DESALINATION

ELSEVIER Desalination 167 (2004) 191-200

www.elsevier.com/locate/desal

Reverse osmosis on open intake seawater:

pre-treatment strategy

V6ronique Bonnelye*, Miguel Angel Sanz, Jean-Pierre Durand, Ludovic Plasse,

Fr6d6ric Gueguen, Pierre Mazounie
Degremont 183, Avenue du 18juin 1940, 92500 Rueil Malmaison, France
Tel.+33 (1) 46 25 38 19; Fax +33 (1) 39 76 35 41; email: veronique.bonnelye@degremont.com

Received 4 December 2003; accepted 15 January 2004

Abstract

Pre-treatment of seawater feeding reverse osmosis (RO) membranes is a key step in designing desalination
plants. The pre-treatment process must be adapted to the seawater quality to be treated (wells, open intake, etc.),
especially when treating surface seawater with highly variable quality. After a general presentation of different pre-
treatment options in relation to the seawater quality, this paper is focussing on two case studies, two open intake
seawater pre-treatment upstream reverse osmosis desalination. The first site is located in the Gulf of Oman (Indian
Ocean), the second in the Persian Gulf. The pre-treatment uses different technology strategies, conventional pre-
treatment (coagulation and direct filtration on dual media filters) and innovative technologies (high rate dissolved
air flotation, ultrafiltration and microfiltration) according to the water quality. The parameters taken into account
for the water quality characterisation are the suspended solids, turbidity, fouling tendency, organic matters and
algae content. This paper presents the pre-treated water quality achieved by the two types of pre-treatment and
discusses potential impacts on RO hydraulic performances.

Keywords: Seawater reverse osmosis; Open intake; Pre-treatment

1. P r e t r e a t m e n t strategy biofilm development (biofouling). The silt density

Reverse osmosis membranes are very sensitive index (SDI according to ASTM) is a useful tool
to foulants such as colloids, inorganic scale and for particle evaluation and by extension, mem-
brane fouling. Many SWRO systems are fed using
*Corresponding author. beach wells with low suspended solids water. In

Presented at the EuroMed 2004 conference on Desalination Strategies in South Mediterranean Countries: Cooperation
between Mediterranean Countries of Europe and the Southern Rim of the Mediterranean. Sponsored by the European
Desalination Society and Office National de l'Eau Potable, Marrakech, Morocco, 30 May-2 June, 2004.

0011-9164/04/$- See front matter © 2004 Elsevier B.V. All rights reserved
doi;10.1016/j.desa1.2004.06.128
192 E Bonndlye et al. / Desalination 167 (2004) 191-200
such cases, it is possible to achieve SDI15(15 min.
SDI) below 3 [1] using sand filtration without
coagulant, or even simple 5 ~tm cartridge filters.
Due to increasing plant size and the limited
permeability of local soils implying a need for
numerous wells, onshore beach wells are used
with less and less frequency and SWRO plants
are operated with direct feed from open seawater
intakes [2].
On open seawater intake, reverse osmosis
membranes are sensitive to different types of
pollution: particles, precipitated metals, organic
matters, hydrocarbons, etc. An efficient pre-
treatment must control the flux of each pollutant.
The pre-treatment must be designed to face the
worst water quality, providing a constant and good
RO feed water quality.
Direct filtration, using mono or dual media, is
the most common technology used for the filtra-
tion of seawater upstream RO desalination plant.
This technique must be optimised and improved
on variable quality surface seawater: the coagula-
tion can be improved by a better understanding
of the phenomenon, the use of different chemicals.
Selected media and filters characteristics can also
improve the performances of this clarification
treatment. Direct filtration treatment is evaluated
in terms of filtered water quality, cycle duration,
maturation and risk of breakthrough. This treat-
ment technology can be improved using a double
step filtration.
On open intake surface water treatment, well-
optimised direct filtration can be replaced by
membrane clarification, such as ultrafiltration or
microfiltration [6]. Furthermore, the impact of a
lower cutoff pre-treatment could lead to an
increase of the RO reliability. The design permeate
flux rate could be higher than the generally
recommended design average flux rate in seawater
RO systems operating on surface seawater, which
is within the 7-8 gfd range (11.9-13.6 L/h.m2)[3],
and recovery (40-45%)[2,3].
Finally, facing high turbid water, risk of algae
bloom and/or hydrocarbon pollution, the main
clarification step (direct clarification or ultra-
filtration/microfiltration membranes) can be
protected by complementary pre-treatment, such
as sand removal, settling and/or flotation. The
limits of each treatment must be evaluated in terms
of design, water quality and adaptation to a
pollution event.
This paper presents the results of two pilot
studies performed on open seawater intakes. The
objectives were to assess the limit of each
technology and to explore the potential of
technology associations to increase the reliability
of the whole open intake seawater pre-treatment
upstream reverse osmosis desalination.
2. Material and method
Both pilot tests were conducted on an open
seawater intake. Sand removal was evaluated as
a pre-treatment step, mainly on the Persian Gulf.
For high suspended solids content, a dissolved air
flotation unit was tested for turbidity, oil and
grease removal on the same site. The high rate
flotation unit includes a pressurized water generator
and a 1 m 2 separation cell.
The direct filtration was then studied in one or
two stages, depending on the feed water quality,
using pilot units with 4 filtering columns operated
in parallel or in series. Transparent plastic columns
were used to optimise the backwash sequences.
The filtering media tested were from several
origins, anthracite, pumice, sand and garnet,
allowing an evaluation in term of effective size,
shape and density.
Two fully automated ultrafiltration units were
used. These pilot units included the filtration
system and automatic backwashes controlled by
a PLC.
The reagents tested were usually chemicals
used in water clarification: sulphuric acid for pH
correction, Fe or A1 salt as coagulants (FeCI 3,
WAC HB, Kemira PIX 123), organic coagulants
as filter aid (Kemazur 4527, Nalco 8103 and 8105,
RO Floe) and floceulent aids (AQnionic polymer
 V. Bonndlye et al. / Desalination 167 (2004) 191-200 193

ASP25, trach). Powdered activated carbon was One WGS267 portable particle counter and in-
also evaluated for organic matter removal im- line Met One PCT.
provement, and chlorine for disinfection shocks
or continuous preoxidation, and membrane back-
wash. 3. Results
Several on-line equipments were used for the
3.1. The G u l f o f Oman
process control: flowmeter (ABB) and flow con-
trollers (Burkert), pressure sensors for the head- The first site evaluated was good surface
loss follow-up (Jumo). seawater, using only one pre-treatment stage
The suspended solids were evaluated in terms before RO. An 18-month pilot study was per-
of turbidity and particles count. Turbidity was formed on the pre-treatment to study and optimise
analysed both on grab samples (Hach 2100P) and the direct coagulation in term of chemicals and
in-line, using both Seres turbilight and Hach filter media characteristics. Two periods were
1720C turbidimeters on raw and filtered water. studied in 2002 and 2003 to take into account the
UV absorbance (at 254 nm) and TOC were water seasonal variability. This paper presents the
analysed to characterise the organic matters. These pilot study and the fisrt results of an industrial
analyses were completed by pyrolysis - - GCMS plant constructed based on the pilot results.
analysis to evaluate the organic matters com- The water quality main characteristics are
position. presented in Table 1: water was taken 4 m below
Phytoplankton was followed during the whole the sea surface. During the test period, the
study. following parameters remained almost constant:
SDI was measured using manual apparatus and pH, turbidity, conductivity, Fe, mineralisation,
an automatic Chemetek FPA-3300 Filter plugging algae, UV, and hydrocarbons. The water quality
analyzer. For filtered water and permeates the was generally very good with turbidity around 0.2
SDI]5 was determined according to ASTM D NTU and 70% of the SDI 5 below 6 (Fig. 1): no
4189-95 (15 min filtration in the 75% fouling relation seems to exist between those two param-
range). For raw water, the SDI yielding 75% eters. 75% of the particles were in 1-2 pm range.
membrane fouling was recorded (SDI 5 or SDI3). The temperature was high, but normal for this part
Particle count analysis was performed with a Met of the world.

20 -'-'--"~
..........................................................................................................
............ ....... 1.0

18 ,, I, ,: I er,,, I 0.9
" [m
'11 I '. I o•, I
16 ,' ~ , , 0.8
l llll I i
• I I I
14 ~ ,, , , 0.7
,, ,,', . ) ,I .
r. ,, ;~, ;, ,:. ;" t p-
12 -- 0.6
] 10
,. ~ ~, , ,: Z

II ~1 rill i II
0.5
II I ,I I I .I I II ~ [
U) 8 I 0.4
6 ,," .; "' ' " he .','.;J/S. 0.3
4 0.2
- ' "'" ) w 1"- v 'lfl
2 0.1
Date (mrn/yyyy)
0 Fig. 1. Evolutionof the turbidityand
01/2002 02/2002 0312002 04/2002 05/2002 0612002 0712002 SDI values.
194 V. Bonndlye et al. / Desalination 167 (2004) 191-200

Table 1 few e m W C / m to more than 1 m W C / m o f

Main seawater characteristics media. This is a direct limitation of the lower
media depth.
Parameters Average Min. Max.
a better retention capacity in the larger size
Temperature, °C 26.7 21.6 33.2 media, on top of the filter.
pH 8.13 7.86 8.54
Conductivity, mS/cm 55.3 54.2 56.5 All the chemicals: WAC HB, Kemira PIX 123,
SDI, %/min 6.2 3.6 20 Kemazur 4527, Nalco 8105, RO Floc, ASP25,
Turbidity, NTU 0.22 0.12 0.56
Fe, mg/L <0.01 -- -- starch polymer and continuous chlorination - - did
UV254,DO/m 0.86 0.6 1.46 not improve or deteriorate the treatment efficiency.
TOC, mg/L C <5 <2 FeC13, coagulant generally used for this appli-
Particles > l~m, part/mL 2469 1633 3296 cation, gave surprisingly very bad results in terms
Hydrocarbons, ~tg/L 2.05 0.46 4.36 of clogging rate of the filtering bed: a head loss
profile clearly showed the clogging of the top layer
of the first dual media filter tested. After the choice
According to the UV absorbance (<1 m-1 most
of the best media configuration (larger effective
o f the t i m e ) , T O C results (<2 m g / l ) , and
size on top), the results improved leading to an
hydrocarbons (<5 ~tg/l), the raw water organic
optimum-dosing rate of 3 g/m 3 as FeC13.
matters concentration is very low.
The pH o f coagulation impacts also the
The algae counts were always low. Macro-
c l o g g i n g velocity, a l l o w i n g a cycle length
algae development has been reported on some
optimisation.
equipment of the pilot plant, but this problem is
When the raw water SDI was higher than 10,
normal with open or transparent equipment with-
a flocculant aid was necessary to lower the clogging
out chlorination.
velocity and to improve the filtered water SDI.
The media tested on the single stage direct
coagulation are listed in Table 2 (Fig. 2). More
than 150 filtration cycles were performed during
this study.
The main conclusions of the tests were:
• a direct relation between the effective size of
the filter bed bottom layer, last in contact with
the filtered water: the lower the ES, the better
the SDI value,
• an impact of the media high on the initial head
loss of the filter bed: the values vary from a

Table 2
Filter medias tested (effective size ES in ram)

Top media Bottom media

Anthracite (1.5) Garnet (0.3)
Anthracite (0.9) Sand (0.5)
Anthracite (0.9) Sand (0.3)
Sand (0.5) Fig. 2. Direct filtration using ferric chloride as coagulant,
Pumice (1.6) Sand (0.5) and two types of media in parallel, dual media pumice/
Pumice (1.6) Sand (0.3) sand and mono-layer sand filter.
 E Bonndlye et al./Desalination 167 (2004) 191-200
Chlorine was used from time to time only to
stop the biological development in the pipes and
equipment. It does not improve the coagulation
efficiency on removing SDI in the filtered water.
The filter backwash has to be optimised in
accordance with the media chosen, in terms of air
and water velocities, the latest necessary to reach
the best media expansion/classification. After
every backwash, the filtered water quality has to
be evaluated to determine the maturation time
needed (production duration with a filtered water
quality unacceptable for the reverse osmosis feed
leading to filtered water rejection, filtration to
waste). During the pilot test, this duration could
be reduced down to 15 min.
With the media configuration chosen and after
the chemicals optimisation described, the filtration
cycles were between 17 to 24 h with a filtration
velocity of 10 m/h.
With the optimised treatment, the filtered water
quality was steady and in a good range for all the
parameter checked:
• SDI, the most important parameter for the
characterisation of RO feed water (Table 3),
was efficiently removed using the lowest
effective size media (garnet or sand).
• Turbidity was always below 0.1 NTU in the
filtered water (average 0.07 NTU), with a
maturation time to get this value below 15 min.
While the filter was clogging, the turbidity
remained below 0.1 NTU, demonstrating no
risk of breakthrough (breakthrough time much
higher than clogging time). Particles were
removed at 98%, with less than 10 particles/
mL larger than 2 ~m.
° Iron concentration was below 0.01 mg/L and
remained at this low value in the filtered water:
all the ferric chloride used for coagulation
effectively precipitate in the filtering bed.
° In terms of mineralisation, chloride and sul-
phate increased according to the treatment rate
of sulphuric acid and ferric chloride, with a
corresponding reduction of the alkalinity.
° Organic matter removal was mainly evaluated
195
Table 3
SDI in the raw and filtered water
SDI,% Raw w~er Filtered water
95 <15 <3.3
90 <9 <3
50 <5 <2.6
using UV absorbtion at 254 nm: a 25% removal
efficiency on this parameter was observed,
with an average filtered water value around
0.6/m. Hydrocarbons concentration remained
at very low levels (<3 ~tg/L) including when
hydrocarbons pellets could be seen floating in
a rather large amount (note that this intake is
located only 3-4 miles from the "rail" going
out of the Arabian Gulf with tankers perm-
anently queuing out from the Ormuz strait).
• The phytoplankton was very low, with algae
concentration always below 10 cell/mL.
From the pilot plant trial, it was concluded that
a single step gravity dual media filtration was
sufficient to obtain adequate pre-treated water
quality subject to the following conditions:
° pH adjustment between 6.5 and 7.2 depending
on raw seawater SDI,
° Coagulant dosage ranging from 2 to 5 mg/L
pure FeCI3,
• Under worst seawater quality conditions, the
dosage of a polymer to reduce the SDI and to
improve significantly the filterability of the
flocs formed thus increasing the filtering run
time.
The first results obtained during the full in-
dustrial plant commissioning were similar to the
ones obtained during the 9-month pilot test: The
filtered water was very steady, and SDI was below
the expected value (Fig. 3).
3.2. The Persian Gulf
The second site evaluated using pilot testing
was the Persian Gulf. The characteristics of the
seawater in term of SDI value, concentrations of
196 If. Bonndlye et aLI Desalination 167 (2004) 191-200

49 "r

4O

i
t-,
X 1 = Ill ~j ll _

¢3

15
~' VV \
40 pH pt
• ~r'tl .~ ~.~l.--~r , ,,
5

0 . SDI pt man. ,,
~o ~oo ~o 200 2~o 300 3~o 400 4~o
hours
Fig. 3. Full scale pre-treatment plant results in terms of SDI.

organic matters and suspended solids determined pre-treatment and ultrafiltration (UF) pre-
the choice o f pre-treatment before reverse treatment efficiencies prior to RO for desalting
osmosis, and the number of stage of the pre- seawater with high-fouling tendency. A four-stage
treatment. A four-month pilot study was conducted conventional pre-treatment process and two UF
on a variable seawater quality. The objective of processes were operated in parallel on open intake
this study was to assess and compare conventional seawater (Fig. 4).
The main characteristics of the raw seawater,
pumped 10 m below the sea surface (in a 15 m
Intake water deep area) are presented in Table 4. With
pump + pipe
an average turbidity around 0.7 NTU and algae

,, [
Sand/grit I
removaltank
~: ...... _ ......................................

Flotation I
AquaDAFTM ULTRAFILTRATION

~r

Dual*media I Ultraflltratlon 1 1
Filtration

Dual-media I I Ultraflltratlon2
Filtration

Fig. 4. Pilot pre-treatment line.

 v. Bonndlye et aL / Desalination 167 (2004) 191-200 197

counts below 100 cell/mL, this surface seawater suspended solids, highly variable in this very
does not seem very difficult to treat, except shallow seawater intake (mainly during storm
regarding the SDI values, which are both events). UV absorbance removal was in 20-30%
permanently very high, and with wide fluctuations range (Fig. 6). Hydrocarbons were also well
(Fig. 5). removed when present in the suspension form,
The preliminary treatment, a dissolved air protecting the aim of the pre-treatment: the direct
flotation, allows a good removal of turbidity and filtration.
The direct filtration step included a double
Table 4 filtration with two coagulant injections: this
Raw water analysis treatment line was selected to take into account
the worst water quality expected in this surface
Parameters Average Min. Max. seawater. Media were chosen to improve both
Temperature, °C 32 32 35 filtration length and filtered water quality.
pH 8.18 8.08 8.26 The results obtained on the filtration pilot
Conductivity, mS/cm 62.7 62.2 63.4
Turbidity, NTU 0.74 0.48 1.13 during the 4-month period of operation yielding
SDI, %/min 21.7 10 45 rather good SDI (1.8-2.9 with incoming sea water
Total alkalinity, 123 122 125 SDI 10-45 %/min) (Table 5). Here also, the
mg/L CaCOa maturation was very short, and the risk of
Total hardness, 8027 8010 8040 breakthrough very low, due to the sticky nature
mg/LCaCO3 of the floe formed with the FeC13-floculant aid
TDS0 44.3 43 45.5
g/L (from conductivity) applied (Figs. 7 and 8). Filtering runs remained
UV absorbance,/m 1.3 0.9 2.2 longer than 24 h.
Algae, cell/ml 50 38 76 Ultrafiltration pre-treatment was evaluated in

* Temperature pH • SDI I
SO j • Turbidity - - ~-- UV absorbance i 5.0

45 • • 4.5

40 , -o •

i
4.0

35 *"w'r* '*r-*~"eT*: " -*** -'*'* * ] ~ N . '• *4*. ~m " ' ~ '** ,.at ~,..~LJli*t,.~ • • 3.5

= 30 -" '~,I * . • • ..,,,..,t~.~..~_ ' 3.0>

25 ,e- o~l~jp, oO • .- - - . z - . . .~ • o -__o
• A .• . . . . . . r % h " ,,'~.""w',,;.
." "~
m
IT'-"'*¢***0" - " T i n • ° ° ° ° * ;) • "o" drl o- w . .... '••" "Irb'~" .i • • 2.5
Z

.z*=;- . , • "io. ".. 4,,, 2.0=

E 10 ~-
~- 1.0

,- --'M,L- i L . W, __

0 0.0

Date (mm/dd)

Fig. 5. Raw water characteristics during the test period (temperature,pH, turbidity and UV absorbance).
198 V. Bonn~lye et aL / Desalination 167 (2004) 191-200

Flotation survey
30 3.0

~FeCI 3 dosing rate x pH i

A 25 - - --*-Turbidity -0- UV absorbance L 2.5
L

I--
z

20
ti .°
15

ui
¢~
O1
E
~ ~o
t-
_ ~ v II I I Ill tr -.I 1.0
0
~ 5 0.5

F I ...... I t , , , t ...... +- ...... IO.O

~, ? _-- ~, ~, ? "7 "7,
¢~
o
©
v-
o~-, ov - =,r* .it-- .T-- ~-
~-
Date (mmldd)

Fig. 6. Floated water quality (coagulation using FeCI3).

Table 5 direct filtration and after coagulation-flotation.

SDI results The SDI measured in the permeate o f the two
membranes tested was similar for both applica-
SDI after pre-treatment Time, %
tions (direct filtration and after dissolved air
<3 100 flotation), and in the same range as the second
<2.7 85 stage filtered water. The SDI seems to be related
<2.5 65
<2.3 50 to the membrane porosity, the higher the cut off
the higher the SDI value (in 1-4 range value).

, ~.~7 Q~,~

I
Fig. 7. Direct filtration optimisation - -
head losses and SDI follow up during a
filtering run using pumice and sand me-
ta 20 2 2 ~
dia, coagulation with ferric chlorine asso-
Backwash & Filter run time (hour)
Filtered to waste ciated with a coagulant aid.
 V. Bonndlye et al. / Desalination 167 (2004) 191-200 199

40 . 2o

35
• --e-Sea ter •- 18
t] lst stage filtration i 16
3O I A 2nd stage filtration

~ 25
t" . . . . . ee -e - "eWe-e e~ 12~.
~ 2o ~ . ' .
"~' • O° •
.. o
•
- .
--
•
|
g) is -" .': -- : - - • • --@ "-. : : = -- -T
• • n Q 04
• • " • °° • "• . . • e• [] a •'°%[] 16
lO

5
2

o I I I I-0
o

o 8 o
Date (mmmldd)
Fig. 8. SDI value in the raw water in each of the dual media filtered water.

High filtration flux was obtained on the thracite as top layer media). The coagulation strategy
pressurized in-out Aquasource membranes, what- optimised during the pilot test includes a double
ever the feed water quality (120-140 L/h/m: in coagulant injection during the worst period (SDI
dead-end filtration). higher than 8) and adapted coagulation pH to the
fouling tendency of the ferric hydroxide formed.
In the case of more degraded water, with a high
4. Discussion
water quality variability expected, and to face
The two seawaters tested can be characterised pollution events (in terms of turbidity, algae bloom
by a low turbidity and low organic content: the or hydrocarbons), the association of dissolved air
main differences observed during the pilot studies flotation with double direct filtration gives a very
are the SDI value range and variability (Fig. 9). efficient and reliable pre-treatment upstream
The Persian Gulf surface water has a high and reverse osmosis: the treatment line is more robust
unstable SDI. Some very high turbidity peaks, and and able to handle very bad water quality. In this
some hydrocarbon pollutions are also reported. case again, filter's media and coagulation chemicals
The pre-treatment must be adapted to the surface and conditions must be optimised to reach low
seawater characteristics, and must be able to face and steady SDI in the filtered water. Alternative
the degraded periods. clarification treatment using membranes (ultra-
A single stage direct filtration using dual media filtration or microfiltration) gives similar treated
is well adapted to the good surface seawater en- water quality. The remaining question being the
countered in the Gulf of • m a n . In this case, the SDI adaptation to characterise the fouling potential
filtration media must be selected to optimise both of a permeated water.
filtered water quality (using a low effective size sand These very good values on both conventional
or garnet) and filtration duration (pumice or an- and membrane treatments should result in both
200 E Bonndlye et al. / Desalination 167 (2004) 191-200
50
45 k
40
35
~. 30
•-~ : • ~
otq . . . . i" ~ i .~.l .... i ....
0 0.5 1 1.5 2 2.5
Fig. 9. Comparison o f the Gulf o f Oman and the Persian Gulf water qualities.
low cartridge consumption and long time between
cleanings, then long expected life of the reverse
osmosis membranes.
5. Conclusion
The pilot testing during 9 months on the Gulf
of Oman, which was paramount to optimise the
pre-treatment stage and the chemical regime in
relation to the seawater quality improves the
optimisation of the process. The results were used
for the commissioning of the full industrial plant,
a 37.5 MGD open seawater intake desalination
plant located in Fujairah. Preliminary full-scale
plant results demonstrate that the foreseen per-
formance and water quality are being achieved.
In the Persian Gulf, on a rather bad surface
seawater intake, the pre-treatment including
dissolved air flotation, direct filtration or ultra-
filtration, gives good results in terms of turbidity,
algae and hydrocarbon removal, leading to a
reliable SDI far bellow 3 value.
These pilot tests improve the knowledge of
surface seawater treatment upstream RO and
a
•
• Persian Gulf • Gulf of Oman
r ..i
3 3.5 4 4.5 5
Turbidity (NTU)
demonstrate the reliability and robustness of such
treatment facing variable surface seawater.
References
[ 1] M.A. Galloway and J.G Minnery, Ultrafiltration as pre-
treatment to seawater reverse osmosis, Proc. 2001
AWWA Membrane Conference, San Antonio, TX,
2001, 10 p.
[2] N. Wade and K. Callister, Desalination: the state of
art, J. CIWEM, 11 April (1997) 87-97.
[3] M. Wilfand M.K. Schierach, Improved performance
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pretreatment, Desalination, 135 (2001) 61--68.
[4] S.C.J.M. van Hoof, A. Hashim and A.J. Kordes, The
effect of ultrafiltration as pretreatment to reverse
osmosis in wastewater reuse and seawater desalination
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[5] A. Teuler, K. Glucina and J.M. Laln6, Assessment of
UF pretreatment prior RO membranes for seawater
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[6] V. Borm61ye, A. Brehant, M.A. Sanz and M. Perez,
Surface seawater pre-treatment upstream reverse
osmosis: long term test using ultrafiltmtion membranes,
Proc. IDA World Congress, Nassau, Bahamas, Sept.
2003, 15 p.