Organization Name:

Note: Representatives submitting on behalf of an organization must enter information below.

Requestor Representative:

Section 301 Investigation: China's Acts, Policies, and Practices Related to Technology 

Transfer, Intellectual Property, and Innovation - Form to Request Exclusion of Product

When submitting a product exclusion request using this form, enter the specified 

information in the following fields and explain the basis and rationale for your statements. 

By completing this form, you certify that the information provided is complete and 

correct to the best of your knowledge. 

1. Indicate whether the comment contains business confidential information (BCI), is a public

document, or is a public version of a BCI document.

3.

2. Please provide a complete and detailed description of the particular product of concern:

4.

*

10-digit HTSUS item number* for product you wish to address in this product exclusion request:

Use numerical characters only with no special characters (example: 1023456789). For help in finding

the HTSUS item number associated with your product, see https://hts.usitc.gov/

7.

5. Requestor's relationship to the product:

6. Does this submission in regulations.gov include additional attachments?

Please indicate whether any additional attachment contains business confidential information 

(BCI), is a public document, or is a public version of a BCI document.

Requestor Information

Requestor Name (Last, First):

VERSION 2 CONTINUED BELOW 1
8. Is this product, or a comparable product, available from sources in the United States? (If you

9. Is this product, or a comparable product, available from sources in third countries? (If you

10. Please provide the value and quantity (with units) of the Chinese-origin product of concern

that you purchased for each calendar year specified. Limit this figure to the products

purchased by your firm (or by members of your trade association) alone. Please provide

estimates if precise figures are unavailable.

2017 Value: 

2016 Value: 

2015 Value:

2017 Quantity: 

2016 Quantity: 

2015 Quantity:

% of your total gross sales in 2017 that the Chinese-origin product accounted for.

% of the total cost of producing the final product(s) the Chinese-origin input 

accounts for.

% of your total gross sales in 2017 that sales of the final product(s) incorporating 

the input accounted for.

VERSION 2 CONTINUED BELOW 2

indicate "NO", you must provide support for your assertion in Box 12).

indicate "NO", you must provide support for your assertion in Box 12).

11. Is the Chinese-origin product of concern sold as a final product or an input used in

a) For imports sold as final products, please provide:

b) For imports of inputs used in the production of final products, please provide:

the production of a final product or products?
12. Please provide information in support your request, taking account of the

VERSION 2 END 3

instructions provided in Section B of the Federal Register notice. If you

responded "NO" to Questions 8 or 9, you must provide support for your

assertion in the box below. (Note: text entered below can extend beyond the

apparent size of this box).
1 

VIA ONLINE SUBMISSION

October 9, 2018 

Ambassador Robert Lighthizer 

U.S. Trade Representative 

Office of the U.S. Trade Representative 

600 17th Street NW 

Washington, DC 20508 

Re: Great Lakes Dredge & Dock Company, LLC Product Exclusion Request for 

5GP2 Dredging Cutting Teeth Imported from China (HTSUS 8431.49.9020) 

Dear Ambassador Lighthizer:

Great Lakes Dredge & Dock Company, LLC (“Great Lakes”) hereby submits its

exclusion request for certain sole source supplies of dredging equipment from the Section 301 

tariffs enacted against products from the People’s Republic of China (“China”). We are 

requesting an exclusion for 5GP2 Dredge Pick Point Cutting Teeth purchased from ESCO, 

imported under HTSUS 8431.49.9020. ESCO is the sole source of those patented products and 

currently only manufactures those products in China. Certain on-going and near-term Great 

Lakes dredging projects in the United States require use of those 5GP1 cutting teeth that wear 

out with use. 

Great Lakes is the largest provider of dredging services in the United States and the only 

U.S. dredging company with significant international operations. Great Lakes is a longtime 

government contractor, and our largest client is the U.S. Army Corps of Engineers (the 

"Corps"). Because we work at several key U.S. ports of entry on behalf of the government, our 

work has critical implications for national security as well as the U.S. economy. As of 

December 31, 2017, we had 1,737 full-time, part-time and seasonal workers. If we are 

successful on our strategic growth plan, we will increase that number in the future. In fact, we 

recently relocated a large domestic cutter dredge back to the U.S. from the Middle East to work 

on major port deepening projects. 

The Section 301 tariffs have already caused economic harm by increasing our supply 

costs. Because our main client is the federal government, the burden of increased costs will fall 

on U.S. taxpayers. Historically, 63-64% of our dredging revenue comes from federal 

government projects administered by the Corps; this year, that number is closer to 70%. Thus, 

the cost of these tariffs is felt not only in higher operational costs and corresponding smaller 

revenues, but also in higher direct costs to the U.S. government, and U.S. taxpayers, as our main 

client. The Section 301 tariffs also threaten our ability to complete essential projects, because 

we have no other alternative source for 5GP2 Dredge Pick Point Cutting Teeth besides ESCO 

Corporation, which manufactures the equipment in China and possesses its sole patent rights. 

 I. Who We Are
2 

II. A Complete and Detailed Description of Our Services and Products

In our 128-year history, Great Lakes has never failed to complete a marine project. Great 

Lakes owns and operates the largest and most diverse fleet in the U.S. dredging industry, 

comprised of over 200 specialized vessels. Providing environmental and remediation services on 

both land and water, we employ civil, ocean and mechanical engineering staff for our 

estimating, production and project management functions. Great Lakes has a disciplined 

training program for engineers that ensures experience-based performance as they advance 

through Company operations. A number of our current projects involve maintaining the 

navigability of major ports and critical waterways, which are projects of national significance 

because they promote national security and commercial interests. Waterway transportation is 

vitally important to U.S. commercial interests and increasing the cost of maintaining those 

systems, or worse – not maintaining them because of cost – causes U.S. industry to suffer. Port 

deepening and widening projects (also known as "capital dredging" projects are also of national 

significance; East Coast and Gulf Coast ports in particular must develop deeper channels and 

wider turning basins to stay competitive worldwide. 

Great Lakes uses Dredge Pick Point Cutting Teeth in nearly every deepening and 

capital works project we complete. These tools are essential Ground Engaging Tools ("GET") 

that our dredges use to perform excavating services on both hard soil and rock surfaces. 

Therefore, we are requesting an exclusion for 5GP2 Dredge Pick Point Cutting Teeth, classified 

under HTSUS 8431.49.9020. This product is easily identified, costly, and crucial for our 

dredging capabilities. 

The 5GP2 Pick Point teeth have a point width of 33.5mm and weight of 42.2 lbs/19.14kgs. 
3 

1

The ESCO Pick Point Cutting Teeth are manufactured only in China. When Great Lakes 

reached out to ESCO about this, they confirmed the manufacturing location of all the products

Great Lakes purchases from ESCO with the following chart (highlighting added): 

Item # Point(s) of Manufacture

642D5G Newton, MS, USA

WN5G Newton, MS, USA

5GP1 Xuzhou, China

5GP2 Xuzhou, China

5678GL Portland, OR, USA

As depicted below, the ESCO Dredge Pick Point Cutting Teeth fit securely into unique 

ESCO adapters with a hammerless locking system. Because the adapters on Great Lakes’ dredges 

are designed by ESCO, Great Lakes needs to source its teeth from ESCO for them to fit properly. 

III. Great Lakes Needs This Product to Complete the Large-Scale, Valuable

Government Contracts It Has Received in 2017-18

Great Lakes has recently been awarded four new government contracts worth 

hundreds of millions of dollars, and we require ESCO Dredge Pick Point Cutting Teeth to 

perform each project. We are currently working on these projects and expect to continue 

working on them into 2021. 

1 The bracketed portions of these comments contain business confidential information. The disclosure of this 

information would endanger trade secrets or profitability and this information would not customarily be released to 

the public. 
4 

The locations and total values of each project are listed below. Since the projects all 

involve deepenings of channels, we expect all options to be exercised to avoid impediments in 

the middle of the channels. 

A. Charleston 1: Total value with all options exercised = $47.2 million

On September 14, 2017, Great Lakes received a $47.2 million award for the Post 45 Foot 

Charleston (South Carolina) Entrance Channel Maintenance and New Work Dredging - Contract 

1 Project. The scope of work for Charleston I includes excavation of approximately 6.1 million 

cubic yards of material to deepen a portion of the Charleston, South Carolina Harbor Entrance 

Channel. Work has already commenced and should be completed by March 2020. 

B. Charleston 2: Total value with all options exercised = $278.3 million 

On October 30, 2018, Great Lakes received a $213.3 million award for the Post 45 

Charleston Entrance Channel Maintenance and New Work Dredging - Contract 2 Project base 

contract. The scope of work includes excavation of approximately 8 million cubic yards of 

material to deepen a portion of the Charleston, South Carolina harbor entrance channel. Work is 

expected to be completed by the end of 2020. The full set of options were awarded to Great 

Lakes, as expected; this additional work consists of the excavation of 5.5 million cubic yards of 

soil valued at $65.1 million to complete the deepening of the entrance channel, resulting in a 

total contract amount of $278,333,700.00, totaling 13.5 million cubic yards of excavation which 

will be completed by the end of 2020. This is the largest dredging contract ever awarded by the 

Corps.

C. Jacksonville B: Total value with all options exercised = $210 million 

On September 27, 2018, Great Lakes received a $113 million base contract award on the 

Jacksonville (Florida) Harbor Construction Dredging Contract ‘B’ 47-Foot Project. Great Lakes 

expects the Corps to award additional option work items on the contract by mid-2019 with a 

value of $97 million, resulting in a total contract award of $210 million. Dredging is expected to 

commence in the fourth quarter of 2018 with completion of both base contract and expected 

options in the second quarter of 2021. 

D. Tampa Big Bend: Total value with all options exercised = $74 million

On October 1, 2018, Great Lakes received a $48 million base contract award on the 

Big Bend Channel of the Port of Tampa Bay. Great Lakes expects the Corps to award 

additional option work items on the contract by early-2019 with a value of $25 million, resulting 

in a total contract award of $74 million. Dredging is expected to commence in the fourth 

quarter of 2018 with completion of both base contract and expected options in the third 

quarter of 2019.
5 

Dredging is critical to our national defense, our national economy, and the protection of 

American lives and property along U.S. coastal areas. It is an expensive, capital-intensive 

industry, supported primarily through U.S. governmental expenditures managed by the U.S. 

Army Corps of Engineers. The need for dredging work has always far outstripped the financial 

resources available to pay for it. As a consequence, the substantial increase in the cost of 

dredging that will be caused by the continued application of increased tariffs on Great Lakes'

supplies, such as the Dredge Pick Point Cutting Teeth used on almost every deepening and 

capital works project, will necessarily result in fewer dredging services provided to the U.S. 

public. That will make the country less safe and secure. 

To ensure our national defense, navigation channels into our naval stations around the 

country must be maintained so that our ships can safely enter and depart port. Our military and 

military support vessels use well over a score of ports in the continental U.S. to berth and support 

military forces, including Portsmouth (New Hampshire), Newport (Rhode Island), New York 

(New York), Earle (New Jersey), Philadelphia (Pennsylvania), Norfolk (Virginia), Yorktown 

(Virginia), Little Creek (Virginia), Morehead City (North Carolina), Wilmington (North 

Carolina), Charleston (South Carolina), Kings Bay (Georgia), Mayport (Florida), Miami 

(Florida), Key West (Florida), Mobile (Alabama), San Diego (California), Alameda (California), 

Everett (Washington), and Kitsap (Washington). All of those ports must be kept open and safe 

for navigation. 

Likewise, navigational channels into fuel and cargo terminals must also be maintained to 

ensure access for the naval auxiliaries, tankers, and cargo ships that are essential to move and

support our military forces in their deployments around the world. A number of commercial 

ports support ready reserve and other vessel used to support our military forces around the world, 

including New York, Philadelphia, Baltimore, Savannah, Tampa, Miami, Houston, Corpus 

Christi, Los Angeles, Long Beach, San Francisco, Oakland, Portland, and Seattle. Those ports 

include the ports and waterways for which Great Lakes has recently been engaged to provide 

work over the next few years. Any reduction in dredging for those ports would necessarily 

impact our national security, by increasing the risks to transiting warships or support vessels, by 

causing delays, or by limiting available channel transit hours. 

Our national security also depends upon a robust economy and access to international 

trade. Our ports are a vital part of our national economy, intermodal transportation system, and 

national defense structure. Over 96 percent of the goods and cargoes that enter the United 

States arrive by ship, and over 360 commercial ports around the country are used to distribute 

those goods. Those hundreds of ports around the country are responsible for an estimated $4.6 

trillion in economic activity, which equates to roughly 26 percent of the United States’ 

economy.2 

However, to remain usable, ports require various combinations of both capital dredging, 

to deepen or widen shipping channels, and maintenance dredging, to periodically remove 

sediments that may accumulate in shipping channels. The need for such dredging is an ongoing 

one. 

2 B. Campanelli, “A Deep Dive on America’s Ports,” Bipartisan Policy Center (Jul. 27, 2017) 

https://bipartisanpolicy.org/blog/a-deep-dive-on-americas-ports/, referencing the American Society of Civil 

Engineers 2017 Infrastructure Report Card at https://www.infrastructurereportcard.org/cat-item/ports/. 

IV. Continued Application of Increased Tariffs to Great Lakes' Supplies Will Threaten 

National Security
6 

Most harbor maintenance projects are managed by the Corps, with funding from the 

federal Harbor Maintenance Trust Fund or other congressional appropriations. While the Trust 

Fund is large, the dredging needs are much larger. In addition, the Trust Fund does not cover 

projects to deepen or widen a channel. Those projects, needed to accommodate the larger 

vessels coming into service, may be partially funded by congressional appropriations, but they 

must also be funded by states or the ports themselves. Those funding sources, like the federal 

funding sources, are limited and at best. 

The continued application of increased tariffs on Great Lakes' supplies such as the 

Dredge Pick Point Cutting Teeth will increase the costs of such dredging projects to the U.S. 

government, states, and individual ports. It will necessarily result in less dredging, and 

therefore it will increase risks and reduce access to vessels using U.S. ports. That will 

increase port delays, reduce trade, and adversely impact the U.S. economy. Indeed, a recent 

study by the American Society of Civil Engineers estimated that failing to invest in the 

deepening and maintenance of port navigation channels will result in a $9.3 billion annual 

trade loss to U.S. businesses.3 

A third type of dredging is also essential to U.S. national security, by directly protecting 

U.S. lives and property. Beach “nourishment” (also called replenishment and restoration) 

dredging projects restore sand to beaches to offset erosion and damage from storms, and to 

build dunes that help protect against storm surges and tsunamis.4 The Corps has found that 

oceanfront beach nourishment is the most cost-effective solution that helps protect against 

flooding, beach erosion, and direct impacts from wind and waves.5 Simply put, beach 

nourishment protects American lives, property, and communities. 

The risks to coastal communities is real and immediate. For example, in 2005, Hurricane 

Katrina ravaged the Louisiana coast, causing the death of least 1,836 people and approximately 

$125 billion in property damage. In 2012, Hurricane Sandy scoured beaches from Virginia to 

Long Island, depleting the dune structures essential to protecting people, homes, and businesses 

from tidal surges. That storm caused an estimated $65 billion in damages and killed at least 230 

people. 

By contrast, the effects of the recent Hurricane Florence, while severe, were significantly 

mitigated by prior beach nourishment work. For example, the Carteret, North Carolina Shore 

Protection Office Manager noted that “there was no flood damage to oceanfront structures, nor 

any breaches of the frontal dune. Structural damage was limited to walkways only.”6 He credited 

beach nourishment with protecting miles of homes and businesses, despite record-setting high 

tides.7

3 American Society of Civil Engineers, “Failure to Act: The Impact of Current Infrastructure Investment on 

America’s Economic Future,” (2013).

4 See, e.g., U.S. ACE “Beach Nourishment,” https://www.iwr.usace.army.mil/Missions/Coasts/Tales-of-theCoast/Corps-and-the-Coast/Shore-Protection/Beach-Nourishment/; ACE Note “Beach Nourishment: Setting the 

Record Straight,” http://www.nap.usace.army.mil/Portals/39/docs/Civil/Coastal/myths_facts.pdf. 5 Id. 

6 B. Rich, “Florence accelerates Bogue Banks beach erosion,” Carteret County News-Times, Sep. 16, 2018, 

http://www.carolinacoastonline.com/news_times/article_c56f22ac-b9ee-11e8-ac08-2b56ed422cfe.html. 7 Id.
7 

Great Lakes' recent and upcoming beach replenishment projects include work in 

Louisiana, Mississippi, South Carolina, New Jersey, Florida, and Georgia, all critical projects to 

help protect the U.S. coastline from future storms. Those projects are funded by various 

governmental entities, including the Corps, states, and local governments. The continued 

application of the increased tariffs will necessarily increase the costs of those projects. In the 

absence of increased funding by the U.S. government or local governments, those increased costs 

would almost certainly cause a number of projects to be cancelled or curtailed. If that happens, 

American citizens, their homes, and their communities, will be at greater risk. 

Thus, the continued application of increased tariffs will increase costs for the U.S., 

states, and local communities that rely upon dredging for national security, economic prosperity, 

and the safety of lives and property. That will reduce the availability of necessary dredging, and 

create an increased risk to our country, our communities, and our citizens. 

V. Continued Application of Increased Tariffs to Great Lakes' Supplies Will 

Cause Severe Harm to This U.S. Business and Its Government Contracts 

Because There Is No Alternative Supplier 

The Section 301 tariffs have already caused severe economic harm by significantly 

increasing costs for Great Lakes. Switching to domestic suppliers is not an option for us, because 

ESCO holds the sole patent rights to the Dredge Pick Point Cutting Teeth that our dredges need 

to excavate soil and rock surfaces. Because ESCO has chosen to manufacture these teeth in 

China, and we have no alternative suppliers, we currently have no other option but to pay the 

25% tariffs. Rather than encouraging domestic manufacturing, these tariffs are forcing us to 

transfer increased costs to our government clients, which include the Corps, state and local 

governments, private port operators, and other commercial clients. These losses also affect our 

individual employees, through reduced revenues available for bonuses and profit-sharing. 

Increased costs may make certain projects infeasible. Commercial clients may not have the 

budgets to cover increased pricing, which may result in project cancellations. If we lose project 

opportunities, we will need to lay off our hourly workforce. Remaining employees will receive 

less compensation if our business continues to be less profitable. Ultimately, U.S. taxpayers will 

bear the brunt of this economic burden, because as a government contractor we ultimately will 

have to pass cost increases along to our U.S. government clients. 

VI. Continued Application of Increased Tariffs to Great Lakes' Supplies Will Not 

Protect U.S. Innovation or Intellectual Property, Because Its Supplies Are 

Standard for the Dredging Industry and Unrelated to “Made in China 2025”

We understand that the Section 301 tariffs were designed, in part, to discourage the 

misappropriation of U.S. intellectual property by Chinese partners engaging in joint ventures 

with U.S. companies. But purchasing dredge teeth from ESCO does not put intellectual property 

at risk. ESCO holds the patent rights to the dredge teeth for which we are requesting an 

exclusion. Attempting to source these parts from another supplier could risk infringement of 
8 

ESCO’s patent rights. Because ESCO holds that patent and they have chosen to manufacture the 

dredge teeth in China, there is not a comparable alternative that we can purchase instead. 

Great Lakes’ supplies are neither related nor strategically important to the “Made in 

China 2025” initiative, in which the Chinese government is subsidizing innovative technologies 

to sharpen China’s edge in the global marketplace. Neither are these supplies related to any other 

known Chinese industrial program, act, or policy related to technology transfer, intellectual 

property, or the practices identified by the USTR as unreasonable or discriminatory. Here, the 

dredge teeth that Great Lakes needs are proprietary but standard products that do not attract 

special attention or support from the Chinese government, because they are not made with 

cutting-edge technology. These parts are stable, simple, and foundational to the dredging 

industry where Great Lakes is striving to remain an American leader.

We also note that Great Lakes does not resell these products. Rather, the 5PG2 

Dredge Pick Point Cutting Teeth are "consumed" during our dredging operations. The use of 

the teeth for digging through soil and rock wear them out quicly, and a number of the teeth 

are regularly expended during our dredging operations.

VII. U.S. Customs and Border Protection (CBP) Can Easily Administer This

Exclusion Request

We have filed a separate Section 301 Investigation Form to Request Exclusion of Product 

for both products for which we are requesting an exclusion. CBP will be able to administer each 

exclusion without undue complication or expense, because the dredge teeth are easy to identify 

and each exclusion request form contains a detailed description including the relevant 

specifications, along with the relevant HTSUS numbers. 

We have included the following exhibits to support our request: 

1. Exhibit 1 is a drawing of ESCO Dredge Pick Point Cutting Teeth. The drawing shows the

specifications for the 5GP2 teeth. The ESCO drawing identifies at least one its patents

that cover this product.

2. Exhibit 2 is a purchase order of two kinds of ESCO Dredge Pick Point Cutting Teeth,

 We have highlighted the

relevant numbers to show that Great Lakes paid a 25% tariff on these products, 5GP1 and

5GP2.

3. Exhibit 3 is a flyer detailing ESCO’s unique products and services.

4. Exhibit 4 is a support letter from Weeks Marine, Inc., another major dredging company

who shares our concerns.

5. Exhibit 5 is a flyer detailing ESCO’s design and specifications for the 5GP1 and 5GP2

dredge teeth. We have highlighted the relevant details.

6. Exhibit 6 is a set of photos depicting Great Lakes’ $213.3 million Charleston 2 dredging

project. This is the largest U.S. Army Corps of Engineers dredging contract ever

awarded. The photos show the custom-designed cutterheads that dredges use to excavate,
9 

which contain the ESCO teeth for which we are requesting an exclusion. 

VIII. Conclusion

Instead of burdening or restricting U.S. commerce, our Chinese suppliers strengthen U.S. 

commerce by complementing our domestic operations and allowing us to perform high-quality 

dredging services for the U.S. government as well as for our state, local, and commercial clients. 

Thus, to enable us to keep serving the nation and to remain global leaders in the dredging 

industry, we respectfully request that the 5GP2 Dredge Pick Point Cutting Teeth be excluded 

from the Section 301 tariffs. 

We appreciate the USTR’s consideration of this exclusion request. Please contact the 

undersigned if you have any questions regarding this submission. I hereby certify that the 

information provided is complete and correct to the best of my knowledge. 

Respectfully submitted,

_____________________________ 

Kathleen Mackie LaVoy 

Senior Vice President, Chief Legal 

Officer & Corporate Secretary 

KMLaVoy@gldd.com 

630-574-3468 
Exhibit 1 
Additional area m

Total are to be co

Weld finished on castingriser to place HAZ in thickerx-sec of tooth
Exhibit 2 

 
ACE 

DEPARTMENT OF HOIMELAND SECURITY 

U.S. Customs and 19order Protection 

ENTRY Sl.!.IMMARY 

8. Importing Carrier 

l 

9. Mode of Transport 

MOL MARVEL I 11 

12. BIL or AWB No. ' 13. Manufacturer ID 

YMLUE240074339 CNESCXUZJIA 

16.1.T. No. 117. I.Tl Date 118. Missing Docs 

21. Location of Goods/G.O. No. *1 · Consignee No. 

LOOS-NIT CONTAINER PER � 

25. UIUmate Coosigoee Name aod AdT

" 

City State IL Zip 

27. 28. Descriplion of Merchandise

29. J 30. 31. 

Line A. HTSUS No. A. ross Weight Net Quantity in 

No. B. AD/CVD Case No. B. Manifest Qtv. HTSUS Units 

� E240074339 � STONFK02553 

NVOICE 00001 I 706431 

001 ACH PTS OTH,HEAD 8429-30,0THR 

£

903.80.01 I 

431 49.9095 I x 

ARBOR MAINTENA CE FEE 

ERC AN ISE PR ESSING FEE

I lrOTAL EV INV. oooo1 

I 

I I Other Fee Summary for Block 35. Total Entered Value

lf� �61 

1$ 

Total Other Fees 

iS 

36. DECLARATION OF IMPORTER OF RECORD (OWNER 

OR PURCHASER) OR AUTHORIZED AGENT 

OMB APPROVAL NO. 1651-0022 

EXPIRATION DATE 01/31/2021 

1. Filer Code/Entry No. 

G61 0042542-0 

4. Surety No.15. Bond Type 

856 8 

10. Country of Origin 

CN 

14. Exporting Country 

CN 

2. Entry Type 3. Summary Date 

01 ABI/A 08/15/2018 

6. Port Code 7. Entry Date 

1401 

11. Import Date

08/05/2018 

15. Export Date 

06/23/2018 

19. Foreign Port of Lading 20. U.S. Port of Unlading

57047 1401 

23. Importer No. 24. Reference No.

20-135441400 

26. Importer of Record Name and Address 

GREAT LAKES DREDGE & DOCK CO LLC 

2122 YORK RD 

City OAK BROOK State IL Zip 60523 

32. 33. 34. 

A. HTSUS Rate Dutv and 1.R. Tax 

A. Entered Value B. AD/CVD Rate Dollars Cents 

B. CHGS C. IRC Rate 

C. Relationship D. Visa No. 

60 PCS 

�OT RELATED 

25% � 

C7796 

------- ----------

C -1RRIED FORWARD 

CBP USE ONLY TOTALS 

A. LIQ CODE B. Ascertained Duty 37. Duty

REASON CODE C. Ascertained Tax 38. Tax 

D. Ascertained Other 39. Other

I declare that I am the D importer of re�ord and that the actual owner. E. Ascertained Total 40. Total

purchaser, or consignee for CBP purpos s is as shown above, OR 0 owner 

or purchaser or agent thereof. I further df cl are that the merchandise IBJ was obtained pursuant to a purchase or agreement to purchase and that the 

prices set forth in the invoices are true, pR 0 was not obtained pursuant to a purchase or agreement to purchase and the statements in the invoices as 

to value or price are true to the best of mt knowledge and belief. I also declare that the statements In the documents herein filed fully disclose to the best 

of my knowledge and belief the true prices, values, quantities. rebates. drawbacks. fees, commissions, and royalties and are true and correct. and that all 

goods or services provided to the seller of the merchandise either free or at reduced cost are fully disclosed. 

I will immediately furnish to the appropriate CBP officer any information showing a different statement of facts. 

41. DECLARANT NAME TITLE SIGNATURE DATE 

Bruning Internationa� Corp. A. I.F. 

42. Broker/Filer Information (Name, a��ress, phone number) 43. Broker/Importer File No. 

Bruning International C�rp. 180947 275 Centre Street 

Holbrook, MA 02343 78 -300-0025 

CBP Form 7501 (02/18) 

EOITRAOE MULTIPLE USE 
DEPARTMENT OF HOMELAND SECURITY 

U.S. Customs and Border Rrotection ENTRY SUMMARY CONTINUATION SHEET 

27. 

Line 

No. 

b02 

I 

! 

I 

, 1. Filer Code/Entry No. I G61 0042542-0 

28. Description of Merchandise 32. 

29. I 30. 31. 

A. Entered Value 

A. HTSUS No. A. Grpss weight Net Quantity in B. CHGS 

B. AD/CVD Case No. B. M�nifest Qty. HTSUS Units C. Relationship 

I BROUGHT FORWARD 

NVOICE 00002 I 

706431 

MACH PTS OTH,HEAd 8429-30,0THR 

903.80.01 I 431.49.9095 38093 x 

C6769 

ARBOR MAINTENAN9E FEE 

MERCHANDISE PROC SSING FEE 

trOTAL EV INV. 00102 

I 

I 

! 

' 

ED TRAOE MULTIPLE USE 

33. 

A. HTSUS Rate 

B. AD/CVD Rate 

C. IRC Rate 

D. Visa No. 

25% 

Page: 2 

OMS APPROVAL NO. 1651-0022 

EXPIRATION DATE 01/31/2021 

34. 

Duty and l.R. Tax 

Dollars Cents 

CBP Form 7501 (02/18) 
ESCO COMMERCIAL INVOICE 

Invoice: 29929532 

2141 NW 25th 

PO Box 10123 

Portland OR, 97210 

United States 

Supplier Id: None 

Ship From: 

Esco (Xuzhou) Wearparts Co Ltd 

No 7 Qianjiang Road 

Hi-Tech Edz 

Xuzhou, Jiangsu 221116 

Ch na� \ 

TJ Control: 

I T ax Id : 930989423 

Ship To: Bill To: 

GREAT LAKES DREDGE & GREAT LAKES DREDGE & DOCK, LLC 

DOCK, LLC 2122 YORK RD STE 200 

800 E. INDIAN RIVER RD. OAK BROOK, IL 60523-1981 

PH: 757-545-7226 United States 

NO;AFOLK, VA 23523 

United States 

lncote 2010 EXW . Ship Mthd: WILL CALL 

Named . iJ � INT Freight Terms: Collect:Carrier Bills Destination or Will Call 

Routed Sli . · � � Cui�tomer PO No: 1706431 

Diversion: These commodities, technology or software were Payment Terms: 

exported from CN In accordance with the Export Administration NET30 

Regulations for ultimate destination to 'us. Diversion contrary to 

United States law oroh lblted. I 

Due: 

cscription ackage Number 

Preliminary 

I . nvo ce 

Please Remit To: 

Page 

1of2 

28-May-18 

00:58 

ESCO CORPORATION 

14784 COLLECTIONS CENTER 

DRIVE 

CHICAGO, IL 60693 

United States 

Ship Date: 

Waybill: 

Delivery Id: 29929532 

Tax Freight 

Yes xx Prepay 

No Collect xx 

3 5137421 5GP2-B;DREDGE PICKCN 

POINT; 

8431.49.90.95 

US HTS Summar 

US HTS Code US HTS Description ECCN Export 

License 

Cntry 

Ori 

8431.49.90.95 Dredge Culterhcad Parts EAR99 

Dimensions (L x W x H) 

Pkg. Num Kind of Package Inches Centimeters 

To als: Package Count 15 

CN0173781 DRUM 88 x 24 x 41 224X61X103 

CN0173782 DRUM 88 x 24 x 41 224 x 61x103 

CN0173783 DRUM 88 x 24 x 41 224 x 61x103 

CN0173784 DRUM BBX24X41 224 x 61x103 

CN0173785 DRUM 8BX24X41 224 x 61x103 

CN0173786 DRUM 8BX24X41 224 x 61x103 

CN0173787 DRUM BB X 24 X 41 224 x 61x103 

CN0173788 DRUM 88 x 24 x 41 224 x 61x103 

CN 

Volume 

Cu. Ft. Cu.M. 

.65 21.15 

50 11 1.41 

50.11 1 41 

50.11 1.41 

50.11 1.41 

50.11 1.41 

50.11 1.41 

50.11 1.41 

50.11 1.41 

Pieces 

Sub Total 

Tax 

Gross Weight 

Pounds Kilos 

Estimated Net 

Wei ht 

Tare Weight 

Pounds Kilos 

Value 

114,280.00 USO 

� 

Net Weight 

Pounds Kilos 
�ESCO® ESCO COMMERCIAL INVOICE Page 

2 of 2 

Invoice: 29929532 28-May-18 

CN0173789 DRUM BB X 24 X 41 224 x 61

x103 50.11 1.41 

CN0173790 DRUM BB X 24 X 41 224X61X103 50.

11 1.

41 

CN0173791 

DRUM as x 24 x 41 224X6

1X103 

50.11 1.41 

CN0173792 

DRUM !!8 x 24 x 41 224 x 61

x103 50.11 

1.41 

CN0173793 DRUM !38X24X41 224 x 61

x103 

50.11 

1.41 

CN0173794 DRUM 88 x 24 x 41 224 X6

X103 5011 1.41 

CN0173795 DRUM 88X24 X41 

I 

224 x 61x103 50.11 1.41 
2141NW 25th 

PO Box 10123 

Portland OR, 97210 

United States 

Supplier Id: None 

Ship From: 

Esco (Xuzhou) Wearparts Co Lid 

No 7 Qianjiang Road 

Hi-Tech Edz 

Xuzhou, Jiangsu 221116 

China 

� 

lncoterms• 2010 EXW � Named Place: SHIPPING INT 

Routed Shipment: Yes 

ESCO COMMERCIAL INVOICE 

In voice: 29929533 

Tax Control: 

I Tax ld·930989423 

Ship To: 

GREAT LAKES DREDGE & 

DOCK, LLC 

800 E. INDIAN RIVER RD. 

PH: 757-545-7226 

NORFOLK, VA 23523 

United States 

Ship Mthd: Will CALL 

Bill To: 

GREAT LAKES DREDGE & DOCK, LLC 

2122 YORK RD STE 200 

OAK BROOK, ll 60523-1981 

United States 

Frei g ht Terms: Cotlect:Carrier Bills Destination or Will Call 

Cus omer PO No: 1706431 

Diversion: These commodities, technology or software were Payment Terms: 

exported from CN In accordance with the Export Administration NET30 

Regulations for ultimate destination to US. Diversion contrary to Due: 

United States law orohlblted. 

escription ackage Number 

P/O 1706431 (1527214) 

Preliminary 

Invoice 

Please Remit To: 

Page 

1of2 

28-May-18 

00:58 

ESCO CORPORATION 

14784 COLLECTIONS CENTER 

DRIVE 

CHICAGO, ll 60693 

United States 

Ship Date: 

Wa y bill: 

Delivery Id: 29929533 

Tax Freight 

Yes xx Prepay 

No Collect xx 

6 5137447 5GP1-B;DREDGE PICKCN 

POINT; 

8431.49.90.95 

US HTS Summar 

US HTS Code US HTS Description ECCN Export 

License 

Cntry 

Ori 

8431.49.90.95 Dredge Cunerhead Parts EAR99 

�-d:\

-cCN 

� � 'i\'1 . q_ar s \ .\{eR__

Dimensions (l x W x H) Volume 

Pkg. Num Kind of Package ' Inches Centimeters Cu. Ft. Cu.M. 

Totals: Package Count 15 751.65 21.15 

CN0173766 DRUM 88 x 24 x 1 224 X61X103 50.l t t .41 

CN0173767 DRUM 88 x 24 x 41 224 X61X103 50.11 1.41 

C 0173768 DRUM 88 x 24 x 41 224 x 61x103 50.11 1.41 

CN0173769 DRUM 88 x 24 x 41 224 x 61x103 50.11 1.41 

CN0173770 DRUM 88 x 24 x 41 224 x 61x103 50.11 1.41 

CN0173771 DRUM 88 x 4 x 41 224 x 61x103 50.11 1.41 

CN0173772 DRUM 88 x 24 x 41 224X61X103 50.11 1.41 

CN0173773 DRUM 88X24X41 224X61X103 50 11 1.41 

Pieces 

Tax 

Gross Weight 

Pounds Kiios 

Eslimated Net 

Wei bt 

Net Weight 

Pounds Kilos 
�Esco� ESCO COMMERCIAL INVOICE Page 

2 of 2 

Invoice: 29929533 28-May-18 

00:58 

CN0173774 DRUM 88 x 24 x 41 224X61X103 50 11 1.41 

CN0173775 DROM 88 x 24 x 41 224 x 

61x103 50.11 1.41 

CN0173776 DRUM 88 x 24 x 41 224X61X103 50.11 

1.41 

CN0173777 DRUM 88 x 24 x 

41 224X61X103 50.11 1.41 

CN0173778 

RUM 88 x 24 x 

41 224X 61X103 50.11 1.41 

CN0173779 DRUM 88 x 24 x 41 224 x 

61x103 50.11 1.41 

CN0173780 DRUM 88 x 24 x 41 224 x 61

x103 

50.11 

1.41 
r:p� Jl��N0 � 

CL CONS DATORS SERVICES LTD. 

FMC-OTI 010486N 

MOC-SMTC-NV00318 

NON-NEGOTIABLE COPY 

as the Carrle1 

OMBINED TRANSPORT BILL OF LADING 

$NIPP A ft e l'fa c1e11I AOo ) 

ESCO (XUZHOU) WEJ\RPARTS COi

L TO 

NO 7 QIANJIANG ROAD 

!X ATRE E�E C£S Hl-H:'.CH EDZ 

XUZHOU, JIANGSU 221116 CHINA 

GREAT LAKES DREDGE & DOCK C . LLC 

2122 YORK RO OAK BROOK, ll 605 3 

POINT •"O (;0UNTAY Of 014 <;1N 

. --- - - --------- -- l\.OTll'Y PAA V (Comc •fl N) ttetf AOdri• } At.SO NOTIFY. ACUl•NC I INSTAUCT10"'� 

SAME AS CONSIGNEE 

- -

P�E CARl\IAGC av -�(1.100£1 ------- !-

PLA--l OF ---- AECEl�T - Oll -OClfVl�Y � Of --ooos Pl EASE --APPlY --TO --------- ---

QINGDAO CHI A BRUNING INTERNATIONAL CORPORATION 

.e-s _H_ tv_o_vA e __ ___ ___ _P_"_O F _O_A_c.._G ___ _ 275 CENTRE STREET HOLBROOK.MA 02343 

HANOI BRIDGE 027E QINGDAO.CHINA TEL:781-300-0025 FAX:781-300-0024 

ro�r OF OISCf<ARG( 

NORFOLK, VA.USA 

R,$ AHC Mtlt:RS 

CO lf>. A l l IJ'lj� S 

I 

"l-4CE O� OELIVC�Y 

NORFOLK. VA.USA 

PARTICULARS OECLAREO SY TH!: SHIPPER 

NUMOER AND DESCRIPTION OF PACKAGES ANO GOODS 

ER'S LOAD & COUNT & SEALED 

CONTAINER(S) SAID TO CONTAIN 

·-THIS SHIPMENT CONTAINS NO WOOD PACKAGING 

MATERIALS" 

CY/CY 

MARKS NUMBER 8. SCB\P� N,S 

OF GOODS AS PER UST ATTA . 

.. 

\ -

T1 �TAL; FOUR ( 4 x 40'GP) CONTAINER($) ONLY. 

GROSS WEIG>il 'AEASURUAEt1;T 

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JUN 23 2018 

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------
!IL NO. · STONFK0255i 

fESSELNOYAGE NO.: HANOI BRIDG

F 

027E 

>ORT OF LOADING : INGDAO CH NA 

>LACE OF DELIVERY:· NORFOLK. V�.USA 

'LACE OF RECEIPT : INGDAO CH NA 

=1NAL DESTINATION : NORFOLK, V USA 

MARKS AND NUMBERS NO F PKG 

GREAT LAKES DREDGE 

& DOCK 

800 EAST INDIAN 

RIVER ROAD 

NORFOLK, VA 23523 

ORDER# 1706431 

MADE IN CHINA 

CONTAINER NO. & SEAL NO.: 

DESCRIPTION OF GOODS 

DREDGE PICK POINT 

GROSS WEIGHT MEARS 

.,. . 
Exhibit 3 

 
www.escocorp.com

Features and Benefits

Increased safety

• Hammerless locking device

•	 Locking device is positioned

for easy access

Reduced maintenance

• Unique nose design for

increased life

•	 Greater point life increases

time between replacement

•	 Reduced point movement

decreases system wear

Greater productivity

•	 Increased penetration

•	 Less maintenance reduces

down-time

Lower operation costs

•	 Less energy required for

penetration

•	 Greater percentage of

useable point wear metal

•	 Reduction in the time to

GeoVor pick replace worn teeth

point

Spherilok

adapter

GeoVor lock

GeoVor pick

point

GeoVor flare

point

GeoVor chisel

point

GeoVor

nose

GeoVor wing adapter

used with sand and

clay cutterheads.

ESCO GeoVorTM Dredge Tooth System

ESCO supplies the most advanced and

productive wear replacement parts,

accessories and solutions to the

growing and ever-changing dredging

industry. ESCO is the leader in hardrock dredging and continues product

advancement with the introduction of the

GeoVor Dredge Tooth System. The

GeoVor system features a hammerless locking

device and is designed to improve productivity with

increased system life.

ESCO is a world leader in production, support and technology

solutions and is committed to greater production from dredging

equipment.
www.escocorp.com

ESCO GeoVorTM Dredge Tooth System

Innovative System Design

Locking Mechanism

The GeoVor Dredge Tooth System features a unique locking

mechanism. Not only is it hammerless, but it is extremely easy to

install and features a visual indicator to ensure proper tightening.

The lock consists of a hardened bolt assembled with retainer plates

and a specialized elastomer. The lock holds the point firmly in place

to minimize movement, thereby limiting system wear.

Tooth Assembly

The initial GeoVor offering consists of a pick point, the most popular

point shape in hard-rock dredging. The design maximizes strength

which allows a longer point for more wear metal without sacrificing

the integrity of the assembly. The system currently offers a Spherilok®

adapter design that can be used on new or old style Spherilok

cutterheads. Additional point shapes and adapter styles will be

available in the future. The GeoVor system will be offered in sizes to

cover the full range of hard-rock dredges. At this time seven sizes

are planned with the projected availability dates as shown below.

2G 3G 4G 5G 6G 7G 8G

3Q

2012

1Q

2012 Available Available Available Available 2Q2012
© 2011 ESCO Corporation. All Rights Reserved. All other brand or product names are trademarks of their respective holders.

P3001DRG01L1011

www.escocorp.com

ESCO Corporation is the preferred provider of

technically rich metal components and wear

solutions for industrial applications. ESCO has

over 40 locations and affiliates worldwide.

North America

2141 NW 25th Avenue

Portland, OR 97210

PH: 800.523.3795 | 503.228.2141

Latin America

Rua Engenheiro Gerhard Ett, 1215

Distrito Industrial Paulo Camilo Sul

Betim/MG – CEP: 32669-110

Caixa Postal 256 - Betim, Minas Gerais – Brasil

PH: 55 31.3539.1200

Europe, Africa, Middle East,

Commonwealth of Independent States

Rue des Fours à Chaux

7080 Frameries, Belgium

PH: 32.65.611.555

Asia Pacific

1 Scotts Road, Number 16-08

Singapore 228208

PH: 65.6733.5858
Exhibit 4 

Exhibit 5 

 
P5003DRG01L0613

DREDGE PRODUCTS

www.escocorp.com ©2013 ESCO Corporation. All Rights Reserved.

ESCO rock dredge cutterheads featuring the GeoVor tooth system are designed 

to dredge the toughest, hardest materials. They have high-performance features 

to ensure maximum productivity with minimum downtime, including ESCO’s unique 

GeoVor system, one of the strongest systems available.

ESCO rock cutterheads are custom designed and manufactured to meet each 

specific customer requirement and offer the following advantages:

	 •	Hub-mounted teeth which assist cutter suction dredges with

hydraulically-advanced spuds to step forward

	 •	Optional ring-mounted teeth to provide extra wear protection

	 •	The arm openings are designed with controlled clearance, subject

to customer requirements

	 •	Tooth roll angle is set specifically for pick point usage

	 •	Tooth angle of attack is set to deliver maximum dredging

performance in hard rock

ESCO has the experience and skills needed to develop solutions for the most 

demanding dredging applications.

For complete information about the ESCO dredge cutterheads, contact your 

ESCO representative.

For detailed information about the full line of ESCO dredge replacement parts, 

refer to the back page.

ESCO engineers use advanced computer design 

systems to model rock dredge cutterheads and 

analyze angles for maximum performance. 

UNIQUE ESCO GEOVOR POINT & ADAPTER SYSTEM

ESCO ROCK CUTTERHEADS

WITH GEOVOR® TOOTH SYSTEM

One-piece lock 

provides positive 

point retention and 

take up

Point attaches 

securely with a 

hammerless locking 

system

ESCO Corporation • European Headquarters

Frameries, Belgium +32.65.61.15.55

Rock Cutter Power Range

Cutterhead Size HP kW

2G 500-900 375-670

3G 900-1800 670-1345

4G 1800-2800 1345-2100

5G 2800-4500 2100-3360

6G 4500-6000 3360-4475

7G 6000-7000 4475-5220

8G 7000-8000 5220-6000
P5003DRG01L0613

DREDGE PRODUCTS

www.escocorp.com ©2013 ESCO Corporation. All Rights Reserved.

Rock Dredge Cutterheads with GeoVor System

Pattern Type A, Bit tip to B, Point Length C, Bit Width D, Nose Length E, Adapter F, System Weight

mm in mm in mm in mm in mm in mm in kg lb

2G SERIES

Points

2GP2 Pick 172.0 6.77 24.1 0.95 21.6 0.85

Adapters

WN2G Weld-On

Pin

234GL

3G SERIES

Points

3GP2 Pick 225.8 8.89 340.4 13.40 24.0 0.96 8.8 19.40

Adapters

490D3G Spherilok 151.8 5.98 317.6 12.52 377.6 14.87 16.1 35.57

WN3G Weld-On 151.8 5.98 216.6 8.53 377.6 14.87 13.7 30.16

Pin

234GL

4G SERIES

Points

4GP2 Pick 225.8 8.89 369.0 14.55 27.3 1.08 11.8 26.00

Adapters

580D4G Spherilok 175.0 6.89 395.6 15.58 400.8 15.78 27.2 60.00

WN4G Weld-On 175.0 6.89 238.5 9.39 400.8 15.78 20.0 44.00

Pin

234GL

5G SERIES

Points

5GP2 Pick 245.4 9.66 404.1 15.91 33.5 1.32

5GP1 Pick 245.4 9.66 404.1 15.91 27.3 1.08

5GC2 Chisel

Adapters

703D5G Spherilok

642D5G Spherilok 189.9 7.47 438.6 17.27 435.3 17.13 37.6 83.00

WN5G Weld-On 189.9 7.47 262.9 10.35 435.3 17.13 27.1 59.80

Pin

5678GL

6G SERIES

Points

6GP2 Pick 246.0 9.68 412.9 16.26 34.3 1.35 24.1 53.10

6GP1 Pick 246.0 9.68 412.9 16.26 33.5 1.32

6GC2 Chisel 278.1 10.95 442.4 17.42 70.0 2.76 25.0 55.10

6GCF2 Chisel/flare 278.0 10.95 442.4 17.42 120.0 4.72 27.4 60.50

Adapters

703D6G Spherilok 211.2 8.31 479.4 18.87 457.2 17.99 49.9 110.00

WN6G Weld-On 211.2 8.31 293.9 11.56 457.2 17.99 39.3 86.60

Pin

5678GL

7G SERIES

Points

7GP3 Pick 36.6 1.44

7GP2 Pick 269.2 10.60 440.6 17.35 36.6 1.44 28.0 61.80

7GC2 Chisel 297.2 11.70 468.8 18.45 70.0 2.76 29.1 64.10

Adapters

703D7G Spherilok 212.7 8.73 482.7 19.00 481.9 19.33 53.8 118.70

WN7G 212.7 8.73 295.3 11.60 509.9 20.43 41.8 92.10

Pin

5678GL

8G SERIES

Points

8GP3 Pick 37.7 1.48

8GP2 Pick 302.0 11.89 494.4 19.46 37.7 1.48 36.7 80.90

Adapters

787D8G Spherilok 245.2 20.37 517.5 20.37 547.2 32.26 71.9 158.50

Pin

5678GL

*Dimension F is comprised of P2 type Pick Points and Nose Length D

GeoVor Assembly 

Components

GeoVor

Weld-on Nose

NOTE: Items 

without dimensions 

are currently under 

development and 

will be available in 

the near future.
Exhibit 6