USCG STEP Environmental Assessment

SeaRiver STDN BalPure 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 BalPureTM System into the 

Shipboard Technology Evaluation Program (STEP)

February 2009

Prepared by Volpe Transportation Research Center for 

U.S. Coast Guard
USCG STEP Environmental Assessment

SeaRiver STDN BalPure 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 Alternative.................................................................................................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 Alternative ................................................................................................................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 Consultation. ..........................................10-1

11.0 Appendix D. State Listed Threatened, Endangered, and Rare Species (TPWD, 2008) ............11-1

12.0 Appendix E. Air Quality 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 BalPure 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 2004a). STEP was established to facilitate the development of prototype ballast water 

management (BWM) systems for reducing nonindigenous species in ballast water. Under STEP, 

management system developers 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 acquire 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 2004a).

The USCG previously prepared 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 Environmental 

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) BalPureTM BP-2000 treatment system, and tiers from the PEA. The 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 with 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 

Commandant Instruction M16475.1D. Specifically, this EA examines the probable environmental impacts 

of accepting the S/R American Progress with the STDN BalPureTM 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 purposes of the action considered within this EA (accepting the S/R American Progress with the 

STDN BalPureTM BP-2000 system into STEP), are to gain valuable scientific 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 nonindigenous species 

(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) ballast water exchange (BWE) and 

2) retention of ballast water could be useful to prevent the introduction and spread of NIS.

Participants in STEP, such as the S/R American Progress with the STDN BalPureTM BP-2000 system, will 

aid in fulfilling the need of the Coast Guard to develop and implement a BWM program as directed by the 

National Invasive Species Act (NISA) of 1996. The development of effective BWM 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). Information gained through STEP will 

provide scientific validation for new systems and aid in the deployment of effective and practicable BWM

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

invasions. 
USCG STEP Environmental Assessment

SeaRiver STDN BalPure System 

STEP Application 1-2

1.3 Background

The S/R American Progress is a U.S. flagged tankship measuring 183 meters 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. Roundtrip voyages usually last about 11 days, and occur year round,

approximately 30 times annually. Cargo discharge and ballast water loading take place primarily in Port 

Everglades, Florida at Port Everglades Municipal Berths 7, 9, or 13. On occasion (approximately 1/year) 

the ship is diverted to Tampa, Florida where ballast is taken on at Kinder Morgan Industries Berth 226. 

The ballast water taken on in Florida is then typically discharged into the Sabine River at the ExxonMobil 

Refinery berth in Beaumont, Texas while the next cargo is loaded. On rare occasions, cargo is loaded at 

the Port of Corpus Christi in Corpus Christi, Texas, in which case ballast water is discharged into Corpus 

Christi Bay. The vessel’s total ballast capacity is 20,277 metric tons (MT); however, the average ballast 

water load is 17,942 MT.

The STDN BalPureTM BP-2000 system is a two-stage treatment process that uses sodium hypochlorite

(NaClO) in the treatment of ballast water. The biocide treatment is referred to as stage one in the 

SeaRiver STEP application and is the disinfectant phase conducted 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 bromoform. These are referred to collectively as “total residual 

oxidants” (TRO). Stage 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 discharged from the ship.

Pilot data indicates that organic matter (total organic carbon [TOC]) in the ballast water will react with the 

injected hypochlorite to form trihalomethanes (THMs) and some haloacetic acids (HAA5), but no 

measurable bromates or chlorates. 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 treatment 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 consequences 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 main 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 would 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 BWMS efficacy and 

impacts.
USCG STEP Environmental Assessment

SeaRiver STDN BalPure System 

STEP Application 1-3

The PEA also found that any impacts abroad would be insignificant, due to the small number of vessels 

involved. The 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 BWMS would be operated under two phases: an 

experimental period (years one through five) and a monitoring period (year six and beyond). During the 

experimental period, the BWMS 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 includes the primary onboard biological experiments measuring the system’s actual performance. 

During the monitoring period, the vessel must submit annual reports on the BWMS operations. During 

both periods, the experimental BWMS shall be the primary method of BWM. During the period in STEP, 

the vessel shall comply with BWM regulations (33 Code of Federal Regulations [CFR] 151 Subparts C 

and D) if the experimental BWMS 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 occur 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 2004a).

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 treated ballast water would be 

discharged, or changes in the engineering and operation of the BWMS) would require revisions to the 

application, and a new review and approval decision by the USCG.
SeaRiver STDN BalPure System 

STEP Application 2-1

2.0 ALTERNATIVES

The USCG has received an application to STEP from SeaRiver, 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 BalPureTM system acceptance to the program. 

This EA will 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 BWM on federal 

vessels. Only the second option, STEP, was deemed appropriate 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 (BWMS), 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 the 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 No Action Alternative, the S/R American Progress with the STDN BalPureTM 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 

vessels 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 BalPureTM 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 opportunity to gain information that would be 

critically important for establishing discharge standards and procedures for BWMS 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 BWMS available for initial and periodic physical 

inspections by USCG personnel, SeaRiver would submit to the USCG detailed annual reports on the 

performance of the management system, including the results and interpretations of rigorous tests of 

system 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 submit annual reports on the operation, maintenance, 

and reliability of the BWMS. The USCG would take this information into consideration during the 

development or refinement of regulations, policies, and procedures related to BWM strategies, 

requirements, and the regulatory program procedures for treatment system approval and compliance 

testing.

As detailed in the PEA, acceptance to STEP would grant the applicant equivalency to current (at the time 

of application) and future BWM regulations regarding management practices for preventing the 

transportation of NIS in ballast water. The period of equivalency for the S/R American Progress with the 
SeaRiver STDN BalPure System 

STEP Application 2-2

STDN BalPureTM 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 Activities

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 discharges it in Port Everglades. Occasional 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 returning 

to Texas without cargo. The ballast water taken on in Florida is then discharged in the place where the 

next cargo is loaded. On these voyages the vessel does not leave U.S. waters, nor go beyond 200 

nautical miles from shore. Therefore, it does not 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

ballast. Loading of ballast is typically started once cargo discharge has begun at full rate. Ballast is 

loaded into each tank first by gravity and then by use of dedicated ballast pumps. Ballast may be used to 

alter the vessel’s position in the water to facilitate 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 during 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 Berth #226. During primary treatment experiments all ballast and deballast operations 

will take place at the dock.

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

berth if convenient and in good weather 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 berth in Beaumont, Texas. 

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

2.2.2 Description of Technology 

The STDN BalPureTM BP-2000 system provides an electrolytic process for the on-site generation of 

oxidant solutions during ballasting operations and the neutralization of residual oxidants during the 

deballasting operation. Sodium hypochlorite is generated by means of electrolysis of seawater. A small 

booster pump injects filtered seawater, at a nominal flow rate of 60 gallons per minute (gpm), through the 

electrolytic cells (electrolyzers), where it is subjected to medium amperage, low voltage direct current. 

The system’s logic controller is designed to protect the electrolyzers from low flow, and will shut down the 

electrical current to the unit if the inlet flow to ballast water treatment electrolyzers falls below 48 gpm (80

percent of rated flow). 

The electrical current passing through the seawater causes the dissolved salt (NaCl) and water (H2O) to 

form aqueous sodium hypochlorite (NaClO) and gaseous hydrogen (H2) as a by-product. Sodium 

hypochlorite solution and hydrogen are produced continuously and separated immediately upon exit from 

the electrolytic cell. The gaseous H2 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 the first ballast tank at a target dose rate of 15ppm of biocide. The BalPureTM

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 electrolyzer

feed water chloride concentration of at least 19,000 ppm for optimum performance. Insufficient chloride 

(which could occur during peak freshwater runoff periods) will activate an alarm and the operator would 
SeaRiver STDN BalPure System 

STEP Application 2-3

manually switch the feed water source to the aft peak tank, which contains full strength seawater carried 

specifically for this purpose. 

The TRO dose rate was 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 

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

re-growth in stored ballast water.

The BalPureTM BP-2000 system is designed to operate automatically. After the unit is energized, the 

system will sense when ballast water uptake begins. Then the transformer/rectifier will supply DC current 

to the electrolyzer to begin producing oxidant. The oxidants will be injected into the main ballast line just 

prior to the first ballast tank. The system may also be activated manually.

Gaseous hydrogen produced in the electrolytic cell is immediately diluted with ambient air to less than 1

percent H2 by redundant air blowers. An H2 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 level in the ballast water 

stored on board. If tests show TRO levels to be out 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 BalPureTM BP-2000 system measures the level of residual 

disinfection chemical exiting the ballast tanks. Then liquid sodium bisulfite (NaHSO3) will be metered into 

the inlet of the deballasting pump. With the turbulent effect of the deballasting 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 supplies 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 data logger. All measured bisulfite 

levels during deballasting are also recorded with date and time in the data logger.

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

BalPureTM BP-2000 system requires 440 volt / 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 Residuals 

For stage one, the initial 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 the 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. 

The 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 requires more disinfectant.

Stage two is the neutralization (dechlorination) of residual chlorine and other oxidants present in the 

ballast tanks by injection of NaHSO3 in the main ballast line just prior to discharge from the ship. Sodium 

bisulfite 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 BalPure System 

STEP Application 2-4

Organic matter in the ballast water (dissolved organic carbon or total organic carbon) 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 bisulfite residual, 

approximately 100 parts per billion (ppb) THMs and 20 ppb HAA5 will form for every 1 ppm TOC in the 

ballast water (Herwig et al., 2006).
SeaRiver STDN BalPure System 

STEP Application 3-1

3.0 AFFECTED ENVIRONMENT

To understand the potential environmental impacts of these alternatives, this chapter 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 the 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 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.

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 the 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 activity 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 vulnerable historic properties (e.g., 

shipwrecks) located in the potentially affected port areas. The BWM system is not expected to have an

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 (H2), 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 and 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 PEA. 
SeaRiver STDN BalPure System 

STEP Application 3-2

Ballast water discharge from the S/R American Progress occurs in the Ports of Beaumont and Corpus 

Christi, Texas. The Port of Beaumont is located in Jefferson County and is accessible from 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 located 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 Christi 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 resource in Texas (Texas Parks and Wildlife Department (TPWD), 

2007a). 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, 

this estimate did not take into consideration wetlands’ functional quality, 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 wetlands 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 birds (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 coastal waters of Texas

(National Biological Information Infrastructure, 2007). This diverse group includes bony fish 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

(Callinectes 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

(Cynoscion 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, 2007b).
SeaRiver STDN BalPure System 

STEP Application 3-3

Plankton in the Nueces Estuary was studied from September 1987 through October 1988 to ascertain 

patterns of biomass and abundance of microzooplankton and mesozooplankton. Microzooplankton (20–

200 μm in length) were extremely abundant throughout 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) abundance 

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 newlyidentified species Aureoumbra lagunensis. 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 seagrass 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 Ports of Beaumont or Corpus Christi (National Oceanic 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, approximately 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 

Montana and North Dakota to the north and extending south through New Mexico. Of the 338 species 

listed as Neararctic-Neotropical migrants in North America, 333 of them have been recorded in Texas 

(Shackelford et al., 2005). Typical birdlife associated with the marshy and coastal areas of Texas 

includes 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. Murphree Wildlife Management area is located 

within Port Arthur, Texas and is approximately 21 miles south of the Port of Beaumont. These refuges 

supply important 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 (USFWS, 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, 2007c).

Padre Island National Seashore (PINS) is 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 (Dermochelys coriacea), hawksbill (Eretmochelys imbricata), and green (Chelonia 
SeaRiver STDN BalPure System 

STEP Application 3-4

mydas) sea turtles. The Aransas National Wildlife Refuge is the winter home for the endangered 

whooping crane (Grus americana) (PINS, 2008).

Threatened and Endangered Species

The USFWS Threatened 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 areas. 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, the 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 species 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 database 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 habitat 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 listed 

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 

necessary to fish for spawning, breeding, feeding, or growth to maturity” (GMFMC, 1998). Species along 

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

spiny lobster (Panulirus sp.), stone crab (Menippe mercenaria), 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 miles) 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 aurorubens), 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 federally 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 estuarine 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 BalPure 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 plant 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 

indications 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 ongoing problem since.

3.3 Water Quality

The Sabine River 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 basin 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-watersheds. 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 Sabine 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), 2004).

The Sabine River & Lake System is one of 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 have 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 streams 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 

habitats 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 freshwater 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 in the 2008 Texas 303(d) List, also for bacteria (USEPA, 2008c).

Information on background levels of disinfection by-products or existing wastewater permits to discharge 

chemicals similar to those potentially discharged by the STDN BalPureTM BP-2000 system as installed 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 (ambient) levels are expected to be high.

3.4 Public Health and Safety

The relevant geographic scope of the proposed action 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 are 
SeaRiver STDN BalPure System 

STEP Application 3-6

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

BWM system is constructed in accordance 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 

operations may last many hours, BWMS 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 BalPure System 

STEP Application 4-1

4.0 ENVIRONMENTAL CONSEQUENCES

The following discussion 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. Therefore the discussion of potential environmental consequences for these ports is limited to 

public health and safety related to the use of the BWMS 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 BalPureTM 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. However, the S/R American Progress would not be granted equivalency 

to current and future BWM requirements, and therefore would be required to comply with such BWM

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 BalPureTM BP2000 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 the 

S/R American Progress 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 BalPureTM BP-2000 system would 

be admitted to STEP, and use of the system would be granted equivalency for applicable future USCG 

BWM regulations. The BWM 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 potential impact to biological resources occurs from exposure to any disinfection byproducts 

remaining in ballast water discharged into the Ports of Beaumont and Corpus Christi, Texas. These 

disinfection byproducts include THMs and HAA5 at levels 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 

and chronic 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 possibly 

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, the 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 American 
SeaRiver STDN BalPure System 

STEP Application 4-2

Progress from the consulted agencies matched their 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 initial TOC 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, Texas 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. Maximum contaminant levels (MCL) based 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 

MCL) 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 results from full scale studies indicated a 

higher concentration of THMs and HAA5, this was mainly due to the extremely high levels of TOC (11.48 

ppm) that were artificially created in the 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). Concentrations 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 dibromochloromethane, for example, the hydrolytic 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. 

The Texas Natural Resources Conservation Council (TNRCC 2001, now known as the TCEQ) posted 

ecological surface water benchmarks for THMs ranging from 257 ppb for chlorodibromomethane in 

freshwater to 4,320 ppb for bromodichloromethane in freshwater. Marine benchmarks are not available 

for some THMs, but concentration levels of concern are assumed to be similar to or higher than 

freshwater values, e.g., tribromomethane has a freshwater value of 149 ppb and a marine value of 1,220 

ppb. The EPA-compiled toxicity levels (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, 2008b).

Toxicity tests were conducted by Herwig et al. (2006) 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 BalPureTM BP-2000 system. Results of these tests 

suggested that seawater dechlorinated with sodium bisulfite was not toxic to the test organisms 

(mesozooplankton) in a 24-hour exposure. Chronic toxicity tests using ballast water samples treated by 

STDN’s BalPureTM 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 residual 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 BalPureTM BP-2000 system also has a monitoring system to measure and control 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 Beaumont 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, both of these protected 
SeaRiver STDN BalPure System 

STEP Application 4-3

biological resources are far enough away not to be impacted by water quality changes as a result of the

use of the STDN BalPureTM 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, this alternative would reduce the chance of a release of nonindigenous organisms in ballast 

water discharged 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 probability of establishing a nonindigenous species in Texas’ waters.

4.2 Water Quality

4.2.1 No Action Alternative

Under the No Action Alternative the S/R American Progress with the STDN BalPureTM BP-2000 system 

would not be accepted into 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. The S/R American 

Progress would continue to discharge untreated, un-exchanged ballast into Texas’ waters from the 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 Texas ports (Beaumont and Corpus Christi), organic matter discharged with ballast should not 

increase the input that would have occurred without the implementation of the BWMS. 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 BalPureTM BP-2000 system does not 

significantly affect the total suspended solids, pH, and temperature, these parameters should remain 

unchanged during the course of treatment.

As discussed, the STDN BalPureTM BP-2000 system will discharge a small quantity of sodium bisulfite 

and disinfection byproducts, including THMs and HAA5. Levels of all of these chemicals in the 

discharged water will be negligible, 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 dilution of one) to meet the 

MCL for drinking water standard (see Table 4-1). Should the manufacturer apply for type-approval of the 

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

effects of the residuals 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 which 
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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 regularly submitted reports and is grounds for halting the experiment and 

re-evaluation or disenrollment of the ship from STEP. All discharges must comply with applicable federal 

and state requirements. 
SeaRiver STDN BalPure System 

STEP Application 4-5

Table 4-1: Summary of Discharges with benchmarks and standards

Residual 

Name

Expected 

dischargea

Texas

ecological 

surface water 

benchmarkb

EPA drinking 

water 

standardsc

EPA discharge standards 

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; bfrom TCEQ (2000) and TNRCC 

(2001); cfrom EPA (2008c); dfrom 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 

BalPureTM 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 risk to public health or crew safety. It is 

likely that the STDN BalPureTM 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 hazardous 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 skin, eye, 

and respiratory irritant. There could be adverse consequences to public health and safety if sodium 

hypochlorite is not handled appropriately. Since the system generates the needed NaClO in real time as 

needed from the ambient seawater, this chemical is never a storage risk. The STDN BalPureTM BP-2000

system 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, the filling of bisulfite 

tanks is a very infrequent operation that will be performed by manufacturer-trained personnel, making the 

risk of exposure very low. Sulfur dioxide (SO2) may be discharged while filling the bisulfite tanks and will 

be monitored manually with a hand held device. Phosphoric 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 used by trained personnel, 

making the risk of exposure very low. Hydrogen will be monitored with a hydrogen sensor which alarms in 

the engine room. Presence of hydrogen in the machinery space will be detected by the sensor which will 

trigger an alarm and the STDN BalPureTM BP-2000 system will shut down immediately.

During re-supply and maintenance activities, manufacturers’ personnel will follow the procedures listed on 

Material Safety Data Sheets for handling of ballast water treatment chemicals. Handling of these 
SeaRiver STDN BalPure System 

STEP Application 4-6

chemicals will be similar to handling of boiler system chemicals already existing on the ship. Trained 

responders with first aid equipment are readily at hand. The STDN operations and maintenance 

procedures cover these situations and will be followed 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 BalPureTM

BP-2000 system has been verified to meet vessel construction and safety standards by plan 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 used 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 BalPure System 

STEP Application 5-1

5.0 CUMULATIVE IMPACTS

The Council on Environmental Quality 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, placing 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 No Action alternative, there will be continued discharge of organisms, potentially including NIS,

associated with the S/R American Progress’ current BWM practice 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, these 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 

carrying the same organisms along with the similarity in environmental factors between Gulf of Mexico 

ports, poses 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 activities, 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 

No Action alternative for a single specific 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 

development, implementation, and enforcement of a national BW management program that is protective 

of U.S. waters from NIS introductions. Since only a small number of ships are intended to operate 

experimental treatment technologies, no significant cumulative 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 BalPureTM BP-2000 system to treat all discharged ballast water, 

resulting in reduced concentrations 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 into STEP. There may be 

discharge of some treatment residuals during deballasting into the waters of industrialized ports. These 

additional chemical concentrations are expected 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. However, the 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 robust and effective ballast water management regulatory regime can be promulgated. 
SeaRiver STDN BalPure System 

STEP Application 6-1

6.0 COMPARISON OF THE ALTERNATIVES AND CONCLUSION

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 Minor adverse impacts Minor adverse impacts; potential beneficial 

impacts

Water Quality Minor adverse impacts Minor adverse impacts; potential beneficial 

impacts

Public Health and 

Safety

No adverse impacts Minor 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 BalPureTM 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 dosing BWMS. This information will be critical in the further 

development of effective ballast water management technologies and in the development of feasible and

sound ballast water management policy and regulations as mandated by Congress. Such benefits would 

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 could 

result from the implementation of the Proposed Action. Further, potentially adverse impacts remain with 

the No Action alternative. Additionally, based on the information presented in sections 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 BalPure System 

STEP Application 7-1

7.0 REFERENCES

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

Dibromochloromethane. 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 

Texas ‘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 Following 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. 2006. 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. Animals 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. Essential Fish Habitat. Gulf of Mexico Fisheries Management 

Council. National Oceanic and Atmospheric Administration. 

http://www.nmfs.noaa.gov/habitat/habitatprotection/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 Pacific Freely Associated States. http://www.nccos.noaa.gov/documents/status_coralreef.pdf

(accessed November 15, 2007).

Nautilus Environmental. 2005. Skeletonema costatum Testing for a Proposed Ballast Water Treatment: Hypochlorite 

Solutions 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 National Seashore, US National Park Service (PINS) 2009. http://www.nps.gov/pais/ (accessed: 

September, 2008).

Port of Beaumont. 2008. http://www.portofbeaumont.com (accessed 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 regarding Smithsonian 

Environmental Research Center surveys and databases on nonindigenous aquatic species. 

Sabine River Authority, 2008. Sabine River Basin overview. http://www.sratx.org/basin/overview.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). 

Booklet, 34 pp.
SeaRiver STDN BalPure 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). 2008. 2008 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.

Texas 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 Land 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). 2007a. 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). 2007c. Texas Gems-McFaddin National 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 2004a. 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 2004b. 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). 2008b. ECOTOX Database. 

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

U.S. Environmental 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 Refuges.

http://www.fws.gov/southwest/refuges/texas/mcfaddin/index.html (accessed November 16, 2007).

U.S. Geological Service (USGS) 2007. Non Indigenous Species information page., http://nas.er.usgs.gov/

accessed October 9, 2007.
SeaRiver STDN BalPure System 

STEP Application 8-1

8.0 APPENDIX A. ACRONYMS AND ABBREVIATIONS

BWE Ballast Water Exchange

BWM Ballast Water Management

BWT Ballast Water Treatment

BWMS Ballast Water Management 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 Agency

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 Act 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 National 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 Trihalomethane

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 Compounds
SeaRiver STDN BalPure System 

STEP Application 9-1

9.0 APPENDIX B. EXAMPLE OF SECTION 7 LETTER SENT TO 

RESOURCE AGENCIES. 
SeaRiver STDN BalPure System 

STEP Application9-2
SeaRiver STDN BalPure System 

STEP Application 10-1

10.0 APPENDIX C. CORRESPONDENCE RECEIVED VIA AGENCY 

CONSULTATION.

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; Winston_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-mail 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 Trent 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 onboard 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 discharging/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 Port 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 

oxyrinchus 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 River

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 from 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 case 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 effects 
SeaRiver STDN BalPure System 

STEP Application 10-2

determination for the proposed 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

1875 Century Blvd., Suite 200

Atlanta, Georgia 30345

Phone: (770) 736-7235

EMail: kenneth_graham@fws.go
SeaRiver STDN BalPure System 

STEP Application 11-1

11.0 APPENDIX D. STATE LISTED THREATENED, ENDANGERED, AND 

RARE SPECIES (TPWD, 2008)

JEFFERSON COUNTY

AMPHIBIANS Federal Status State Status

Pig 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

Brown 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

Southeastern 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

Plains 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) Strophitus undulatus

Fawnsfoot Truncilla donaciformis

Little spectaclecase Villosa lienosa

Louisiana pigtoe Pleurobema riddellii

Pistolgrip Tritogonia verrucosa
SeaRiver STDN BalPure System 

STEP Application 11-2

Rock pocketbook Arcidens confragosus

Sandbank pocketbook Lampsilis satura

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 snapping 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 Dermochelys 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 Notophthalmus 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

Eskimo 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

Snowy Plover Charadrius alexandrinus

Sooty Tern Sterna fuscata T

Southeastern Snowy Plover Charadrius alexandrinus tenuirostris
SeaRiver STDN BalPure 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 Anguilla 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 Status

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 LE 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 diamondback 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 elmendorfii

Lila de los llanos Echeandia chandleri

Mexican mud-plantain Heteranthera mexicana
SeaRiver STDN BalPure System 

STEP Application 11-4

Plains gumweed Grindelia oolepis

Slender rushpea Hoffmannseggia tenella LE E

South Texas ambrosia Ambrosia cheiranthifolia LE E

Texas windmill-grass 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 status
SeaRiver STDN BalPure System 

STEP Application 12-1

12.0 APPENDIX E. AIR QUALITY ANALYSIS 

Evaluation of potential for air emissions generated by the use of the 

SevernTrentDeNora BalPure 2000 system on the S/R American Progress

Air quality impacts associated with the BWM technology 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 one air pollutant. There is no circumstance where the S/R 

American Progress will load ballast in Texas. Therefore the BWMS will only be activated when the 

vessel is loading ballast which only occurs at the cargo discharge ports in Florida.

As mentioned above, 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 360 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 for 360 hours annually would result in annual emissions of each 

pollutant 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 

characteristics 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 BWMS; in 

other words, the BWMS 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 Texas. 

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

STEP Application 13-1

13.0 APPENDIX F. EFFLUENT TOXICITY TEST RESULTS 

Toxicity testing was done on water simulated to mimic ballast water treated with the BalPure-2000. 

Results of those test follow:
SeaRiver STDN BalPure System 

STEP Application 13-2
SeaRiver STDN BalPure System 

STEP Application 13-3
SeaRiver STDN BalPure System 

STEP Application 13-4
SeaRiver STDN BalPure System 

STEP Application 13-5
SeaRiver STDN BalPure System 

STEP Application 13-6
SeaRiver STDN BalPure System 

STEP Application 14-1

14.0 APPENDIX G: MATRIX OF COMMENTS AND RESPONSES

Docket 

Number

Commenter(s) Comment Coast Guard’s Response

USCG2008-

0126

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 of 

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.

USCG2008-

0126

CSLC The commenter stated that the 

last sentence of Section 1.1, 

paragraph 1 seemed to indicate 

that yearly reports are required 

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 indicates that reports are required yearly.

USCG2008-

0126

CSLC The commenter requested 

elaboration for Section 1.3, 

paragraph 2, and inquired as to if 

there was a required holding 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.

USCG2008-

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..

USCG2008-

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.

USCG2008-

0126

CSLC The commenter asked 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 

regulations for National Environmental Policy Act of 1969 

(NEPA) compliance/

USCG2008-

0126

CSLC The commenter wanted to know 

what “availability” of the BWM 

system meant in Section 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.

USCG2008-

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 

treated by the experimental 

The Coast Guard 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 the 
SeaRiver STDN BalPure 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 decision by the 

USCG.”

.

USCG2008-

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-existing 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 system 

have been thoroughly evaluated and inspected by the Coast 

Guard, the owner, the flag state and the ship’s classification 

society. 

USCG2008-

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 can 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.

USCG2008-

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.

USCG2008-

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 ensure 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 order to clarify these 

concerns.

USCG2008-

0126

CSLC The commenter wanted to know 

how long are these three tanks of 

sodium bisulfate expected to last, 

and how often they are expected 

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.

USCG2008-

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 as 
SeaRiver STDN BalPure System 

STEP Application 14-3

2008-

0126

clarification 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 dictated. 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: “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 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.”

USCG2008-

0126

CSLC The commenter asked for a more 

recent data set for plankton 

populations in Section 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 the affected environment; however if more recent data 

are available, we welcome their submission.

USCG2008-

0126

CSLC The commenter requested more 

information concerning 

background 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 

background 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 water quality laws. The 

Coast Guard welcomes the submission of any data regarding 

background levels of disinfection byproducts in the affected 

environment.

USCG2008-

0126

CSLC In Section 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 water, exchanging ballast water is currently a permissible 

option as long as a vessel can do so in accordance with 

applicable regulations.. 

USCG2008-

0126

CSLC The commenter wanted 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 residuals 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.

USCG2008-

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, paragraph 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 dosage 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 in 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 include 
SeaRiver STDN BalPure System 

STEP Application 14-4

Oxyrrhis marina) may have 

played a significant 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 of 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.

USCG2008-

0126

CSLC The commenter requested 

clarification 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 year of operation, who 

the responsibility lies with in 

performing maintenance and resupply 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 reflect that the manufacturer will provide training for the 

ship’s personnel to operate the system. 

USCG2008-

0126

CSLC The commenter asked: 

“[f]ollowing the first year of 

operation, 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.

USCG2008-

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 that the potential for adverse impacts 

due to additional DBPs as a result of the S/R American 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 American 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 treatment technologies and 

as such, no significant cumulative impacts from the proposed 

action are expected.

USCG2008-

0126

CSLC In Section 4.1.2, Biological 

Resources, Proposed Action 

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 compare 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 BalPure System 

STEP Application 14-5

treatment system. The 

commenter suggested adding a 

table.

USCG2008-

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 to 

improve readability.
SeaRiver STDN BalPure 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

Southeast 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 Service

Clear Lake Ecological Services Field Office

Dr. Nader Elkassabany

U.S. Environmental Protection Agency

Office of Pesticides Programs and Toxic Substances

Washington, D.C.