1



# Washington State Dept. of Fish and Wildlife

Application Package Ballast Water Treatment System Severn Trent DeNora 1110 Industrial Blvd. Sugar Land, Texas 77478 281 - 240 - 6770 www.severntrentdenora.com sales@severntrentdenora.com CONTACT: Rudy Matousek Technology Manager 281 - 274 - 8493 rmatousek@severntrentservices.com NAME: BalPure TM

– Chemical classification as sodium hypochlorite MODEL: BP - 1000 AVAILABLE DATE: Nov 1, 2005 SUBMITTED: August 8, 20052 

## Table of Contents SECTION I: V endor Letter of Intent SECTION II: Vessel Ow ner Letter of Intent SECTION III: Resume of Principal Investigator SECTION IV: Shore Based System (not applicable) SECTION V: System Description

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

Report + September U of W Report + October U of W Report + December U of W Report + EJR Technology – Literature Review + ISO 2001 Certificate3



### SECTION I Vendor Letter of Intent
Se e next page4



### Memorandum

Date: A ugust 8, 2005 To: Scott Smith From: Rudy Matousek Subject: Application for Approval to Conduct

Shipboard Testing of the BalPure BW T System in W ashington State W aters STSDN 1110 Industrial Blvd. Sugar Land, TX 77478 Tel 281 240 6770 Fax 281 240 6762

Dear Mr. Smith, Severn Trent DeNora wishes to conduct shipboard testing of its BalPure TM Ballast Wa ter Treatment System on a Marine Transport Corporation vessel. T he chosen vessel ballasts and de - ballasts in W ashington State waters. This letter serves as a request for approval to conduct such ballast water tests. Also enclosed is the accompanying documentation required by the State of Wa shington as part of the rev iew and approval process. The document list is identified in the table of contents of this submittal titled “ Wa shington State Dept. of Fish and Wi ldlife Application Package Ballast W ater Treatment System”. Severn Trent DeNora understands and agrees to th e terms and conditions set forth by W ashington Department of Fish and W ildlife for this approval process.5



### SECTION II Vessel Owner Letter of Intent See next page.67



### SECTION III Principal Investigator See next five pages.8 

## RESUME NAME: Russell P . Herwig TITLE: Research Associate Professor and Marine Ballast Water Specialist DEPARTMENT: School of Aquatic and Fishery Sciences and Washington Sea Grant Program INSTITUTION: University of Washington DAY TELEPHONE: 206 685
- 2163 FAX: 206 685
- 7471 E - MAIL: herwig@u.washington.edu EDUCATION Ph.D. University

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

WA RDS College of Ocean and Fishery Sciences, University

of Washington

– Award for Outstanding Undergraduate Teaching, 1999 Nav y- ASEE Summer Faculty Research Program, Summer Faculty Research Associateship, 1994 J.V. Shankweiler Award, for out standing graduating Biology student, Muhlenberg College, 1974 East Coast Athletic Conference Merit (Scholar
- Athlete) Award, Muhlenberg College, 1974 Graduated with Honors in Biology , cum laude , Muhlenberg College, 1974 POSITIONS HELD (1991 to present) Marine Water Ballast Specialist, Marine Advisory Service, Washington Sea Grant. 2002

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

of Washington. 1998
- present Adjunct Research Associate Professor, Department of Microbiology , University of Washington. 1998
- present. Adjunct Research Assistant Professor, Department of Microbiology , University of Washington. 1996
- 1998. Research Assistant Professor, School of Fisheries, University of Washington. 1995
- 1998. Research A ssistant Professor, Department of Microbiology , University of Washington. 1991
- 1995 PROFESSIONAL MEMBERSHIPS American Society for Microbiology, International Society for Microbial Ecology, American Association for the Advancement of Science PROFESSIONAL AND OUTSIDE SERVICES Editorial Board, Journal of Food Protection, 1/1998
- present9

Graduate Fellowship Review Panel: EPA Terrestrial Ecology and Ecosystems, 2000, 2001; EPA Microbiology, 2005 Grant Proposal Review Panel: EPA Exploratory Research in Environmental Biology , 1998 Ad Hoc Journal Reviewer: Aquaculture, Applied and Environmental Microbiology , Organic Geochemistry , Water Environment Research, International Journal of Sy stematic and Evolutionary Microbiology Ad Hoc Grant Proposal Reviewer: Univers ity of Washington Royalty Research Fund, Washington Sea Grant, Maryland Sea Grant, Michigan Sea Grant, Oregon Sea Grant, Illinois/Indiana Sea Grant Program, National Science Foundation, Cooperative Institute for Coastal and Estuarine Environmental Technolo gy SELECTED PUBLICATIONS Estes, R.M., C.S. Friedman, R.A. Elston, and R.P. Herwig. 2004. Pathogenicity testing of shellfish hatchery

bacterial isolates on Pacific oy ster Crassostrea gigas larvae. Dis. Aquat. Organisms 58:223
- 230. Lee, S.B., S.E. Strand , H.D. Stensel, and R.P. Herwig. 2004. Pseudonocardia chloroethenivorans sp. nov., a chloroethene
- degrading actinomycete. Int. J. Syst. Evol. Microbiol. 54:131
- 139. Dong, F.M. A.R. Cook, and R.P. Herwig. 2003. High h ydrostatic pressure treatment of f infish to inactivate Anisakis sp. J. Food Prot. 66: 1924
- 1926. Herwig, R.P. 2002. Role of bacteria in the nutrition of bivalve molluscs: intriguing results and research possibilities, p. 31
- 60. In C.
- S. L ee and P. O'Bryen (ed.), Microbial Approaches to Aquatic Nutrition within Environmentally Sound Aquaculture Production Sy stems. The World Aquaculture Soc.: Baton Rouge, Louisiana. Sun, T, G.M. Pigott, and R.P. Herwig. 2002. Lipase
- assisted concentration of n
- 3 poly unsaturated fatty acids from the vis cera of farmed Atlantic salmon (Salmo salar L.) viscera. J. Food Sci. 67: 130
- 136. Herwig, R.P. 2000. Pathogens transmitted by seafoods, p. 109
- 182. Y.H. Hui, D. Kitts, and P.S. Standfield (ed.), Foodborne Disease Handbook: volume 4, Seafood and Environmental Toxins. Marcel Dekker: New York. Shaw, T.R., R.P. Herwig, and J. Wakeman. 1999. Microbial degradation of intertidal creosote
Wyckoff/Eagle Harbor Superfund Site, p. 315
- 319. Bioremediation technologies for polycyclic aromatic hydrocarbon compounds: proceedings from the Fifth International In Situ and On
- Site Bioremediation Symposium, San Diego, April 19
- 22, 1999. Rockne, K.J., H.D. Stensel, R.P. Herwig, and S.E. Strand. 1998. Cometabolic enhancement of PAH degradation b y marine methanotrophic enrichment cultures. Bioremediation J. 1: 209
- 222. Herwig, R.P., and J.P. Gray . 1997. Microbial response to antibacterial treatment in marine microcosms. Aquaculture 152: 139
- 154. Herwig, R.P., J.P. Gray , and D.P. Weston. 1997. Antibacterial resistant bacteria in surficial sediments near salmon net
- cage farms in Puget Sound, Washington. Aquaculture 149: 263
- 283. Ederer, M.M., R.L. Crawford, R.P. Herwig, and C.S. Orser. 1997. PCP degradation is mediated b y closel y related species of the genus Sphingomonas . Molecular Ecology 6: 39
- 49.10

Gray , J.P., and R.P. Herwig. 1996. Phylogenetic anal ys is of the bacterial communities in marine sediments. Appl. Environ. Microbiol. 62:4049
- 4059. Geiselbrecht, A.D., R.P. Herwig, J.W. Deming, and J.T. Staley . 1996. Enumeration and phylogenetic anal ys is of polycyclic aromatic h ydrocarbon
- degrading marine bacteria from Puget Sound sediments. Appl. Environ. Microbiol. 62: 3344
- 3349. Dy ksterhouse, S.E., J.P. Gray , R.P. Herwig, J.C. Lara, and J.T. Staley . 1995. Cycloclasticus pugetii , gen. nov., sp. nov., an aromatic hydrocarbon
- degrading bacterium from marine sediments. Int. J. Sy stem. Bacteriol. 45: 116
- 123. RECENT MEETING PRESENTATIONS Lawrence, D., and R.P. Herwig. March 2005. Enumerating ph yt oplankton abundance in ballast water treatment experiments. 2005 Puget Sound Georgia Basin Research Conference. (Seattle, WA). Perrins, J., and R.P. Herwig. March 2005. Analysis of ozone and chlorine disinfectant by
- products concerning ballast water treatment. 2005 Pu get Sound Georgia Basin Research Conference. (Seattle, WA). Nielsen, B., and R.P. Herwig. March 2005. Efficacy of an on
- site filtration and chlorination ballast water treatment s ys tem. 2005 Puget Sound Georgia Basin Research Conference. (Seattle, WA). Herwig, R.P., and J.R. Cordell. March 2005. Defending Our Shores: Ballast Water Treatment Technologies. 2005 Puget Sound Georgia Basin Research Conference. (Seattle, WA). Herwig , R.P., J.C. Perrins, J.R. Cordell, N.C. Ferm, P.A. Dinnel, G.M. Ruiz, R.W
. Gensemer, W. J. Cooper. November 2004. Shipboard testing of a prototyp e ballast water treatment s ys tem: experiments on the West Coast with ozone. Fourth SETAC World Congress. Society for Environmental Toxicology and Chemistry

(SETAC). (Portland, OR). Herwig , R.P., J.R. Cordell, J.C. Perrins, N.C. Ferm, J.L . Grocock, E.R. Blatchley III. November 2004. Mesocosm experiments for evaluating potential ballast water treatment s ys tems. Fourth SETAC World Congress. Society for Environmental Toxicology

an d Chemistry

(SETAC). (Portland, OR). Cordell , J.R., N.C. Ferm, J.L . Grocock, J.C. Perrins, R.P. Herwig. November 2004. Examination of mesozooplankton present in ballast water of ships entering Puget Sound, Washington. Fourth SETAC World Congress. Soci ety for Environmental Toxicology

and Chemistry

(SETAC). (Portland, OR). Perrins , J.C., R.P. Herwig. November 2004. Flow cy tometry versus other methods for enumerating microorganisms present in ballast water. Fourth SETAC World Congress. Society for E nvironmental Toxicology and Chemistry (SETAC). (Portland, OR).11

RESUME NAME: Jeffery R. Cordell TITLE: Principal Research Scientist DEPARTMENT: School of Aquatic and Fishery Sciences INSTITUTION: University of Washington DAY TELEPHONE: 206 543
- 7532 F AX: 206 685
- 7471 E - MAIL: jcordell@u.washington.edu EDUCATION M.S. University

of Washington, Seattle, Washington (Fisheries). Chairperson: Dr. David Armstrong. Thesis: Structure and Dy namics of an Epibenthic Harpacticoid Assemblage and the Role of Predation b y Juvenile Salmon. 1986. B.S. Huxley

College of Environmental Studies, Bellingham, WA. 1976. POSITIONS HELD Fisheries Biologist, School of Fisheries, University of Washington, 1977
- 2002 Principal Research Scientist, School of Aquatic and Fis hery Sciences, University

of Washington, 2002
- present PROFESSIONAL MEMBERSHIPS Crustacean Society, Estuarine Research Federation, International Association of Meiobenthologists, Pacific Estuarine Research Society, Western Society of Naturalists, World S ociety of Copepodologists. SELECTED PUBLICATIONS Dean, A.F., S.M. Bollens, C.A. Simenstad, and J.R. Cordell. 2005. Marshes as sources or sinks of an estuarine my sid: demographic patterns and tidal flux of Neomysis kadiakensis at China Camp marsh, San Fr ancisco estuary . Est. Coast. Shelf Sci. 63: 1
- 11. Levings, C.D., J.R. Cordell, S. Ong, and G.E. Piercey . 2004. The origin of invertebrate organisms being transported to Canada’s Pacific coast by ballast water. Can. J. Fish. 61(1): 1
- 11. Toft, J.D., C.A . Simenstad, J.R. Cordell, and L .F. Grimaldo. 2003. The effects of introduced water h ya cinth on habitat structure, invertebrate assemblages, and fish diets. Estuaries 26(3): 746
- 758. Tanner, C.D., J.R. Cordell, J. Rubey and L.M. Tear. 2002. Restoratio n of freshwater intertidal habitat functions at Spencer Island, Everett, Washington. Rest. Ecol. 10(3): 564
- 576 Bollens, S.M., J.R. Cordell, S. Avent, and R. Hooff. 2002. Occurrences, causes and consequences of zooplankton invasions: a brief review, plus two case studies from the northeast Pacific Ocean. Hydrobiologia 480: 87
- 110. Toft, J.D, J.R. Cordell, and W.C. Fields. 2002. New records of crustaceans (Amphipoda, Isopoda) in the Sacramento/San Joaquin Delta, California, and application of criteria for i ntroduced species. J. Crust. Biol. 22(1): 190
- 200. Simenstad, C.A. and J.R. Cordell. 2000. Ecological assessment criteria for restoring anadromous salmonid habitat in Pacific Northwest estuaries. Ecol. Eng, 15:283
- 302. Giles, S.L . and J.R. Cordell. 1999. Zooplankton composition and abundance in Budd Inlet, Washington. Pages 634
- 642. In: Puget Sound Research '98: From Basic12

Science to Resource Management, Puget Sound Water Quality Action Team, Oly mpia, Washington. Prahl, F.G., L.F. Small, B.A. Sullivan, J.R. Cordell, C.A. Simenstad, B.C. Crump, and J.A. Baross. 1998. Biogeochemical gradients in the lower Columbia River. Hydrobiologica. 361: 37
- 52. Cohen, A, C. Mills, H. Berry , M. Wonham, B. Bingham, B. Bookheim, J. Carlton, J. Chapman, J. Cordell, L . H arris, T. Klinger, A. Kohn, C. L ambert, G. Lambert, K. Li, D. Secord, and J. Toft. 1998. Puget Sound expedition, a rapid assessment survey of non - indigenous species in the shallow waters of Puget Sound. Nearshore Habitat Program, Aquatic Resources Divis ion, Wash. State Department of Natural Resources, Oly mpia, WA. 37 pp. Morgan, C. A., J. R. Cordell, and C. A. Simenstad. 1997. Sink or Swim? Copepod population maintenance in the Columbia River estuarine turbidity maxima region. Mar. Ecol. Progr. Ser. 1 29: 309
- 317. Cordell, J.R. and S.M. Morrison. 1996 The invasive Asian copepod Pseudodiaptomus inopinus in Oregon, Washington, and British Columbia estuaries. Estuaries 16 (3): 629
- 638. Bollens, S.M., B.W. Frost and J.R. Cordell. 1994. Chemical, mechanical, and visual cues in the vertical migration behavior of the marine planktonic copepod Acartia hudsonica . J. Plankton Res. 16 (5): 555
- 564. Cordell, J.R., C.A. Morgan, and C.A. Simenstad. 1992. Occurrence of the Asian calanoid copepod Pseudodiaptomus inopinus in the zooplankton of the Columbia River estuary . J. Crust. Biol. 12(2): 260
- 269.13

SECTI ON V S ys tem Description General Background The BalPure TM Sy stem that will be used by MTC for this test is a scaled up version of the sy stem that has bee n tested by the University of Washington at the Marrowstone Island USGS facility . The BalPure TM process is a patent pending s ys tem to generate, control, and optimize hy

pochlorite use for the treatment of ballast water. It is proven high capacity , compact , and modular technology , which can handle in excess of 3,000 cubic meters of ballast per hour. The sy stem also neutralizes all the chlorine before de
ballasting. Several s ys tem variables including key ones, residual chlorine to the ballast tank and sulf

ite in the deballast, are recorded in a data logger to document proper s ys tem operation.
The BalPure TM sy stem as proposed for the MTC shipboard test program is designed to treat a ballast flow of 5000 gpm. Based upon the STDN experience with the treatm ent of seawater in cooling water applications, the typical dosage is 1
- 2 ppm. Port water used for ballast has a higher chlorine demand, so greater chlorine dosage is required. The field tests carried out on behalf of STDN and work done at the University of Washington show that 5 ppm chlorine is a maximum dosage required for the kill necessary to meet the Washington State and recent IMO proposed regulations. A more ty pical dosage ranges from 3.0
- 3.5 ppm of h yp ochlorite for typical seawater with < 5 ppm TOC . The installed BalPure TM sy stem will have the capability to reach 5 ppm hy

pochlorite or 320 pounds per day . Adjusting the current applied to the BalPure TM generator will increase or reduce the amount of oxidant generated within the design conditions of the sy stem. Therefore hy pochlorite production can be tailored to meet both organic and aquatic life content of the ballast water. This adjustment can be done both automatically or manually

through the PL C.
The main BalPure TM system will be delivered fu lly contained on an epoxy

painted (meets marine requirements) steel skid with dimensions of 144 inches long b y 72 inches wide b y 96 inches high. Lifting lugs are provided to facilitate movement and installation (shown in Dwg. D006711
- P
- 01). All equipment is provided in NEMA 4 enclosures or rated for14

full wash down service. Total weight of the skid is projected to be 7800 pounds. In cases where space is a constraint the various components can be installed separately to bulkheads or as space permits and f ield connected to operate as a full y skid mounted integrated s ys tem. This will be done with this project as shown in Dwg. D006711
- P
- 50. Major components on the skid, hung on the room walls, and method of operation are listed in the following sections.
Th e BalPure TM sy stem is sold and built by Severn Trent DeNora (STDN) a leader in water treatment and marine sanitation devices. Severn Trent DeNora has been manufacturing like equipment for the offshore industry since 1974. It has an installed base of thes e s ys tems producing over 1 million pounds of hy pochlorite per day . STDN accounts for 65% of the worldwide operating on
- site hy pochlorite capacity

with over 400 sy stems operating in 59 countries. For Offshore applications STDN offers 21 different size sys tems capable of producing from 3 to 2400 pounds per day of h ypochlorite. Our manufacturing facility

is ISO
- 9001
- 2000 certified and we manufacture NSF 61 certified products. We also have received the ABS certificate of Product Design Assessment for our SC
- 96, which is the precursor to our BalPure TM BP
- 500 model. All these certifications are provided in the Ancillary Documentation Section. Chemistry Chlorination is now established as an integral part of water and wastewater treatment practice in the Unite d States. Several hundred technical articles have been written on the subject. It is the consensus that the primary use of chlorine is for disinfection. Disinfection practices are governed b y the chlorine residual
- contact time envelope. The major facto rs affecting the germicidal efficiency of the free residual process are: chlorine residual concentration, contact time, pH, and water temperature. Increasing the chlorine residual, the contact time, or the water temperature increases the germicidal effici ency . Since seawater has a relatively constant pH and volumes are large, this is assumed to be a constant. Contact time for ballast water treatment is the length of the vo ya ge, but the BalPure TM sy stem is based on contact times of less than 4 hours. Thi s therefore sets the chlorine to be added based on the chlorine (oxidant) demand of the seawater.15

Seawater (normally

b etween 15 and 35 grams/liter NaCl) or other water containing NaCl may b e used to generate a disinfecting solution containing chlorine by p assing a direct electrical current through the solution. O n - site generation of hy pochlorite from seawater has been used for over 25 ye ars. These sy stems can be purchased as completely s kid mounted sy stems that generate sodium hy pochlorite from seawater. These systems are used in refining, petrochemical power plants, offshore drilling production, and marine applications around the world. S ys tems can be scaled to the appropriate size depending on the quantity

of h ypochlorite required. The ty pe of electrol ytic cell commonly used in these marine and offshore applications is a “tube within a tube.” Due to the high chlorine demands for ballast water applications the cells offered in this design are the dense pack monopolar / bipolar electroly zers. This all ows high chlorine production in a relativel y small space. T he anode surface is coated with proprietary

precious metal oxides, primarily ruthenium and iridium. Seawater enters one end of the electrolyzer and passes between the cathodes and the anodes. Th e hy pochlorite solution, depleted seawater, and hydrogen exit out of the opposite end of each electrolyzer. Up to three horizontal electrol yzers can be stacked vertically o n top of one another and flow serpentines through all three to increase pounds per hour production rate linearl y by

the number of electroly

zers. Electroly

zer size may

vary and can produce up to 220 pounds/hour per electrol yz er.
In some applications, such as ballast water treatment, a dechlorination step can be added to the process. T his requires adding a reducing agent such as sodium sulfite to the end of the sy stem to neutralize any r esidual chlorine at the point of discharge. The end result is a non - toxic stream with no free chlorine. The process is based on the partial electrol ys is of NaCl present in seawater as it flows through an unseparated electrol ytic cell. The resulting solution exiting the cell is a mixture of seawater, sodium hy pochlorite (h ypo), hydrogen gas and hy pochlorous acid. Electrol ys is of sodium chloride solutio n (seawater in this application) is the passage of direct current between an anode (positive pole) and a cathode (negative pole) to separate salt and water into their basic elements. C hlorine generated at the anode immediatel y16

goes through chemical reacti ons to form sodium hy pochlorite and hy

pochlorous acid. Reactions are shown below: Eq. 1 Cl -  Cl 2 (aq) + 2e Eo = 1.396 V Which is hydrolyzed in solution to form hy pochlorous acid: Eq. 2 Cl 2 + 2H 2 O  2HOCl + 2H + Hy pochlorous acid dissociat es to hy pochlorite at alkaline pH levels: Eq. 3 HOCl  OCl - + H + pKa = 7.5 In seawater bromide ions are present, together with a range of inorganic cations as well as possibly ammonia and a variety of organic compounds. The reaction of molecular c hlorine or hy

pochlorite ions with ammonia or amino compounds leads to the disinfectants and react to destroy b acteria and microorganisms in the water just as do chlorine, hy

pochlorous acid and hy

pochlorite ions. The rapid oxidation of bromide ions will al so occur and (as with chlorine) in the aqueous environment form hy pobromous acid (HOBr) and hy

pobromite ions (OBr- ). T hese reactions will also be equilibrium processes, dependent upon temperature and pH. N ote also that brominated species will react with ammonia and/or amino compounds if present in the water, just like the chlorine analogues. Hydrogen and hydroxides are formed at the cathode, the hydrogen forms a gas and is vented and the hydroxide aids in the formation of sodium hy pobromite and increas es the exit stream pH to approximately 8.5. This reaction is shown below: Eq. 4 2H 2 O + 2e -  H 2 (g) + 2OH Eo =
- 0.828 V17

Because the electrol yt ic cell used for this application is unseparated the reactants at both anode and cathode can further react to form the respective end products shown in the overall electrochemical and chemical reaction below: Eq. 5 NaCl + H + + Br - + 2e  NaOBr + H 2 + Cl Salt + Water + Energy  Sodium Hy pochlorite + Hydrogen
In some applications, such a s ballast water treatment, a dechlorination step can be added to the process. This requires adding a reducing agent such as sodium sulfite to the end of the sy stem to neutralize any r esidual chlorine at the point of discharge. The end result is a non - tox ic stream with no free chlorine. T he neutralization of the free halogen (hy pochlorite and hy

pobromite) between the discharge point and the ballast tanks. Sodium sulfite is used and the simplified reaction is shown below to form sodium sulfate. As shown in the equation, neutralization occurs at one to one molar ratio but two to one (sulfite to halogen) as a weight ratio. Eq. 6 Na2 SO 3 + Cl 2 + H 2 O

–> Na2 SO 4 + 2HCl
Sodium Sulfite + Chlorine + Water

–> Sodium Sulfate + Hydrochloric Acid Ty pically there are 4 g/L sulfate in seawater and based on the concentrations of halogen required onl y 10 mg of sulfate will be added to the discharge ballast water. A lso the amount of HCl generated is negligible and will not change the pH of the discharge ballast water. Operating Environments and Conditions Ballast water turbidity : At this time STDN does not limit the turbidity of the incoming ballast water. Ballast water pressure: A nominal 10 PSI G is required to pass through the inlet strainers, otherwise there are no requirements on minimum pressure because the provided sy stem18

has booster pumps to increase pressure through the BWT s ys tem. Due to the construction of the cells STDN does limit the line pressure from the shipboard ballast pump to 50 psig.
Ballas t water temperature: The inlet temperature to the electrol ytic cells must be above 38 degrees F. The split in ballast flow and portion to the generator is 220 to 1 so a small heat exchanger can be added in applications where ambient ballast water tempera ture will be below 38 degrees F. Maximum ambient temperature up to 120 degree F is acceptable. Ballast Water Flow: The sy stem that is being provided in this proposal can treat 5000 gpm flow at an organic loading of 5 ppm. STDN has provided offshore s ys tems to treat 40,000 gpm at 5 ppm. Therefore we do not restrict flow rate but require matching the hy pochlorite production unit to standard ship rate of ballast. Electrical Requirement: The proposed BalPure TM unit will require 54 kVA at 480 volts, 3 ph ase, 60 HZ. Air: There are no process air requirements. Weight: Approximately

7800 pounds Dimensions: 144 inches long X 72 inches wide X 96 inches high Environment: All equipment is provided in NEMA 4 boxes or with full wash down capabilities. Equipment can be provided to meet class 1 div. 1 hazardous zones. Therefore selective environment is not required. Treatment Limitations: STDN does not know of any at this time. The amount of disinfection by
- products will be proportional to the amount of TOC in the ballast water.19

Operating and Maintenance Manual See Ancillary

Document One.
Installation Installation instructions are listed in the O&M Manual. STDN is committed to a successful installation and operation of any equipment we provide to M TC. STDN will provide on
- site service during the installation and commissioning phase of this project by at least one field service engineer. Those available for field service are listed below: Harold Childers

– 281
- 274
- 8459 Rudy Matousek

– 281
- 274
- 8493 Lucette Falcon
- 281
- 274
- 8460 STDN will also make available for phone consultation the following individuals: Vince Wedlich

– 281
- 274
- 8488 Electrical Engineering Supervisor Sean McMillan

– 281
- 274
- 8492 Instrument and Electrical Engineer Larry Knight

– 2 81
- 274
- 8402 PE Mechanical Engineer James Moore

– 281
- 274
- 8452 Mechanical Engineer
Hydraulic and Mechanical Connections: Please refer to drawings D006711
- F
- 01, D006711
- F
- 02, D006711
- P
- 01 and the O & M manual sections 11 and 12.
Electrical Connections: Please refer to drawing D006711
- EP
- 01, D006711
- E
- 21, D006711
- E
- 01.
Operation and Equipment Operation: 1.1 The BalPure Sy stem is a safe and simple electrol ytic process for on
- site generation of sodium hypochlorite solutions via the electrol ys is of seaw ater. Seawater will be supplied by the customer at a minimum pressure and will be fed to the sy stem inlet via a booster pump. Seawater passes through the electroly zer where it is subjected to a DC current. The20 current passing through the seawater soluti on causes the disassociation of NaCl (salt) and H 2 O (water), which then allows for the formation of sodium hy

pochlorite. The proposed s ys tem is designed to produce 320 lb/day (13.75 pounds/hour) maximum capacity . Lower outputs can be achieved b y reducing the current to the electrol yz er. 1.2 Optimum performance of the BalPure S ys tem is obtained by maintaining a constant seawater flow through the electrolyzer. Varying the DC amperage applied to the cell then controls the produc tion of hy pochlorite. 1.3 The BalPure Sy stem, as proposed, will control and pass the seawater through the electroly

zer at a constant value using an orifice
- ty pe flow controller. An inlet flow transmitter protects the sy stem. This transmitter will shut down the electrical current to the electrol yz er should seawater flow through the electrol yz er stop. The inlet seawater temperature should be at least 5  C and have a chloride concentration of at least 19,000 ppm for optimum performance. The BalPure s ys tem will be tied into the ballast water pump. The system will not operate in automatic mode if the ballast water pump is not operating. The BalPure sy stem must also be set to the “Ballast” mode of operation. With the unit in the ballast mode the automatic valve on the inlet side will open as well as the valve on the discharge side permitting the flow of seawater. 1.4 An inline booster pump will feed a slip stream from the main ballast water line at a feed rate of 32 gpm. A duplex strainer will filter the water with a DP alarm (based on actual field experience with sea water) to remov e any particles larger than 800 microns. 1.5 The BalPure Sy stem, as proposed, is designed to operate automaticall y. After the unit is energized, the sy stem will sense that adequate seawater flow is available. After the unit is purg ed, the transformer/rectifier will supply DC current to the electrol yz er to produce h ypochlorite. Again, for the ballast water treatment mode of operation, the sy stem will be designed to operate when the ballast pumps are activated. The sodium hy pochlorite will be injected into the discharge stream of the ballast pumps. The system may also be activated during voyage if required in manual mode. 1.6 The sy stem is arranged and designed to provide flexibility of the operation in terms of solution and dosing strength. 1.7 Inthe Ballast Water mode, there is a continuous chlorine anal yz er that will measure the oxidant concentration of the treated ballast water after the in jection of the hypochlorite into the main ballast water stream. This anal yz er will feed the results to the sy stem PLC and data logger to automatically

adjust the DC current to the generator in order to maintain the oxidant level at the desired set point in the ballast water feeding the ballast water tanks21 1.8 Inthe deballast mode of operation, liquid sodium sulfite will be metered into the inlet of the deballast water pump. With the mixing effect of the deballast water pump and the 39’ of pipe to overboard, the sulfite will easily react with any

free oxidants. A sensor in the deballast line will monitor the level of sulfite and feed back a signal to the sulfite metering pump to insure the proper dosage of sodium sulfite. We will plan to supply a drum manifold line (suction side of metering pump), metering pump, sulfite anal yz er, and of course PLC control and data logger. 1.9 All mea sured h ypochlorite levels during s ys tem operation will be recorded with date and time in the date logger. All measured sulfite levels during deballasiting will be recorded with date and time in the data logger. 1.10 The BalPure Sy stem needs seawater to operate. If the vessel is going to be ballasting in water that has less than 10,000 ppm of chlorides in it, the normal operation of the BalPure TM sy stem will have to change and an automatic briner s ystem using bulk salt will be activated. The briner system is automatic except for adding salt. The hold tank also serves as the briner and holds 4,900 pounds of salt. Based on ballast tank data there are 12 tanks each requiring 180,000 gallons. This will require approximately 2,000 pounds of salt if the ballast is fresh water. The metering pump attached to the tank will be electrically tied to the conductivity

of the brine through cel l voltage. When the voltage rises above a pre
- set value the metering pump will turn on and have a variable frequency drive to allow for fine adjustments of the flow to maintain proper salinity for the electroly

tic cell. The brine tank and pump will be mounted within the shop building and the discharge line from the pump will inject into the BalPure s ys tem just before the booster pumps. The salt will be added manually and should be purchased in 2, 000 pound “super
- sacs”. The sack is designed to release full contents from a nozzle at its bottom. A small jib crane will be required to lift the bag over the tank to empty the contents. This is a semi manual job required of the operato r and can be done anytime prior to the ballasting operation. 1.11 Hydrogen gas is generated at the cathode of the BalPure unit. Immediately upon exiting the electroly tic cell the gas liquid mixture will be separated in the Hydrogen Degas Separator. Hydrogen is removed and immediatel y diluted with ambient air from a blower to less than 1%. The (LEL) lower explosive limit of a hydrogen / air mixture is 4% hydrogen. 1.12 The ballast water tanks use an Ameron coating. According to Ameron, there will be no problems with the coating as long as the oxidants are less than 10 ppm. (see Ancillary Documents

– Coating Letter) Equipment:22

The major items of equipment are listed as follows: 2.1 Seawater Booster Pu mp : Vertical multistag e, inline pump, all stainless, with stainless steel impeller, diffusers, shaft, chamber and head, with 2” x 2” grooved end connections. T he pump is equipped with a cartridge ty pe mechanical seal, with silicon carbide faces and EPDM elastomers. Pumps are rigid coupled to a 7.5 HP, 3450 RPM, TEFC enclosure, standard efficient, 230/460V, 3ph, 60Hz, 1.15SF vertical 56C motor. Pump is 36.5” tall.
2.2 Transformer/Rectifier: The transformer/rectifier is NEMA 3R rated, and constructed of painted carbon steel. The transformer/rectifier is shipped loose and connected to the generator panel by the interconnecting cable. The control panel converts 480 VAC to 800 ADC @ 47VDC. The internal electrical items consist of a current adjust switch, a set of diodes, fuses an d required relay s. The panel has the following local indications and controls:

- Ammeter

– DC
- meter

- Voltmeter

– DC
- meter

- Current adjust DC pot Power On / flow is OK

– lamp The control panel/transformer/rectifier dimensions are 20” Deep x 84” high x 72” wide. The control panel contains the Operator Interface Panel, which is used to control the overall operations of the BalPure sy stem. T he OI T provides a visual display

o f the status of the various sy stem components, and alarm messages are used to i ndicate malfunctions in critical areas. The following control devices are necessary t o protect the BalPure Sy stem. The PL C uses the output from the flow transmitter to monitor the flow of the seawater at the inlet to the electrol yz er, and will shut the s ys tem down if the flow rate drops to 30 gpm. T emperature switches in the transformer will cut the power to the rectifier if the internal temperature is above 350 F. D C over - current will cause the circuit breaker to trip. Displayed on the control panel:

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

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

- Power on/Flow OK Li ght: T his is a light to indicate that the unit is running, the transformer temperature is acceptable, and there is sufficient seawater flow, sensed from the flow meter.23 In the event of an electrical trip or low
- flow actu ation, the unit will turn off and the light will turn off. If the unit turns off due excess transformer temperature or insufficient seawater flow, there will be a time delay until the unit and the light turn off and an external alarm could be indicated. When the light is off and an alarm actuated, the unit will require operator investigation and correction of sy stem valves, flow, or electric power

- Power On/Off Knob: A llows the operator to start or stop the unit. T here is a time delay f rom switching th e Knob to “On” and the Power On/Flow OK light turning on, indicating that the rectifier is energized. 2.3 Generator Panel: The generator panel converts seawater to sodium Hy pochlorite. The generator panel assembly c onsists of an inlet automatic electric valve , a flow meter (with visual indication and a switch), one electrol yz er, and an outlet automatic valve used for isolation and flow control.
2.4 BalPure Electrolyzer: The Balpure electrolyzer consists of 8 bipolar cells with an electrode area of 0.8 square meters. O ne end of the electrol yz er is an anode (+) and the other end a cathode (
- ). The bipolar plates are inserted in each of the electrol yz er’s terminal electrodes. The seawater flow is channeled between the electrode plates. The main body

o f the el ectrol yz er is about 8.5 feet long with an overall length of 10.5 feet long when the electrical connections are included. T he electrolyzer is about 2 feet in diameter. There is a 3 inch seawater inlet and a 3 inch outlet even though we are using 2” pipe t o and from. The electrol ytic cell is stable under all normal operating conditions and has a guaranteed life of 5 years. 2.5 Continuous On - Line Analyzers: The chlorine analy tical instrument can measure free oxidants on a continuous basis. The sulfite an aly zer measures the sulfite level in the deballast water stream. T he oxidant results are fed to the PL C where when in ballast mode, the current from the transformer/rectifier will be adjusted to maintain the generated oxidants at the proper set point. In the deballast mode, the sulfite anal yz er will feed a signal back to the PL C to adjust the metering pump to dose the correct amount of 42% liquid sodium sulfite into the inlet of the deballast pump to remove any free oxidants in the deballast water. 2.6 Sulfite Addition System: The sulfite addition sy stem is comprised of two metering pumps, one on - line and the other an in
- line spare. T hey w ill be mounted on an exterior wall inside the present shop building. The suction line will run from the sulfite storage tank to the metering pumps. The pump is supplied to meter the sodium sulfite into the inlet of the deballast pump. The pump will be PLC controlled based upon the BalPure s ys tem in the deballast mode, and a signal from the anal yz er (2.5) that there is sulfite in the deballast water. The sodium sulfite will be pumped from 55 gallon drums.24 The operator will have to check tank volume before each deballasiting operation to insure sufficient material. 2.7 PLC and Data Logger: A PL C is supplied to control the BalPure system. A data logger is supplied to collect and store the data for future down loading and record of ballast water treatment and dechlorination. D ata s uch as run time, amperage, voltage, oxidant levels, sulfite levels, etc. will be recorded and logged. The Solid State Data Recorder is a Paperless Recording instrument. Data is stored on either an internal floppy disk, a removable PCMCIA memory card or a Zip Drive. All data is stored in MSDOS format and may be archived or anal yz ed on any IBM compatible PC running Microsoft Windows 3.1 or Windows 95/98 using the available Companion Software . The instrument retains all the features of a traditional Pap er Chart Recorder b y virtue of its large STN monochrome or TFT color L iquid Cry stal Display (L CD), which presents the data in the traditional chart mode as well as in bar graph or digital numeric form. The unit has many features and functions, which are unique and cannot be performed on traditional paper recorders, such as data compression and historic data browsing. The recorder is programmed via a touch screen key pad on the display . The recorder will measure and process up to six direct inputs, calculated, conditional, or external points for logging, trending, or data manipulation. I f direct inputs are not desired, the Data Recorder will accept up to fifteen points from a combination of calculated, conditional, or external point ty pes. 2.8 Sam ple Station : T here will not be a master sample station. S TDN requires the MTC vessel operators to sample and analyze the available chlorine content of each ballast tank 24 to 48 hours prior to de
- ballasting. The sampling and anal ys is procedures will be detailed in the operating and maintenance manual provided with the equipment. This task is estimated to take 15 minutes per ballast tank. 2.9 Hydrogen Dilution: The electrol yz er output enters the Hydrogen Degas Separator where the hydrogen is separated from the Sodium Hy pochlorite solution. In the Hydrogen Degas Separator, H2 that is being generated is removed from the two - phase (liquid/gas) solution and safel y routed to the vent stack. T he hydrogen in the vent stack is diluted to less than 1% by o ne (1) of the two (2) dilution air blowers. The lower explosive limit (LEL) of a hydrogen/air mixture is 4% hydrogen. T wo 100% blowers are provided to ensure an automatic standby to the operator selected lead blower. Inlet filter screens prevent unwanted d ust/debris from being admitted to the vent system. E ach blower line is provided with an individual airflow switch to provide logic feedback for the standby blower startup. D ampers prevent backflow through the standby b lower during operation.25 After the h ydrogen is diluted to below the lower flammability l imit, it is safel y vented. T he Sodium Hy pochlorite solution flow from the degas separator is routed to the required injection points. 2.10 Briner System: Seawater will enter the brine tank through a side feed chamber. Li quid lever control maintains water at 30% from the bottom to ensure full saturation. Flow requirements will be approximately 1 .5gpm to achieve the required brine concentration to the electrol yz er. The brine tank is sized for a working volume of 4,900 pounds to facilitate additions via 2000 pound super sacks. The brine tank will be installed inside next to the generator. I t will be made of HDPE with bulkhead fittings. Brine addition to the electroly zer will be controlled by

salinity of the incoming seawater. 2.11 Alarms: Various alarms will display through the control panel PLC for proper operation of hy

pochlorite generator, sulfite addition, hy po addition, and concentrated brine addition. T here will also be a general purpose audible and visual alarm on deck outside of the room housing the generator.

Maintenance and Consumables Refer to the O & M manual; section 14 regarding maintenance and appendix A for spare parts. Sodium bisulfite is the other consumable material used during de
- ballasting for chlorine neutralization. The stoichiometric ratio of sulfite to chlorine is 1.6 to 1. To be safe assume 2:1 by

weight and assume a 2 ppm residual chlorine that must be neutralized with a 2 ppm sulfite excess. Therefore the worst
- case c onsumption rate for the MTC test protocol for a 5,000 gallon (18,925 liters) per minute would be: 18,925 kg X 2 ppm = .0378 kg (.083 lb.) of chlorine to neutralize At 2:1 ratio .0378 kg X 2 = .0757 kg sodium bisulfite At 2ppm excess 18,925 kg X 2 ppm = .0378 kg of bisulfite extra Therefore total sulfite per 5,000 gallon discharge would be .15 kg (.33lb) of bisulfite per minute. The MTC total ballast is 2.6 million gallons or 173 pounds of sulfite per full de
ballast.26

Costs The purchase price for the BP
- 1000 unit as delivered for this proposal will be less than $500,000. This price covers all h ypochlorite generating equipment, gas separation, all instrumentation, all analyzers, brine supplement system, and data logger. Operating costs are projected to be $0.03 per cubic meter of treated ballast water. The only consumables in operating the s ys tem (assuming proper salinity seawater is available) are electricity

and sodium sulfite. Breakdown would be as follows: At power costs of $0.15 p er Kwh, electricity would be $0.02 per cubic meter of ballast treated. Sulfite costs are $0.004 per cubic meter of ballast treated. The other major replacement item is the electrodes in the electrol yt ic cell. Operating life is 3000 hours with a contributing cost of $0.003 per cubic meter of ballast treated. Other miscellaneous operating costs for reagents, pump seals, etc. would be another $0.003 per cubic meter of treated ballast water.27



### SECTION VI: Discharge Validation
We at Severn Trent DeNora be lieve that the de
- ballasted water from any ship using our BalPure TM ballast water treatment sy stem, when operated as designed, will meet all regulatory

requirements. This belief is based on the following land based testing, clinical toxicity testing, and input from Federal agencies. Toxicity Nautilus Environmental Northwest Laboratory conducted tests per the guidelines published by

the Washington Department of Ecology titled “Toxicity

Testing to Establish the Environmental Safety o f Proposed Ballast Water Biocides”. The more aggressive 7
- day s urvival tests were conducted. W ater environments were prepared following the full cycle of our electrol yt ic ballast water treatment sy stem. P uget Sound water was treated with chlorine using the BalPure TM chlorinat or. That seawater was then neutralized with varying amounts of sodium sulfite to establish a safety factor for commercial operation. Standard treatment will require a residual of 1
- 2 ppm sulfite during normal operation. Results indicate no adverse effec t on Mysid (M. bahia and M. beryllina), bivalve larval, kelp germination, and herring embryo up to 16 ppm residual sulfite. The summary report is attached in the Ancillary Documents.
The University

o f Washington also did toxicity t ests following a similar test protocol with systems of 75 gallons, which indicate no adverse effects on bacteria, phy toplankton, and mesozooplankton. This work is summarized in the December 2004 report, also attached in the Ancillary

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

water. T he benefit of disinfecting drinking water is obvious as thousands of people died from waterborne disease before municipalities began to disinfect drinking water, but it is also generally

recognized that it is important to minimize the formation of DBPs in drinking water. S everal DBPs have been linked to cancer in laboratory animals, and as a result, the U.S. EPA has regulated some DBPs.
While we anticipate that most people will not be drinking ballast water and other treated seawater, we have evaluated the formation of selected DBPs that may b e formed following the generation of hy poc hlorite in seawater. S eawater is significantly different than freshwater, not just because of the relatively high concentration of Na+ and Cl and oftentimes higher levels of natural organic material, but also because of the presence of Br- (bromide). Th e presence of this ion may l ead to the formation of bromate (BrO 3 - ), a compound that is considered a possible human carcinogen. In the U.S., bromate is regulated at 10 μ g/L (10 parts per billion) in drinking water. S eawater contains a ty pical bromide con centration of 65 mg/L so the concentration in seawater is significant. Therefore, bromate was one of the DBPs measured in our research. In addition, the presence of haloacetic acids (HAAs) and trihalomethanes (THMs) are a concern and were measured as part of the overall study
. Results are provided in the December 2004 University o f Washington Report. Indications were that when treating Puget Sound water spiked with 50% more zooplankton and phy

toplankton than normal concentrations, result in de
- ballasted water that meets drinking water standards for THM, HAA5, and Bromate.
Permitting and Certifications Chemicals that are involved in the BalPure TM process are: 0.1 wt% hy pochlorite solution or 50 times weaker than household bleach is not subject to the same regulations that govern strong h ypochlorite greater than 1.0 wt%. In fact we do not know any regulations that pertain to this hy

pochlorite concentration. Sodium bisulfite, either 42 wt% liquid or29

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

documents. STDN spoke with Dennis Edwards of the EPA in Washington D.C. pertaining to the BalPureTM s ys tem and how it would be classified as a pesticide generation device. We presentl y have o ur manufacturing site registered and all our pesticide devices built on this site are covered b y Establishment Number 048482
- TX
- 001. We submit documentation annually and will include our BalPureTM in the future. Mr. Edwards mentioned that this documentation was more than adequate to cover any regulations pertaining to a chemical Ballast Water Treatment Sy stem. No other FIFRA laws pertain to our situation at this time.
A literature review b y Dr. E. Rudd (PHD in Electrochemistry) from ElectroTechnologies is included in the Ancillary Documentation. The review concludes that hy pochlorite / chlorine concentrations as low as 0.1 ppm can be effective as a disinfectant to kill living marine organisms. The review also indicates sodium sulfite is a non
- toxic and non hazardous chemical. The report is included in the Ancillary Documentation.30

SECTION VII: Land Based Experiments Discharge Water Quality Per the work of Russ Herwig at Marrowstone Island, the BalPure TM unit can treat seawater to meet the Wash ington State interim ballast water discharge standards: In activation of ninety- five percent of Zooplankton organisms In activation of ninety- nine percent of Phy toplankton In activation of ninety- nine percent of Bacteria Per the work of Russ Herwig at Mar rowstone Island, the BalPure TM unit can treat seawater to meet IMO standards: < 10 Viable Organisms per cubic meter at > 50 micron < 10 Viable Organisms per milliliter at < 50 micron Eliminate bacteria to < 250 colony forming units per 100 ml
Please re fer to the three summary reports by

Russ Herwig for the work done by the University

of Washington at the Marrowstone Island USGS site. The work is contained in the Ancillary

Documents
- Marrowstone Sodium Hy pochlorite Mesocosm September 2004, Marrowstone Sodium Hy pochlorite Mesocosm October 2004, Marrowstone Sodium Hy

pochlorite Mesocosm December 2004.31



### SECTION VIII: Performance Capabilities As outlined above in the ballast flow section, STDN has provided offshore seawater treatment s ys tems up to 40,000 gpm at 5 ppm available hypochlorite. STDN is proposing a sy stem to handle 5000 gpm at 5 ppm available hy pochlorite. All results should be scalable up or down in production capacity . Please see the table below for various available BalPure TM Sy stems. STDN is marketing six different size BWT sy stems based on ballast water flow rates in increments of 500 cubic meters per hour. MODEL SEA

WA TER TO BE TRE ATED @ 5 ppm SYSTEM OUTPUT REQUIREMENTS AC POWER

REQUIRED 

### DC POWER
M 3/H GPM kg/H Lbs/Day AC KVA AM PS V OLTS BP - 500 400 - 825 2200 2.5 132 35 500 48 BP - 1000 826 - 1250 4400 5.0 264 52 500 72 BP - 1500 1251 -

1800 6600 7.5 396 78 500 108 BP - 2000 1801 -

2200 8800 10.0 528 103 500 144 BP - 2500 2201 -

2600 11000 12.5 660 110 800 96 BP - 3000 2601 -

3600 13200 15. 0 792 165 800 14432



### SECTION IX: Shipboard Test Plan Objectives Demonstrate operational efficacy and reliability

of the BalPure s ys tem. + Hy pochlorite Generation + Chlorine monitor and control + Sulfite monitor and control + Data logger oper ation Characterize geochemical and biological composition of ballasted and de
- ballasted treated and un
- treated seawater.
Introduction The BalPure s ys tem is divided into hy pochlorite generation, chlorine monitoring and control, sulfite monitoring and co ntrol, sulfite dosing, and data logging. Only the monitoring sy stems will require some operator attention. The anal yz ers operate with pre
packaged reagents with somewhat short shelf life and should be changed (once opened) every 14 day s. The rest of the sy stem is relatively free of maintenance and has a 20
- ye ar proven history

in power plants and offshore applications. The intent of the sampling and anal ys is program is to provide initial start
- up, training, and commissioning assistance to the Crowley staf f. Once the mechanical sy stem operation is verified a second phase would be to execute a detailed sampling and anal ys is program with a team from University of Washington and STDN. This program would establish the efficacy

of the BalPure unit with ballast water from various ports. This program would be conducted over the first three voyages. The sampling and anal ys is sequence would follow that listed in Table 1. To provide a control for this test, we will fill one ballast tank with un
- treated seawater and the rest with treated seawater. This will aid in determining efficacy of the s ys tem with the same quality seawater and characterize both ty pes of ballast water with time. Accommodations will be required for the sampling and test team of two people to do anal ys es at the prescribed intervals.33

The demonstration portion of the test program follows the intense one month period described above. This portion of the overall program will cover the next two months. This period is required to demonstrate relia bility of the equipment and provide logged data to demonstrate s ys tem control and meeting operating parameters. The final portion of the program is a six
- month maintenance period to establish maintenance cycles and further demonstrate robustness of the sy stem. If all critical validation points are met during the first six months it would be Marine Transport’s decision to continue the elevated monitoring program or pursue the STEP program.

Test Procedure

– Every Ballasting Operation Four hours prior to Ballasting, turn on power to chlorine anal yz er to warm up, move sensor from holding tube to unit. Replace sample line filter and reagent bottle if required. 1. Once ballast pump(s) begin pumping and BalPure unit is making chlorine, collect sample balla st water after the mix point. Do chlorine anal ys is using Hach Colorimeter and adjust BalPure Chlorine anal yz er (see manual) to match test kit value. (Should be infrequent and minimal adjustment). 2. Set BalPure unit to desired chlorine residual, to be deter mined (3.0

– 5.0 ppm range) based on initial efficacy tests during the first two weeks of operation. Allow BalPure unit to control residual chlorine concentration. 3. When sy stem is fully

commissioned, take samples per sampling Table 1 for three bal lasting operations during the next month. 4. Once per month (for the next two months) collect two ballast water samples from the none treated tank and two ballast water samples from a treated ballast tank right after tank is full. Send samples immediately to laboratory (to be determined) for anal ys is. Sampling could be scheduled through University of Washington or STDN to minimize time spent by Marine Transport personnel. 5. Once per month (for the next two months) collect two ballast water samples from the n one treated tank and two ballast water samples from a treated ballast tank right before de
- ballasting.

Test Procedure

– Every De - ballasting Operation Two hours before de
- ballasting, install sensor and then turn on power to the sulfite anal yz er. Confirm there is at least 30 gallons of sulfite solution in the dosing34

drum. Turn on power to the chlorine analyzer to confirm there is residual chlorine in the ballast tanks just prior to de
- ballasting. 1. Once ballast pumps b egin pumping, confirm de
- chlorination unit is working. 2. Sample overboard discharge and check for chlorine with Hach test kit to confirm no chlorine is present. Match hand held reading with analyzer. 3. Confirm sulfite analyzer is working and if required, adjust sulfite analyzer per manual. Maintain 1
- 2 ppm sulfite in the exit stream. 4. Once de
- ballasting operation is completed, shutoff power to sulfite anal yz er. Record sensor sensitivity , rinse, remove sensor and affix storage cap. 4. When sy stem is fully

commissioned, follow intense sampling sequence in Table 1 for three de
- ballasting operations that match like ballasting cycles. 5. Once per month (for the next two months) collect two samples after dechlorination s ystem that match those taken in item 5 under ballasting. Send samples to laboratory

(to be determined). Sampling could be scheduled through University

of Washington or STDN to minimize time spent by Marine Transport personnel. Sample Analysis All retur ned samples will be anal yz ed to characterize the geochemical and biological composition of the seawater. The data will include the following: 1. Salinity 2. Dissolved Organic Carbon 3. Live organisms greater than 50 micron and smaller than 50 micron 4. Chlorophyll a 5. Bacteria 6. Disinfectant By
- Products 7. Sulfite and Sulfate Conc. 8. Toxicity35 Table 1. Data collected during ballast water treatment and voyage of Crowley vessel with STDN BalPure sy stem installed. The number of intermediate samples collected will depend on the length of the voyage. Data Collected Ballast Tank

After Filling Ballast Tank

24 h Ballast Tank

48 h Ballast Tank Before

Discharge Discharge Chemistry Data Salinity X Temperature X X X X X Organic carbon X Total residual oxidant (TRO) X X X X X Disinfection by products X X X X X Sulfite X Biology Data Zooplankton X X X X Chlorophyll a X X X X X Cu lturable phy toplankton X X X X X Bacteria X X X X X36



### SECTION X: Ancillary Documentation