not significantly affect corrosion creep of coating 

system comparing with natural seawater condition and corrosion creep of coating system 

well satisfied IMO PSPC criterion, below 8mm regardless of seawater condition. 

# The cathodic disbondment difference between natural 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. 
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# 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 negligible chemical structure change or chemical 

aging even though the coating films were exposed to UV-treated seawater environment. 

As a conclusion, results clearly indicated that UV-treated seawater, the effluent of ìEcoBallastî 

system, has negligible effect on coating performance of shipís ballast tank, when compared with 

natural seawater and coating performance will meet the IMO PSPC requirement regardless of 

seawater condition. 

* * * 
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APPENDIX 5

HAZID STUDY

Hazard identification (HAZID) study of ìEcoBallastî to be installed on board ship was 

conducted. The objective of study is to identify and summarize all known hazardous events 

during the normal operation and maintenance phases. HAZID workshop was carried out by 

attendees who have a lot of experiences in mechanical and process 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 hazards were identified for the normal operation 

and maintenance phases of ìEcoballastî. Among those identified, critical 12 hazards were 

compiled in the Hazard Register, and recommended 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 operation 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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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 ballast 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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