	

Environmental Assessment	

Review of the Application for Acceptance of the SeaRiver Maritime Inc.
S/R American Progress and Severn Trent de Nora BalPure™ System into
the 

Shipboard Technology Evaluation Program (STEP)

February 2009

Prepared by Volpe Transportation Research Center for 

U.S. Coast Guard

Table of Contents

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc231203609"  1.0	Purpose and
Need for Action	  PAGEREF _Toc231203609 \h  1-1  

  HYPERLINK \l "_Toc231203610"  1.1	Introduction	  PAGEREF _Toc231203610
\h  1-1  

  HYPERLINK \l "_Toc231203611"  1.2	Purpose and Need	  PAGEREF
_Toc231203611 \h  1-1  

  HYPERLINK \l "_Toc231203612"  1.3	Background	  PAGEREF _Toc231203612
\h  1-1  

  HYPERLINK \l "_Toc231203613"  1.4	PEA for STEP	  PAGEREF _Toc231203613
\h  1-1  

  HYPERLINK \l "_Toc231203614"  1.5	Scope and Related Activities	 
PAGEREF _Toc231203614 \h  1-1  

  HYPERLINK \l "_Toc231203615"  2.0	Alternatives	  PAGEREF _Toc231203615
\h  2-1  

  HYPERLINK \l "_Toc231203616"  2.1	Alternative 1:  No Action
Alternative - Deny application	  PAGEREF _Toc231203616 \h  2-1  

  HYPERLINK \l "_Toc231203617"  2.2	Alternative 2:  Proposed Action
Alternative - Accept application	  PAGEREF _Toc231203617 \h  2-1  

  HYPERLINK \l "_Toc231203618"  2.2.1	Typical Vessel Activities	 
PAGEREF _Toc231203618 \h  2-1  

  HYPERLINK \l "_Toc231203619"  2.2.2	Description of Technology	 
PAGEREF _Toc231203619 \h  2-1  

  HYPERLINK \l "_Toc231203620"  3.0	Affected Environment	  PAGEREF
_Toc231203620 \h  3-1  

  HYPERLINK \l "_Toc231203621"  3.1	Resources Dismissed from Further
Consideration	  PAGEREF _Toc231203621 \h  3-1  

  HYPERLINK \l "_Toc231203622"  3.2	Biological Resources	  PAGEREF
_Toc231203622 \h  3-1  

  HYPERLINK \l "_Toc231203623"  3.3	Water Quality	  PAGEREF
_Toc231203623 \h  3-1  

  HYPERLINK \l "_Toc231203624"  3.4	Public Health and Safety	  PAGEREF
_Toc231203624 \h  3-1  

  HYPERLINK \l "_Toc231203625"  4.0	Environmental Consequences	  PAGEREF
_Toc231203625 \h  4-1  

  HYPERLINK \l "_Toc231203626"  4.1	Biological Resources	  PAGEREF
_Toc231203626 \h  4-1  

  HYPERLINK \l "_Toc231203627"  4.1.1	No Action Alternative	  PAGEREF
_Toc231203627 \h  4-1  

  HYPERLINK \l "_Toc231203628"  4.1.2	Proposed Action Alternative	 
PAGEREF _Toc231203628 \h  4-1  

  HYPERLINK \l "_Toc231203629"  4.2	Water Quality	  PAGEREF
_Toc231203629 \h  4-1  

  HYPERLINK \l "_Toc231203630"  4.2.1	No Action Alternative	  PAGEREF
_Toc231203630 \h  4-1  

  HYPERLINK \l "_Toc231203631"  4.2.2	Proposed Action Alternative	 
PAGEREF _Toc231203631 \h  4-1  

  HYPERLINK \l "_Toc231203632"  4.3	Public Health and Safety	  PAGEREF
_Toc231203632 \h  4-1  

  HYPERLINK \l "_Toc231203633"  4.3.1	No Action Alternative	  PAGEREF
_Toc231203633 \h  4-1  

  HYPERLINK \l "_Toc231203634"  4.3.2	Proposed Action Alternative	 
PAGEREF _Toc231203634 \h  4-1  

  HYPERLINK \l "_Toc231203635"  5.0	Cumulative Impacts	  PAGEREF
_Toc231203635 \h  5-1  

  HYPERLINK \l "_Toc231203636"  5.1	No Action Alternative	  PAGEREF
_Toc231203636 \h  5-1  

  HYPERLINK \l "_Toc231203637"  5.2	Proposed Action Alternative	 
PAGEREF _Toc231203637 \h  5-1  

  HYPERLINK \l "_Toc231203638"  6.0	Comparison of the Alternatives and
conclusion	  PAGEREF _Toc231203638 \h  6-1  

  HYPERLINK \l "_Toc231203639"  6.1	Conclusion	  PAGEREF _Toc231203639
\h  6-1  

  HYPERLINK \l "_Toc231203640"  7.0	References	  PAGEREF _Toc231203640
\h  7-1  

  HYPERLINK \l "_Toc231203641"  8.0	Appendix A. Acronyms and
Abbreviations	  PAGEREF _Toc231203641 \h  8-1  

  HYPERLINK \l "_Toc231203642"  9.0	Appendix B.  Example of Section 7
Letter Sent to Resource Agencies.	  PAGEREF _Toc231203642 \h  9-1  

  HYPERLINK \l "_Toc231203643"  10.0	Appendix C.  Correspondence
Received Via Agency Consultation.	  PAGEREF _Toc231203643 \h  10-1  

  HYPERLINK \l "_Toc231203644"  11.0	Appendix D. State Listed
Threatened, Endangered, and Rare Species (TPWD, 2008)	  PAGEREF
_Toc231203644 \h  11-1  

  HYPERLINK \l "_Toc231203645"  12.0	Appendix E.  Air Quality Analysis	 
PAGEREF _Toc231203645 \h  12-1  

  HYPERLINK \l "_Toc231203646"  13.0	Appendix F.  Effluent Toxicity Test
results	  PAGEREF _Toc231203646 \h  13-1  

  HYPERLINK \l "_Toc231203647"  14.0	Appendix G: Matrix of comments and
responses	  PAGEREF _Toc231203647 \h  14-1  

  HYPERLINK \l "_Toc231203648"  15.0	Appendix H: List of agencies and
persons consulted	  PAGEREF _Toc231203648 \h  15-1  

 

Purpose and Need for Action

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) BalPure™ 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 BalPure™ 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.   

Purpose and Need

The purposes of the action considered within this EA (accepting the S/R
American Progress with the STDN BalPure™ 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
BalPure™ 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.  

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 BalPure™ 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.

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.

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).

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.

 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 BalPure™ 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.  

Alternative 1:  No Action Alternative - Deny application

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

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.

™ 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.  

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. 

Description of Technology 

The STDN BalPure™ 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). 

™ 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 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 BalPure™  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 BalPure™ 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.

™ 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.  

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).

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.

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.

 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. 

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).

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 newly-identified 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
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.

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 on-going problem since. 

 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.

  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 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.

 

 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.  

 Biological Resources

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 BP-2000 system, the vessel
would continue to manage ballast water as it does currently.  Because
the S/R American Progress remains within 200 miles of the U.S. coast at
all times in its voyage, it does not conduct ballast water exchange and
therefore always discharges untreated, un-exchanged ballast in the cargo
loading port areas.  Consequently, a small but real potential exists
that transportation of NIS by the S/R American Progress is possible,
although the specific risk is difficult to quantify for any single ship.

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 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 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.

 Water Quality

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.  

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 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.  

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/1ppm TOC)	69.5ppb	257-4320 ppb	80 ppb	80ppb

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

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

Public Health and Safety

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.

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
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.

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.  

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.  

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.  Comparison of the
Alternatives and conclusion

Table 6-1 compares the potential consequences of the Proposed Action
Alternative and the No Action Alternative.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  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



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. 

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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

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

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 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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	 	 

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	 	 

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	 	 

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

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.

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:

Appendix G: Matrix of comments and responses

Docket Number	Commenter(s)	Comment	Coast Guard’s Response

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter requested clarification as to why the
hypochlorite injection rate is compared to the equivalent chlorine rate
in Section 1.3, paragraph 2.	The comparative terms are used to better
capture the actual amount of biocide dosed to the ballast water versus
the total mass of chemical injected, which includes some inert matter..

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter inquired as to whether the
neutralization step was inline during discharge or in tank immediately
prior to discharge in Section 1.3, paragraph 2. 	Yes, the neutralization
step is inline. This issue is addressed in the technology description
section 2.2.2 in the FEA.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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/



  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter requested clarification of Section
2.2, paragraph 2, where it is stated that under Alternative 2, that the
SR American Progress would be “free to discharge ballast water treated
by the experimental 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”	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 applicable regulations and may
require revisions to the STEP application, and a new review and approval
decision by the USCG.”

.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter asked, in regards to Section 2.2.2,
paragraph 2: Is the gaseous hydrogen vented from the ship in dedicated
piping or pre-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.  

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter wanted to know if the system would
allow the alarm to be disabled or shut off without manually switching to
feed water source.  The commenter also asked if there was a reason that
this switch doesn’t occur automatically.(Section 2.2.2, paragraph 1)
Yes, the alarm 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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter requested elaboration on Section
2.2.2, paragraph 2. The commenter wanted to know if there was a required
holding time once the ballast water had been treated. The commenter
wanted to know if the organisms were assumed to be killed immediately
upon uptake.	There is no required holding time related to treatment of
potential organisms in the ballast water.  The Coast Guard has added an
additional paragraph in this section in order to clarify this concern. 
Organisms are assumed to be killed upon exposure to the treatment, as
explained in 2.2.2.  However, for purposes of neutralization of the
disinfectant upon discharge, the system relies upon an assessment of
residual disinfectant 24 hours prior to discharge.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter asked if the hypochlorite level (in
addition to the sodium bisulfate level) was measured post-neutralization
to ensure the water is safe to discharge.  The commenter also wanted to
know if the neutralization was instantaneous.(Section 2.2.2, paragraph
4)	The residual hypochlorite level will be measured 24 hours prior to
discharge in order to 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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter wanted to know how long are these
three tanks of sodium bisulfate expected to last, and how often they are
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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	In the second paragraph of the Chemical Residuals
section within Section 2.2.2, the commenter asked if the initial target
dose was automatically adjusted based upon ballast water quality, or if
it would require assessment by the crew.	No, the target dose is not
automatically adjusted based on ballast water quality.  The basis for
target dosage levels comes from the analysis of ranges of total organic
carbon, found in water quality data from Tampa, Florida, the original
ballasting source for this ship.  

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter asked for 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.	The Coast Guard agrees that the sentence might be perceived as
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.”



  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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.. 

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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 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.

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ation in paragraph 2 of Section 4.3.2 of who would be responsible for
the training of personnel in how to refill sodium bisulfate, and to
handle the TOC analyzer (STDN employees, ship crew).  The commenter also
asked for clarification of, after the first year of operation, who the
responsibility lies with in performing maintenance and re-supply of the
system, and how they will be trained to ensure personnel safety.(Section
4.3.2, paragraph 3)	The Coast Guard has amended Section 4.3.2., third
paragraph, to reflect that the manufacturer will provide training for
the ship’s personnel to operate the system. 

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The commenter requested a discussion of cumulative
water quality impacts from the discharge of HAA5 and THM into an already
industrialized waterway to be inserted into Section 5.2.	The Coast Guard
believes 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.

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	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 treatment system.  The commenter
suggested adding a table.	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..

  HYPERLINK
"../Public%20Comments/AmericanProgressComments_CSLC%20rae.doc" 
USCG-2008-0126 	CSLC	The Coast Guard received a number of comments from
the CSLC regarding minor editorial changes.	The Coast Guard has
incorporated these comments in order to improve readability.



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.

USCG STEP Environmental Assessment		

 PAGE   

SeaRiver STDN BalPure System 

STEP Application	  PAGE  15-1 

FINAL DRAFT

