# Page 1 of 1



# Telephone Record

Date: February 23, 2012

From: Mary Willett To: Mr. Peter McNulty

Company: ERG NEI Marine

Phone #: 213-383-5855

RE: Feasibility of Ballast Water Treatment (BWT) for Sma ll Vessels

Identified myself and the purpose of my call. Indicated that we are not authorized to handle CBI and information provided could be made public witho ut notice.

Asked about capacity of BWT systems for small vessels. Mr. McNulty did not have any information on capacity for smaller vessels.

Asked about feasibility and safety of using deoxygenation/ca vitation for smaller vessels. Mr. McNulty commented that he believed the technology could be scaled down for use with small vessels and that they looked at lab-scale uni ts several years ago when they were first developing the technology for larger vessels. He thought that the technology would not be used on passenger vessels (and they have made a decision not to recommend it for cruise ships) because of the potential proxi mity of deoxygenation equipment to a passengers room. For smaller vessels it is possible that smaller compressed gas cylinders for use in the BWT system may be possible and could be

automated for use.

Asked about effectiveness of the technology and whether he thought it would be as

effective if scaled down to a small vessel. Mr. McNu lty commented that the technology should be just as effective regardless of the size.

Asked what the limiting issues would be to try to incorporate the deoxygenation/cavitation BWT technology onto a small vesse l. Mr. McNulty commented that space might be the most limiting factor, however noted that one of the first prototypes was installed on a large tug boat (with part of the system on the tug and part on barge)

Asked if he was aware of any costing data for smaller ty pe systems. Mr. McNulty commented that he was not aware of any costing data for smaller systems. For their technology the costs generally go up as the size decreas es, however, if the system were designed with small compressed gas cylinders you could make it more cost effective.

# Telephone Record

Date: February 22, 2012

From: Mary Willett To: Mr. Jon Stewart

Company: ERG IMTC

Phone #: 954-565-4044

RE: Feasibility of Ballast Water Treatment (BWT) for Sma ll Vessels

Identified myself and the purpose of my call. Indicated that we are not authorized to handle CBI and information provided could be made public witho ut notice.

Asked about capacity of BWT systems for small vessels. Mr. Stewart indicated that the smallest systems he h as seen have a 100 m3/hr capacity.

Asked whether it is feasible to scale BWT technologies t o vessels that are <1,600 metric

tons or have ballast tanks <8 m3. Mr. Stewart felt that many BWT systems could be scaled down. However, the economics of designing such systems have precluded the vendor industry f rom looking at what

would be considered a “niche” market. It is still not a ro bust market even for the systems that have been designed and tested for large vessels. He commented that UV and electrolytic chlorination systems exist for swimming poo ls and “under the sink” drinking water systems that are essentially scaled down versio ns of the some of the technologies used for ballast water. He commented that the industry uses electrolytic systems for cooling water on ships. He thought that stand alone technolo gies (UV, ozone, filter) would lend themselves better to scaling down compared to more complicated integrated process systems. He indicated that there is not a pur e chemical solution to BWT at this point and integrated technologies are required to address th e problem. He also commented that scaling down deoxygenation type systems woul d likely be more difficult than chemical based systems.

Asked whether there is a minimum footprint for BWT syste ms on small vessels. Mr. Stewart commented that if the smallest BWT syste m available now is 100 m3/hr, that size of a system would be too big for placement on a smal l vessel.

Asked whether a scaled down BWT system would be likely to c reate weight concerns. Mr. Stewart felt that scaling down a system would resu lt in a similar drop in the system’s weight.

Asked about any safety issues with the use of BWT systems on smaller vessels.

# Page 2 of 2

Mr. Stewart commented that whatever system was design ed for a smaller vessel would still need to meet the same safety requirements of th e systems available now so the same safety measures would apply regardless of the system siz e.

Asked if he thought scaled down technology would be as eff ective as current systems and likely to comply with the IMO D-2 standards. Mr. Stewart indicated that for technologies, such as c hemical dosing systems, so long as the appropriate dose of chemical is applied it wouldn’t matt er what the system size was and he did not think that scaling down the technology woul d be likely to impact its

effectiveness for treatment.

Asked what the limiting issues would be for trying to incorpor ate BWT technology to

smaller vessels. Mr. Stewart had several points regarding the feasibility of trying to incorporate BWT to

smaller vessels as follows:

1. The small vessel market would be a niche market for techn ology developers.

2. He did not think that smaller BWT systems would be econ omically viable given the required design costs that would be required. These sy stems are not currently available and would require specific design for automatio n and installation into

smaller vessels.

3. Any system will require certification to meet the curr ent requirements including land testing at 200 m3/hr.

4. Use of these systems on smaller vessels will still require meeting monitoring and reporting requirements and Mr. Stewart felt that these r equirements would be costly for smaller vessels.From: "M. Merksamer" <marcie.merksamer@ecochlor.com>

To: "'Mary Willett'" <Mary.Willett@erg.com>

CC: <tom.perlich@ecochlor.com>

Date: 2/23/2012 7:00 PM Subject: RE: Feasibility of Filter + Chlorine Dioxide Balla st Water Treatment Systems to Small Vessels

Attachments: Ralph Michael.vcf

Dear Ms. Willet,

Thank you for your inquiry. At this time, the very small treatment systems that would be required for the vessels you are seek ing information for are not Ecochlor's target market.

For smaller treatment systems, Ecochlor refers inqu iries to Mahle, which offers a UV/Filtration ballast water treatment syst em. I've included

contact information below.

Ralph Michael

If I can be of further assistance, please let me kn ow.

Best Regards,

Marcie Merksamer

Regulatory Consultant/Compliance Manager

Ecochlor, Inc.

P.O. Box 2136

Pismo Beach, CA 93448

Phone: 805-331-0740

Fax: 805-473-3961

marcie.merksamer@ecochlor.com

www.ecochlor.com

From: Mary Willett [mailto:Mary.Willett@erg.com] Sent: Wednesday, February 22, 2012 9:59 AM

To: marcie.merksamer@ecochlor.com Subject: Feasibility of Filter + Chlorine Dioxide B allast Water Treatment Systems to Small Vessels

Ms. Merksamer:

Hello, I am Mary Willett an engineer with ERG. We are a technical contractor for EPA's Office of Wastewater Managemen t and are supporting EPA

in their evaluation of the Vessel General Permit. As part of that effort, we are supporting EPA in evaluating whether ballast water treatment systems are feasible for smaller vessels. Specifically, wh ether they might be

feasible for commercial vessels that are smaller th an 1,600 metric tons

and/or vessels with ballast tanks smaller than 8 cu bic meters. I would like to see if you could provide some information about the feasibility of a filter + ClO2 system for smaller vessels.

Under our EPA contract for this work, we are not au thorized to handle
Confidential Business Information. Therefore, I wo uld like to see what information you could provide that could be made pu blic without notice. If you have information that would be useful but would need to be handled as CBI, I can provide you with contact information for our EPA client and theinformation could be sent directly to him. [Ryan A lbert, EPA/OWM, Program

Manager for Vessel General Permit]

The types of vessels that fall into these smaller s ize categories include:

commercial fishing vessels,

freight ships (such as a Gate Lifter or general car go),

passenger vessels (such as crew boats, inland river towboats, vessels for less than 100 passengers, small cruise boats, and s mall ferries),

utility vessels (such as liftboats, offshore crewbo ats and supply vessels, tug boats, etc.)

Do you know of any Ballast Water Treatment (BWT) sy stems currently being marketed that would be applicable to a smaller vess el? The smallest systems

that we have identified as available are for at lea st 100 m3/hr. Do you know of any smaller?

Would be it feasible to scale a filter + ClO2 BWT t echnology to vessels < 1,600 MT?

If a filter + ClO2 system were scaled down to you k now whether its footprint could be made small enough to fit on a smaller vess el?

Can you estimate what the weight of such a system w ould be? [would be likely that if a system could be scaled down its weight wo uld also be lower]

Would there be safety issues with the use of a filt er + ClO2 BWT technology

on a smaller vessel that would be different than on a larger vessel?

Would a scaled down version of the technology be as effective and likely to comply with the IMO D-2 standards?

What would you see as the limiting issues for tryin g to incorporate a filter + ClO2 BWT technology into a smaller vessel? (for example, design costs, the footprint of the technology, cost, effectivenes s of treatment, complexity of the system?)

Are you aware of any costing information that would apply to a scaled down BWT technology system?

I understand from your voicemail that you are out this week and will try to contact you next week when you are back. Any infor mation that you might have to address these issues is greatly appreciated !Mary R. Willett

Mary R. Willett

ERG (703) 633-1615 mary.willett@erg.comFrom: Mark Riggio <MRiggio@hydemarine.com>

To: "Mary Willett" <Mary.Willett@erg.com>

CC: Jim Mackey <JMackey@hydemarine.com>, "Tom Mackey" <TMackey@HydeMarine.com>

Date: 2/24/2012 11:38 PM Subject: Re: Fwd: Feasibility of Ballast Water Treatment Sy stems to Small Vessels

Mary:

Thank you for your email and interest in our system . With Jim out of the office this week, I took a f ew minutes today to get you the information you requested. The answers to your questions are l isted below:

Do you know of any BWTS that are currently being ma rketed that would be applicable to a smaller vessel ? Yes, the Hyde GUARDIAN HG60 is a UV/Filter treatment system designed specifical ly for low flow, space constrained locations. We d esigned this product with the small vessel

market in mind.

Would it be feasible to scale a solids separation a nd UV BWT technology to vessels <1600 MT? Absolute ly.

If a solids separation and UV system were scaled do wn, do you know whether its footprint could be made small enough to fit on a smaller vessel? We currently install our systems on offshore supply vessels and are in the process of installing in a small passenger tour-vessel in the Great Lakes for the National Parks Service. Each of these appl ications have very narrow space restrictions. The footprint of our HG60 skid-mounted system is 2.1m long x 1.5m wide. This system, however, ma y be further broken down in size as a component sys tem.

Would it be likely that if a system could be scaled down its weight would be low enough not to create stability issues in smaller vessels? Yes. Our HG60 system weighs less 1000 kg including the s kid.

Would there be safety issues with the use of a soli ds separation and UV BWT technology on a smaller ve ssel that would be different than on a larger vessel? No, there would be no difference fo r our system between a large or small vessel.

Would a scaled down version of the technology be as effective and likely to comply with the IMO D-2 st andards.? Yes. Our scaled down HG60 is one of our highest performing systems based upon computational flow dynamics analysis. The small s ize of the reactor shell combined with the relatively low flow rates exposes the stream to a high dose of UV in relation to our larger reacto rs.

What would you see as the limiting issues for tryin g to incorporate a solids separation and UV BWT tec hnology into a smaller vessel? Primary limitations on these applications are power require ments, pump configuration and initial installation of the equipment. Access to piping and engine spaces is restricted to bring larger items i nto them, which means accesses may need to be cut i n the hull or superstructure to install the systems. Also, as smaller vessels often use multi- purpose pumps for ballasting, their performance cur ves, piping configurations and location in the engine room may create specific challenges to r etrofit.

Are you aware of any costing information that would apply to a scaled down BWT technology system? An HG60 skidded system would cost less than $200,000 for typical installations. Inst allation costs would be separate.

Hopefully that helps. Please feel free to contact me if you need any additional information.

Best regards,

Mark Riggio

Hyde GUARDIAN Product Manager

+1.412.298.5772

mriggio@hydemarine.com

-----Jim Mackey/HQPGH/CCC wrote: -----

To: "Mary Willett" <Mary.Willett@erg.com> From: Jim Mackey/HQPGH/CCC

Date: 02/22/2012 05:50PM Cc: "Mark Riggio" <MRiggio@hydemarine.com>, "Tom Ma ckey" <TMackey@HydeMarine.com> Subject: Re: Fwd: Feasibility of Filter + Chlorine Dioxide Ballast Water Treatment Systems to Small Ve sselsDear Ms Willett,

Thank you for your questions. We won't be able to reply in detail until next week but I will tell you that Hyde does have a type approved BWT system using filtration and UV (no chemicals) with approved capacity lower than 100 m3/hr. Hyde GUARD IAN Model HG60 (60 m3/hr) that has been ordered for projects in 30 to 60 m3/hr ran ge. We have delivered a number of these and so hav e a rather unique perspective on this subject. Thank you for the opportunity to cooperat e in your study. Best regards, Jim Mackey mob: +1(440)725-3813 ----- Original Message ----- From: "Mary Willett" [Mary.Willett@erg.com]

Sent: 02/22/2012 04:07 PM EST To: Jim Mackey Subject: Fwd: Feasibility of Filter + Chlorine Di oxide Ballast Water Treatment Systems to Small Vess els

Mr. Mackey:

Hello, I am Mary Willett an engineer with ERG. We are a technical contractor for EPA's Office of Wast ewater Management and are supporting

EPA in their evaluation of the Vessel General Permi t. As part of that effort, we are supporting EPA i n evaluating whether ballast water treatment systems are feasible for smaller vessels. Specifically, whether they might be feasible for commercial vessels that are smaller than 1,600 metric tons and/or vessels with ballast tanks smaller than 8 cubic meters. I would like to see if you could provide some information about the feasibility of using a solids separation and UV system for smaller vessels.

Under our EPA contract for this work, we are not au thorized to handle Confidential Business Informatio n. Therefore, I would like to see what information you could provide that could be made pu blic without notice. If you have information that would be useful but would need to be handled as CBI, I can provide you with contact info rmation for our EPA client and the information coul d be sent directly to him.

The types of vessels that fall into these smaller s ize categories include: commercial fishing vessels, freight ships (such as a Gate Lifter or general car go), passenger vessels (such as crew boats, inland river towboats, vessels for less than 100 passengers, sm all cruise boats, and small ferries), utility vessels (such as liftboats, offshore crewbo ats and supply vessels, tug boats, etc.)

Do you know of any Ballast Water Treatment (BWT) sy stems currently being marketed that would be applic able to a smaller vessel? The smallest systems that we have identified as availab le are for at least 100 m3/hr. Do you know of any smaller?

Would be it feasible to scale a solids separation a nd UV BWT technology to vessels < 1,600 MT?

If a solids separation and UV system were scaled do wn to you know whether its footprint could be made small enough to fit on a smaller vessel?

Would it be likely that if a system could be scaled down its weight would be low enough not to create stability issues in smaller vessels?

Would there be safety issues with the use of a soli ds separation and UV BWT technology on a smaller ve ssel that would be different than on a larger vessel?

Would a scaled down version of the technology be as effective and likely to comply with the IMO D-2 st andards?

What would you see as the limiting issues for tryin g to incorporate a solids separation and UV BWT tec hnology into a smaller vessel? (for example, design costs, the footprint of the technol ogy, equipment cost, effectiveness of treatment, co mplexity of the system?)

Are you aware of any costing information that would apply to a scaled down BWT technology system?

I understand from your voicemail that you are out t his week and will try to contact you next week when you are back. Any information that you might have to address these issues is greatly appre ciated!

Mary R. Willett Mary R. Willett

ERG (703) 633-1615 mary.willett@erg.com This email and attachment(s) contain proprietary an d/or confidential information which is protected fr om disclosure. It is for the sole use of the intended recipient(s) and any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient(s),please contact the sender by reply email and destroy the o riginal message and any copies of the message as we ll as any attachment(s) to the original

message.

This email is for your information only and is not intended to be legally binding. Neither Calgon Car bon Corporation nor its affiliates or subsidiaries will have any legally binding obligati on until execution by both parties of formal contra ct documents, all of the terms of which, including the terms herein, must first have been re viewed and approved by Calgon Carbon Corporation 217;s Management and/or, if required by Calgon Carbon Corporation’s authority limi tations, its Board of Directors.

# Telephone Record

Date: February 27, 2012

From: Mary Willett To: Mr. Mario Tamburri

Company: ERG University of Maryland, Center for Envr. Science

Phone #: 410-326-7440

RE: Feasibility of Ballast Water Treatment (BWT) for Sma ll Vessels

Identified myself and the purpose of my call. Indicated that we are not authorized to handle CBI and information provided could be made public witho ut notice.

Asked about capacity of BWT systems for small vessels. Mr. Tamburri indicated that for small vessels (such as fishing boats and small passenger vessels) it is likely that the boat is taking on ballast to replace the fuel as it is used or potentially to help during severe

weather conditions that dictate the need for more bal last. For these purposes the ballast

water rate would be slow.

Asked if he thought it would be feasible to scale down the current existing technologies to small vessels. Mr. Tamburri commented that yes, cur rent technologies can be scaled down and specifically mentioned the potential for UV and e lectrochlorination systems. For small ballast needs (to replace fuels) there are ot her options than ballast water treatment. Specifically, the NOAA research fleet is looking at ballast water from potable water systems that would be on the ship, or use of city potable water. Alternatively, boat route changes are an option that would allow a boat to avoid leaving an invasive species

zone.

Asked if he thought there would be safety issues associat ed with small vessel BWT technologies vs. large vessel safety issues. Mr. Tam burri indicated that he didn’t think there would be additional safety issues that would arise w ith small vessels.

Asked if he thought the BWT systems in use now would be as effective at treatment if scaled down. Mr. Tamburri felt that existing BWT technol ogies would be as effective on small vessels as large.

Asked what he thought the limiting issues would be in trying to incorporate BWT technologies onto small vessels. Mr. Tamburri indicat ed that space and power consumption needs would likely be the biggest limiting fact ors and that the holding time required by the BWT technology could also be an issue.

# Page 2 of 2

Asked if he was aware of any costing data sources. Mr. T amburri was not aware of any costing data for smaller systems. He felt that the i nitial purchase price of the BWT system would lower for small systems but that the engi neering design costs would likely be similar to those incurred for larger vessels. The inst allation costs could be lower.

# Page 1 of 1



# Telephone Record

Date: February 27, 2012

From: Mary Willett To: Mr. Jim Mackey

Company: ERG Hyde Marine

Phone #: 440-725-3813 (cell)

RE: Feasibility of Hyde Marine Ballast Water Treatment (BW T) for Small Vessels

I sent email to Mr. Mackey that identified myself and th e purpose of my contact, indicated that we are not authorized to handle CBI, and indicated information provided could be made public without notice. He responded to my ema il with a phone call. He was also aware of the email response that I had from M ark Riggio of Hyde Marine on February 24, 2012.

I asked about the smallest capacity of the Hyde Marine B WT system for small vessels. Mr. Mackey indicated that the smallest system that Hy de Marine markets for small vessels has a process capacity as low as 30-35 m 3 

# /hr (which is about 100 gallons/minute).

He indicated that this would be the minimum flow rate for the system and below that rate they would need to look at the system design. He also no ted that for smaller vessels there may be a minimum pumping capacity since you would combine bal last pumping with fire fighting pumping rather than have a separate pump.

I asked Mr. Mackey specifically about challenges for smal ler vessel ballast water treatment systems. He noted the following issues that should be considered:

1. Modular treatment design is important for small vessels due to space constraints.

2. Smaller vessels have limited holding time for the balla st tanks and the ballast water treatment systems that require significant holdi ng times may not work. He noted that the filtration + UV system Hyde Marine marke ts does not have a minimum holding time for efficacy.

3. Smaller vessels may operate in “brown water condition s” unlike larger vessels and operation of a system with high sediment could be an issue for smaller

vessels.

4. Some smaller vessels (research vessels) may operate in very cold climates and he

noted that some of the ballast water treatment techno logies do not operate or do not operate at full efficiency below certain temperat ures.

Mr. Mackey indicated that they will have an article i n the March issue of Marine News

on ballast water treatment for small vessels. He wa s not aware of any published costing data for small systems but they would be willing to provide a quote if requested.From: "DJ Seo 서 서서 " <djseo@techcross.com>

To: <mary.willett@erg.com>

Date: 3/16/2012 7:41 AM Subject: RE: Feasibility of Electro-Clean Ballast Water Tre atment System toSmall Vessels

Attachments: CSLC_update_on_BWTS-Summary_ENG.pdf; ECS_Models.jp g; ECS150Bx1Set_Footprint.pdf; TP_201202_109_ECS150Bx1Set.pdf

Dear Mary R. Willett

Good day to you.

This is DJ Seo at the sale and marketing department of Techcross. We would like to send you this email to answer for your questions.

The answers are below.

Do you know of any Ballast Water Treatment (BWT) sy stems currently being marketed that would be applic able to a smaller vessel? The smallest systems that we have identified as availab le are for around 100m3/h. Do you know of any small er?

l First, please note that our system name is “Elec tro Cleen System” not “Electro Clean System”. l ECS-150B Type which has been developed by Techcr oss and Type Approved is the smallest BWMS for arou nd 100m3/hr. Techcross is also in the process of developing stage for even smallest c apacity of 50m3/hr. As we understand, the other sys tems such as UV and injection type systems with filters and TRO generators require lar ger foot prints than ECS without filter. The techni cal proposal (“TP_201202_109_ECS150Bx1Set”) and footprint of ECS 150B (“ECS150Bx1Set_Footprint”) are attached.

Would be it feasible to scale the Electro-Clean tec hnology to vessels < 1,600 MT?

l It depends on the structure and installation spa ce of the vessels for BWMS. As other electrical equ ipments – Auto Neutralization Unit (ANU), TRO Senor Unit (TSU), and Power Distributor Equipme nt (PDE) -- are able to be installed in any place i ndependently, if ECU (the main part of ECS and which requires modification on main ballast pipeline after the ballast pump) can be installed at the main ballast pipe line, it is feasible to fit to vessels < 1,600 MT. l Development of newly upgraded ECS-B type which i s simpler than ECS-A type has been completed and ju st waiting for type approval. Also, Techcross is developing much smaller and simpler ve rsion of ECS than ECS-B type.

If your system were scaled down, do you know whethe r its footprint could be made small enough to fit o n a smaller vessel?

l Techcross can assure that ECS-B type is small en ough to fit on a smaller vessels or vessels having smaller space for BWMS installation. The system would not need to be scaled down to make it suitable for any smaller vessels.

Can you estimate what the weight of such a system w ould be? [would be likely that if a system could be scaled down its weight would also be low enough not to create stability issues in the ve ssel]

l ECS150B is small and simple enough to treat 100m 3/h. You can find the information on the weight as per the attached technical proposal. Please review the attachment, “TP_201202_109_ECS150 Bx1Set”.

Would there be safety issues with the use of Electr o-Clean technology on a smaller vessel that would b e different than on a larger vessel?

l There would not be any safety issue, as small EC S like ECS150B does not have any difference from la rge ECS like ECS1000B in term. Only the size of the chamber is getting larger as the ca pacity of the chamber is getting bigger. Please rev iew the attached file, “ECS_Models“; then, you can find what the differences between ECS150 an d ECS1000.

Would a scaled down version of the technology be as effective and likely to comply with the IMO D-2 st andards?

l The scaled down version of technology would be e ffective enough to comply with the IMO D-2 standard , as all ECS models have the appropriate level of its performance depending on i ts capacity. Please find the attached file called “ CSLC_update_on_BWTS-Summary_ENG” which proves all types of ECS can comply with IMO D -2 standard.

What would you see as the limiting issues for tryin g to incorporate a BWT technology (like Electro-Cle an) into a smaller vessel? (for example, design costs, the footprint of the technology, equi pment cost, effectiveness of treatment, complexity of the system?)

l Since existing vessels (especially small vessels < 1,600 MT) were constructed without considering s ufficient installation space for BWMS, making installation space in vessels in order to in stall ECS would be an issue

Are you aware of any costing information that would apply to a scaled down BWT technology system?

l ECS150B costs about U$150K for system price only and we expect even lower cost for smaller version. l Currently, ECS150B is the smallest size of BWMS in the lineup. However, the smaller ECS is being de veloped to meet the demands of theBWMS market. As it is an on-going project, data for expected R&D costs for the scaled down project are not available.

The files we mentioned on this email are attached. Please find the attachments, and if there are any a ttachments you cannot read, do not hesitate

to contact us. Also, if you have other requests or questions, plea se give us an opportunity of providing you with the feedbacks.

Thank you for your time. We hope that you are satis fied with our answers for your questions.

Sincerely,

DJ Seo.

----------Origin Message---------- From: Mary.Willett@erg.com (Mary Willett) To: mike@techcross.net;

Cc:

Date: 2012/02/23 03:47 Subject: Feasibility of Electro-Clean Ballast Water Treatment System toSmall Vessels

Mike:

Hello, I am Mary Willett an engineer with ERG and h ave your contact information from Shirley Fan of EP A. We are a technical contractor for EPA's Office of Wastewater Management and are suppo rting EPA in their evaluation of the Vessel General Permit. As part of that effort, we are supporting EPA in evaluating whether ballast water treatment systems are feasible for smaller vessels. Specifically, whether they might be

feasible for commercial vessels that are smaller th an 1,600 metric tons and/or vessels with ballast ta nks smaller than 8 cubic meters. I would like to see if you could provide some information about the feasibility of a electrolysis/residual hypochlo rite system for smaller vessels. If you would prefer to talk to me by phone about any of this ple ase give me a call at 703-633-1615.

Under our EPA contract for this work, we are not au thorized to handle Confidential Business Informatio n. Therefore, I would like to see what information you could provide that could be made pu blic without notice. If you have information that would be useful but would need to be handled as CBI, I can provide you with contact info rmation for our EPA client and the information coul d be sent directly to him.

The types of vessels that fall into these smaller s ize categories include: commercial fishing vessels, freight ships (such as a Gate Lifter or general car go), passenger vessels (such as crew boats, inland river towboats, vessels for less than 100 passengers, sm all cruise boats, and small ferries), utility vessels (such as liftboats, offshore crewbo ats and supply vessels, tug boats, etc.)

Do you know of any Ballast Water Treatment (BWT) sy stems currently being marketed that would be applic able to a smaller vessel? The smallest systems that we have identified as availab le are for around 100 m3/hr. Do you know of any sm aller?

Would be it feasible to scale the Electro-Clean tec hnology to vessels < 1,600 MT?

If your system were scaled down do you know whether its footprint could be made small enough to fit on a smaller vessel?

Can you estimate what the weight of such a system w ould be? [would be likely that if a system could be scaled down its weight would also be low enough not to create stability issues in the ve ssel]

Would there be safety issues with the use of Electr o-Clean technology on a smaller vessel that would b e different than on a larger vessel?

Would a scaled down version of the technology be as effective and likely to comply with the IMO D-2 st andards?

What would you see as the limiting issues for tryin g to incorporate a BWT technology (like Electro-Cle an) into a smaller vessel? (for example, design costs, the footprint of the technology, equi pment cost, effectiveness of treatment, complexity of the system?)

Are you aware of any costing information that would apply to a scaled down BWT technology system?

Also, Shirley Fan asked that we let you know that R yan Albert (EPA/OWM) will be getting back to you an d is waiting to get more information from USCG. Any information that you might have to address these issues is greatly appreciated!

Mary R. Willett Mary R. Willett

ERG (703) 633-1615 mary.willett@erg.com

# Page 1 of 1



# Telephone Record

Date: March 27, 2012

From: Mary Willett To: Ms. Allegra Cangelosi

Company: ERG Northeast Midwest Institute (NEMW)

Phone #: 202-464-4014

RE: Ballast Water Treatment (BWT) for Small Vessels

Identified myself and the purpose of my call. Indicated that we are not authorized to handle CBI and information provided could be made public witho ut notice.

Asked about the size of vessels studied by the Great Ships Initiative, explained the vessel types we believe to be in the “small vessel” category ( < 1,600 grt and ballast tank size > 8 m3), and asked which technologies Ms. Cangelosi was aware of that would be candidates

for small vessel ballast water treatment.

Ms. Cangelosi indicated:

The smallest vessel studied by the Great Ships Initiativ e for ballast water treatment was a cruise ship (the Regal) which had ballast water flow rate s in the 200 - 300 m3/hr range.

Other ballast water treatment technologies that she would recommend for analysis on small vessels include a ultrasonic technology (she will send contact information on the vendor/developer of this technology), UV (though the qualit y of water will impact how well this technology can work), and filtration (she note d that 25 micron vs. 50 micron filters may be feasible but do create greater backwashing f low).

Asked whether she was aware of any data sources that would help define the ballast tank size or ballast water flow rates that apply to small v essels. Ms. Cangelosi indicated:

She was not aware of any specific sources to look at to i dentify typical ballast water tank size or flow rates for "small vessels" but did suggest tha t contacting the trade associations representing the various vessel types (e.g., tug boats et c.) might result in information of

this nature.