### USCG STEP Environmental Assessment

SeaRiver STDN B alPure System STEP Application i 

# Environmental Assessment Review of the Application for Acceptance of the SeaRiver

Maritime Inc. S/R American Progress and Severn Trent de

Nora BalPure TM System into the Shipboard Technology Evaluation Program (STEP)

February 200 9

Prepared by Volpe Transportation Research Center for
U.S. Coast Guard

### USCG STEP Environmental Assessment

SeaRiver STDN B alPure System STEP Application ii 

## Table of Contents

1.0 Purpose and Need for Action

................................ ................................ ................................ ........ 1

- 1

1 .1 Introduction

................................ ................................ ................................ ............................... 1

- 1

1.2 Purpose and Need

................................ ................................ ................................ .................... 1

- 1

1.3 Background

................................ ................................ ................................ ............................... 1

- 2

1.4 PEA for STEP

................................ ................................ ................................ ........................... 1

- 2

1.5 Scope and Related Activities

................................ ................................ ................................ .... 1

- 3

2.0 Alternatives

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

- 1

2.1 Alternative 1: No Action Alternative

- Deny application

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

- 1

2.2 Alternative 2: Proposed Action Alternative

- Accept application

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

- 1

2.2.1 Typical Vessel Activities

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

- 2

2.2.2 Description of Technology

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

- 2

3.0 Affected Environment

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

- 1

3.1 Resources Dismissed from Further Consideration

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

- 1

3.2 Biological Resources

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

- 1

3.3 Water Quality

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

- 5

3.4 Public Health and Safety

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

- 5

4.0 Environmental Consequences

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

- 1

4.1 Biological Resources

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

- 1

4.1.1 No Action Alternative

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

- 1

4.1.2 Proposed Action A lternative

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

- 1

4.2 Water Quality

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

- 3

4.2.1 No Action Alternative

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

- 3

4.2.2 Proposed Action Alternative

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

- 3

4.3 Public Health and Safety

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

- 5

4.3.1 No Action Alternative

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

- 5

4.3.2 Proposed Action Alternative

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

- 5

5.0 Cumulative Impacts

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

- 1

5.1 No Action Alter native

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

- 1

5.2 Proposed Action Alternative

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

- 1

6.0 Comparison of the Alternatives and conclusion

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

- 1

6.1 Conclusion

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

- 1

7.0 References

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

- 1

8.0 Appendix A. Acronyms and Abbreviations

................................ ................................ .................... 8

- 1

9.0 Appendix B. Example of Section 7 Letter Sent to Resource Agencies.

................................ ...... 9

- 1

10.0 Appendix C. Correspondence Received Via Agency Consu ltation.

................................ .......... 10

- 1

11.0 Appendix D. State Listed Threatened, Endangered, and Rare Species (TPWD, 2008)

............ 11

- 1

12.0 Appendix E. Air Qua lity Analysis

................................ ................................ ................................ 12

- 1

13.0 Appendix F. Effluent Toxicity Test results

................................ ................................ .................. 13

- 1

14.0 Appendix G: Matrix of comments and responses

................................ ................................ ....... 14

- 1

15.0 Appendix H 

### : List of agencies and persons consulted

................................ ................................ . 15

- 1

### USCG STEP Environmental Assessment

SeaRiver STDN B alPure System STEP Application 1

- 1 

## 1.0 PURPOSE AND NEED FOR ACTION

1.1 Introduction

The U .S. Coast Guard (USCG) established the Shipboard Technology Evaluation Program (STEP) in 2004 (USCG 2004 a ). STEP was established to facilitate the development of prototype ballast water management (BW M ) systems for reducing nonindigenous species in ballast water . Under STEP, management system developer s acquire increased access to ships for purposes of testing prototype treatment systems . The vessel owners get assurances that prototype systems installed on their vessels will be deemed acceptable by the Coast Guard

, and the Coast Guard and the public ac quire rigorous and credible data on the actual performance of the prototype systems. While in STEP, owners are required to use the prototype treatment system as the primary method of BWM when operating in U.S. waters during the five year evaluation period . The applicants must monitor the engineering performance of the system and in all years submit detailed reports to the Coast Guard on the system performance and results of efficacy tests per the vessel’s study plan (USCG 2004 a ).

The USCG previously prepa red a Programmatic Environmental Assessment (PEA) (USCG 2004b) for the implementation of the USCG’s STEP. The STEP PEA, along with the Finding of No Significant Impact, was published in the Federal Register on December 8, 2004 (69 FR 71068) . This Environ mental

Assessment (EA) addresses the Coast Guard’s review of the SeaRiver Maritime

, Inc. (SeaRiver) application for inclusion in STEP for their vessel the S/R American Progress with the Severn Trent de Nora ( STDN ) BalPure TM BP

- 2000 treatment system

, and tie rs from the PEA

. T he PEA should be

consulted for additional background information, legislative history

, and detail on STEP 's goals and requirements as well as additional discussion of environmental and social impacts.

This EA was prepared in accordance w ith the Council on Environmental Quality’s (CEQ) Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act (NEPA), the Department of Homeland Security Management Directive 0023 .1, and the United States Coast Guard
Comm andant Instruction M 16475.1D. Specifically, this EA examines the probable environmental impacts of accepting the S/R American Progress with the STDN BalPure TM BP

- 2000 system into STEP, including the experimental test and evaluation of the routine operation of the sodium hypochlorite treatment system described in the application.



### 1.2 Purpose and Need

The purpose s of the action considered within this EA (accepting the S/R American Progress with the
STDN BalPure TM BP

- 2000 system into STEP)

, are to gain valuable s cientific information on the system’s efficacy and to facilitate the development of effective treatment technologies

.
The USCG is the lead Federal agency to prevent the introduction and spread of n on i ndigenous s pecies (NIS) from ballast water discharges in U.S. waters and from U.S. vessels worldwide. The USCG has recognized that alternatives to the existing approved procedures of 1) b allast w ater e xchange (BWE) and 2) r etention of ballast water could be useful to prevent the introduction and spread of NI S.

Participa nts in STEP, such as the S/R American Progress with the STDN BalPure TM BP

- 2000 system , will aid in fulfilling the need of the Coast Guard to develop and implement a BWM p rogram as directed by the National Invasive Species Act (NISA) of 1996 . Th e development of effective BW M technologies will create more options for vessel owners seeking to comply with NISA but having concerns about

, or limitations in

, the practicability of ballast water exchange ( BWE )

. I nformation gained through STEP will provi de scientific validation for new systems and aid in the deployment of effective and practicable BW M technologies

, which will result in reducing or eliminating ballast water as a source of further NIS

invasions.

### USCG STEP Environmental Assessment

SeaRiver STDN B alPure System STEP Application 1

- 2 

### 1.3 Background

The S/R American Progress is a U .S. flagged tankship measuring 183 m eter s in length and weighing 46,095 gross tons . It is operated by 18 crewmembers . It runs an ocean route carrying motor gasoline
from Texas to Florida

. R oundtrip voyage s usually last about 11 days, and occur year roun d

, approximately 30 times annually

. Cargo di scharge and ballast water loading take place primarily in Port Everglades, Florida at Port Everglades Municipal Berth s 7, 9, or 13. On occasion (approximately 1/year) the ship is diverted to Tampa, Florida wher e ballast is taken on at Kinder Morgan Industries Berth 226.

Th e ballast water taken on in Florida is then typically discharged in to the Sabine River at the ExxonMobil Refinery berth in Beaumont, Texas while the next cargo is loaded. On rare occasion s , c argo is loaded at the Port of Corpus Christi in Corpus Christi, Texas, in which case ballast water is discharged in to Corpus Christi Bay. T he vessel’s total ballast capacity is 20

, 277 metric tons ( MT ) ; however

, the average ballast

water load is 17,942 MT.

The STDN BalPure TM BP

- 2000 system is a two

- stage treatment process that uses sodium hypochlorite (NaCl O ) in the treatment of ballast water. The biocide treatment is referred to as s tage one in the SeaRiver STEP application and is the disinfectant phase c onduct ed during the loading of ballast water

. Sodium hypochlorite is generated onsite by means of electrolysis of seawater. The hypochlorite flows to the main ballast line and is injected just prior to the first ballast tank at a rate of 938 lbs ( 426 kg ) per day of equivalent chlorine. Once in the ballast water , the hypochlorite undergoes further reaction with the chemical constituents in seawater, resulting in several halogenated compounds , including hypochlorous acid, hypobromous acid, chloroform and b romoform. These are referred to collectively as “total residual oxidants” (TRO). Sta g e two

, the neutralization of the TRO chemicals prior to the ballast water’s discharge from the ship , is accomplished by injection of sodium bisulfite as the water is dis charged from the ship

.

Pilot data indica te s that organic matter (total organic carbon [ TOC ] ) in the ballast water will react with the injected hypochlorite to form t rihalomethanes (THMs) and some h alo a cetic a cids (HAA5)

, but no

measurable bromates or chl orates. Further study on the fate of these byproducts is part of the testing

program. The USCG’s STEP testing requirements are fully described in the PEA and consist of three challenge experiments in the first year of operation and one primary experiment in the fifth year of operation. The purpose of the experiments is to analyze ballast water and the entrained organisms,
before and after treatment

, and compare treated to untreated ( control ) water taken up at the same time,

location

, and using the same pumping method to determine treatmen t system efficacy. Finally

, if the vessel is accepted into STEP

, the treatment system will be used for all ballast water management in the covered ports.



### 1.4 PEA for STEP

The PEA examined the reasonably foreseeable conseque nces that could result from the implementation of the program as a whole. It considered the potential environmental impacts for all vessels using unique experimental technologies to control ballast water

- mediated invasive species introductions.

The mai n conclusions of that analysis were that STEP participation would not represent significant environmental impacts because:

a very small number of ships relative to the total number calling on the U.S. would be involved in STEP, so any possible impacts wo uld be very small;

a treatment system passing the STEP acceptance criteria would likely provide greater protection
from NIS than does BWE, since the efficacy of exchange may be quite low under many circumstances, and may not be possible in some cases due to voyage and safety constraints. In such cases, current regulations allow for discharge of ballast water with no management for invasive species and;

there is a benefit from having considerable data to validate and verify BW M S efficacy and impacts.

### USCG STEP Environmental Assessment

SeaRiver STDN B alPure System STEP Application 1

- 3 The PEA also found that any impacts abroad would be in significant, due to the small number of vessels

involved

. T he Coast Guard’s primary interest in STEP is to enroll only those vessels that discharge ballast water in U.S. ports. Therefore

, an evaluation of the vessel ’s application is made to verify that the ship’s practices are such that they have routinely brought ballast water to U.S. ports and discharge their ballast

water in a U.S. place coincident with cargo operations. Finally

, any STEP vessel would still be required to comply with all applicable foreign laws and regulations when operating abroad.

As described in the STEP PEA

, the experimental BW M S would be operated under two phases: an experimental period (year s one thr ough five ) and a monitoring p eriod (year six and beyond). During the experimental period, the BW M S would be closely evaluated as outlined in the applicant’s proposed study plan and the USCG’s STEP document titled “ Criteria and Conditions for Acceptance ” . The experimental period includ es the primary onboard biological experiments measuring the system’s actual performance.

During the monitoring period, the vessel must submit annual reports on the BW M S operations. During both periods, the experimental BW M S shall be the primary method of BWM. During the period in STEP

, the vessel shall comply with BWM regulations (33 Code of Federal Regulations [C FR ] 151 Subparts C and D) if the experimental BW M S is not in use. With the exception of the equivalencies outlined by the
Coast Guard ’s National Vessel Inspection Circular 01

- 04 ( NVIC ) on STEP , discharged ballast water must meet all other federal, state, local, and tribal environmental regulations (e.g., with respect to residual concentrations of any primary treatment chemicals, chemicals that occ ur as by

- products, or other water quality parameters of the discharged ballast water affected by the treatment process and any other water discharged by the vessel in conjunction with operation of the system ) (USCG 2004 a )

.



### 1.5 Scope and Related Activities

The STEP PEA established the need for site

- specific analyses for each of the applicants to the program

to ensure there would be no unacceptable localized impacts.

This analysis tiers off of the STEP PEA, considering the potential resource issues pertinent to the

treatment technology

, the vessel , and the service route being proposed.

This EA is vessel, treatment technology

, and route specific. Therefore any significant changes to operations (e.g., schedule changes involving new U.S. ports where treate d ballast water would be discharged, or changes in the engineering and operation of the BWM S ) would require revisions to the application, and a new review and approval decision by the USCG.SeaRiver STDN B alPure System

STEP Application 2

- 1 

## 2.0 ALTERNATIVES

The USCG has received an application to STEP from S eaRiver, and therefore must make a decision about whether to accept the vessel into STEP. For this decision, the USCG has two options to consider: grant or deny the S/R American Progress with the STDN BalPure TM system acceptance to the program.

This EA wi ll examine these two alternatives and their associated potential impacts. In the PEA for STEP, the USCG assessed three options: no action ; STEP as currently structured ; and testing BW M on federal vessels. Only the second option, STEP, was deemed appropri ate for accomplishing the needed facilitation of technology development. At the current stage, the decision before the USCG is whether to accept a specific combination of vessel, route, ballast water management system ( BW M S ) , and test plan
into STEP. At this stage, the only options are to accept or deny the application. If the test program proposed by the applicant were found to be unacceptable, the USCG would deny the application and inform the applicant of the reasons. The applicant would then have t he option of revising the application to address the concerns or deficiencies, and/or submitting a new application with a different treatment option.



### 2.1 Alternative 1 : No Action Alternative

- Deny application

Under the N o A ction A lternative, the S/R Americ an Progress with the STDN BalPure TM BP

- 2000 BWMS would continue to manage ballast water under the provisions of the current regulations. When moving between ports within the U.S. Exclusive Economic Zone ( EEZ ) , the current USCG regulation provides that

vess els are not required to conduct BWE. With the vessel’s current coastwise trade, there are no BWM requirements.

2.1.1 PROGRAMMATIC CONSEQUENCES

If the S/R American Progress with the STDN BalPure TM BP

- 2000 BWMS is denied entrance into STEP,
the USCG would miss the opportunity to acquire original scientific data on the performance of the prototype treatment system and on the practicability of the test methods under operational circumstances. With a denial of the application, the USCG would lose the opportu nity to gain information that would be critically important for establishing discharge standards and procedures for BWM S testing and approval. Further, the vendor would lose the opportunity to evaluate system performance when used consistently

under real operating conditions aboard a vessel.



### 2.2 Alternative 2 : Proposed Action Alternative

- Accept application

Under the proposed Action Alternative, the Coast Guard would accept the vessel into STEP. While participating in STEP, in addition to making the ship and BW M S available for initial and periodic physical inspections by USCG personnel, SeaRiver would submit to the USCG detailed annual reports on the performance of the manage ment system, including the results and interpretations of rigorous tests of syste m performance in reducing the concentration of living organisms and quality and quantity of

chemical residuals related to the treatment process in discharged ballast water

. In addition, during the first five years of STEP participation

, SeaRiver will subm it annual reports on the operation, maintenance,

and reliability of the BW M S

. The USCG would take this information into consideration during the development or refinement of regulations, policies, and procedures related to BWM strategies, requirements

, an d the regulatory program procedures for treatment system approval and compliance testing

.

As detailed in the PEA, a cceptance to STEP would grant the applicant equivalency to current (at the time of application) and future BWM regulations regarding managem ent practices for preventing the transportation of NIS in ballast water. The period of equivalency for the S/R American Progress with theSeaRiver STDN B alPure System

STEP Application 2

- 2 STDN BalPure TM BP

- 2000 system would be the life of the vessel or of the treatment system, whichever is shorter. Under this alternative, the vessel would be free to discharge ballast water treated by the experimental treatment system while operating in the ports noted in this EA. The actual amounts of ballast water taken on and treated and available for discharge would vary between zero and 20,277 MT depending on voyage

- specific cargo loading and unloading

, with an average of about 17,942 MT

.


### 2.2.1 Typical Vessel Activitie s

The S/R American Progress is a petroleum tankship which carries refined cargo from Texas, typically from the Port of Beaumont to Florida’s Port Everglades. Occasionally the vessel loads refined petroleum cargo in Corpus Christi , Texas and typically disc harge s it in Port Everglades. O ccasion al voyages are made between Texas and the Port of Tampa, Florida. In either case the vessel discharges cargo and loads sufficient ballast water, averaging about 17,942 MT

, in Florida to maintain safe trim while retur ning

to Texas without cargo

. The ballast water t aken on in Florida is t hen discharged in the place where the next cargo is loaded. On th e s e voyage s the vessel does not leave U.S. waters

, nor go beyond 200
nautical miles from shore

. T herefore

, it does no t conduct BWE and discharges untreated, unexchanged BW most frequently from Port Everglades into the Sabine River within the Port of Beaumont , TX

.

The ballast system on the S/R American Progress tankship consists of 12 tanks dedicated specifically to
ball ast. Loading of ballast is typically started once cargo discharge has begun at full rate. Ballast is loaded into each tank first by gravit y and then by us e of dedicated ballast pumps. Ballast may be used to

alter the vessel ’s position in the water to fa cilitate stripping and discharge of the cargo (i.e.

, the crew may induce an intentional list or trim to pool cargo residues near suction points in the bottoms of the cargo

tanks ). Ballast is typically loaded at the dock

, but ballast loading may continue d uring the transit to sea, as required by schedule and as allowed by weather. Ballast is loaded in Port Everglades, Florida at Municipal Berths #7, 9

, or 13. If the ship is diverted to Tampa, Florida

, then ballast is loaded at Kinder Morgan Industries Ber th #226. During primary treatment experiments all ballast and deballast operations will take place at the dock.

Otherwise, during normal ship operations, d ischarge of ballast may begin upon the ship’s approach to the

berth if convenient and in good weath er or may wait until the ship is tied to the loading dock. Discharge begins with gravitation (free flow) of ballast and is completed using the dedicated ballast pumps. Ballast is discharged in the Sabine River while alongside the ExxonMobil Refinery bert h in Beaumont, Texas.

Most b allast discharge is done at the dock coincident with cargo loading.



### 2.2.2 Description of Technology

The STDN BalPure TM BP

- 2000 system provides a n electrolytic process for the on

- site generation of oxidant solutions during ballastin g operations and the neutralization of residual oxidants during the

deballast ing operation. Sodium hypochlorite is generated by means of electrolysis of seawater. A small booster pump injects filtered s eawater, at a nominal flow rate of 60 gallons per mi nute ( gpm ), through the

e lectrolytic c ells ( e lectrolyzers)

, where it is subjected to medium amperage, low voltage direct current.

The system’s l ogic controller is designed to protect the e lectrolyzers from low flow, and will shut down the

electrical curre nt to the unit if the inlet flow to ballast water treatment e lectrolyzers falls below 48 gpm (80 percent of rated flow).

The electrical current passing through the seawater causes the dissolved salt (NaCl) and water (H 2 O ) to

form aqueous sodium hypochlor ite (NaCl O ) and gaseous hydrogen (H 2 ) as a by

- product. Sodium hypochlorite solution and h ydrogen are produced continuously and separated immediately upon exit from the electrolytic cell. The gaseous H 2 is drawn off via a dedicated venting system where it is diluted with pressurized air to below the flammable range and is then exhausted out of the ship. The generated

sodium hypochlorite solution ( at 1,000 parts per million ( ppm ) concentration ) flows to the main ballast line and is injected just prior to t he first ballast tank at a target dose rate of 15ppm of biocide

. The BalPure TM

BP

- 2000 system senses ballast water flow rate to vary hypochlorite production to maintain the target dose

rate needed for organism deactivation

. The system also checks for the required minimum e lectrolyzer
feed water chloride concentration of at least 1 9,000 ppm for optimum performance

. Insufficient chloride (which could occur during peak freshwater runoff periods ) will activate an alarm and the operator wouldSeaRiver STDN B alPure System

STEP Application 2

- 3 manually switch the fe ed water source to the aft peak tank

, which contains full strength sea wa ter carried specifically for this purpose

.

The TRO dose rate wa s implemented based upon extensive industrial experience sterilizing sea water as well as data from industrial laboratory studies. These two sources prescribe a concentration sufficient to

b oth instantaneously neutralize and to provide a residual treatment concentration sufficient to prevent any

re

- growth in stored ballast water.

The BalPure TM BP

- 2000 s ystem is designed to operate automatically. After the unit is energized, the system will sense when ballast water uptake begins. Then t he transformer/rectifier will supply DC current

to the e l ectrolyzer to begin produc ing oxidant. The oxidants will be injected into the main ballast line just prior to the first ballast tank. The system may a lso be activated manually

.

Gaseous h ydrogen produced in the electrolytic cell is immediately diluted with ambient air to less than 1 percent H 2 by redundant air blowers. A n H 2 sensor with alarm will be provided in the general work area.

A sail switch in the vent line confirms proper air flow is maintained and

, if not, the programmable logic

controller (PLC) interface will shut down the system and activate an alarm.

Prior to deballasting, the ship’s crew will perform chemical tests to verify the TRO le vel in the ballast water
stored on board. If tests show TRO levels to be o ut of expected ranges, the crew will take action to correct them. This may include, for example, circulating the water via ballast system in order to inject
additional disinfectant.

In the deballast mode of operation, the BalPure TM BP

- 2000 system measures the level of residual

disinfection chemical exiting the b allast t anks. Then liquid sodium bisulfite (NaHSO 3 ) will be metered into
the inlet of the deballast ing pump. With the turb ulent effect of the deballast ing pump and the discharge pipe, the sodium bisulfite will thoroughly mix with and neutralize the remaining 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

ensure the continued proper dosage of sodium bisulfite. The BP

- 2000 system suppl ies three tanks of

bisulfite and a common manifold line (suction side of metering pump), metering pump, chemical
disinfectant concentration analyzer, and PLC control and data logger. All measured hypochlorite levels during system operation will be recorded with date and time in the dat a logger. All measured bisulfite levels during deballast ing are also recorded with date and time in the data logger.

At the m aximum ballast water flow rates on the S/R American Progress (nearly 2,000 MT/hour), the

BalPure TM BP

- 2000 system requires 440 v olt / three phase service

. This power requirement does not result in up

- sizing the electrical generation plant or in significant changes in the way the ship’s power is managed.

Chemical R esiduals

For stage one, t he initi al target dose based on the laboratory tests for S/R American Progress is 15 ppm hypochlorite in the ballast tanks. This corresponds with an oxidation reduction potential ( ORP ) target of

>700mV. The hypochlorite immediately reacts with the bromides in th e seawater to form hypobromous acid, the actual primary oxidizing and disinfectant agent, which subsequently breaks down to form hypochlorous acid, hypobromous acid, chloride (referred to collectively as TRO) and other trace oxidants

. Th e target dosage is meant to ensure that a minimum TRO of 1 ppm residual is maintained in the ballast

tanks throughout a typical voyage

. The initial target dose will be adjusted based upon ballast water quality. Greater organic content in the ballasting source water requir es more disinfectant.

Stage two is the neutralization (de chlorination) of r esidual chlorine and other oxidants present in the

ballast tanks by injection of NaHSO 3 in the main ballast line just prior to discharge from the ship. Sodium

b isulfite addition is monitored and controlled to insure that a small residual concentration (<2 ppm) is present at discharge, indicating that complete neutralization of all disinfection chemicals has occurred in

the discharged ballast water.SeaRiver STDN B alPure System

STEP Application 2

- 4 Organic matter in the ballast water ( d issolved o rganic c arbon or t otal o rganic c arbon ) will react with the injected hypochlorite to form disinfection byproducts including THMs and HAA5 but no measurable

bromates or chlorates. Pilot data indicate that along with the above sodium bisulf ite residual, approximately 100 parts per billion ( ppb ) THMs and 20 ppb HAA5 will form for every 1 ppm TOC in the

b allast w ater ( Herwig et al., 2006)

.SeaRiver STDN B alPure System

STEP Application 3

- 1 

## 3.0 AFFECTED ENVIRONMENT

To u nderstand the potential environmental impacts of these alternatives, this chap ter describes the potentially affected environmental resources in their current condition. Based on this description of potentially affected aquatic ecosystems, the impacts of the alternatives are presented and compared in Chapter 4. Further detail on th e broader programmatic scale is in the STEP PEA.

The affected environment for this project is determined by the service of the vessel housing the proposed experimental BWM system . The S/R American Progress operates on a regular schedule , loading cargo

in Beaumont, Texas and discharging it in Port Everglades, Florida

. The vessel occasionally loads cargo in Corpus Christi, Texas and may occasionally divert offloading cargo in Tampa, Florida. The affected environments analyzed in this EA are the marine eco systems within the se relevant ports of Texas and
Florida. Since the S/R American Progress does not discharge ballast water in Port Everglades and Tampa, Florida, the only potentially affected resources discussed for these ports are public health and
safet y

.



### 3.1 Resources Dismissed from Further Consideration

There were several resources that were initially considered but dismissed from further analysis. After initial analysis it was determined that the following resources would not be affected and would not be
considered further in this EA:

transportation

infrastructure coastal barrier systems topography and floodplains geology and soil

cultural and historic resources air quality

The S/R American Progress is not expected to operate more frequently with th e BWM system installed. Thus, the proposed action should not have any effects on routes or frequency of transportation, or any relevant infrastructure. We expect no impact on coastal barrier systems because the action does not

involve increased vessel ac tivity and the treatment system is expected to have no impact on mechanisms that might affect coastal barriers . As the Proposed Action deals solely with a vessel, no effects on land resources, including floodplains or soils

, are expected. There are no vu lnerable historic properties (e.g., shipwrecks) located in the potentially affected port areas. The BWM system is not expected to have a n effect on the vessel’s electrical service capacity

, and therefore its usage will not result in any additional

vessel emissions. Additionally, the only emission from the BWM system itself is hydrogen gas (H 2 )

, a byproduct of the electrolytic generation of chlorine from seawater

. The system will only be activated at ballast loading ports (in Florida). The public health an d safety aspect of hydrogen gas is addressed in
Section 4.3 of this EA.



### 3.2 Biological Resources

This section presents information on the specific characteristics of the biological resources in the potentially

- affected aquatic ecosystems. For information on the general characteristics and biological organisms of U.S. aquatic ecosystems, general NIS impacts, and relevant regulatory background, refer to
the STEP P EA.SeaRiver STDN B alPure System

STEP Application 3

- 2 Ballast water discharge from the S/R American Progress occurs in the Port s of Beaumont and Co rpus Christi, Texas. The Port of Beaumont is located in Jefferson County and is accessible fro m the Gulf of Mexico and Intracoastal Waterway via the federally maintained Sabine

- Neches Ship Channel (Port of Beaumont, 2008) . The Port of Corpus Christi is l ocated within Corpus Christi Bay in Nueces County and lies adjacent to the mouth of the Nueces river. The Port connects with the Gulf Intracoastal Waterway via the Corpus Chr isti Ship Channel

. Continuous with Corpus Christi Bay and approximately 5 miles south of

the Corpus Christi Ship Channel is the Laguna Madre

, a large body of shallow water separating Padre
Island from the South Texas mainland. The Laguna Madre is one of only five hyper

- saline lagoons in the

world , making it an important natural resou rce in Texas (T exas P arks and W ildlife D epartment (TPWD)

, 2007 a )

. The descriptions in the subsections below are for both the Port of Beaumont and the Port of Corpus Christi since the ports are very similar biologically.

Plants and Wetlands

According to a 1992 estimate , Texas has approximately 3,894,753 acres of coastal wetlands. Between 1955 and 1992, Texas sustained an estimated net loss of 210,950 acres of coastal wetlands. However,

t his es timate did not take in to consideration wetlands ’ functional qua lity, and functional losses are believed to be much greater. The primary threats to Texas coastal wetlands are agriculture, development, and invasive species (TGLO , 2002 )

.

Wind

- tidal flats and salt marshes are the dominant types of emergent coastal wetl ands in Texas, salt marshes being dominant in the northern part and wind

- tidal flats becoming dominant south of Corpus
Christi. The wind

- tidal flats function as essential habitat for the endangered piping plover and peregrine falcon, among many other bird s (Onuf, 2006)

.

One dramatic example of wetlands destruction resulting from land

- use changes has been the loss of shoal grass ( Halodule wrightii ) in the Lower Laguna Madre. Between 1965 and 1998, there was an estimated 60 percent reduction in shoal grass beds in this water body. Studies attribute the loss of sea grasses to suspension of fine

- particle sediment caused by the dredging of the Gulf Intracoastal Waterway (Moulton et al., 1997)

.

Fish and Invertebrates

Approximately 624 miles of Texas coastline borders the Gulf of Mexico. There are over 600 species of

marine fish , 250 species of marine invertebrates, and 33 species of coral in the coast al waters of Texas (National Biological Information Infrastructure, 2007). This diverse group includes bony fi sh and cartilaginous fish such as sharks, skates, and rays that live in a variety of habitats including sandy bottoms, open water, and coral and rocky reefs. In addition to the corals, invertebrates include sponges, sea urchins, oysters, lobsters, snails, octopus, shrimp, and jellyfish species

.

Commercial fishing in Texas is almost exclusively a saltwater business. Texas commercial fishery landings were valued at more than $209 million in 1998, with oysters ( Crassostrea virginica )

, blue crab ( Callinecte s sapidus ) , black drum ( Pogonias cromis )

, brown shrimp ( Penaeus aztecus) , and red snapper ( Lutjanus campechanus) being the most economically important

.

Recreational inshore fishing in Texas targets red drum ( Sciaenops ocellatus) , spotted seatrout ( Cynos cion nebulosus ) , and southern flounder ( Paralichthys lethostigma)

. The Coastal Conservation Association and Central Power and Light Company Marine Development Center in Corpus Christi produces red drum and spotted sea trout for releasing into Texas bays ( TPWD , 2007 b ).SeaRiver STDN B alPure System

STEP Application 3

- 3 Plankton in the Nueces Estuary was studied from September 1987 through October 1988 to ascertain pattern s of biomass and abundance of microzooplankton and mesozooplankton. Microzooplankton (20

– 200 μm in length) were extremely abundant throu ghout the study. Abundances of ciliates (including both

aloricate ciliates and tintinnids) ranged from 5,000 to 400,000 per liter, with a mean of 38,000 per liter of

seawater over the entire course of the study. Mesozooplankton (200

– 2,000 μm in length) abu ndance averaged 6,100 per cubic meter for samples collected during the day and 10,100 per cubic meter for samples collected at night. Mesozooplankton were dominated by Acartia tonsa which made up approximately 50 percent of the total. Biomass estimates for microzooplankton (based on volume estimates) were often higher than measured biomass of mesozooplankton (Buskey, 1993).

Laguna Madre experienced a dense, persistent brown tide algal bloom from 1990 to 1997, of the newly

identified species Aureoumbra lag unensis . This bloom was maintained for this length of time due most likely to the hypersaline conditions of Laguna Madre and the long turnover time (approximately one year) for the lagoon waters. The bloom often reduced water clarity, which reduced seagr ass extent, and also reduced the biomass and diversity of planktonic and benthic grazers on phytoplankton (Buskey et al., 1998).

Coral Reefs

No coral reef species are found near the Port s of Beaumont or Corpus Christi ( National Ocean ic and Atmospheric Administration ( NOAA ) , 2002). The Flower Garden Banks

, which have numerous coral types

, are designated as a protected national marine sanctuary . They are located on the edge of the outer continental shelf in the northwestern Gulf of Mexico, approximatel y 192 km southeast of Galveston,

Texas.

Wildlife

More than 600 species of birds have been recorded in Texas , and half of these species are migratory. Texas is located within the central migratory bird flyway , which is composed of ten states

, including

M ontana and North Dakota to the north and extending south through New Mexico

. Of the 338 species

listed as Nea ra rctic

- Neotropical migrants in North America, 333 of them have been recorded in Texas ( Shackelford et al

. , 2005 ). Typical birdlife associated wi th the marshy and coastal areas of Texas

include s laughing gulls ( Larus atricilla ), boat

- tailed grackles ( Quiscalus major ), killdeer ( Charadrius

vociferus ), great blue herons ( Ardea herodias ), cattle egrets ( Bubulcus ibis ), great egrets ( Ardea alba ),

snowy egrets ( Egretta thula ), American coots ( Fulica americana ), brown pelicans ( Pelecanus

occidentalis ), mottled ducks ( Anas fulvigula ), and several species of plovers and sandpipers (Graber, 1992).

The McFaddin and Texas Point National Wildlife Refuges are located approximately 30 to 33 miles south
of the Port of Beaumont

, off of Highway 87 . The J

. D

. Mur phree Wildlife Management area is located within Port Arthur, Texas and is approximately 21 miles south of the P ort of Beaumont . These refuges supply impo rtant feeding and resting habitat for migrating and wintering populations of waterfowl using the central flyway. McFaddin has one of the highest densities of American alligators found in the state of

Texas ( US FWS, 2007)

. The coastal marshes and estuaries within the refuges serve as nursery areas for many important commercial and recreational fish and shellfish species including red drum, flounder, speckled trout, white and brown shrimp, and blue crab (TPWD, 2007 c ).

Padre Island National Seashore (PINS) i s located approximately 26 miles south of the Port of Corpus Christi, and the Aransas National Wildlife Refuge is located approximately 67 miles north. Both refuges provide habitat for large numbers of migratory birds and other wildlife. PINS is the most important nesting
beach in the U.S. for the endangered Kemp’s ridley sea turtle ( Lepidochelys kempii ) , and is also an important nesting site for four other threatened and endangered sea turtle species : loggerhead ( Caretta

caretta ), leatherback ( Dermochely s coriacea ), hawksbill ( Eretmochelys imbricat a ), and green ( CheloniaSeaRiver STDN B alPure System

STEP Application 3

- 4 mydas ) sea turtles

. The Aransas National Wildlife Refuge is the winter home for the endangered

w hooping c rane ( Grus americana ) (PINS, 2008 )

. Threatened and Endangered Species

The USFWS T hreatened and Endangered Species System internet database and the TPWD Lists of Rare Species database (TPWD, 2008) were reviewed to determine if any federally listed endangered, threatened, or candidate species could occur in the project area s . The USFWS database search
identified five listed animal species with the potential to occur in Jefferson County , near the Port of

Beaumont . These species include brown pelican, piping plover ( Charadrius melodus ), the green sea turtle, Kemp’s ridley sea turtle

, and loggerhead sea turtle.

In Nueces County, near the Port of Corpus Christi, t he USFWS database identified 13 listed animal and

two listed plant species with the potential to occur in Nueces County. Animal species include the brown pelican, piping plover, whooping crane, the green sea turtle, Kemp’s ridley sea turtle, Hawksbill sea turtle, leatherback sea turtle, Gulf coast jaguarondi ( Herpailurus yagouaroundi cacomitli ), ocelot ( Leopardus pardalis ), and West Indian manatee ( Trichechus manatus ). Plant spe cies include the slender rushpea ( Hoffmannseggia tenella ) and the South Texas ambrosia ( Ambrosia cheiranthifolia ). The USFWS has provided a list of potentially affected species in the project area

, which has been included in Appendix C.

The TPWD databa se indicates that 49 species listed by the state as threatened, endangered

, or rare have the potential to occur in Jefferson County. There are 46 state

- listed species in Nueces County. A complete list of these species is provided in Appendix D

. The habi tat in and adjacent to the project areas provides suitable habitat for the brown pelican, green sea turtle, Kemp’s ridley sea turtle, Hawksbill sea turtle, and leatherback sea turtle. No potentially suitable habitat occurs for other federal or state liste d species in the area.

Essential Fish Habitat

The Gulf of Mexico Fishery Management Council (GMFMC) has designated essential fish habitat (EFH) for 26 species of fish and coral complexes (NMFS, 2007)

. EFH is defined as “those waters and substrate

neces sary to fish for spawning, breeding, feeding, or growth to maturity” ( GMFMC, 1998). S pecies a long

the Texas coast include red drum, gray snapper ( Lutjanus griseus ) , Gulf stone crab ( Menippe adina )

, spiny lobster ( Panulirus sp. ) , stone crab ( Menippe merce naria )

, brown shrimp, white shrimp ( Penaeus
setiferus ) , pink shrimp ( Penaeus duorarum ) , and Spanish mackerel ( Scomberomorus maculates ) . Other managed species typically not found in estuarine environments but found within State waters (out to 9
nautical mi les) include bluefish ( Pomatomus saltatrix ) , dolphin ( Coryphaena hippurus ) , cobia ( Rachycentron canadum ) , king mackerel ( Scomberomorus cavalla ) , little tunny ( Euthynnus alletteratus )

, lane snapper ( Lutjanus synagris ) , vermillion snapper ( Rhomboplites auro rubens ) , and red snapper.

The project areas are located within or are adjacent to areas identified as EFH for post

- larval, juvenile,

and sub

- adult life stages of red drum, Gulf stone crab, brown shrimp, white shrimp, pink shrimp, and Spanish mackerel. Detailed information on f ederally managed fisheries and their EFH is provided in the 1998 generic amendment of the Fishery Management Plans for the Gulf of Mexico prepared by the
GMFMC. The EFH designations for those species generally include all estuarin e waters of the Gulf of

Mexico from Florida to Texas.

Nonindigenous Species

According to the USGS Nonindigenous Aquatic Species Database, 160 species of aquatic animals and 27 species of aquatic plants have been introduced into Texas. Of these species, 92 are considered exotic and 40 are classified as being marine at some point during their life cycle. A total of 15 aquatic animal and plant species (13 NIS ) have been introduced into Jefferson County. A total of 6 species (3
NIS ) have been introduced into Nueces County.SeaRiver STDN B alPure System

STEP Application 3

- 5 For purposes of this EA, Florida is the source water for all ballast water discharges into the ports of Beaumont and Corpus Christi, Texas, and is host to a wide variety of NIS. According to state and

national web sites

, at least three pl ant species, 32 fish species, 37 invertebrate species and two disease organisms have been introduced into Florida’s marine waters (USGS

, 2007

, and FLFWCC

, 2007). However, ongoing work by the Smithsonian Environmental Research Center is providing strong

in dications that the number of introduced aquatic species is likely to be much greater (Ruiz

, 2007). The introduction of nonindigenous species into southern Florida began in the late 1800s and has been an on

going problem since.



### 3.3 Water Quality

The Sabine R iver Basin is relatively long and narrow, with a length of approximately 300 miles and a maximum width of approximately 48 miles. At the point where it becomes the state line, the Sabine River drains an area of approximately 4,846 square miles. The lower b asin or state line portion has a contributing area of some 4,910 square miles , of which approximately 2,550 square miles lie within Texas (Sabine River Authority of Texas, 1996). The Sabine River Basin is organized into seven reaches based

on sub

- watersh eds . The Port of Beaumont is located within Reach 1 , which includes the Sabine River

and its drainage from Sabine River Confluence into Sabine Lake to Morgan’s Bluff in Orange County,

Texas. Since 2006 , the Sabine River Tidal (from the confluence of Sabi ne Lake to West Bluff in Orange County, Texas) has been listed as Category 5c due to elevated levels of bacteria

, under Section 303( d ) of
the Clean Water Act ( Texas Commission on Environmental Quality ( TCEQ ) , 200 4 ).

The Sabine River & Lake System is one o f the largest petrochemical producing complexes in Texas and

both industrial , municipal and domestic wastewaters are discharged into the system

. Water quality and aquatic health in Sabine Lake ha ve improved since passage of the Clean Water Act in 1972 and subsequent regulations. Threats to the system include industrial and commercial development along the shoreline, operation of petroleum and chemical plants

, and general non

- point source pollution primarily from agricultural lands. Gulf waters and tidal s treams experience low oxygen levels caused by significant
increases in sediment carried in surface run

- off following tropical storms. Other threats include the

maintenance dredging of the Sabine

- Neches Waterway, increasing salinities that damage wetland

h abitats and the NIS plants that clog tidal streams and channels (TPWD, 2005).

The Port of Corpus Christi is located near Corpus Christi Bay , in a semi

- arid region in the southern Texas Coastal Bend. The Nueces River and Oso Bay are the only sources of fr eshwater drainage to Corpus Christi Bay. The state of Texas currently lists Oso Creek and Oso Bay as an impaired water body due to depressed dissolved oxygen and elevated bacteria counts

. Portions of Corpus Christi Bay were recently

included i n the 2008 Texas 303(d) List , also for bacteria (USEPA, 2008 c )

.

Information on background levels of disinfection by

- products or existing wastewater permits to discharge

chemicals similar to those potentially discharged by the STDN BalPure TM BP

- 2000 system as install ed on
the S/R American Progress in the Port of Corpus Christi and the Port of Beaumont receiving waters was not readily available

. However, because of the numerous industrial and municipal wastewater treatment

facilities located on the rivers

, existing (a mbient) levels are expected to be high

.



### 3.4 Public Health and Safety

The relevant geographic scope of the p roposed a ction with regard to public health and safety is onboard the ship and within the port facilities themselves and their immediate environs. It does not include surrounding public spaces and buildings, residential areas, or businesses. The ports themselves areSeaRiver STDN B alPure System

STEP Application 3

- 6 industrialized areas, and only appropriately authorized and trained personnel have general access. The

BW M system is constructed in accor dance with applicable codes for shipboard machinery, electrical

installation

, and containing chemical processes and storage , and has been assessed by the U.S. Coast
Guard and an independent classification society for conformance to these codes. The system is installed by STDN personnel and maintained by both STDN personnel and the ship ’ s crew. While ballasting operation s may last many hour s, BWM S operation is automatic and the crew’s attention will normally be required for only about one hour per ballast cycle

. The system is self

- monitoring and includes alarms and automatic shutdowns for all critical operating parameters. In addition, generated hydrogen and sodium
bisulfite fumes are vented away from areas used by the crew. Therefore little crew contact with the equipment or associated chemicals is likely and when such proximity is required, the crew will have the applicable level of safety protection as with all other ship ’ s machinery installations.SeaRiver STDN B alPure System

STEP Application 4

- 1 

## 4.0 ENVIRONMENTAL CONSEQ UENCES

The following discussio n of potential environmental consequences focuses on the two locations in Texas where treated ballast water would be discharged by the S/R American Progress : the Port of Beaumont

and the Port of Corpus Christi. The vessel does not discharge ballast water in Port Everglades or Tampa,

Florida

. T herefore the discussion of potential environmental consequences for these ports is limi ted to public health and safety related to the use of the BWM S in treating ballast water during uptake

.



### 4.1 Biological Resources

4.1.1 No Action Alternative

Under the No Action Alternative, the S/R American Progress with the STDN BalPure TM BP

- 2000 system would not be admitted to the program. The vessel could continue to test or operate the experimental technology as a private action. Howe ver, the S/R American Progress would not be granted equivalency

to current and future BWM re quirement s , and therefore would be required to comply with such BW M requirements, and any applicable future Coast Guard regulations. Therefore, if the S/R American Progress is not accepted into STEP, and not granted an equivalency for using the STDN BalPure TM BP

2000 system , the vessel would continue to manage ballast water as it does currently. Because the S/R American Progress remains within 200 miles of the U.S. coast at all times in its voyage, it does not conduct ballast water exchange and therefore always discharges untreated, un

- exchanged ballast in the cargo loading port areas. Consequently, a small but real potential exists that transportation of NIS by th e S/R American Prog r

ess is possible

, although the specific risk is difficult to quantify for any single ship.



### 4.1.2 Proposed Action Alternative

Under the Proposed Action, the S/R American Progress with the STDN BalPure TM BP

- 2000 system would
be admitted to STEP , and use of the system would be granted equivalency for applicable future USCG BWM regulations. The BW M system would process all ballast water taken on and discharged by the ship. All discharged water would be treated rather than exchanged or unmanaged

. The greatest po tential impact to biological resources occur s from exposure to any disinfection byproducts

rema ining in ballast water discharged into the Ports of Beaumont and Corpus Christi, Texas. These disinfection byproducts include THMs and HAA5 at l evels that depend on the TOC concentration in the incoming ballast water and hypochlorite dosage. Pilot data indicate approximately 100 ppb THMs and 20 ppb HAA5 will form for every 1 ppm TOC in the ballast water. Chloroform in water has moderate acute

an d chr onic toxicity to aquatic life. It is non

- persistent in natural waters with a half

- life of less than two days. Chloroform can cause damage to various plants including brittleness in roots and chromosomal damage. No data are available on the short

- term or long

- term effects of chloroform on birds or land

animals. Chloroform and other THMs are considered human carcinogens and the U.S. EPA has established a limit of 80 ppb concentration of THMs in discharges of treated effluent.

The potential impacts from the discharge of these substances would possibly be acute toxicity to the planktonic community in the immediate vicinity of the ship during ballast water discharge and possib ly plankton

- consuming fish in the near vicinity of the vessel during discharges. Appendix F contains preliminary toxicity results. Birds would be affected indirectly through any change (potential decline) in their food supply (plankton dependent fish).

As with the previous STEP enrollments, t he USCG conducted informal consultation with the USFWS and the NMFS to determine if implementing the subject BWMS could potentially harm aquatic organisms as well as threatened and endangered species. Responses received concerning the S/R AmericanSeaRiver STDN B alPure System

STEP Application 4

- 2 Progress from the consulted agencies matched th eir previous support for acceptance of vessels into STEP and conduct of demonstration pilot tests. (see appendix C)

Their evaluation and conclusions have been based on the University of Washington pilot study report (Herwig et al., 2006) that, for an in itial T OC concentration of 0.8 ppm and residual chlorine concentration of 3.71 ppm, the concentration of THMs and HAA5s were 69.5 ppb and 1.8 ppb , respectively. Few marine surface water criteria exist for THMs and HAA5s. For human consumption of fish, Te xas lists marine surface water quality criteria of 861 ppb and 47.7 ppb for chloroform and dibromochloromethane (TCEQ, 2000), respectively, although these THMs have not been detected as byproducts of the treatment system . M aximum contaminant levels (MCL) b ased on drinking water standards for THMs and HAA5s are 80 ppb and 60 ppb

, respectively. For an initial TOC concentration of 2.1 ppm and residual chlorine concentration of 3.6 ppm, the concentration of THMs and HAA5s were 131.5 ppb (above drinking water

M CL) and 28.3 ppb (below drinking water MCL), respectively.

While drinking water quality standards are not written to be protective of marine life, there are no other related discharge standards for seawater discharged into the marine environment. Thus the MCL are used here as a benchmark safety standard only. Although r esults from full scale studies indicated a higher concentration of THMs and HAA5 , t his was mainly due to the extremely high levels of TOC (11.48 ppm) that were artificially created in th e challenge water that required a high concentration of chlorine

residual to be maintained. Since actual TOC levels in ballast water are expected to be much lower (in Port Everglades, where loading of ballast would occur, TOC is typically between 0.33 ppm and 7.28 ppm, with an average of 3.60 ppm [EPA

, 2008a] ) , formation of these chemicals will typically be at lower levels (it should be noted that TOC will be monitored in influent ballast water to provide an indication of

THM /HAA5 formation )

. C oncentration s of THMs and HAA5 should also decline rapidly in the receiving

waters due to dilution

. Limited information on natural degradation is available, but this pathway is not expected to be significant. For dibromo chloro methane, for example, the hydroly t ic half

- life is 274 years (ATSDR, 2005)

.

Aquatic organism toxicity information for THMs and HAA5s is limited, but the available data suggest that the expected concentrations on discharge are likely to be below levels associated with significant toxicity.

T he T e xas Natural Resources Conservation Council (T NRCC 2001 , now known as the TCEQ ) posted ecological surface water benchmarks for THMs rang ing from 257 ppb for chlorodibromomethane in freshwater to 4,320 ppb for bromodichloromethane in freshwater. Marine benc hmarks a re not availa ble for some THMs, but concentration levels of concern are assum ed to be similar to or higher than
freshwater values

, e.g., t ribromomethane has a freshwater value of 149 ppb and a marine value of 1,220 ppb

. The EPA

- compiled toxicity l evels (LC50) for HAA5 chemicals range from 1,500 ppb for 24

- hour exposure of trichloroacetic acid to the fairy shrimp ( Streptocephalus proboscideus ) to 23,000 ppb for 96

- hour dichloroacetic acid exposure to harpacticoid copepod ( Nitocra spinipes ) (EPA

, 200 8 b ).

Toxicity tests were conducted by Herwig et al. (200 6 ) to study the toxicity of the residual sodium bisulfite to aquatic species. These tests were a part of the pilot study conducted at the USGS Marrowstone Marine Station to test the efficacy of the STDN BalPure TM BP

- 2000 system. Results of these tests suggested that seawater dechlorinated with sodium bisulfite was no t toxic to the test organisms (mesozooplankton) in a 24

- h ou r exposure. Chronic toxicity tests using ballast water samples treated by
S TDN’s BalPure TM BP

- 2000 system during pilot studies were conducted by the University of Washington (Nautilus

, 2005)

. Results of the toxicity tests indicated that the residual sodium bisulfite in the treated

ballast water (a typical concentration of residu al sodium bisulfite in the treated ballast water is 2 ppm ) did not cause any statistically significant adverse effects on the tested species after seven days of exposure.
The STDN BalPure TM BP

- 2000 system also has a monitoring system to measure and contro l the doses of

sodium bisulfite and prevent discharges of excessive bisulfite concentrations.

The Laguna Madre is located approximately 5 miles south of the Corpus Christi Ship Channel. Stetson Bank is the nearest coral reef system to the Port of Beaumon t and is located approximately 162 km south
of the Texas

- Louisiana border. Because of the rapid dilution and environmental degradation of the potential disinfection byproducts discharged with the treated ballast water, b oth of these protectedSeaRiver STDN B alPure System

STEP Application 4

- 3 biological r esources are far enough away not to be impacted by water quality changes as a result of the
use of the STDN BalPure TM BP

- 2000 system as proposed above on the S/R American Progress

.

Overall, it is expected that the potential biological impacts associated with the S/R American Progress , as a result of exposure and toxicity of disinfection byproducts remaining in the treated discharge water, will be negligible.

Additionally, t his alternative would reduce the chance of a release of nonindigenous organisms i n ballast water discharge d from the S/R American Progress

, since the existing rules allow for the release of

untreated and un

- exchanged ballast water in cargo loading port areas under all of the vessel’s voyage

scenarios . Use of the system should be much more effective in reducing the delivery of viable nonindigenous species relative to repeated releases of untreated water from the same source in Florida,

and is likely to reduce the probabilit y of establishing a nonindigenous species in Texas’ waters.



### 4.2 Wat er Quality

4.2.1 No Action Alternative

Under the No Action Alternative the S/R American Progress with the STDN BalPure TM BP

- 2000 system would not be accepted in to STEP and would continue to be required to comply with current and future
Coast Guard ballast water management regulations. Therefore, under the No Action Alternative, the practices of the S/R American Progress would be expected to remain unchanged . T he S/R American Progress would continue to discharge untreated, un

- exchanged ballast into Texas’ waters from t he same source in Florida, significantly increasing the risk of introducing NIS to Sabine and Corpus Christi Bay systems

. This would be expected to have potential moderate adverse impacts on water quality.



### 4.2.2 Proposed Action Alternative

In the Texa s ports (Beaumont and Corpus Christi), organic matter discharged with ballast should not increase the input that would have occurred without the implementation of the BWM S. Rather, the killing of various species, and their degradation in the ballast tanks during transit may

, as a result of settling, net a lower organic matter load at discharge. Since the STDN BalPure TM BP

- 2000 s ystem does not significantly affect the t otal s uspended s olids, pH, and temperature , these parameters sh ould remain unchanged dur ing the course of treatment

.

As discussed, t he STDN BalPure TM BP

- 2000 system will discharge a small quantity of sodium bisulfite

and disinfection byproducts

, including THM s and HAA5

. L evels of all of these chemicals in the discharged water will be neglig ible, and concentrations should decline rapidly in the highly industrialized receiving waters

, due to dilution. Even with maximum reported concentration of THMs, the discharge would have to be diluted by only an equal volume of receiving water (i.e., a dil ution of one ) to meet the
MCL for drinking water standard (see Table 4

- 1)

. S hould the manufacturer apply for type

- approval of the

BalPure TM BP

- 2000 system which would allow for general sale , a very detailed analysis of the fate and

effects of the residual s would be conducted

.

Overall, it is expected that the potential adverse water quality impacts associated with the S/R American Progress discharging treated ballast water will be negligible. However the likelihood of reducing NIS

translocation results in a minor indirect beneficial water quality impact. As part of the evaluation of the performance of the STDN BalPure TM BP

- 2000 system on the S/R American Progress, the treated ballast water discharged from the vessel will be monitored regularly to assess the degree to whichSeaRiver STDN B alPure System

STEP Application 4

- 4 concentrations of residuals conform to the predicted levels. Any discharges exceeding the design levels will be noted and reported in the regular ly submitted reports and is grounds for halting the experiment and

re

- evaluation or disenr ollment of the ship from STEP. All discharges must comply with applicable federal and state requirements.SeaRiver STDN B alPure System

STEP Application 4

- 5

Table 4

- 1: Summary of Discharges with benchmarks and standards

Residual

Name Expected

discharge a Texas

ecological
surface water

benchmark b EPA dr inking

water

st andar ds c EPA discharge st andar ds

or toxicity levels of concern (where present) d

TOC (range 0.33 ppm and 7.28 ppm) .8ppm n/a n/a n/a

THM (100ppb/1p pm TOC) 69.5ppb 257

- 4320 ppb 80 ppb 80ppb

HAA5 (20ppb/1pp m TOC) 18ppb none 60ppb EPA 1,500 ppb/24 hr

exposure

Data sources: a from STDN’s application package; b from TCEQ (2000) and TNRCC (2001); c from EPA (2008c); d from EPA (2008b)



### 4.3 Public Health and Safety

4.3.1 No Action Alternative

Under the No Action Alternative, there would be no risks to public health or crew safety from the STDN

BalPure TM BP

- 2000 BWMS since the system would not be used to comply with U.S. BWM regulations.



### 4.3.2 Proposed Action Alternative

Under the Proposed Action alternative, there could be a minor ris k to public health or cre w safety. It is likely that the STDN BalPure TM BP

- 2000 system will be operated more frequently under the STEP

program than if the vessel were not enrolled in STEP. However the vessel is certificated for carrying and transferring large volumes of a hazard ous substance

- refined gasoline. The crew is well trained and equipped and has the experience necessary for safe handling practices of hazardous substances.

Sodium hypochlorite (NaClO) is a corrosive substance. It is poisonous to humans; it is also a s kin, eye, and respiratory irritant. There could be adver s e consequences to public health and safety if sodium hypochlorite is not handled appropriately. Since the system generates the needed NaCl O in real time as needed from the ambient seawater, this ch emical is never a storage risk. The STDN BalPure TM BP

- 2000

s ystem is liquid tight, which means the sodium hypochlorite solution should not leak from the system. Sodium bisulfite is also poisonous and a skin, eye, and respiratory irritant. However, t he f illing of bisulfite

tanks is a very infrequent operation that will be performed by manufacturer

- trained personnel, making the

risk of exposure very low

. Sulfur d ioxide ( SO 2 ) may be discharged while filling the bisulfite tanks and will

be monitored manuall y with a hand held device. Phos phoric acid is used as a reagent in the TOC analyzer. Phosphoric acid is a corrosive substance and may cause severe irritation and burns to areas of contact if not handled appropriately. However, the TOC analyzer will be us ed by trained personnel, making the risk of exposure very low. Hydrogen will be monitored with a hydrogen sensor w hich alarm s in the engine room. Presence of hydrogen in the machinery space will be detected by the sensor which will trigger an alarm and th e STDN BalPure TM BP

- 2000 system will shut down immediately.

During re

- supply and maintenance activities, manufacture r s’ personnel will follow the procedures listed on Material Safety Data Sheets for handling of ballast water treatment chemicals. Handlin g of theseSeaRiver STDN B alPure System

STEP Application 4

- 6 chemicals will be similar to handling of boiler system chemicals already existing on the ship. Trained responders with f irst aid equipment are readily at hand. The STDN operations and maintenance procedures cover these situations and will be f ollowed as part of the ship’s procedures

. STDN personnel will operate and maintain the equipment for the first year of operation. In addition, the installed BalPure TM

BP

- 2000 system has been verified to meet vessel construction and safety standards by pl an review and physical inspection by the corporate engineering staff, the vessel’s classification society

, and the U.S.
Coast Guard.

Therefore, as with any similar marine industrial process, although adverse consequences are possible

with the chemicals us ed and generated during treatment and monitoring , the risk would be low and impacts to public health and safety are reasonably concluded to be well

- mitigated and not significant.SeaRiver STDN B alPure System

STEP Application 5

- 1 

## 5.0 CUMULATIVE IMPACTS

The C ouncil on E nvironmental Q uality defines cumulative effects as “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency or person undertakes such other actions” (40 CFR 1508.7 ).

This section summarizes the cumulative impacts of the alternatives analyzed in this EA

, plac ing them in the context of the impacts associated with other actions in order to determine the total cumulative environmental changes, as well as which changes result from the alternatives and which result from other

actions.



### 5.1 No Action Alternative

Under the N o A ction a lternative, there will be continued discharge of organisms, potentially including NIS

, associated with the S/R American Progress’ current BWM pr actice of ballast water discharges in the port

areas of Beaumont and Corpus Christi in Texas approximately 30 times each year. In accordance with current BWM regulations

, t hese discharges need not be managed at all to remove organisms. It should

be noted that the source water for all these discharges would be south Florida, where many organisms

, including nonindigenous ones

, are resident. The repeated “inoculations” of ballast water potentially

carry ing the same organisms along with the similarity in env ironmental factors between Gulf of Mexico ports, pose s a significantly enhanced risk of NIS establishment in Texas waters.

As described in section three , marine and coastal resources in the affected environments are under increasing pressure from human ac tivities, including coastal development, fishing, industrial processes, resource exploitation, and biological invasions by NIS via numerous pathways including vessel operations. The cumulative effects of these activities are significant impacts to marine and coastal habitats, biodiversity, and resource sustainability. In the context of increasing rates of aquatic NIS invasions and consequences on marine and coastal resources, the incremental cumulative effect of the

N o A ction alternative for a single spec ific ship would likely be negligible, although the potential for NIS

introductions from the S/R American Progress would remain.



### 5.2 Proposed Action Alternative

The STEP PEA discusses the scope of shipboard experiments sought by the USCG for informing the

dev elopment, implementation

, and enforcement of a n ational BW management program that is protective
of U.S. waters from NIS introductions. Since only a small number o f ships are intended to operate experimental treatment technologies, no significant cumulati ve impact from the proposed action is expected. Under the Proposed Action alternative, the S/R American Progress would be accepted into STEP and would operate the STDN BalPure TM BP

- 2000 system to treat all discharged ballast water, resulting in reduced co ncentrations of organisms discharged into the Texas ecosystem. This suggests
that a small decrease in the threat of successful introductions of NIS into Texas waters from overall shipping activities could result from accepting the S/R American Progress int o STEP

. There may be discharge of some treatment residuals during deballasting into the waters of industrialized ports. These additional chemical concentrations are expe cted to be negligible in relation to chemical discharges from

other sources. Because the ports are already heavily industrialized, receiving inputs of many substances from many sources, we do not expect that treated ballast water discharges from the S/R American Progress will contribute adversely to the water quality in these ports. Howe ver, t he primary impact of the proposed action will be the gathering of data for development and refinement of a ballast water discharge standard and BWT testing procedures. Indirectly, this will lead to a net cumulative environmental benefit

as a more ro bust and effective ballast water management regulatory regime can be promulgated.SeaRiver STDN B alPure System

STEP Application 6

- 1 

## 6.0 COMPARISON OF THE AL TERNATIVES AND CONCL USION

Table 6

- 1 compares the potential consequences of the Proposed Action Alternative and the No Action Alternative.

Table 6

- 1 : Comparison of the Environmental Impacts Associated with the NEPA Alternatives

Category No Action Alternative Proposed Action Alternative

Biological Resources M inor adverse impacts Minor adverse impacts; potentia l beneficial impacts

Water Quality M inor adverse impacts Minor adverse impacts ; potential beneficial impacts

Public Health and Safety No adverse impacts Mi nor adverse impacts



### 6.1 Conclusion

There is a long term programmatic benefit of the Proposed Action alternative. By accepting the S/R American Progress and the STDN BalPure TM BP

- 2000 system into STEP, the USCG would acquire valuable information on the shipboard performance and treatment effectiveness of the sodium hypochlorite and sodium bisulfate dosin g BW M S . This information will be critical in the further development of effective ballast water manage ment technologies and in the development of feasibl e and sound ballast water management policy and regulations as mandated by Congress. Such benefits wo uld have wide geographic scope as prototype treatment technologies move to fully evaluated and approved systems and mandatory installation on a larger numbers of ships.

The conclusion of the environmental consequences analysis is that negligible adverse impacts c ould result from the implementation of the Proposed Action. Further, potentially adverse impacts remain with

the N o A ction alternative. Additionally, based on the information presented in s ections four and five , the Proposed Action could result in potentially beneficial impacts through the reduction of risk of the
introduction of NIS from the S/R American Progress

.SeaRiver STDN B alPure System

STEP Application 7

- 1 

## 7.0 REFERENCES

Agency for Toxic Substanc es and Disease Registry (ATSDR). 2005. Toxicological Profile for Bromoform and

Dibromochloromet hane. U.S. Department of Health and Human Services. 223 pages + appendices.

Buskey, Edward J. 1993. “ Annual pattern of micro

- and mesozooplankton abundance and biomass in a subtropical estuary.” J. Plankton Res. 15(8): 907

- 924

Buskey, Edward J., Brian Wysor, and Cammie Hyatt. 1998. “The Role of Hypersalinity in the Persistence of the

Texa s ‘Brown Tide’ in the Laguna Madre.” J. Plankton Res. 20(8): 1553

- 1565.

GMFMC. 1998. Generic Amendment for Addressing Essential Fish Habitat Requirements in the F ollowing Fishery

Management Plans of the Gulf of Mexico. Gulf of Mexico Fishery Management Council. Tampa, Florida. 238 pages + appendices.

Graber, William J., M.D. 1992. Winter Checklist of Birds at Sea Rim State Park, Texas.

http://www.tpwd.state.tx.us/spdest/findadest/parks/sea_rim/media/pdf/winter.pdf . (accessed November 15, 2007).

Herwig, R.P., J. R. Cordell, B.C. Nielsen

, N.C. Ferm , D. J. Lawrence

, J

. C. Perrins , and A.C.E. Rhodes. 200 6 . Efficacy Testing of the Severn Trent De Nora Balpure System. University of Washington. Final Report. 62 pages + appendices

.

National Biological Information Infrastructure. 2007

. Central Southwest and Gulf Coast. Anim als and Plants of the

Region. http://cswgcin.nbii.gov/portal/community/Communities/Geographic_Perspectives/Central_Southwest_&_Gulf _Coast/Animals_and_Plants_of_the_Region/ (accessed November 15, 2007).

National Marine Fisheries Service (NMFS)

. 2007. Ess ential Fish Habitat. Gulf of Mexico Fisheries Management Council. National Oceanic and Atmospheric Administration. http://www.nmfs.noaa.gov/habitat/habit atprotection/profile/gulfcouncil.htm#overview (accessed November 15, 2007).

National Oceanic and Atmospheric Administration (NOAA)

. 2002. The State of Coral Reef Ecosystems of the United
States and Pacifi c Freely Associated States. http://www.nccos.noaa.gov/documents/status_coralreef.pdf (accessed November 15, 2007).

Nautilus Environmental

. 200 5. Skeletonema costatum Testing for a Proposed Ballast Water Treatment: Hypochlorite
Soluti ons Treated with Sodium Sulfite. 3 pages plus appendix.

Onuf, Christopher P. 2006. “ Aspects of the Biology of Salicornia bigelovii Torr. In Relation to a Proposed Restoration
of a Wind

- Tidal Flat System on the South Texas, USA Coast. “ Wetlands . 26(3): 649

- 666.

Padre Island Nationa l Seashore , US National Park Service (PINS) 2009

. http://www.nps.gov/pais/ (accessed: September, 2008 ).

Port of Beaumont

. 2008. http://www.portofbeaumont.com (acces sed March 6, 2008).

Ruiz, G. M., 2007. Personal Communication. See the Invasion Biology web page: http://www.serc.si.edu/labs/marine_invasions/index.jsp for additional information reg arding Smithsonian Environmental Research Center surveys and databases on nonindigenous aquatic species.

Sabine River Authority, 2008. Sabine River Basin overview. http://www.sratx.org/basin/overvie w.asp Corporate Web

page accessed March 2008.

Shackelford, C.E., E.R. Rozenburg, W.C. Hunter, and M.W. Lockwood. 2005. Migration and Migratory Birds of Texas: Who They Are and Where They Are Going. Texas Parks and Wildlife PWD BK W7000

- 511 (11/05).

Bo oklet, 34 pp.SeaRiver STDN B alPure System

STEP Application 7

- 2 Texas Commission of Environmental Quality (TCEQ) . 2000. 2000 Texas Surface Water Quality Standards.

http://www.tceq.state.tx. us/permitting/water_quality/wq_assessment/standards/WQ_standards_2000.html (accessed May 27, 2008).

Texas Commission of Environmental Quality (TCEQ)

. 2004. 2004 Texas Water Quality Inventory and 303(d) List.

http://www.tceq.state.tx.us/compliance/monitoring/water/quality/data/wqm/305_303.html (accessed November 16, 2007).

Texas Commission of Environmental Quality (TCEQ). 200 8 . 200 8 Texas Water Quality Inventory and 303(d) List.

http://www.tceq.state.tx.us/assets/public/compliance/monops/water/08twqi/2008_303d.pdf (accessed November 16, 2007).

Texas General Land Office (TGLO) . 2002. Texas Coastal Wetlands: A Handbook for Local Governments. 140 pages.

Te xas Natural Resource Conservation Commission (TNRCC). 2001. Guidance for Conducting Ecological Risk Assessments at Remediation Sites in Texas. Toxicology and Risk Assessment Section. December, 2001.

Texas Parks and Wildlife Department (TPWD)

. 2005. 2005 L and and Water Resources Conservation and Recreation

Plan. Conservation of Texas Bays and Estuaries. http://www.tpwd.state.tx.us/publications/pwdpubs/pwd_pl_e0100_0867/water_priorities/conserve_bays/ (accessed November 18, 2007).

Texas Parks and Wildlife Department (TPWD)

. 2007 a . Texas Gems

- Laguna Madre.

http://www.tpwd.state.tx.us/landwater/water/conservation/txgems/lagmadr/ (accessed March 6, 2008).

Texas Parks and Wildlife Department (TPWD)

. 2007b. CCA/CPL Marine Development Center.

http://www.tpwd.state.tx.us/fishboat/fish/management/hatcheries/ccacpl.phtml (accessed March 6, 2008).

Texas Parks and Wildlife Department (TPWD)

. 2007 c . Texas Gems

- McFaddin Nat ional Wildlife Refuge.

http://www.tpwd.state.tx.us/landwater/water/conservation/txgems/mcfaddin/ (accessed November 15, 2007).

Texas Parks and Wildlife Department (TPWD)

. 2008. Rare, Threatened and Endangered Species of Texas.

http://gis.tpwd.state.tx.us/ TpwEndangeredSpecies/DesktopDefault.aspx (accessed March 14, 2008).

United States Coast Guard (USCG) 2000. National Environmental Policy Act: Implementing Regulations and Policy for Considering Environmental Impacts. COMDTINST M16475.1D. Washington D.C .: United States Coast
Guard.

United States Coast Guard 2004 a . Final Programmatic Environmental Assessment for Shipboard Technology

Evaluation Program (STEP) for U.S. Waters. United States Coast Guard. http://dmses.dot.gov/docimages/pdf90/307046_web.pdf

United States Coast Guard 2004 b

. Navigation and Vessel Inspection Circular 01

- 04 STEP . United States Coast
Guard. http://www.uscg.mil/hq/cg5/nvic/pdf/2004/NVIC_01

- 04.pdf

U.S. Environmental Protection Agency (EPA)

. 2008a. Water quality data from STORET (STOrage and RETrieval environmental data system, accessed 27 May 2008 ). http://www.epa.gov/storet/index.html

U.S. Environmental Protection Agency (EPA)

. 2008 b . ECOTOX Database. http://cfpub.epa.gov/ecotox/ecotox_home.cfm (accessed March 17, 2008)

U.S. Envir onmental Protection Agency (EPA). 2008c. Clean Water Act Section 303(d): Availability of List Decisions.

Federal Register Vol. 73, page 73326, December 2, 2008.

U.S. Fish and Wildlife Service (USFWS)

. 2007. McFaddin and Texas Point National Wildlife Re fuges. http://www.fws.gov/southwest/refuges/texas/mcfaddin/index.html (accessed November 16, 2007).

U.S. Geological Service (USGS) 2007. Non Indigenous Species information p age., http://nas.er.usgs.gov/
accessed October 9 , 2007.SeaRiver STDN B alPure System

STEP Application 8

- 1 

## 8.0 APPENDIX A. ACRONYMS AND ABBREVIATIONS

BWE Ballast Water Exchange

BWM Ballast Water Management

BWT Ballast Water Treatment

BW M S Ballast Water Manage ment System
CAA Clean Air Act of 1990
CEQ Council on Environmental Quality
CFR Code of Federal Regulations
DOC Dissolved Organic Carbon

EA Environmental Assessment

EEZ Exclusive Economic Zone

EFH Essential Fish Habitat

EPA Environmental Protection Agenc y ESA Endangered Species Act of 1973

gpm Gallons per minute

HAA5 Halo Acetic Acids

MT Metric ton
NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act of 1969
NIS Nonindigenous Species
NISA National Invasive Species Ac t of 1996
NMFS National Marine Fisheries Service
NOAA National Oceanic and Atmospheric Administration
NVIC Navigation and Vessel Inspection Circular
ORP Oxidation Reduction Potential

PEA Programmatic Environmental Assessment
PINS Padre Island Nationa l Seashore
PLC Programmable Logic Controller ppb Parts per billion

ppm Parts Per Million
SSDG Ship Service Diesel Generator
STEP Shipboard Technology Evaluation Program
STDN Severn Trent de Nora
TCEQ Texas Council on Environmental Quality

THM T ri halomethane

TPWD Texas Parks and Wildlife Department
TOC Total Organic Carbon
TRO Total Residual Oxidant
USCG U.S. Coast Guard
USFWS U.S. Fish and Wildlife Service
USGS U.S. Geological Survey
VOCs Volatile Organic CompoundsSeaRiver STDN B alPure System

STEP Application 9

- 1 

## 9.0 APPENDIX B. EXAMPLE O F SECTION 7 L ETTER S ENT TO

R ESOURCE A GENCIES.SeaRiver STDN B alPure System

STEP Application 9

- 2SeaRiver STDN B alPure System

STEP Application 10

- 1 

## 10.0 APPENDIX C. CORRESP ONDENCE R ECEIVED V IA A GENCY
C ONSULTATION.

From: Kenneth_Graham@fws.gov Sent: Monday, March 24, 2008 2:34 PM To: Moore, Brian LCDR Cc: Deb_Carter@fws.gov; Gloria_Bell@fws.gov; Wi nston_Hobgood@fws.gov; Heath_Rauschenberger@fws.gov; Karen_Soileau@fws.gov Subject: Southeast Regional Species Lists (LA , FL) for Coast Guard STEP

LCDR Brian Moore
U.S. Coast Guard 2100 2nd Street, SW Washington, D.C. 20593

- 001

Mr. Moore,

This E

- m ail is in response to your request for a species list for the Coast Guard's Shipboard Technology Evaluation Program (STEP). It is our understanding that SeaRiver Maritime, Inc., of Houston, Texas
vessel S/ R AMERICAN PROGRESS plans to install the Severn Tren t De Nora (STDN) BalPure treatment system on the vessel. This system uses electrolytic cells to produce sodium hypochlorite from

seawater which acts as the primary disinfection agent to eliminate the nonindigenous species while

ballast water is stored o nboard the vessel. The applicant's vessel will be traveling to (a) Corpus Christi Bay, Texas, (b) along the Sabine River from the Gulf of Mexico to Beaumont, Texas, (c) Tampa Bay, Florida, and (d) Port Everglades (Fort Lauderdale), Florida, and dischar ging/uptaking ballast water during the uploading/unloading of cargo, respectively, while in port. As we understand it, ballast water will not be discharged while the vessel is anywhere between these ports, unless the vessel is facing a maritime

emergency.

In reviewing the proposed ports of call for the vessel, the Southeast Region has determined that we have responsibility for the States of Louisiana and Florida. Our response is meant only to address your proposed activity in these two States.

For Por t Everglades

- the West Indian manatee (Trichechus manatus), an endangered species, is present in the waters at Port Everglades, Broward County , Florida.

For Tampa Bay

- The West Indian manatee (Trichechus manatus) and the Gulf sturgeon (Acipenser oxyrinc hus desotoi), are endangered species present in the waters of Tampa Bay, Florida.

For the Sabine River from the Gulf of Mexico to Beaumont, Texas

- there are no threatened or endangered species that may be affected by the proposed project in the Sabine Ri ver

Upon reviewing the details of the ballast water treatment process found on the manufacturer's website

located at: http://www.severntrentservices.com/denora/balpure/system

- overview.aspx, our Region found that oxidants and toxic chemicals resulting fr om the process will be removed to rigorous standards before the

treated ballast water is discharged into the natural environment. The discharge levels of possible harmful

chemic ® als are apparently lower than levels in untreated seawater . If this is cas e for the proposed project, the Southeast Region would likely have few concerns for the effects of the proposed activity on Federally listed species. However, we would be happy to review the project description and your effectsSeaRiver STDN B alPure System

STEP Application 10

- 2 determination for the propo sed action once it is available. The potential benefits of this process to stop
NIS from being translocated in ship ballast water are encouraging. If you have any questions, please

contact me as indicated below:

Ken Graham
Fish and Wildlife Service

1 875 Century Blvd., Suite 200 Atlanta, Georgia 30345 Phone: (770) 736

- 7235 EMail: kenneth_graham@fws.goSeaRiver STDN B alPure System

STEP Application 11

- 1 

## 11.0 APPENDIX D. STATE LI STED THREATENED, END ANGERED, AND
RARE SPECIES (TPWD, 2008)

JEFFERSON COUNTY

AMPHIBIANS Federal Status State Status

Pi g frog Rana grylio

BIRDS Federal Status State Status
American Peregrine Falcon Falco peregrinus anatum DL E

Arctic Peregrine Falcon Falco peregrinus tundrius DL T

Bald Eagle Haliaeetus leucocephalus DL T

Black Rail Laterallus jamaicensis

Br own Pelican Pelecanus occidentalis LE E

Henslow's Sparrow Ammodramus henslowii

Peregrine Falcon Falco peregrinus DL E T

Piping Plover Charadrius melodus LT T

Reddish Egret Egretta rufescens T

Snowy Plover Charadrius alexandrinus

Southeaster n Snowy Plover Charadrius alexandrinus tenuirostris

Swallow

- tailed Kite Elanoides forficatus T

Western Snowy Plover Charadrius alexandrinus nivosus

White

- faced Ibis Plegadis chihi T

Wood Stork Mycteria americana T

FISHES Federal Status State Status

American eel Anguilla rostrata

INSECTS Federal Status State Status
Bay skipper Euphyes bayensis

MAMMALS Federal Status State Status

Black bear Ursus americanus T/SA;NL T

Louisiana black bear Ursus americanus luteolus LT T

P lains spotted skunk Spilogale putorius interrupta

Rafinesque's big

- eared bat Corynorhinus rafinesquii T

Red wolf Canis rufus LE E

Southeastern myotis bat Myotis austroriparius

MOLLUSKS Federal Status State Status
Creeper (squawfoot) Stroph itus undulatus

Fawnsfoot Truncilla donaciformis

Little spectaclecase Villosa lienosa

Louisiana pigtoe Pleurobema riddellii

Pistolgrip Tritogonia verrucosaSeaRiver STDN B alPure System

STEP Application 11

- 2 Rock pocketbook Arcidens confragosus

Sandbank pocketbook Lampsilis satu ra
Southern hickorynut Obovaria jacksoniana

Texas heelsplitter Potamilus amphichaenus

Texas pigtoe Fusconaia askewi

Wabash pigtoe Fusconaia flava

Wartyback Quadrula nodulata

REPTILES Federal Status State Status
Alligator sn apping turtle Macrochelys temminckii T

Atlantic hawksbill sea turtle Eretmochelys imbricata LE E

Green sea turtle Chelonia mydas LT T

Gulf Saltmarsh snake Nerodia clarkii

Kemp's Ridley sea turtle Lepidochelys kempii LE E

Leatherback sea turtle D ermochelys coriacea LE E

Loggerhead sea turtle Caretta caretta LT T

Northern scarlet snake Cemophora coccinea copei T

Sabine map turtle Graptemys ouachitensis sabinensis

Texas diamondback terrapin Malaclemys terrapin littoralis

Texas horned lizard Phrynosoma cornutum T

Timber/Canebrake rattlesnake Crotalus horridus T

PLANTS Federal Status State Status
Chapman's orchid Platanthera chapmanii

NUECES COUNTY

AMPHIBIANS Federal Status State Status

Black

- spotted newt Notopht halmus meridionalis T

Sheep frog Hypopachus variolosus T

BIRDS Federal Status State Status
American Peregrine Falcon Falco peregrinus anatum DL E

Arctic Peregrine Falcon Falco peregrinus tundrius DL T

Brown Pelican Pelecanus occidentalis LE E

E skimo Curlew Numenius borealis LE E

Mountain Plover Charadrius montanus

Peregrine Falcon Falco peregrinus DL E T

Piping Plover Charadrius melodus LT T

Reddish Egret Egretta rufescens T

Sennett's Hooded Oriole Icterus cucullatus sennetti

Sno wy Plover Charadrius alexandrinus

Sooty Tern Sterna fuscata T

Southeastern Snowy Plover Charadrius alexandrinus tenuirostrisSeaRiver STDN B alPure System

STEP Application 11

- 3 Texas Botteri's Sparrow Aimophila botterii texana T

Western Burrowing Owl Athene cunicularia hypugaea

Western Snowy Plover Charadrius alexandrinus nivosus

White

- faced Ibis Plegadis chihi T

White

- tailed Hawk Buteo albicaudatus T

Whooping Crane Grus americana LE E

Wood Stork Mycteria americana T

FISHES Federal Status State Status

American eel Angui lla rostrata

Opossum pipefish Microphis brachyurus T

Texas pipefish Syngnathus affinis

Corpus Christi Bay; seagrass beds

INSECTS Federal Status State Status
Manfreda giant

- skipper Stallingsia maculosus

MAMMALS Federal Status State S tatus Maritime pocket gopher Geomys personatus maritimus

Ocelot Leopardus pardalis LE E

Plains spotted skunk Spilogale putorius interrupta

Red wolf Canis rufus LE E

Southern yellow bat Lasiurus ega T

West Indian manatee Trichechus manatus L E E

White

- nosed coati Nasua narica T

REPTILES Federal Status State Status

Atlantic hawksbill sea turtle Eretmochelys imbricata LE E

Green sea turtle Chelonia mydas LT T

Gulf Saltmarsh snake Nerodia clarkii

Indigo snake Drymarchon corais T

Keeled earless lizard Holbrookia propinqua

Kemp's Ridley sea turtle Lepidochelys kempii LE E

Leatherback sea turtle Dermochelys coriacea LE E

Loggerhead sea turtle Caretta caretta LT T

Spot

- tailed earless lizard Holbrookia lacerata

Texas diamo ndback terrapin Malaclemys terrapin littoralis

Texas horned lizard Phrynosoma cornutum T

Texas scarlet snake Cemophora coccinea lineri T

Texas tortoise Gopherus berlandieri T

PLANTS Federal Status State Status

Elmendorf's onion Allium elme ndorfii

Lila de los llanos Echeandia chandleri

Mexican mud

- plantain Heteranthera mexicanaSeaRiver STDN B alPure System

STEP Application 11

- 4 Plains gumweed Grindelia oolepis

Slender rushpea Hoffmannseggia tenella LE E

South Texas ambrosia Ambrosia cheiranthifolia LE E

Texas windmill

- g rass Chloris texensis

Welder machaeranthera Psilactis heterocarpa

LE, LT

- Federally Listed Endangered/Threatened PE, PT

- Federally Proposed Endangered/Threatened E/SA, T/SA

- Federally Listed Endangered/Threatened by Similarity of Appearance
C

- Federal Candidate for Listing; formerly Category 1 Candidate DL, PDL

- Federally Delisted/Proposed for Delisting

NL

- Not Federally Listed E, T

- State Listed Endangered/Threatened

NT

- Not tracked or no longer tracked by the State
“blank”

- Rare, but with no regulatory listing statusSeaRiver STDN B alPure System

STEP Application 12

- 1 

## 12.0 APPENDIX E. AIR QUA LITY ANALYSIS

Evaluation of potential for air emissions generated by the use of the SevernTrentDeNora BalPure 2000 system on the S/R American Progress

A ir quality impacts associated with the BWM tech nology being evaluated in this EA may arise from one source: the emissions from the SSDG that powers the STDN system. Such emissions are particularly of concern at the port of Beaumont, as it is located in nonattainment or
maintenance areas for at least o ne air pollutant. There is no circumstance where the S/R American Progress will load ballast in Texas. Therefore the BWM S will only be activated when the vessel is loading ballast which only occurs at the cargo discharge ports in Florida.

As mentioned ab ove, the S/R American Progress uses an SSDG to generate shipboard electrical power, and this electricity powers the BalPure system. In general, vessels such as the S/R American Progress would have 2

- 3 SSDGs sized between 2000 and 5000 kW on board. Thus, during ballasting and deballasting operations, there would be some incremental added loading of
the SSDG

– the BalPure 2000 system uses a maximum of 60 kilowatts (kW) of the ship’s electrical power. The technology would likely be activated for a total of 36 0 hours annually for 30 voyages/year

.

A preliminary emissions inventory, using emissions factors (for stationary internal combustion sources) found in AP 42 (EPA 1995), indicated that 60 kW of energy supplied by a large stationary diesel

- fuel engine fo r 360 hours annually would result in annual emissions of each polluta nt of less than one ton. If an emissions amount of one ton were put into a screening model (e.g. SCREEN3 (EPA’s air pollution screening model)), using conservative inputs for

characteris tics from a vessel such as the S/R American Progress , then the ground level concentrations of that pollutant would be negligible to immeasurable (Noel 2006). Furthermore, it is unlikely that an SSDG would be activated solely for the purposes of operating the BWM S ; in other words, the BWM S would simply draw more current from an SSDG that is running regardless.

Finally, no additional sources of electrical power would be installed onboard to accommodate the
BWMS . Therefore, using the BalPure system would not result in any new emissions, as it is no additional electrical power sources are being installed or operated. As emissions from the operation of the BalPure are negligible, local or regional levels of pollutants will not be affected, including levels in the area of concern in Tex as

.

It can be concluded that the Proposed Action Alternative will have no impacts on air quality.SeaRiver STDN B alPure System

STEP Application 13

- 1 

## 13.0 APPENDIX F. EFFLUENT TOXICITY TEST RESULT S

Toxicity testing was done on water simulated to mimic ballast water treated wit h the BalPure

- 2000.
Results of those test follow:SeaRiver STDN B alPure System

STEP Application 13

- 2SeaRiver STDN B alPure System

STEP Application 13

- 3SeaRiver STDN B alPure System

STEP Application 13

- 4SeaRiver STDN B alPure System

STEP Application 13

- 5SeaRiver STDN B alPure System

STEP Application 13

- 6SeaRiver STDN B alPure System

STEP Application 14

- 1 

## 14.0 APPENDIX G: MATRIX O F COMMENTS AND RESPO NSES

Docket

Number Commenter(s) Comment Coast Guard’s Response

USCG

2008

- 0 126 California

State Lands

Commission (CSLC) The commenter requested a map

of the port areas in Section 1.3, paragraph 1,section 3.2 The Coast Guard does not believe including a map or chart of the harbor locations is necessary or needed in the interest o f keeping the FEA a manageable length and avoiding repetition of information that is considered general knowledge in the project area or readily available elsewhere. Each port is part of a major metropolitan area of the same name and easily located on any map, chart, or Web mapping service.

USCG

2008

- 0126 CSLC The commenter stated that the last sentence of Section 1.1, paragraph 1 seemed to indicate that yearly reports are requi red on efficacy testing, when efficacy testing was only performed in years 1 and 5. The

commenter asked for

clarification. The Coast Guard notes this comment but believes that as in the PEA for STEP and in this project specific FEA, the phrasing clearly i ndicates that reports are required yearly.

USCG

2008

- 0126 CSLC The commenter requested elaboration for Section 1.3, paragraph 2, and inquired as to if there was a required holdi ng time

once the ballast water is treated.

The commenter also asked if the organisms were assumed to be killed immediately upon uptake. The Coast Guard believes that this issue is adequately addressed in the technology description section 2.2.2 of the FEA. Organisms are assumed to be killed upon exposure to the treatment, as explained in 2.2.2.

USCG

2008

- 0126 CSLC The commenter requested clarification as to why the hypochlorite injection rate is compared to the equivalent chlorine rate in Section 1.3, paragraph 2. The comparative terms are used to better capture the actual

amount of biocide dosed to the ballast water versus the total mass of chemical injected, which includes some inert matter..

USCG

2008

- 0126 CSLC The commenter inquired as to whether the neutralization step was inline during discharge or in tank immediately prior to discharge in Section 1.3, paragraph 2. Yes, the neutralization step is inline. This issue is addressed in the technology description section 2.2.2 in the FEA.

USCG

2008

- 0126 CSLC The commenter ask ed that the Coast Guard “add that system engineering and mechanical performance is verified throughout the five year evaluation period even though biological efficacy is only assessed in years 1 and 5.” The Coast Guard disagrees with the need to add this basic STEP program information;. Such information is readily available to the public in the PEA and STEP guidance documents mentioned

in Section 1.1 and Section 1.4. .Further restatement in the FEA has been avoided per Council on Environmental Quality

re gulations for National Environmental Policy Act of 1969 (NEPA) compliance/

USCG

2008

- 0126 CSLC The commenter wanted to know what “availability” of the BWM system meant in Secti on 2.2, paragraph 1. The Coast Guard has replaced the word “availability” with the word “reliability,” which in this case means that the system is operable and ready for use whenever the ship must conduct ballast operations.

USCG

2008

- 0126 CSLC The commenter requested clarification of Section 2.2, paragraph 2, where it is stated that under Alternative 2, that the SR American Progress would be “free to discharge ballast water

trea ted by the experimental The Coast Gu ard agrees that the sentence might be perceived as inconsistent with the parameters as established in the PEA for

STEP and has edited the text in section 1.5 to read as follows: “...Any significant changes to operations (e.g., schedule changes involving new U.S. ports where treated ballast water would be discharged, or changes in the engineering and operation of the BWMS), would be reviewed against theSeaRiver STDN B alPure System

STEP Application 14

- 2 treatment system into U.S. waters as operations dictated.” The commenter thought that this

conflicted with statement in Section 1.5, paragraph 3 that states, “This EA is vessel, treatment technology, and route specific ” applicable regulations and may require revisions to the STEP application, and a new review and approval deci sion by the

USCG.”

.

USCG

2008

- 0126 CSLC The commenter asked, in regards to Section 2.2.2, paragraph 2: Is the gaseous hydrogen vented from the ship in dedicated piping

or pre

- e xisting piping for other emissions? If it is pre

- existing piping, could the hydrogen combine with other emissions, in a negative way? The hydrogen produced is vented through dedicated piping and therefore no mixing occurs. The safety aspects of the syste m have been thoroughly evaluated and inspected by the Coast Guard, the owner, the flag state and the ship’s classification society.

USCG

2008

- 0126 CSLC The commenter wanted to know if the system would allow the

alarm to be disabled or shut off without manually switching to

feed water source. The

commenter also asked if there

was a reason that this switch

doesn’t occur automatically.(Section 2.2.2, paragraph 1) Yes, the alarm c an be manually turned off without switching to feed water source. As regards the automatic switch, STEP’s primary concern is biological efficacy, therefore the Coast

Guard believes that this comment addresses an issue outside the scope of the FEA.

USCG

2008

- 0126 CSLC The commenter requested elaboration on Section 2.2.2, paragraph 2. The commenter

wanted to know if there was a required holding time once the

ballast water had been treated.

The commenter wanted to know if the organisms were assumed to be killed immediately upon uptake. There is no required holding time related to treatment of potential organisms in the ballast water. The Coast Guard has added an additional paragraph in this section in order to clarify this concern. Organisms are assumed to be killed upon exposure to the treatment, as explained in 2.2.2. However, for purposes of neutralization of the disinfectant upon discharge, the system relies upon an assessment of residual disinfectant 24 hours prior to discharge.

USCG

2008

- 0126 CSLC The commenter asked if the hypochlorite level (in addition to the sodium bisulfate level) was

measured post

- neutralization to

ensure the water is safe to discharge. The commenter also

wanted to know if the

neutralization was instantaneous.(Section 2.2.2, paragraph 4) The residual hypochlorite level will be measured 24 hours prior to discharge in order to e nsure proper dosage of the neutralization chemical, so that the discharged water meets state water standards. The neutralization reaction is for all practical purposes instantaneous. The Coast Guard has added an additional paragraph in this section in or der to clarify these

concerns.

USCG

2008

- 0126 CSLC The commenter wanted to know how long are these three tanks of sodium bisulfate expected to last, and how often they are expec ted

to be re

- filled. (Section 2.2.2, paragraph 4) The Coast Guard has conducted a thorough review of this system and found that the design is adequate for the route and

service of the American Progress. How often the tanks are filled

are both concerns that fall outside the scope of the FEA.

USCG

2008

- 0126 CSLC In the second paragraph of the

Chemical Residuals section within Section 2.2.2, the

commenter asked if the initial

target dose was automatically adjusted based upon ballast water quality, or if it would require assessment by the crew. No, the target dose is not automatically adjusted based on ballast water quality. The basis for target dosage levels comes from the analysis of ranges of total organic carbon, found in water quality data from Tampa, Florida, the original ballasting source for this ship.

USCG

- CSLC The commenter asked for The Coast Guard agrees that the sentence might be perceived asSeaRiver STDN B alPure System

STEP Application 14

- 3 2008

- 0126 c larification for a discrepancy between Section 3.0, paragraph 2 and Section 2.2, paragraph 2. It

is stated that the SR American Progress would be free to discharge ballast water treated by the experimental treatment system into U.S. waters as operations d ictated. However, later it is stated that only ports in

Texas and Florida will receive discharged ballast water. inconsistent and has edited the second paragraph of 3.0 to read

as follows: “Th e S/R American Progress operates on a regular schedule, loading cargo in Beaumont, Texas and discharging it in Port Everglades, Florida. The vessel occasionally loads cargo in Corpus Christi, Texas and may occasionally divert offloading cargo in Tampa, Fl orida. The affected environments analyzed in this FEA are the marine ecosystems within these relevant ports of Texas and Florida. Since the S/R American Progress does not discharge ballast water in Port Everglades and Tampa, Florida, the only potentially affected resources discussed for these ports are public health and safety.”

USCG

2008

- 0126 CSLC The commenter asked for a more recent data set for plankton populations in Sect ion 3.2, in the first paragraph of the Fish and

Invertebrates Section. The Coast Guard has not found more recent studies describing the general planktonic characteristics of the affected environment. We believe that the cited study adequately

describes t he affected environment; however if more recent data are available, we welcome their submission.

USCG

2008

- 0126 CSLC The commenter requested more information concerning backgrou nd levels of disinfection by

- products as an important factor in assessing any potential cumulative impact from release of treated discharges by the American Progress .(Section 3.3., last paragraph) The Coast Guard was unable to locate information about

bac kground levels of disinfection byproducts in the affected environment. While knowing the existing levels of such byproducts in the affected port areas would be useful for analyzing cumulative impacts, we expect any byproduct amounts in discharged ballast water will be very small and will, therefore, only have a negligible contribution to currently occurring cumulative impacts. Further, it remains the responsibility of the vessel owner/operator to be in compliance with all applicable state and federal wate r quality laws. The Coast Guard welcomes the submission of any data regarding background levels of disinfection byproducts in the affected

environment.

USCG

2008

- 0126 CSLC In S ection 4.1.2, paragraph 1,

last sentence

– As the American Progress does not exchange ballast, the sentence should state that the discharged water would

be treated rather than unmanaged. Although the American Progress does not plan to exchange

ballast w ater, exchanging ballast water is currently a permissible option as long as a vessel can do so in accordance with applicable regulations..

USCG

2008

- 0126 CSLC The commenter wan ted to know how the chloroform is produced

and in what concentration in section 4.1.2, paragraph 2. The

commenter stated that chloroform is not brought up when discussing the chemical

residuals earlier in the document. Formation of chloroform and other re siduals is described in section 2.2.2, Chemical Residuals, of the FEA. The Coast Guard has added chloroform to the list of trihalomethanes (THMs) produced in Section 1.3.

USCG

20 08

- 0126 CSLC Toxicity tests were performed on mesozooplankton test organisms but were any tests performed on micro zooplankton organisms or is there any indication as to the potential effects on these organisms? It’s mentioned on (section 4.1.2, paragrap h 3) that potential impacts could include acute toxicity to the planktonic community and it has also been

well documented that [temperature

- induced and hypersaline

- induced] declines in microzooplankton (notably The tests did not include microzooplankton. The University of Washington laboratory toxicity tests with organisms were not specific for microzooplankton, other zooplankton and other microphytoplankton were evaluated, all with no adverse effects

shown. At the initial dosa ge rate, and in tank holding time of 3 to 3.5 days followed by neutralization of biocide prior to discharge into the sea, effluent toxicity tests show little toxicity to a wide range of organisms. See Appendix F in the FEA for the complete laboratory test results. The water that is discharged through the test system will experience essentially infinite dilution effects from being pumped into the unconfined waters of either port complex. Also, the vessel history shows it has not discharged ballast water i n Corpus Christi in the last two years. The Coast Guard believes that the potential for adverse impacts on the organisms in or around Corpus Christi to includeSeaRiver STDN B alPure System

STEP Application 1 4

- 4 Oxyrrhis marina) may have played a significan t role in the initiation of the persistent ‘brown tide’ algal bloom in Laguna Madre (5 miles south of Corpus Christi ship channel) from 2000

- 2007(see Buskey et al. 1998

– cited in EA), which was

mentioned several times throughout the EA. the Laguna Madre area as a result of STEP acceptance is negligible. Further toxicity testing o f the actual water discharged from the system is a primary purpose of STEP. Compliance with Clean Water Act provisions for commercial vessels also requires testing and evaluating the ecological toxicity of all water streams discharged from the ship.

USCG

2008

- 0126 CSLC The commenter requested

clarific ation in paragraph 2 of

Section 4.3.2 of who would be responsible for the training of personnel in how to refill sodium bisulfate, and to handle the TOC analyzer (STDN employees, ship crew). The commenter also asked for clarification of, after the first y ear of operation, who the responsibility lies with in performing maintenance and re

supply of the system, and how they will be trained to ensure personnel safety.(Section 4.3.2, paragraph 3) The Coast Guard has amended Section 4.3.2., third paragraph,

to r eflect that the manufacturer will provide training for the ship’s personnel to operate the system.

USCG

2008

- 0126 CSLC The commenter asked: “[f]ollowing the first year of

opera tion, please clarify who will be responsible for performing maintenance and resupply of the system, and how they will be trained to ensure personnel safety.” While this system is
used under STEP, the manufacturer will provide all operating and maintenance training. The Coast Guard has amended Section 4.3.2., third paragraph, to reflect that the manufacturer will provide this training. Specifics about how training is done are beyond the scope of

this FEA.

USCG

2008

- 0126 CSLC The commenter requested a

discussion of cumulative water quality impacts from the discharge of HAA5 and THM into an already industrialized waterway to be inserted into

Section 5.2. The Coast Guard believes th at the potential for adverse impacts

due to additional DBPs as a result of the S/R A merican Progess discharges into the Sabine River is negligible. Because the ports are already heavily industrialized, receiving inputs of many substances from many sources , we do not expect that treated ballast water discharges from the S/R A merican Progress will contribute adversely to the water quality in these ports. As determined in the PEA for STEP, only a small number of ships are intended to operate experimental tre atment technologies and as such, no significant cumulative impacts from the proposed action are expected.

USCG

2008

- 0126 CSLC In Section 4.1.2, Biological Resources, Proposed Ac tion Alternative, the commenter stated that there were a confusing

number of residuals values for

THM’s and HAA5’s (benchmarks, EPA standards, freshwater standards, etc.) scattered throughout this section, which the commenter stated,

made it difficult to c ompare to expected discharge values for the The Coast Guard agrees that the information was not presented clearly and succinctly and has added a table summarizing the requested data in Section 4.1. 2..SeaRiver STDN B alPure System

STEP Application 14

- 5 treatment system. The commenter suggested adding a

table.

USCG

2008

- 0126 CSLC The Coast Guard received a

number of comments from the CSLC regarding minor editorial changes. The Coast Guard has incorporated these comments in order t o improve readability.SeaRiver STDN B alPure System

STEP Application 15

- 1 

## 15.0 APPENDIX H LIST OF AGENCIES AND PERSONS CONSULTED

David Burnhard South Eastern Regional Office
U.S. National Marine Fisheries Service

Deb Carter Division of Endangered Species
U.S. Fish and Wildlife Service

Ken Graham
Sou theast Region Atlanta
U.S. Fish and Wildlife Service

Linda S. Smith
North Florida Field Office
U.S. Fish & Wildlife Service

Mary Orms
U.S. Fish and Wildlife Service Corpus Christi Ecological Services Field Office

Stephan Parris
U.S. Fish and Wildlife Se rvice Clear Lake Ecological Services Field Office

Dr. Nader Elkassabany U.S. Environmental Protection Agency Office of Pesticides Programs and Toxic Substances Washington, D.C.