Feasibility and Efficacy of Using
Potable Water Generators as an
Alternative Option for Meeting
Ballast Water Discharge Limits
                         i
      United States Environmental Protection Agency
      Office of Wastewater Management
      1200 Pennsylvania Avenue, NW
      Washington, DC 20460
                                 m
EPA 830-R-15-002
    July 2015

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                              ACKNOWLEDGEMENTS

       The EPA Office of Wastewater Management (OWM), in partnership with the United
States Maritime Administration (MARAD), developed the following report evaluating the
feasibility and efficacy of using onboard potable water generators as a ballast water source. EPA
acknowledges Eastern Research Group, Inc. (ERC); the University of Maryland Center for
Environmental Sciences, Maritime Environmental Resource Center (UMCES/MERC); Ocean
Associates; and H2O, Inc. for their contract support on this project. In particular, EPA thanks
Carolyn Juneman (MARAD); Mario Tamburri, Janet Barnes, and George Smith
(UMCES/MERC); Debra Falatko and Edward Viveiros (ERG); Carl Setterstrom (Ocean
Associates); and Stan Adams (H2O, Inc.) for their contributions toward implementing and
completing this project. EPA would also like to acknowledge the significant contributions made
to this effort by James Schardt in EPA's Great Lakes National Program Office.

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                         The primary technical contact for this document is:



                                          Ryan Albert

                              U.S. Environmental Protection Agency

                       Office of Wastewater Management (Mail Code 4203M)

                                 1200 Pennsylvania Avenue, NW

                                     Washington, DC 20460

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                      Table of Contents
                               TABLE OF CONTENTS
                                                                                  Page
SECTION 1 INTRODUCTION	1-1
       1.1    Regulatory Framework for Ballast Water Discharges	1-1
       1.2    Evaluating the Feasibility and Efficacy of Using a Potable Water
             Generator (PWG) to Meet Ballast Water Numeric Discharge Limits	1-1

SECTION 2 VESSEL TYPES FOR WHICH A PWG OPTION is POSSIBLE	2-1
       2.1    Ballasting Operations by Type of Vessel	2-1
             2.1.1  Ballasting Operations for Tugboats and Towboats	2-3
             2.1.2  Ballasting Operations for Offshore Workboats	2-5
             2.1.3  Ballasting Operations for Passenger Vessels	2-6
             2.1.4  Ballasting Operations for Commercial Fishing Vessels	2-7
             2.1.5  Ballasting Operations for Research and Other Potentially Relevant
                    Vessels	2-9
       2.2    Ballast Discharge Rates by Type of Vessel	2-10
       2.3    Capacity of Onboard PWGs	2-10
       2.4    Vessels for Which PWGs are Possible for Ballast Water Replacement	2-14

SECTION 3 PWG AND DISINFECTION TECHNOLOGIES APPLICABLE TO VESSELS	3-1
       3.1    Overview of Technical Specifications for PWG and Disinfection Systems	3-2
             3.1.1  Summary of Available PWGs	3-2
             3.1.2  Summary of Available Disinfection Systems	3-3
       3.2    Overview of PWG and Disinfection System Costs	3-8
             3.2.1  Capital Costs	3-8
             3.2.2  O&M Costs	3-10
             3.2.3  Combined Costs for PWG and Disinfection Systems	3-13

SECTION 4 FEASIBILITY OF DESIGN - CASE STUDIES	4-1
       4.1    Research Vessel	4-1
             4.1.1  Vessel Characteristics	4-1
             4.1.2  PWG Retrofit Analysis	4-6
             4.1.3  Alternative Arrangement	4-9
             4.1.4  Conclusion	4-9
       4.2    Inland River Towboat	4-11
             4.2.1  Vessel Characteristics	4-11
             4.2.2  PWG Retrofit Analysis	4-15
             4.2.3  Conclusion	4-18
       4.3    Research Class Vessel	4-18
             4.3.1  Vessel Characteristics	4-18
             4.3.2  PWG Retrofit Analysis	4-26
             4.3.3  Conclusion	4-29
       4.4    Parametric Analysis to Extrapolate the Case-Study Findings	4-29
             4.4.1  Meaningful Design Parameters	4-30
             4.4.2  Designs Used for EPA's Parametric Analysis	4-30
             4.4.3  Parametric Relationships	4-32
                                           IV

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                     Table of Contents
                              CONTENTS (Continued)

                                                                             Page

            4.4.4  Case Studies vs. Parametric Data	4-36
            4.4.5  Application of Case Study Results to Retrofitting Various Vessel
                   Types	4-37
            4.4.6  Conclusions	4-43
      4.5   New Design vs. Retrofitting	4-43
            4.5.1  Parametric Data for PWGs	4-44
            4.5.2  Impact on Vessel Characteristics	4-45
            4.5.3  Economic Considerations	4-48
            4.5.4  Extrapolation to Other Vessel Types and Sizes	4-48

SECTION 5 EFFICACY OF PWG AND DISINFECTION SYSTEMS FOR BALLAST WATER
      GENERATION	5-1
      5.1   Literature Data on Treatment Efficacy of PWG Systems	5-1
            5.1.1  Literature Search Methodology	5-1
            5.1.2  Overview of Literature Data on PWG Treatment Efficacy	5-2
            5.1.3  Conclusion	5-3
      5.2   Engineering Assessment of PWG and Disinfection System Treatment
            Efficacy	5-3
            5.2.1  RO Treatment Mechanism and Expected Effect on Living
                   Organisms	5-3
            5.2.2  Distillation Treatment Mechanism and Expected Effect on Living
                   Organisms	5-5
            5.2.3  Biocide Disinfection Treatment Mechanism and Expected Effect
                   on Living Organisms	5-6
            5.2.4  Physical Disinfection Treatment Mechanism and Expected Effect
                   on Living Organisms	5-9
            5.2.5  Conclusions	5-10
      5.3   "Proof of Concept" Evaluation of PWG-Disinfection System Efficacy	5-11
            5.3.1  Background	5-11
            5.3.2  Summary of Results	5-12
            5.3.3  Conclusions	5-13
      5.4   Comparison of PWG-Disinfection System Treatment Efficacies against
            2013 VGP Numeric Treatment Limits	5-13

SECTION 6 CONCLUSIONS REGARDING THE FEASIBILITY OF USING PWGs FOR
      BALLAST OPERATIONS	6-1

SECTION 7 REFERENCES	7-1

APPENDIX A:  TECHNICAL SPECIFICATIONS FOR PWG AND DISINFECTION
              SYSTEMS
APPENDIX B:  SUMMARIES OF INFORMATION GATHERED IN TELEPHONE
              CONVERSATIONS WITH PWG VENDORS
APPENDIX C:  PROOF OF CONCEPT EVALUATION OF PWGS OPTIONS FOR
              MANAGING BALLAST WATER FOR TARGET VESSELS

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                          List of Tables
                                     List of Tables

                                                                                  Page

Table 2-1. Small Commercial Vessel Types and their Ballasting Operations	2-2
Table 2-2. Summary of Gathered Vessel Data and Ballasting Rates	2-12
Table 2-3. Summary of Available PWGs Aggregated by Water Production Capacity	2-13
Table 3-1. Summary of Disinfection Systems Aggregated by Disinfection Technology	3-3
Table 3-2. Summary of Technical Specifications for PWGs	3-5
Table 3-3. Summary of Technical Specifications of Disinfection Systems	3-6
Table 3-4. Components of Technology Option Total Capital Investment	3-8
Table 3-5. Total Capital Investment Costs by PWG Technology	3-10
Table 3-6. Total Capital Investment Costs by Disinfection  System Technology	3-10
Table 3-7. Total O&M Cost by PWG Technology1	3-11
Table 3-8. Total O&M Cost by Disinfection System Technology1	3-12
Table 3-9. Total Capital Investment Cost for PWG and Disinfection Systems Combined	3-14
Table 3-10. Total Daily and Annual O&M Cost for PWG and Disinfection Systems
        Combined	3-16
Table 4-1. Summary of R/VPelican Vessel Characteristics and Mechanical Systems	4-1
Table 4-2. Summary of USAGE Vessel Characteristics and Mechanical Systems	4-11
Table4-3. Summary of Oscar Dyson Vessel Characteristics and Mechanical Systems	4-18
Table 4-4. Vessel Data Used in the Parametric Analysis	4-31
Table 4-5. Vessel Characteristics for Various Small Cruise Ships	4-42
Table 4-6. Vessel Characteristics for Various Fishing Vessels	4-43
Table 4-7. Deck Area Requirements by PWG Model	4-44
Table 4-8. Required Increase in Length x Beam due to PWG Requirements	4-46
Table 4-9. Vessel and PWG Characteristics for Select Cruise Ships	4-49
Table 5-1. Reported Organism Reductions for Sodium Hypochlorite, Silver, and Bromine
        Disinfection	5-7
Table 5-2. Reported Organism Reductions for Disinfection by UV Radiation	5-9
Table 5-3. MERC Evaluation Results for Key Parameters Related to PWG Treatment
        Efficacy for Living Organisms	5-13
Table 5-4. Comparison of Numeric Ballast Water Discharge Limits against MERC
        Evaluation Results	5-14
                                           VI

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                        List of Figures

                                    List of Figures
                                                                                  Page

Figure 4-1. Hold Arrangement for the R/VPelican	4-4
Figure 4-2. Machinery Arrangement for Existing Equipment on the R/V Pelican	4-5
Figure 4-3. Machinery Arrangement after Retrofitting the R/V Pelican	4-8
Figure 4-4. Machinery Arrangement after Retrofitting the R/VPelican (Alternate
        Arrangement)	4-10
Figure 4-5. Hold and Main Deck Arrangement for the USAGE Vessel	4-12
Figure 4-6. Machinery Arrangement for Existing Equipment on the USAGE Vessel	4-14
Figure 4-7. Machinery Arrangement after Retrofitting the US ACE Vessel	4-16
Figure 4-8. Machinery Space Locations for the Oscar Dyson	4-22
Figure 4-9. Main Machinery Room (Lower Level) for Existing Equipment on the Oscar
        Dyson	4-23
Figure 4-10. Main Machinery Room (Upper Level) for Existing Equipment on the Oscar
        Dyson	4-24
Figure 4-11. Auxiliary Machinery Room and Domestic Equipment Space for Existing
        Equipment on the Oscar Dyson	4-25
Figure 4-12. Auxiliary Machinery Room after Retrofitting the Oscar Dyson	4-28
Figure 4-13. Machinery Space Deck Area vs. Propulsion Horsepower	4-33
Figure 4-14. Machinery Space Deck Area vs. Displacement	4-33
Figure 4-15. Machinery Space Deck Area vs. Length Overall	4-34
Figure 4-16. Machinery Space Deck Area vs. Length x Beam	4-34
Figure 4-17. Machinery Space Deck Area vs. Cubic Number	4-35
Figure 4-18. Machinery Space Deck Area vs. Cubic Number (Vessel Types Identified)	4-36
Figure 4-19. Machinery Space Deck Area vs. Length x Beam (Case Study Vessels
        Identified)	4-36
Figure 4-20. PWG Required Deck Area vs. PWG Capacity	4-45
Figure 5-1. Comparison of Organism Sizes against Filter Pore Sizes for Various Filtration
        Processes	5-4
                                          vn

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                   Section 1-Introduction

                                                                          SECTION 1
	INTRODUCTION

1.1    REGULATORY FRAMEWORK FOR BALLAST WATER DISCHARGES

       On March 28, 2013, EPA reissued the Vessel General Permit (VGP) for discharges
incidental to the normal operation of vessels. A key new provision of the permit is numeric
discharge limits to control the release of non-indigenous invasive species in ballast water1
discharges from inland and seagoing vessels greater than 1,600 gross registered tons (GRT), or
3,000 gross tons (GT), unless otherwise excluded.2 The VGP specified that owners/operators of
these vessels must use one of the following four ballast water management methods to meet the
numeric ballast water discharge limits:

       •      Ballast water treatment system,
       •      Onshore treatment,
       •      Use of a public water supply for ballast, or
       •      No discharge of ballast water.

       While not required by the 2013 VGP, the permit also encouraged owners and operators of
"Lakers" (i.e., vessels built before January 1, 2009 and operating exclusively on the Laurentian
Great Lakes) and inland and seagoing vessels smaller than 1,600 GRT (3,000 GT) to use
alternative management measures to reduce the number of living organisms in their ballast water
discharges.

1.2    EVALUATING THE FEASIBILITY AND EFFICACY OF USING A POTABLE WATER
       GENERATOR (PWG) TO MEET BALLAST WATER NUMERIC DISCHARGE LIMITS

       EPA is assessing whether additional options may be available for meeting ballast water
numeric discharge limits in future iterations of the VGP, or other regulatory mechanisms, as
appropriate. One option the Agency is considering is the use of onboard potable water generators
(PWGs). This report provides an overview of a study performed  by EPA, in partnership with the
U.S. Maritime Administration (MARAD), to assess the feasibility and efficacy of using PWGs to
manage ballast water.3 The study considered:
1 Ballast water means any water taken onboard into ballast water tanks that assists with vessel draft, buoyancy, and
stability (USEPA, 2013a).
2 As specified in Part 2.2.3.5.3 of the 2013 VGP, the following types of vessels are excluded from having to meet
the numeric standards: (1) vessels engaged in short-distance voyages that operate in or take on and discharge ballast
water exclusively in one Coast Guard Captain of the Port (COPT) zone; (2) vessels that do not travel more than 10
nautical miles and do not cross any physical barriers or obstructions; (3) unmanned and unpowered barges (such as
hopper barges); and (4) vessels that operate exclusively on the Laurentian Great Lakes (known as Lakers) that were
built before January 1, 2009.
3 For this report, EPA considers a PWG to be any system that produces purified water from fresh, brackish, or
saltwater sources using distillation or reverse osmosis technologies, with the purified water then being disinfected
with chemicals or ultraviolet radiation to neutralize any remaining living organisms and pathogens and make the
water potable.
                                            1-1

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                    Section 1-Introduction
        •       Applicable vessel types and the amount of ballast water needed,
        •       PWG design characteristics and costs,
        •       Feasibility of installing a PWG onboard a vessel, and
        •       Efficacy of a PWG to meet ballast water numeric discharge limits.
                                               1-2

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Feasibility and Efficacy of Using Potable Water Generators                     Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits           Which a PWG Option is Possible

                                                                       SECTION 2
     VESSEL TYPES FOR WHICH A PWG OPTION IS POSSIBLE

       To assess whether onboard PWGs are a feasible option for managing ballast water
discharges, EPA evaluated typical ballasting operations, volumes, and flow rates required for
various vessel types. EPA then compared vessel ballast requirements against what is achievable
using commercially available PWGs to determine under what conditions this technology could
apply to vessels. This section presents the information EPA gathered on vessel ballasting
operations and PWG capacities and  discusses the conditions under which PWG technologies
may appropriate for ballast water management.

2.1    BALLASTING OPERATIONS BY TYPE OF VESSEL

       According to the United States Coast Guard (USCG, 2012), large commercial vessels
(e.g., container ships, bulk carriers, other cargo vessels, and tankers) load and offload ballast
water in large quantities at high rates over relatively short periods. For example, large
commercial vessels have ballast water capacities ranging from 1,700 m3 to approximately
215,000 m3 and ballast water pump  capacities ranging from 250 m3/hr to 6,500 m3/hr (USCG,
2012).  These rates far exceed the capacity of existing onboard PWGs; although in some
instances, such generators are currently used aboard vessels to satisfy daily fresh water demands
for drinking, laundry, galley, dishwashing, sinks, showers, and sanitary water. Commenters
responding to the proposed 2013 VGP indicated that PWGs may be a viable option for satisfying
ballast water requirements for certain small commercial vessels that ballast to compensate for
fuel burn (e.g., towboats) and for certain large vessels with relatively modest ballasting
requirements (e.g., passenger vessels and fishing vessels). Accordingly,  EPA's data collection
for this analysis focused on these vessel types and operations for which PWG ballasting may be
applicable.  Table 2-1  summarizes the information EPA collected on ballasting operations by
vessel type.
                                          2-1

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                                     Section 2-Vessel Types for
                                                                                               Which a PWG Option is Possible
                              Table 2-1. Small Commercial Vessel Types and their Ballasting Operations
    Vessel Type
          Description
                  Ballasting Operations
                                                                                                                          Ballast Volume
      (gal)
                          (m3)
 Utility: Tugboats
Tugboats or towboats
Tugboats carry relatively small volumes of ballast water and
have low ballasting rates in the 20 to 250 gallon/minute (gpm)
range.1 Using potable water as ballast is common practice for
inland towing vessels. These types of vessels do use potable
water for accommodating changes in displacement and
balance as fuel is consumed during the voyage. For these
operations the ballast is discharged prior to refueling. Some
tugboats may also use permanent ballast.	
Inland tug:
20,000 to 40,0002

Coastal tug:
20,000 to 70,0002

Small harbor tug:
2,000 to 3,OOP2
                   Inland tug:
                   76tol512

                   Coastal tug:
                   76 to 2652

                   Small harbor tug:
                   8 to  II2
 Utility: Off-
 Shore Support
 Vessels (OSVs)
Supply vessels that support off-
shore oil and gas operations.
Includes crew boats, lift boats,
and tugs and barges that carry
equipment, supplies, and workers.
OSVs generally have designated ballast tanks, take on fresh
municipal water as ballast, and offload ballast at the off-shore
rig or back in port. These types of vessels do not use seawater
for ballast and do not discharge ballast water to the sea. Lift
boats take on and discharge seawater as ballast in the exact
same location.
26,000 to
1,321,0003
                   100 to 5,0003
  Small Passenger
  Vessels
Dinner cruise vessels, sightseeing
and excursion vessels, passenger
and vehicular ferries, private
charter vessels, whale watching
and eco-tour operations,
windjammers, gaming vessels,
amphibious vessels, water taxis,
and overnight cruise ships	
Very few commercial passenger vessels carry or discharge
ballast water. Passenger vessels that do carry ballast water
carry 2,000 to 21,000 gallons, and ballast at rates ranging
from 180 to 800 gpm.3 Recreational charter boats generally do
not have ballast water tanks.
0 to 21,000'
                   0 to 794
 Fishing Vessels
Vessels 65 to 297 feet (ft) in
length
Smaller fishing vessels do not require and are not equipped
with ballast tanks (but would be equipped with fish holding
tanks). Among fishing vessels equipped with ballast tanks,
some use PWG as ballast, others are permanently ballasted,
and others ballast/deballast routinely.	
0 to 566,0004
                   Oto2,1004
 Research Vessels
Coastal and oceangoing vessels
86 to 470 ft in length3
Vessel profile is relatively stable, generally requiring only
minor adjustments to maintain trim, often managed using fuel.
Larger vessels that perform longer-term surveys may ballast
to compensate for fuel burn.	
0 to 1,268,0004
                   0 to 4,8004
Source: USEPA, 2012
1 AWO, 2012
2AWO, 2009
3IMO, 2012
4 USEP A, 2013b, rounded to the nearest thousand gallons
                                                                       2-2

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Feasibility and Efficacy of Using Potable Water Generators                      Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits           Which a PWG Option is Possible

2.1.1   Ballasting Operations for Tugboats and Towboats

       EPA obtained information and data regarding tugboats and towboats and their ballasting
operations from comments submitted in response to the proposed 2013 VGP, as well as
telephone contacts with vessel owners/operators, as described below:

       •     The American Waterways Operators (AWO) is the national trade association for
             the tugboat, towboat, and barge industry. AWO's member companies include
             owners and operators  of barges and towing vessels operating on the U.S. inland
             and intracoastal waterways; the Atlantic, Pacific, and Gulf coasts; and the Great
             Lakes. According to AWO:
             -     Towing vessels use relatively small volumes of ballast water - a typical
                    inland towboat can carry 20,000 to 40,000 gallons (gal) of ballast water,
                    and a typical coastal tugboat has a ballast water capacity of 20,000 to
                    70,000 gal (AWO, 2012). A  small harbor tug might have a capacity of
                    2,000 to 3,000 gal (AWO, 2009).
                    Towing vessels have very low ballasting rates, usually ranging from 20 to
                    250 gpm (AWO, 2012).
             AWO acknowledges that using potable water as ballast is common practice for
             inland towing vessels, but not universal. In particular,  this practice is not
             operationally or economically feasible for towing vessels that carry ballast water
             to maintain stability and trim  (i.e., accommodate changes in vessel displacement
             and balance) as fuel is consumed during a voyage. As  an example, AWO
             describes that a towboat may  need to take up 3,000 to  5,000 gal of ballast water
             per day to offset fuel consumption. The percentage of these vessels that use
             potable water as ballast is unknown.

             AWO acknowledges that some tugboats use permanent ballast and never
             discharge that water, but others need to take on and discharge ballast water for
             safe operation. The percentage of vessels that use permanent ballast is unknown
             (AWO, 2012).

       •     Canal Barge Company operates a fleet of 32 inland towboats and more than  800
             barges that operate on the Intracoastal Waterway, Lower Mississippi River,
             Illinois River, and Ohio River. Canal Barge Company describes a large towing
             vessel as one that takes on ballast to compensate for burning 10,000 gal of fuel
             per day (equivalent to 8,320 gal of ballast water, assuming a diesel fuel density of
             0.832 kilograms per liter) (Canal Barge Company, 2012).
       •     Allied Transportation Company owns and operates 8 oceangoing tugboats and 13
             barges on the East and Gulf Coasts of the United States. Their towing vessels take
             on ballast only to compensate for fuel consumed and only discharge ballast prior
             to refueling. Their largest capacity tugboat carries a maximum of 178 m3 of
             ballast water (47,022 gal) (Allied Transportation Company, 2012). According to
             EPA's VGP Notice of Intent (NOI) database, this vessel is 863 GT and 124 ft
             long.  Other Allied Transportation Company vessels (non-barge) in the NOI
                                          2-3

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Feasibility and Efficacy of Using Potable Water Generators                      Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits          Which a PWG Option is Possible

              database range from 95 to 700 GT, from 80 to 128 ft, and from 0 to 50,400 gal of
              ballast water capacity.
       •      American River Transportation Co. (ARTCO) operates a fleet of 1,835 barges, 28
              linehaul vessels, and over 50 local harbor vessels on the inland river system.
              ARTCO described a typical voyage for a linehaul vessel operating on the Lower
              and Upper Mississippi River, below St. Louis:
                     Departs St. Louis southbound full of fuel with approximately 18,500 gal
                     of ballast on board.
                     About two days later (Memphis), the crew adds another 18,500 gal of
                     ballast.
                     In New Orleans, the crew discharges 22,000 gal of ballast when adding
                     fuel.
                     About three days later (Rosedale), the crew adds 18,000 gal of ballast.
                     About three days later (New Madrid), the crew adds 18,000 gal of ballast.
              -      In St. Louis, the crew fully fuels the vessel and discharges all ballast
                     except for 18,500 gal (ARTCO, 2012).
       •      Great Lakes Towing Company tugboats operate in harbors  and do not require
              ballast water; their vessels are not equipped with ballast tanks (ERG, personal
              communications, May 17, 2013).
       •      Sause Bros, operates: (1) harbor vessels such as assist/general towing/escort
              vessels and tugs/crew boats that shuttle crews to offshore production facilities,
              and (2) oceangoing unmanned barges and towing vessels operating on the West
              Coast. Harbor vessels do not carry ballast water and  many are not equipped with
              ballast tanks. Oceangoing towing vessels maintain trim by shifting fuel between
              tanks; ballast water is rarely used and only under such conditions as operating in
              heavy seas when the vessel is light on fuel (ERG, personal communications, May
              14,2013).
       •      AEP River Operations provides barge transportation services of dry bulk
              commodities throughout the inland river system. AEP's inland towing vessels
              ballast and deballast to compensate for  fuel consumption or refueling.  A voyage
              may run five to seven days from Memphis to St. Louis. Fuel is taken on every
              four or five days; after about two days of fuel burn, the vessel trim is affected, at
              which point ballast water is added from time to time at a slow rate. Other towing
              vessels are able to add fuel every day, and it is not critical for them to use ballast
              water to maintain trim (ERG, personal communications, March 26, 2014).

       These comments and  communications regarding tugboat and towing vessels and NOI
data indicate that:

       •      Inland and coastal tugboats and towboats of all sizes routinely carry ballast water.
              Many of these vessels use potable water as ballast; however, the percentage of
              vessels that use potable water as ballast is unknown.  In addition, an unknown
                                           2-4

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Feasibility and Efficacy of Using Potable Water Generators                      Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits          Which a PWG Option is Possible

              percentage of vessels are not equipped with ballast tanks or use permanent ballast
              that is never discharged.
       •      Vessels that take on ballast while underway use ballast to compensate for fuel
              burned during a voyage. This ballast is discharged when refueling. The
              percentage of vessels with these ballasting operations is unknown.
       •      The amount of ballast water varies by vessel type. A typical inland towboat can
              carry 20,000 to 40,000 gal of ballast water, a typical coastal tugboat has a ballast
              water capacity of 20,000 to 70,000 gal, and a small harbor tug may have a
              capacity of 2,000 to 3,000 gal.

2.1.2   Ballasting Operations for Offshore Workboats

       EPA obtained information and data regarding offshore workboats and their ballasting
operations from comments submitted in response to the proposed 2013 VGP and the USCG
proposed ballast water discharge standard rulemaking (2012), as described below:

       •      The Offshore Marine Service Association (OMSA) represents owners and
              operators of approximately 1,200 vessels (offshore supply vessels, crewboats,
              liftboats, and tugs and barges) that carry equipment, supplies, and workers in
              support of offshore oil and gas exploration and development in the Gulf of
              Mexico. According to OMSA, vessels in their membership have designated
              ballast tanks that take on only fresh municipal water that is then offloaded to an
              offshore rig or to a facility once back in port (OMSA, 2012a and 2012b). They do
              not take on  seawater for ballast, and they do not discharge ballast water to the sea.
              Coastwise vessel operators specifically do not allow seawater in ballast tanks due
              to its corrosivity (OMSA, 2009).
              Also, according to OMSA, liftboats take on seawater, referred to as "preload"
              water, to firmly attach their legs to the seafloor to work alongside  a rig. The
              vessel discharges the preload water completely (as mandated by their USCG
              certified Operations Manual) before moving and navigating to its next point.
              Therefore, liftboats take on and discharge seawater in the exact same location
              (OSMA, 2009).

              Per OSMA, 2009, more than 80 percent of membership vessels operate within
              two COTP zones (New Orleans and Morgan City, Louisiana).

       •      Rowan Companies, Inc. requested that EPA consider adding an option to use
              freshwater generated from seawater (from watermakers, desalinization units,
              reverse osmosis units, etc.) as a source of ballast water.  According to Rowan
              Companies, freshwater generated from seawater is often used for potable water on
              mobile offshore drilling units and as a source of ballast water for vessels with
              moderate ballast water requirements (-84,000 gal) (Rowan Companies, Inc.,
              2012).
       •      Hornbeck Offshore Operators, LLC provides offshore supply vessels serving the
              oil and gas industry in the Gulf of Mexico. They also operate tugboats and barges
                                           2-5

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Feasibility and Efficacy of Using Potable Water Generators                      Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits           Which a PWG Option is Possible

              to transport petroleum products in northeastern United States and the Gulf of
              Mexico. Hornbeck Offshore states that the majority of their vessels use municipal
              water as their primary source of ballast water (Hornbeck Offshore Operators,
              2009).

       These comments regarding offshore workboats indicate that:

       •      The vast majority of offshore workboats use municipal potable water as their
              primary or sole source of ballast water.
       •      A typical offshore workboat ballasting requirement may be 84,000 gal.
       •      Liftboats take on and discharge ballast at the exact same location.
       •      An estimated 80 percent of offshore workboats operate within two COTP zones,
              in Louisiana.

2.1.3   Ballasting Operations for Passenger Vessels

       EPA obtained information and data regarding passenger vessels and their ballasting
operations from comments submitted on the proposed 2008 VGP and proposed 2013 VGP, as
well as telephone contacts with vessel owners/operators, as described below:

       •      The Passenger Vessel Association represents U.S.-flagged passenger vessels of all
              types (dinner cruise vessels, sightseeing and excursion vessels, passenger and
              vehicular ferries, private charter vessels, whale-watching and eco-tour operators,
              windjammers, gaming vessels, amphibious vessels, water taxis, and overnight
              cruise ships), with nearly 600 vessel and associate members. According to the
              association, very few commercial passenger vessels either carry or discharge
              ballast water (PVA, 2008).
       •      The National Association of Charterboat Operators represents over 3,300 charter
              boat owners and operators  of for-hire vessels ranging from 15-ft center console
              outboards to 120-ft triple engine headboats. The commenter states that
              recreational charter boats do not have ballast water tanks (NACO, 2008).
       •      Argosy Cruises operates 11 vessels in and around the Seattle harbor and Lake
              Washington, performing sightseeing tours and private charters. These vessels do
              not carry ballast water or leave local waters. The Argosy Cruises website (Argosy
              Cruises, 2012) describes 9  vessels ranging in length from 36 to 180 ft (Argosy
              Cruises, 2008).
       •      The Boat Company operates two vessels with overnight accommodations on
              week-long conservation/education cruises in Southeast Alaska Inside Passage
              waters. Both vessels are  150 ft in length; one vessel is less than 100 GRT and the
              other is 403 GRT. Neither vessel carries ballast water (The Boat Company, 2008).
       •      According to Maryland's Pride, sailing school vessels (limited to 500 GRT) and
              sail  and auxiliary sail vessels (limited to 100 GRT) operating under Subchapter T
              do not have water ballast tanks (fixed ballast only). Voyages are typically short
              and frequent (Maryland's Pride, 2008).
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Feasibility and Efficacy of Using Potable Water Generators                      Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits          Which a PWG Option is Possible

       •      River Cruises operates a 157-ft Riverboat with two-day overnight cruises on the
              Upper Mississippi River. According to River Cruises, while the vessel has ballast
              water tanks, they have never been used; if the ballast tanks were to be used, they
              would be filled with fresh water from shore (River Cruises, 2008).
       •      Seabourn Cruise Line operates 6 oceangoing cruise vessels that carry between
              130 and 450 passengers. Seabourn vessels do not take on seawater for ballasting,
              but manage trim by adding advanced wastewater treatment permeate, untreated
              graywater, or treated blackwater to ballast tanks. These ships may add ballast
              using these water sources to compensate for fuel consumption or for bad weather
              (ERG, personal communications, May 28, 2013).
       •      According to EPA's VGP NOT database, medium cruise ships carrying 100 to 499
              passengers have an average ballast water capacity of approximately 135,000 gal
              (512 cubic meters (m3)). Large cruise ships carrying more than 500 passengers
              have an average ballast water capacity of approximately 1,000,000 gal (3,900 m3).

       These comments and communications regarding passenger vessels and NOT data indicate
that:

       •      Very few passenger vessels either carry or discharge ballast water; however, the
              percentage of vessels that do not carry or discharge ballast water is unknown.
       •      Among the passenger vessels that do carry ballast water, some use bunkered
              potable water as ballast. The percentage of these vessels that use potable water is
              unknown.
       •      Among the smaller passenger vessels that do carry ballast water, the amount of
              ballast water carried is unknown; however, available information regarding ballast
              capacities suggest the amount may range from less than 2,100 gal (8 m3) to
              20,700 gal (78 m3).
       •      Many larger passenger vessels have ballasting options other than seawater and
              municipal potable work, depending on onboard sanitary systems. Medium and
              large cruise ships have average ballast water capacities of approximately 135,000
              gal (512 m3) to 1,000,000 gal (3,900 m3), respectively.

2.1.4   Ballasting Operations for Commercial Fishing Vessels

       EPA obtained information and data regarding commercial fishing vessels and their
ballasting operations from comments submitted in response to the proposed 2013 VGP, as  well
as telephone contacts with vessel owners/operators, as described below:

       •      United Fisherman of Alaska (UFA) is the largest statewide commercial fishing
              trade association, representing 37 commercial fishing organizations participating
              in fisheries throughout the state and its offshore federal waters. According to
              UFA, in 2007, the Alaska commercial fishing fleet included 9,828 commercial
              fishing vessels ranging in length from 7 to 635 ft, including 497 vessels over 79
              ft. In a comment, UFA requested that EPA make explicit that water taken on
              board in a fish hold for purposes of fishing and tendering (fish and shellfish) is
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Feasibility and Efficacy of Using Potable Water Generators                      Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits          Which a PWG Option is Possible

              not defined as ballast water. Further, UFA stated that ballast tanks on some
              fishing vessels are filled with potable water or are permanently filled (UFA,
              2012).
       •      United Catcher Boats and Pacific Seafood Processors Association provided joint
              comments. United Catcher Boats represents owners of vessels that trawl for
              groundfish in the Bering Sea, Gulf of Alaska, and West Coast commercial
              fisheries. Their 72 member vessels range from 75 to 190 ft and range between 100
              and 500 GT. Pacific Seafood Processors Association corporate members are
              major seafood processing companies with operations in Alaska and Washington.
              Their only comment regarding ballast water was to request that EPA exempt re-
              circulating seawater tanks from ballast water requirements (UCBA and PSPA,
              2012).
       •      At-sea Processors Association, the Freezer Longline Coalition, and the Ground
              Fish Forum provided collective comments. At-sea Processors Association
              represents six companies that own and operate 16 U.S.-flag catcher processor
              vessels that participate in the Alaska pollock fishery, accounting for more than
              one-third of all fish harvested in the United States. These vessels range in size
              from approximately 250 to 340 ft and approximately 1,500 to 5,000 GT. The
              Freezer Longline Coalition represents owners and operators of 30 U.S.-flag
              vessels that participate in the freezer longline or catcher/processor hook-and-line
              sector of the Pacific cod fishery in the federal waters of the Bearing Sea, Aleutian
              Islands, and the Gulf of Alaska. These vessels range in size from approximately
              110 to 180 ft and approximately 140 to 900 GT. The Ground Fish Forum
              represents 5 companies and 17 vessels/licenses that are part of the "Amendment
              80" sector in the Bering Sea/Aleutian Islands and operate in the Gulf of Alaska.
              These vessels range in size from 100 to 295 ft in length and from 180 to 1,600
              tons. The commenters stated that most of their members' vessels are equipped
              with ballast tanks and will be subject to VGP ballast water requirements. The
              commenters described the need to ballast/deballast when operating in severe
              weather and rough seas. The commenters also stated that several vessels currently
              use potable water generated on board for ballast water (APA, FLC, and GFF,
              2012).
       •      An anonymous commenter stated that smaller Alaskan commercial fishing vessels
              discharge 70,000 gal or less of ballast water (Anonymous, 2012).
       •      iWorkWise provides consulting services to the commercial fishing industry in the
              Pacific Northwest and Alaska. According to iWorkWise, commercial fishing
              vessels primarily deballast as they use fuel and catch fish, which they stow in
              their cargo holds. They also ballast to control trim when they are transiting to and
              from Alaska (ERG, personal communications, April 9, 2014).

       These comments and communications regarding fishing vessels indicate that:

       •      Many of the fishing vessels within this group, especially the smaller fishing
              vessels, do not require and are not equipped with ballast tanks (they are equipped
              with fish hold tanks, which are typically not used to maintain the trim and
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Feasibility and Efficacy of Using Potable Water Generators                      Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits          Which a PWG Option is Possible

              stability of the vessel). The percentage of these vessels without ballast tanks is
              unknown.
       •      Among the fishing vessels equipped with ballast tanks, some use potable water
              (either bunkered municipal water or potable water generated on board) as ballast,
              or they are permanently ballasted. Some may never use or discharge ballast water.
              However, others ballast and deballast frequently and routinely when conducting
              fishing operations and burning fuel.

2.1.5   Ballasting Operations for Research and Other Potentially Relevant Vessels

       EPA obtained information and data regarding other types of small vessels or other vessels
with modest ballasting requirements from comments submitted in response to the proposed 2013
VGP, as well as telephone contacts with vessel owners/operators, as described below:

       •      Cetacean Marine operates and maintains research, training, and offshore support
              vessels. According to Cetacean Marine, the only time Great Lakes non-cargo
              vessels must ballast is at the commencement of the sailing season and when the
              accumulation of onboard sewage or the consumption of fuel requires shifting,
              uptaking, or discharging of ballast water. Cetacean Marine requested that EPA
              consider the use of onboard PWGs such as an onboard reverse osmosis
              watermaker as another compliance alternative (Cetacean Marine, 2012).
       •      The ocean survey vessel Bold is a 224-ft oceangoing research vessel previously
              owned by EPA. This vessel's trim is  adjusted to sit low in the water to provide
              greater stability; trim  is generally maintained using fuel (250,000-gal fuel
              capacity). The vessel  uses ballast water to compensate for fuel consumption.
              Ballasting is performed once or twice during a 2-week survey with a typical
              ballasting volume of about 3,000 gal  (ERG, personal communications, May 29,
              2013).
       •      R/VLake Guardian is a 180-ft Great  Lakes research vessel owned by EPA. In
              2010, the vessel's ballast tanks were  converted to potable water tanks. At the
              onset of the season (April), the vessel operators fill the Guardian's potable water
              tanks with municipal  potable water. Potable water, fuel, and sewage are shifted
              between tanks as necessary to maintain stability and trim. Additional ballasting
              and deballasting is minimized, and no ballast water has been discharged over the
              last several years (ERG,  personal communications, June  7, 2013).
       •      R/V Savannah is a 92-ft oceangoing research vessel that operates primarily in the
              South Atlantic, Cape Hatteras, and Cape Canaveral. The  vessel has a 27,000-gal
              capacity for freshwater ballast. The vessel's stability profile is fairly standard,
              requiring only minor adjustments during the voyage, primarily made with fuel.
              Only rare conditions would require seawater ballasting, such  as if the peak tank
              was low and the vessel encountered rough seas (ERG, personal communications,
              June 30, 2013).
       •      R/VHugh R. Sharp is a 146-ft coastal research vessel that operates in the
              Delaware and Chesapeake Bays and adjacent coastal waters out to 200 nautical
                                           2-9

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Feasibility and Efficacy of Using Potable Water Generators                      Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits           Which a PWG Option is Possible

              miles. The vessel does not have ballast water tanks or use water as ballast; fuel is
              used to maintain trim (ERG, personal communications, July 11, 2013).

       These comments and communications indicate that:

       •      Non-cargo vessels in the Great Lakes ballast infrequently. Vessels maintain trim
              by shifting potable water, fuel, or sewage.
       •      Research vessels internally ballast fuel to maintain trim. Some also use ballast
              water to compensate for fuel consumption. The percentage of vessels that use
              ballast water to compensate for fuel consumption is unknown.

2.2    BALLAST DISCHARGE RATES BY TYPE OF VESSEL

       To assess ballast discharge rates, EPA gathered information on eight vessels and seven
vessel classes ranging from 138 to 32,000 GT. Table 2-2 summarizes the information for each
vessel or vessel class. The information is grouped by vessel type (e.g., research, utility,
passenger, etc.), and presents general information about the vessel, typical vessel ballast pump
ratings in gpm, and fuel burn rates in gpm.

       Most operators indicated their vessels or vessel classes take on ballast to compensate for
fuel consumption, while some operators reported taking on ballast to level out the vessel or to
compensate for cargo loads (Rowan EXL jackup rigs and the NFS vessel M/VRanger III,
respectively) (GA,  2011  and  ERG, personal communications, June 11, 2013). Overall, vessel
ballast rates range from 155 to 800 gpm. These rates largely are determined by the ballast pump
(i.e., vessels take on ballast as quickly as their ballast pumps  allow).

       For commercial fishing vessels, EPA did not receive information on typical vessel
ballasting rates. However, comments from the VGP docket and iWorkWise indicate that fishing
vessels ballast to compensate for fuel use, satisfying ballasting requirements by managing cargo
holds, using ballast tanks filled with potable water, or using permanently filled ballast tanks.

       For comparative purposes, EPA  estimated fuel burn rates for those vessels that indicated
they ballast solely for compensating for fuel burn off. This rate, shown in Table 2-2, represents
the minimum ballasting rate required to maintain vessels at a steady draft or trim. These rates
range from approximately 0.3 to 3.4 gpm for research vessels, and from approximately 3.4 to
18.3 gpm for utility (towing) vessels. These values are based on fuel  consumption estimates
provided by vessel operators, and have been adjusted to reflect an assumed specific gravity of
0.82 for fuel oil. In general, fuel burn rates are one to two orders of magnitude lower than ballast
pump rates.

2.3    CAPACITY OF ONBOARD PWGs

       To determine if commercially available PWGs can provide enough water for ballasting,
EPA researched and contacted PWG vendors and used publicly available data sources. Table 2-3
summarizes the number of PWG vendors and systems available by the range of water production
rating (in gpm). The information provided in Table 2-3 indicates that most PWGs are designed to
generate potable water in the 0 to 30 gpm range. Above 30 gpm, the number of system options
                                          2-10

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Feasibility and Efficacy of Using Potable Water Generators                       Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits           Which a PWG Option is Possible

are reduced. The largest PWG on the market was designed to handle generation rates up to about
400 gpm.

       Information on PWGs, their sizes, and their potable water generation rates are included in
Section 3.
                                              2-11

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
     Section 2-Vessel Types for
Which a PWG Option is Possible
                                Table 2-2. Summary of Gathered Vessel Data and Ballasting Rates
Vessel Name/Class
Vessel Information
Length
(ft)
Breadth
(ft)
Gross
Tonnage
Gross
Registered
Tonnage
Detailed
Drawings?
(Y/N)
Vessel Ballast Data
Ballast
Pump
Rating
(gpm)
Fuel Burn Rate
(gpm)
Ballasting Notes
Research Vessels
NSF UNOLS Pelican
(Geared Diesel Engine)
NSF UNOLS Savannah
(Geared Diesel Engine)
NOAA FSV Class Vessels1
(Diesel Electric Engine)
NOAA T-AGOS Class
Vessels2
(Diesel Electric Engine)
NSF UNOLS Endeavor
EPA Bold
EPA GLNPO Lake Guardian
NSF UNOLS Hugh R. Sharp
116
92
209
224
176
224
180
146
27
27
49
43
40
20
40
32
—
265
2,218
1,914
292
1,914
299
495
261
—
—

—
—
—
—
Y
Y
Y
Y
N
N
N
N
200
170
176 or 353
175
140 to 150
155 to 175
—
—
0.3
0.3
1.4
1.5
2.9 to 3.4
—
—
—
Based on fuel burn rate of 0.4 gpm and fuel
SG of 0.82.
Assume similar fuel burn rate as the
Pelican.
Based on fuel burn rate of 1 .8 gpm and fuel
SG of 0.82.
Based on fuel burn rate of 1 .9 gpm and fuel
SG of 0.82.
Based on fuel burn rate of 3.5 to 4.2 gpm
and fuel SG of 0.82.
3,000 gal, intermittently.
Ballast discharges kept to a minimum; use
fuel and sewage as ballast.
—
Utility Vessels
AEP River Operations
Towing Vessels
Sause Bros. Towing Vessels
Marquette Transportation
Towing Vessels
Rowan EXL Jackup Rigs
85 to 195
96 to 143
52 to 200
--

—
—
--
138 to 839
82 to 199
50 to 1,103
--
232 to 1,415
139 to 280
—
--
N
N
N
Y
20 to 250
250
—
--
3.4 to 4.6
3. 4 to 18.3
—
--
Based on fuel burn rate of 4.2 to 5.6 gpm
and fuel SG of 0.82.
Based on fuel burn rate of 4.2 to 22.3 gpm
and fuel SG of 0.82.
—
~83,000 gal per ballasting event.
Passenger Vessels
NFS M/V Ranger III
Seabourn Cruise Line
(Cruise Vessels)
150
—
34
—
648
10,000 to
32,000
—
—
N
N
180
800
—
—
Ballasts over short intervals, hence sizeable
rating.
79,250 to 3 17,000 gal per voyage. Ballasts
over short intervals.
                                                                 2-12

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
     Section 2-Vessel Types for
Which a PWG Option is Possible
                                Table 2-2. Summary of Gathered Vessel Data and Ballasting Rates
Vessel Name/Class
Vessel Information
Length
(ft)
Breadth
(ft)
Gross
Tonnage
Gross
Registered
Tonnage
Detailed
Drawings?
(Y/N)
Vessel Ballast Data
Ballast
Pump
Rating
(gpm)
Fuel Burn Rate
(gpm)
Ballasting Notes
Training Vessels
TS Golden Bear
(Geared Diesel Engine)
466
72
13,574
—
Y
350 to 550
—
53,800 to 80,700 gal every few weeks.
Sources: ABS, 2014a; LUMCON, no date; NOAA, no date a and b; SIO, 2013; USEPA, 2009 and 2013b.
SG - Specific gravity
1 Based on vessel information for the Henry B. Bigelow.
2 Based on vessel information for the McArthur II.
                       Table 2-3. Summary of Available PWGs Aggregated by Water Production Capacity
Water Production
Rating
<10 gpm
10 to 20 gpm
20 to 30 gpm
30 to 40 gpm
40 to 50 gpm
50 to 60 gpm
60 to 70 gpm
70 to 80 gpm
80 to 90 gpm
90 to 100 gpm
>100 gpm
>200 gpm
>300 gpm
No. of Vendors1
13
11
7
3
2
3
1
3
0
2
3
1
1
No. of Vendor
Systems2
144
30
12
5
3
3
1
3
0
2
7
2
1
                                            1 EPA identified a total of 13 PWG vendors. This table
                                              double counts vendors offering multiple PWGs with
                                              different ratings.
                                            2 EPA identified a total of 213 vendor systems.
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Feasibility and Efficacy of Using Potable Water Generators                      Section 2-Vessel Types for
as an Alternative Option for Meeting Ballast Water Discharge Limits           Which a PWG Option is Possible

2.4    VESSELS FOR WHICH PWGs ARE POSSIBLE FOR BALLAST WATER REPLACEMENT

       A comparison of large vessel ballasting rates to potable water generation rates indicates
that it is impractical to generate potable water at rates high enough to compensate for large, rapid
changes in displacement, such as those seen in cargo operations of many larger ship types.  A
small oil tanker has ballast discharge rates of tens of thousands of gallons per minute. Bulk
carriers have ballast discharge rates  of several hundred to over a thousand tons per hour. Small
container ships that unloaded at the rate of 20 to 30 (or more) containers per hour require
ballasting rates of between 800 to 1,200 gpm, assuming an average container weighs
approximately 20,000 pounds and they are not able to internally ballast.4 PWG use by any  of
these vessel types likely would not be feasible due to needed pumping rates.

       For small vessels, comparing the ballast pump rates (Table 2-2) to possible PWG
production rates (Table 2-3) indicates that using PWGs as an all-purpose source of ballast water
(e.g., when loading and unloading cargo or fighting fires) may not be feasible. Overall, the
ballast pump rates in Table 2-2 show that these vessels take on hundreds of gallons of water per
minute. Of the 213 PWGs listed in Table 2-3, only 10 systems (5 percent) could meet ballast
water demands at this order of magnitude. The size of these  10 PWGs likely would preclude
them from being feasible for small vessels. However, it would be more realistic for vessels to
maintain draft or trim using PWGs with production capacities comparable to their fuel burn
rates. EPA has analyzed PWG feasibility using fuel burn rates for vessels for the following
reasons:

       •      Ballast water pumps  also serve as firemain pumps, with firefighting capacity
              driving pump design  requirements.
       •      Steady-state filling represents a best-case scenario. If the analysis is not successful
              under this condition,  it is reasonable to conclude that it would not be able to meet
              the surges in demand associated with non-steady-state scenarios.
       •      While steady-state filling of ballast tanks is not typical, EPA believes vessel
              stability concerns can be managed using the steady-state generation rates of
              PWGs.

       Based on this initial analysis of ballasting rates versus PWG rates, using PWGs to
generate onboard ballast water would appear to be limited primarily to smaller vessel types to
maintain draft or trim or to compensate for fuel burn unless those vessels also use other
ballasting management strategies (e.g., internal ballasting or using public water supply water) to
complement use of PWGs. Therefore, the remainder of this report focuses on the feasibility of
using PWG's to generate onboard ballast water for smaller commercial vessels.
1 Containers typically are 20 or 40 ft long, with a height and width of just under 8 ft (WSC, 2014).

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Feasibility and Efficacy of Using Potable Water Generators                 Section 3—P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits    Technologies Applicable to Small Vessels

                                                                       SECTION 3
                         PWG AND DISINFECTION TECHNOLOGIES
	APPLICABLE TO VESSELS

       As discussed in Section 1, this report evaluates the feasibility of using onboard PWGs to
meet vessel ballasting requirements. Vessel generation of potable water requires both
purification of the water source and subsequent disinfection to remove harmful microorganisms
to ensure the water is safe for human consumption. As a result, the onboard PWGs considered in
this report represent a composite of two primary subsystems: the PWG and the disinfection
system. Together, these two subsystems would generate potable water that would be supplied
directly to vessel ballast or potable water storage tanks. The following section provides an
overview of PWG and disinfection technologies, including their technical specifications and
associated capital and operating and maintenance (O&M) costs.

       PWGs use either vacuum distillation or reverse osmosis (RO) technologies to draw fresh,
brackish, or salt water into the PWG for purification. The treated water is then typically passed
through disinfection systems to remove microorganisms (MCA, 1999). Operational factors that
can impact the efficiency of PWGs include inlet water temperatures and contamination (e.g.,
hydrocarbons can foul RO filter membranes).

       Vacuum distillation systems use heat and low pressure to purify fresh or seawater. The
heat source used for this process is waste heat produced by the vessel's main engine. This waste
heat is delivered to the distiller through the main engine's cooling water and has a typical
temperature of about  65ฐC. Because the distiller operates under vacuum, the boiling point of
water is reduced to less than 45ฐC. In this manner, approximately half of the seawater fed into
the distiller is converted into distilled water (McGeorge, 1995).

       RO systems use semipermeable membranes to physically separate dissolved solids from
water. These membranes have pore sizes that range from approximately 0.2 to 1 nanometers
(nm) (KMS, 2012). A pump continually forces feedwater (i.e., fresh, brackish, or salt water)
against the semipermeable membrane; dissolved salts in the feedwater are too large to pass
through the pores and are continually rejected from the system as a brine discharge, while the
treated water passes through the membrane (McGeorge, 1995).

       Product water from distillation and RO processes typically are passed through
disinfection systems to remove harmful microorganisms that would make the water unsafe for
human consumption.  Typical technologies used  for water disinfection include
chlorination/bromination,  electro-katadyn, and ultraviolet (UV) technologies. Chlorination,
bromination, and electro-katadyn disinfection systems are installed between the PWG and the
potable water storage tank(s). UV disinfection systems, on the other hand, are installed
downstream of storage tank(s) (McGeorge, 1995).

       Chlorination and bromination disinfection systems deliver a fixed amount of chlorine or
bromine to kill microorganisms. Chlorine is supplied as calcium hypochlorite powders or pellets,
as a sodium hypochlorite solution, or as a gas  that is generated onboard through electrolysis of
sodium chloride solutions. In systems using dry  powders or pellets, the chlorine is dropped
                                          3-1

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Feasibility and Efficacy of Using Potable Water Generators                  Section 3—P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits    Technologies Applicable to Small Vessels

directly into a water tank. Systems using hypochlorite solutions or chlorine gas dose chlorine
continuously  through a metering pump.

       The electro-katadyn process is used as an alternative method for disinfecting water. In
this method, silver ions, which are toxic to bacteria, are dissolved into water as it passes through
a chamber containing a silver anode. The amount of silver released from the anode and into the
water is governed by the intensity of the current passing through the silver anode.

       UV sterilizers use ultraviolet radiation to eliminate microorganisms present in water.
These units are typically positioned as  close to tap supply points as possible (McGeorge, 1995).
UV sterilizers are most effective when treating water with a higher UV transmittance such as
treated water. This is because any suspended solids present in the water can block UV light. The
reduced UV dose resulting from the presence of suspended solids would mean that more
microorganisms could pass through the sterilizer without being neutralized or inactivated.

3.1    OVERVIEW OF TECHNICAL SPECIFICATIONS FOR PWG AND DISINFECTION SYSTEMS

       The information presented in this section is based  on EPA's review of vendor literature.
EPA identified these vendors through general internet searches for PWG and disinfection
systems and through searches of marine supply websites, as guided by previous EPA efforts
supporting the ballast water best available technology analysis for small vessels (USEPA, 2012).
From the vendor websites, EPA collected technical data about vendor systems, including their
dimensions, weight, and power requirements. This information is provided in Attachment A.

       In addition to reviewing vendor literature, EPA contacted several vendors directly for
supplemental information about their systems and to discuss the feasibility and availability of
PWG and disinfection systems. Attachment B summarizes the information gathered from those
conversations.

3.1.1   Summary of Available PWGs

       EPA identified 13 vendors offering a total of 213 unique PWG systems.  Of this total, 4
vendors offered 35 distillation systems while the remaining vendors offered 178 RO systems.
Only one vendor provided both distillation and RO systems (this particular vendor provided ten
distillation systems and six RO systems). Based on these observations, there appears to be a
greater availability of PWG vendors and vendor systems utilizing RO technologies than
distillation-based PWGs.

       Table 3-2 summarizes the technical specifications associated with each of the PWGs
identified by EPA. The data are aggregated by PWG technology (i.e., distillation or RO) and by
water production rate, in gpm. Overall, the table shows water production rates spanning from
<10 gpm up to 400 gpm. Of the PWGs identified by EPA, the greatest production rates are
associated with RO systems,  with rates ranging from <10  gpm up to 400 gpm. Distillation
systems provide rates that are an order of magnitude lower (<10 gpm up to 20 gpm).

       In comparing RO and distillation system dimensions, there does not appear to be a
significant difference when comparing similarly rated systems. However, distillation systems
tend to be heavier than RO systems. For example, the 10- to 20-gpm distillation systems in Table
                                           3-2

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
       Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
3-2 weigh 2,006 to 18,000 Ib; however, similarly rated RO systems weigh only 1,350 to 10,200
Ib.

       Power requirements represent a second distinguishing feature between the two PWG
technologies. As mentioned previously, distillation systems must recover heat from vessel
engines. These systems also use electrical power, but only to the extent needed to run ancillary
distillation equipment. Heat input requirements for the distillation systems in Table 3-2 range
from 75,000 to 7,165,000 British thermal units per hour (BTU/hr), while electrical requirements
range from 0.6 to 1.6 kilowatts (kW). RO systems, on the other hand, rely solely on electricity
and therefore have significantly greater electrical power requirements than their distillation-
based counterparts. Comparing 10- to 20-gpm systems, Table 3-2 shows that distillation-based
PWGs consume 1.6 kW while similarly rated RO systems consume 15.3 to 40 kW.

3.1.2   Summary of Available Disinfection Systems

       EPA identified 10 vendors offering a total of 99 unique disinfection systems. These
systems are sold independently of PWGs and use one of four disinfection technologies:
bromination, chlorination, electro-katadyn, or UV. Table 3-1 lists the number of vendors and
vendor systems for each of the four technologies. Based on Table 3-1, there appears to be greater
availability of chlorination and UV systems than of bromination and electro-katadyn systems.

    Table 3-1. Summary of Disinfection Systems Aggregated by Disinfection Technology
Disinfection System
Technology
Bromination
Chlorination
Electro-Katadyn
UV
Total
No. of
Vendors1
1
5
2
6
14
No. of Vendor
Systems
8
21
6
64
99
                      1 EPA identified a total of 10 vendors. This table double
                       counts vendors offering more than one technology.

       Table 3-3 summarizes the technical specifications associated with each of the disinfection
systems identified by EPA. The data are aggregated by disinfection technology and by
disinfection rate, in gpm. It is important to note that disinfection rates in Table 3-3  represent the
maximum flow rate that a given disinfection system can accommodate when installed alongside
a PWG as a turnkey system. In this regard, the systems listed in Table 3-3 represent only those
turnkey systems identified by EPA. Disinfection systems can also be independently built from
individual components. For example, a marine engineer could design and assemble a
chlorination system from separately purchased components (i.e., metering pumps and
hypochlorite solution storage tanks). However, to simplify the assumptions for this feasibility
study, EPA excluded individual disinfection system components from the scope of the vendor
system reviews.

       Overall, Table 3-3 shows disinfection rates ranging from <10 gpm to 158,500 gpm. Of
the systems identified by EPA, the greatest rates are associated with chlorine-  and UV-based
systems (900 to 158,500 gpm and  <10 to 6,000 gpm, respectively). Electro-katadyn and
                                           3-3

-------
Feasibility and Efficacy of Using Potable Water Generators                  Section 3—P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits    Technologies Applicable to Small Vessels

bromination systems represent the lower end of the spectrum (30 to 300 gpm and <10 to 40 gpm,
respectively). Compared to PWG water production rates, chlorine- and UV-based systems are
capable of meeting and exceeding the rates in Table 3-2 (i.e., <10 gpm to 400 gpm). Vessels
using bromination and UV systems would need to install multiple units operating in parallel to
achieve the upper-end PWG production rates (i.e., 70 to 400 gpm).

       In terms of overall dimensions and weights, disinfection systems  are significantly smaller
and lighter than PWGs. Disinfection systems also have significantly lower electrical power
requirements than PWGs. Overall requirements for disinfection systems range from 0.04 to 3.3
kW, compared to 0.6 to 180 kW for PWGs. While EPA did not identify data for specific
bromination system power requirements, for the purposes of this analysis, the Agency expects
their power requirements to be comparable to chlorination systems, given that these two
technologies operate similarly (i.e., continuous, metered dispensation of a dilute chemical
solution into the PWG water product stream). Based  on these observations, disinfection system
overall dimensions, weights, and power requirements are not expected to be a significant factor
in feasibility considerations.

       In comparing disinfection systems, the overall dimensions of each system in Table 3-3 do
not differ significantly, although  it appears that chlorination systems tend to require the most
space while  electro-katadyn systems tend to be the most compact. Of the disinfection systems in
Table 3-3, UV systems require the most power (0.03  to 3.3 kW) as compared to the other three
system types (0.04 kW).

       A key distinction among disinfection  system technologies pertains to the types of
consumables associated with each. Bromination systems use consumable cartridges that contain
bromine and have an expected life of 55,000  gal per cartridge. Electro-katadyn systems use silver
anodes that must be replaced approximately every 1,060,000 gal. UV systems use UV lamps that
must be replaced every 9,000 hours. Chlorination systems typically dispense chlorine from a
solution tank containing a dilute solution of sodium hypochlorite. The frequency of solution
replenishment depends on both the concentration of the sodium hypochlorite solution and the
desired  chlorine  dose. For this reason, Table 3-3 does not include the expected life of
chlorination system  consumables.
                                           3-4

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
        Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
                                     Table 3-2. Summary of Technical Specifications for PWGs
Water Production
Rate
No. of
Vendors
No. of
Vendor
Systems
System Dimensions (ft)
Height
Min
Max
Width
Min
Max
Depth
Min | Max
System Cubic
Volume (ft3)
Min
Max
Weight (Ib)
Min
Max
Electrical
Requirement
(kW)
Min
Max
Heat Input
Requirement (BTU/hr)
Min
Max
Distillation
<10 gpm
10to20gpm
4
3
29
6
1.9
4.5
9.6
9.6
0.9
2.8
9.7
9.7
1.7
7.1
10.5
10.5
2.9
90.0
671.6
671.6
125
2,006
15,000
18,000
0.6
1.6
6.5
1.6
75,000
5,800,000
5,971,000
7,165,000
Reverse Osmosis
<10 gpm
10 to 20 gpm
20 to 30 gpm
30 to 40 gpm
40 to 50 gpm
50 to 60 gpm
60 to 70 gpm
70 to 80 gpm
90 to 100 gpm
100 to 200 gpm
200 to 300 gpm
300 to 400 gpm
10
8
7
3
2
3
1
3
2
3
1
1
115
24
12
5
3
3
1
3
2
7
2
1
1.0
1.8
2.6
5.5
6.0
7.4
23.3
7.4
7.4
7.4
29.2
29.2
13.3
16.3
19.3
23.3
23.3
19.6
23.3
29.2
23.3
29.2
29.2
29.2
1.7
3.5
6.0
5.0
6.0
5.0
6.0
6.0
6.0
6.0
7.1
7.1
13.2
13.2
19.0
13.2
14.0
18.6
6.0
14.0
14.0
25.8
7.1
7.1
1.2
2.7
2.7
6.0
2.7
2.7
6.7
2.7
2.7
6.0
6.7
6.8
6.2
10.3
8.2
6.7
6.7
9.5
6.7
7.3
6.7
7.5
6.7
6.8
2.3
17.1
114.8
450.7
224.0
276.9
933.3
276.9
276.9
1,149.6
1,377.3
1,394.5
450.7
900.0
1,253.8
840.0
933.3
1,361.7
933.3
1,166.7
933.3
1,666.7
1,377.3
1,394.5
80
1,350
1,550
5,400
2,400
3,200
13,000
3,200
3,500
5,900
21,000
22,000
6,544
10,234
6,520
6,800
12,000
7,160
13,000
14,000
15,000
19,000
21,000
22,000
1.5
15.3
28
49
_
100
_
140
_
180
_
-
30.5
40
48
49
_
100
_
140
_
180
_
-
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
  N/A - Not applicable
                                                                    3-5

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
        Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
                              Table 3-3. Summary of Technical Specifications of Disinfection Systems
Water
Disinfection
Rate
No. of
Vendors
No. of
Vendor
Systems
System Dimensions (ft)
Height
Min
Max
Width
Min
Max
Depth
Min | Max
System
Cubic
Volume (ft3)
Min
Max
System
Weight (Ib)
Min
Max
Electrical
Requirement
(kW)
Min
Max
Expected Life of System Consumables
(gal/cartridge)
(hr/lamp)
(gal/anode)
Bromination
<10 gpm
10to20gpm
20 to 30 gpm
30 to 40 gpm
1
1
1
1
1
5
1
1
-
3.7
2.3
2.3
-
3.7
2.3
2.3
-
1.2
2.0
3.1
-
1.2
2.0
3.1
-
1.7
0.7
1.3
-
1.7
0.7
1.3
-
7.2
3.1
8.7
-
7.2
3.1
8.7
30
141
45
44
30
141
45
44
-
_
-
-
-
_
-
-
55,000
55,000
55,000
55,000
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Chlorination
900 to
1,000 gpm
2,000 to
3,000 gpm
3,000 to
4,000 gpm
15, 000 gpm
42,000 gpm
158,500 gpm
1
2
1
1
1
1
3
4
3
3
1
1
1.6
3.1
2.3
2.3
2.9
2.9
3.1
3.1
2.3
2.3
2.9
2.9
1.7
1.7
1.7
1.7
3.3
3.3
1.7
1.7
1.7
1.7
3.3
3.3
1.7
1.7
1.7
2.0
2.0
2.0
1.7
1.7
1.7
2.0
2.0
2.0
4.8
4.8
2.3
3.3
19.3
19.3
9.1
9.1
6.3
7.6
19.3
19.3
18
22
40
28
60
60
35
35
40
28
70
70
.
0.04

-
-
-
.
0.04

-
-
-
.


-
-
-
.


-
-
-
.


-
-
-
Electro-Katadyn
30 to 40 gpm
60 to 70 gpm
70 to 80 gpm
100 to 200 gpm
200 to 300 gpm
1
1
1
1
1
1
1
1
2
1
1.6
-
2.0
2.0
2.0
1.6
-
2.0
2.0
2.0
0.2
-
0.5
0.5
0.5
0.2
-
0.5
0.5
0.5
0.2
-
0.5
0.5
0.5
0.2
-
0.5
0.5
0.5
0.1
-
0.4
0.4
0.4
0.1
-
0.4
0.4
0.4
19
-
42
43
45
19
-
42
43
45
0.04
-
0.04
0.04
0.04
0.04
-
0.04
0.04
0.04
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1,056,688
-
1,056,688
1,056,688
1,056,688
Ultraviolet
<10 gpm
10 to 20 gpm
20 to 30 gpm
30 to 40 gpm
40 to 50 gpm
50 to 60 gpm
3
3
4
3
1
1
4
5
5
3
1
1
3.1
1.8
2.7
3.2
2.7
-
3.1
3.2
3.2
3.2
2.7
-
0.7
0.7
0.8
0.8
1.6
-
0.7
1.4
1.6
0.8
1.6
-
0.7
0.5
0.7
0.7
1.0
-
0.7
0.7
1.0
0.7
1.0
-
1.6
1.3
1.8
1.8
4.4
-
1.6
1.6
4.4
1.8
4.4
-
4
23
53
_
55
-
33
23
53
_
55
-
0.03
0.03
0.08
0.12
0.18
-
0.09
0.08
0.48
0.13
0.18
-
N/A
N/A
N/A
N/A
N/A
N/A
9,000
-
9,000
_
9,000
-
N/A
N/A
N/A
N/A
N/A
N/A
                                                                  3-6

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
        Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
                              Table 3-3. Summary of Technical Specifications of Disinfection Systems
Water
Disinfection
Rate
60 to 70 gpm
70 to 80 gpm
80 to 90 gpm
100 to 200 gpm
200 to 300 gpm
300 to 400 gpm
400 to 500 gpm
500 to 600 gpm
600 to 700 gpm
700 to 800 gpm
800 to 900 gpm
900 to
1,000 gpm
1,000 to
2,000 gpm
2,000 to
3,000 gpm
3,000 to
4,000 gpm
5,000 to
6,000 gpm
No. of
Vendors
3
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
No. of
Vendor
Systems
3
1
1
5
2
3
1
2
1
1
1
1
6
3
1
1
System Dimensions (ft)
Height
Min
-
4.1
-
-
-
-
_
-
-
-
-




_
Max
-
4.1
-
-
-
-
_
-
-
-
-




_
Width
Min
-
1.2
-
-
-
-
_
-
-
-
-




_
Max
-
1.2
-
-
-
-
_
-
-
-
-




_
De
Min
-
1.0
-
-
-
-
_
-
-
-
-




_
nth
Max
-
1.0
-
-
-
-
_
-
-
-
-




_
System
Cubic
Volume (ft3)
Min
-
4.8
-
-
-
-
_
-
-
-
-




_
Max
-
4.8
-
-
-
-
_
-
-
-
-




_
System
Weight (Ib)
Min
-
_
-
55
-
-
_
-
-
-
-




_
Max
-
_
-
55
-
-
_
-
-
-
-




_
Electrical
Requirement
(kW)
Min
0.16
0.20
0.20
0.29
0.48
0.64
0.90
0.80
1.20
-
0.96
1.50
1.20
2.70

_
Max
0.16
0.20
0.20
0.40
0.60
0.75
0.90
0.80
1.20
-
0.96
1.50
2.25
3.30

_
Expected Life of System Consumables
(gal/cartridge)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
(hr/lamp)
-
_
-

-
-
_
-
-
-
-




_
(gal/anode)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
 N/A - Not applicable
                                                                   3-7

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
       Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
3.2    OVERVIEW OF PWG AND DISINFECTION SYSTEM COSTS

       This section provides an overview of the capital and O&M costs associated with PWG
and disinfection systems applicable to small vessels.

3.2.1   Capital Costs

       The capital investment costs presented in this section include both direct and indirect
capital costs. Direct capital costs (i.e., the costs associated with purchasing the equipment) are
based on quotes provided directly by vendors. EPA assumes that vessel owners will contract out
equipment installation. Therefore, indirect capital costs related to equipment installation, but
which are not technology-specific, are included. Indirect costs are based on a cost factor analysis
previously developed by EPA (USEPA, 201 la). Table 3-4 lists each of the component costs and
cost factors included in the analysis and describes which specific costs are associated with each
factor.
          Table 3-4. Components of Technology Option Total Capital Investment
Item Component Cost Escalation Description
1
2
3
4
5
6
7
8
Equipment capital
costs
Control systems
Space
Shipboard
installation
Installed capital
costs
Engineering
Contractor overhead
and profit
Classification/
certification
Direct capital cost
17.7% of Item 1
$305/ft2
27% of Items 1-3
Sum of Items 1-4
8% of Item 5
10% of Item 5
2% of Item 5
Direct capital cost obtained from technology option vendors.
Costs for additional control systems, programmable logic
controllers, software interface, sensors, and wiring that would be
incorporated into vessels' existing control systems. The
escalation rate is based on the Department of Defense (DOD)
Military Construction (MILCON) estimating procedures
(USDOD, 2001).
Costs for potential compartment rearrangement, demolition, or
retrofitting necessary to accommodate installation of new
equipment (USEPA, 201 la).
Installation costs estimated for equipment, based on published,
land-based construction data. This escalation factor accounts for
the complexities associated with shipboard construction and
installation (USEPA, 201 la).
Sum of direct capital cost of equipment, plus costs associated
with control system, space rearrangement, and shipboard
installation.
Engineering costs associated with administrative support,
process design and general engineering, communications,
consultant fees, legal fees, travel, supervision, and inspection of
installed technology equipment (USEPA, 201 la).
Costs incurred by the contractor to operate their business, such
as general and administrative expenses, office rent, equipment
purchase/rental, depreciation on office equipment, licenses, and
advertising (USEPA, 201 la).
Costs for activities such as classification and certification
services and on-site survey and construction monitoring.
Classification services are used to verify that a vessel meets the
safety and pollution prevention rules set forth by a specific
classification society. Certification services are used to verify
                                            3-8

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
       Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
          Table 3-4. Components of Technology Option Total Capital Investment
Item Component Cost Escalation Description

9
10
11
12
13

Performance bonds
Scheduling
Insurance
Contractor markup
Contingency

2.5% of Item 5
0.8% of Item 5
2.3% of Item 5
10% of Item 5
20% of Items 5-12
that a vessel complies with various international codes such as
the International Convention for the Prevention of Pollution
from Ships (MAHPOL) and the International Convention for the
Safety of Life at Sea (SOLAS) (USEPA, 201 la).
Costs for performance bonds, which are contracts guaranteeing
performance and demonstrating that the contractor is reliable
and able to carry out the construction project (USEPA, 20 1 la).
Cost to prepare construction progress documents, update Gantt
charts, and develop monthly progress reports (USEPA, 201 la).
Costs for insurance on the construction project, insurance on
heavy equipment used during construction, and public liability
for property damage or non-employee injury (USEPA, 201 la).
Costs added by the contractor to the base price of materials for
handling, procurement, subcontracting, and equipment costs
(USEPA, 201 la).
Costs that may result from incomplete design, unforeseen and
unpredictable conditions, or the complexity and uncertainty
involved, at a conceptual level, in estimating costs (USEPA,
201 la).
       3.2.1.1    PWG Capital Costs

       Table 3-5 provides total capital investment costs by PWG technology. Costs have been
adjusted to account for installed capital costs (i.e., those associated with control systems, space,
and shipboard installation) as well as the total indirect costs associated with equipment
installation, as discussed in Section 3.2.1.

       In comparing total capital costs between the distillation and RO PWG technologies, it
appears that RO systems are less expensive than distillation systems. For example, the total
capital investment cost associated with a 1.7-gpm distillation system is approximately $170,000.
However, at just over half of this capacity, a 1-gpm RO system would cost only one quarter of
the total capital investment cost (i.e., approximately $44,000). Based on these figures, a vessel
owner would be able to install 4, 1-gpm RO systems (total capacity of 4 gpm) for approximately
the same total capital investment cost as a single 1.7-gpm distillation system. This difference is
not a result of cost escalation, as a comparison of direct capital costs reveals the same
relationship.
                                           3-9

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
       Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
              Table 3-5. Total Capital Investment Costs by PWG Technology
System Technology
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
System
Generation
Capacity
(gpm)
1.7
5.0
2.6
1.0
15.3
29.9
Direct
Capital Cost
$40,000
$47,500
$100,000
$11,000
$37,000
$152,845
Installed
Capital Cost
$68,000
$80,000
$155,000
$17,000
$59,000
$260,000
Total Indirect
Capital Costs
$103,000
$122,000
$236,000
$26,000
$90,000
$395,000
Total Capital
Investment Cost
$171,000
$202,000
$391,000
$43,000
$149,000
$655,000
       3.2.1.2    Disinfection System Capital Costs

       Table 3-6 provides total capital investment costs by disinfection system technology. As in
the previous section, costs have been adjusted to account for installed capital costs as well as
total indirect costs associated with equipment installation.

       In comparing capital costs among the four technologies (i.e., bromination, chlorination,
electro-katadyn, and UV disinfection), there do not appear to be disparities in cost to the extent
observed with PWGs. Based solely on the total capital investment cost, it appears that
chlorination systems represent the least expensive disinfection technology. The total capital
investment costs of chlorination systems are one order of magnitude lower than those of the
other three technologies; in addition, their disinfection capacities are greater than those of the
other three technologies by one to two orders of magnitude. Based on these observations, it
appears that chlorination systems are the least expensive of the four technologies, particularly for
vessels requiring significant ballasting volumes.

       Table  3-6. Total Capital Investment Costs by Disinfection System Technology
System Technology
Bromination
Bromination
Chlorination
Chlorination
Electro -Katadyn
Ultraviolet
Ultraviolet
System
Disinfection
Capacity
(gpm)1
19
35
917
138
66
6
31
Direct
Capital Cost
$13,278
$6,577
$712
$765
$4,300
$2,550
$3,550
Installed
Capital Cost
$21,000
$11,000
$2,000
$2,000
$7,000
$4,000
$6,000
Total Indirect
Capital Costs
$31,000
$17,000
$3,000
$3,000
$10,000
$6,000
$9,000
Total Capital
Investment Cost
$52,000
$28,000
$5,000
$5,000
$17,000
$10,000
$15,000
     1 These values represent the maximum water flow rate that a given system can disinfect. They are not a
      measure of output from the unit itself.

3.2.2  O&M Costs

       O&M costs comprise all costs related to operating and maintaining PWG and disinfection
systems and components. In this analysis, O&M costs specifically include:
                                            3-10

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
       Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
              PWG maintenance (e.g., descaling distillation systems or cleaning and replacing
              RO filter membranes).
              Replacing disinfection system consumables.
              Electricity costs.
       PWG maintenance and disinfection system consumables costs are based on estimates
provided by vendors. Electricity costs are based on technology-specific power requirements and
an assumed unit cost of electricity of $0.08/kWh (USEPA, 201 la).

       3.2.2.1     PWG O&M Costs

       Table 3-7 summarizes the O&M costs associated with powering and maintaining
distillation- and RO-based PWGs. The electricity costs in  Table 3-7 assume continuous system
operation over a 24-hour period. This analysis also assumes no  operating costs are incurred from
distillation system heat input requirements, since the heat is recovered in a manner that is
coincidental to the continuous operation of vessel engines. EPA received annual maintenance
costs ranging between  2 and 3 percent of direct capital costs from vendors.  The costs in Table
3-7 assume a maintenance cost of 3 percent. Since ballasting volumes over the course of a year
vary significantly by vessel type, function,  and length of operating season, EPA normalized the
vendor estimates over 365 days per year to establish maintenance costs in terms of dollars per
day.

       For distillation-based PWGs, Table 3-7 suggests that overall daily maintenance costs are
similar, although the cost data are limited to a narrow range of 1.7 to 5 gpm. Electricity costs for
distillation-based PWGs are attributed solely to its ancillary systems, such as feedwater and
distillate pumps. The electricity costs for the distillation systems are inconclusive, as the table
suggests that a 5-gpm system would incur smaller electricity costs than a 1.7-gpm system. For
RO-based PWGs, system maintenance costs increase with system capacity, as do electricity
costs. Given that RO systems have greater electrical requirements than distillation systems, EPA
expects that RO systems will incur the greatest electricity  costs  overall. Based on these
observations, it appears that O&M costs for RO-based PWGs are greater than those for
distillation-based systems, particularly for vessels requiring significant ballasting volumes.

                    Table 3-7. Total O&M Cost by PWG Technology1
Technology
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
System
Capacity
(gpm)
1.7
5
1
15
30
Electrical
Requirement
(kW)
6.5
1.6
2.4
15.3
30.5
Direct
Capital
Cost ($)
40,000
47,500
11,000
37,000
153,000
System
Maintenance
Cost ($/day)2
3.29
3.90
0.90
3.04
12.56
Electricity
($/day)
12.48
3.07
4.59
29.3
58.62
Total O&M
Cost ($/day)
15.77
6.98
5.50
32.34
71.18
     1 Assumes continuous operation over 24 hours per day.
     2 Daily system maintenance cost based on 3% of direct capital cost, normalized over 365 days per year.
                                           3-11

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
       Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
       3.2.2.2     Disinfection System O&M Costs

       Table 3-8 summarizes the O&M costs associated with powering and replacing
consumables for each type of disinfection system. Since ballasting volumes over the course of a
year vary significantly by vessel type, function, and length of operating season, EPA estimated
O&M costs solely in terms of dollars per day, and assumed continuous system operation over the
entire day.

       Overall, Table 3-8 shows that O&M costs are driven by the type of disinfection system
that would be used onboard vessels.  The daily O&M cost of a given system is largely determined
by the cost and frequency of consumables replacement and not by daily electricity costs. Based
on conversations with vendors, EPA determined that bromination and electro-katadyn systems
require cartridge/anode replacements approximately every 55,000 and 1,057,000 gal,
respectively (Everpure, LLC, no date and Aquafides, no date). UV lamps, on the other hand,
require replacement every 9,000 hours (DOE, no date).  Chlorination system
replacement/replenishment rates will depend on the strength of the solution used to disinfect
water. Electrical requirements will depend on the capacity of a given system; however, based on
Table 3-8, there does not appear to be a significant difference in electrical costs when comparing
systems of various capacities.

       Based solely on total O&M costs, it appears that ultraviolet-based disinfection systems
are the most economically feasible of the four technologies. Chiorination-based disinfection
systems appear to  be the second most economically feasible option, and have the greatest overall
disinfection capacities of all systems listed. Given this observation, it appears that both UV- and
chlorination-based disinfection systems would be best suited for vessels with large ballasting
requirements.

              Table 3-8. Total O&M Cost by Disinfection System Technology1
Disinfection
Technology
Bromination
Bromination
Chlorination
Chlorination
Electro -
Katadyn
Ultraviolet
Ultraviolet
System
Disinfection
Capacity
(gpm)
19
35
138
917
66
6
31
Electrical
Requirement
(kW)
0.04
0.04
0.04
0.04
0.04
0.04
0.12
Electrical
Cost
($/day)
0.08
0.08
0.08
0.08
0.08
0.07
0.23
System-Specific Consumables Costs2
Bromine
Cartridges
($/day)
53.73
98.97
N/A
N/A
N/A
N/A
N/A
Sodium
Hypochlorite
Solution3
($/day)
N/A
N/A
79.20
528.00
N/A
N/A
N/A
UV
Lamps
($/day)
N/A
N/A
N/A
N/A
N/A
0.52
0.52
Silver
Anodes
($/day)
N/A
N/A
N/A
N/A
88.20
N/A
N/A
Total
O&M
Cost
($/day)
53.80
99.04
79.28
528.08
88.28
0.59
0.75
 N/A - Not applicable
 1 Assumes 24-hour-per-day operation of each system at the listed system capacity.
 2 Assumes the following costs based on estimates provided by vendors: $108/cartridge (bromination), $24/gal
  solution (chlorination), $980/anode (electro-katadyn), and $195/lamp (ultraviolet).
 3 Assumes chlorine dosing at 2 parts per million (ppm) using a 12% sodium hypochlorite solution.
                                            3-12

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Feasibility and Efficacy of Using Potable Water Generators                  Section 3—P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits     Technologies Applicable to Small Vessels

3.2.3   Combined Costs for PWG and Disinfection Systems

       Table 3-9 summarizes the capital costs associated with each combined PWG-disinfection
system. The figures represent the sum of Table 3-5 and Table 3-6 values (capital costs for
individual PWG and disinfection systems, respectively). Overall, PWGs utilizing RO
technologies are significantly less expensive than distillation systems. For example, the direct
capital cost of a 15-gpm RO PWG is $37,000. At approximately the same cost ($40,000), a
distillation PWG has a capacity of only 1.7 gpm. For disinfection systems, chlorine-based
systems have the lowest capital costs overall, while bromine-based systems have the greatest
capital costs.

       For a given PWG technology (i.e., distillation or RO), the total capital investment cost is
a function of the system's production capacity. However, the type of disinfection system used in
conjunction with the PWG is also a major driver. This is most apparent when comparing costs
for a given PWG. For example, the total capital investment cost of a 15-gpm RO PWG ranges
from approximately $154,000 to $200,000. This differential is directly attributed to the greater
direct capital cost of bromine-based systems over that of the other three types (i.e., chlorine-,
electro-katadyn-, and ultraviolet-based systems).

       Table 3-10 summarizes the O&M costs associated with each combined PWG-disinfection
system, as gathered from correspondence from system vendors. The figures  represent the sum of
Table 3-7 and Table 3-8 values (O&M costs for individual PWG and disinfection systems,
respectively). Looking solely at the PWG component, O&M costs are proportional to production
capacity. Similar to what was observed with capital costs, the type of disinfection system drives
total O&M costs  for a given PWG. Of the four disinfection technologies, ultraviolet- and
chlorine-based systems are the least expensive, while bromine tends to be the most expensive.
The cost differential is largely due to consumables costs, as the combined electrical and system
maintenance costs are relatively consistent among all four disinfection technologies.
                                           3-13

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
       Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
                     Table 3-9. Total Capital Investment Cost for PWG and Disinfection Systems Combined
PWG
Capacity
(gpm)
DS Technology
DS
Capacity
(gpm)
Direct Capital Cost ($)
PWG
DS
Both
Installed Capital Cost ($)
PWG
DS
Both
Total Indirect
Capital Cost ($)
PWG 1 DS
Both
Total Capital
Investment Cost ($)
PWG
DS
Both
Distillation
1.7
5
Bromination
Bromination
Chlorination
Chlorination
Electro -Katadyn
Ultraviolet
Ultraviolet
Bromination
Bromination
Chlorination
Chlorination
Electro -Katadyn
Ultraviolet
Ultraviolet
Reverse Osmosis
1
15
Bromination
Bromination
Chlorination
Chlorination
Electro -Katadyn
Ultraviolet
Ultraviolet
Bromination
Bromination
Chlorination
Chlorination
Electro -Katadyn
Ultraviolet
19
35
917
138
66
6
31
19
35
917
138
66
6
31
40,000
40,000
40,000
40,000
40,000
40,000
40,000
47,500
47,500
47,500
47,500
47,500
47,500
47,500
13,278
6,577
712
765
4,300
2,550
3,550
13,278
6,577
712
765
4,300
2,550
3,550
53,278
46,577
40,712
40,765
44,300
42,550
43,550
60,778
54,077
48,212
48,265
51,800
50,050
51,050
68,000
68,000
68,000
68,000
68,000
68,000
68,000
80,000
80,000
80,000
80,000
80,000
80,000
80,000
21,000
11,000
2,000
2,000
7,000
4,000
6,000
21,000
11,000
2,000
2,000
7,000
4,000
6,000
89,000
79,000
70,000
70,000
75,000
72,000
74,000
101,000
91,000
82,000
82,000
87,000
84,000
86,000
103,000
103,000
103,000
103,000
103,000
103,000
103,000
122,000
122,000
122,000
122,000
122,000
122,000
122,000
31,000
17,000
3,000
3,000
10,000
6,000
9,000
31,000
17,000
3,000
3,000
10,000
6,000
9,000
134,000
120,000
106,000
106,000
113,000
109,000
112,000
153,000
139,000
125,000
125,000
132,000
128,000
131,000
171,000
171,000
171,000
171,000
171,000
171,000
171,000
202,000
202,000
202,000
202,000
202,000
202,000
202,000
52,000
28,000
5,000
5,000
17,000
10,000
15,000
52,000
28,000
5,000
5,000
17,000
10,000
15,000
223,000
199,000
176,000
176,000
188,000
181,000
186,000
254,000
230,000
207,000
207,000
219,000
212,000
217,000

19
35
917
138
66
6
31
19
35
917
138
66
31
11,000
11,000
11,000
11,000
11,000
11,000
11,000
37,000
37,000
37,000
37,000
37,000
37,000
13,278
6,577
712
765
4,300
2,550
3,550
13,278
6,577
712
765
4,300
3,550
24,278
17,577
11,712
11,765
15,300
13,550
14,550
50,278
43,577
37,712
37,765
41,300
40,550
17,000
17,000
17,000
17,000
17,000
17,000
17,000
59,000
59,000
59,000
59,000
59,000
59,000
21,000
11,000
2,000
2,000
7,000
4,000
6,000
21,000
11,000
2,000
2,000
7,000
6,000
38,000
28,000
19,000
19,000
24,000
21,000
23,000
80,000
70,000
61,000
61,000
66,000
65,000
26,000
26,000
26,000
26,000
26,000
26,000
26,000
90,000
90,000
90,000
90,000
90,000
90,000
31,000
17,000
3,000
3,000
10,000
6,000
9,000
31,000
17,000
3,000
3,000
10,000
9,000
57,000
43,000
29,000
29,000
36,000
32,000
35,000
121,000
107,000
93,000
93,000
100,000
99,000
43,000
43,000
43,000
43,000
43,000
43,000
43,000
149,000
149,000
149,000
149,000
149,000
149,000
52,000
28,000
5,000
5,000
17,000
10,000
15,000
52,000
28,000
5,000
5,000
17,000
15,000
95,000
71,000
48,000
48,000
60,000
53,000
58,000
201,000
177,000
154,000
154,000
166,000
164,000
                                                                3-14

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
       Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
                     Table 3-9. Total Capital Investment Cost for PWG and Disinfection Systems Combined
PWG
Capacity
(gpm)
30
DS Technology
Bromination
Chlorination
Chlorination
Electro -Katadyn
Ultraviolet
DS
Capacity
(gpm)
35
917
138
66
31
Direct Capital Cost ($)
PWG
152,845
152,845
152,845
152,845
152,845
DS
6,577
712
765
4,300
3,550
Both
159,422
153,557
153,610
157,145
156,395
Installed Capital Cost ($)
PWG
260,000
260,000
260,000
260,000
260,000
DS
11,000
2,000
2,000
7,000
6,000
Both
271,000
262,000
262,000
267,000
266,000
Tc
Cai
PWG
395,000
395,000
395,000
395,000
395,000
rtal Indirect
pital Cost ($)
DS
17,000
3,000
3,000
10,000
9,000
Both
412,000
398,000
398,000
405,000
404,000
Total Capital
Investment Cost ($)
PWG
655,000
655,000
655,000
655,000
655,000
DS
28,000
5,000
5,000
17,000
15,000
Both
683,000
660,000
660,000
672,000
670,000
DS - Disinfection System
                                                                3-15

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
       Section 3-PWG and Disinfection
Technologies Applicable to Small Vessels
                 Table 3-10. Total Daily and Annual O&M Cost for PWG and Disinfection Systems Combined
PWG
Capacity
(gpm)
DS Technology
DS
Capacity
(gpm)
PWG
Electrical
Cost ($/day)
DS Electrical
Cost ($/day)
Combined
Electrical
Cost ($/day)
System
Maintenance
Cost
($/day)
Consumables
Cost
($/day)
Total Daily
O&M Cost
($/day)
Total Annual
O&M Cost
($/year)
Distillation
1.7
5
Bromination
Chlorination
Electro-Katadyn
Ultraviolet
Ultraviolet
Bromination
Chlorination
Electro-Katadyn
Ultraviolet
Ultraviolet
19-35
138-917
66
6.2
31
19-35
138-917
66
6.2
31
12.48
12.48
12.48
12.48
12.48
3.07
3.07
3.07
3.07
3.07
0.08
0.08
0.08
0.07
0.23
0.08
0.08
0.08
0.07
0.23
12.56
12.56
12.56
12.55
12.71
3.15
3.15
3.15
3.14
3.3
3.29
3.29
3.29
3.29
3.29
3.9
3.9
3.9
3.9
3.9
4.81
0.98
2.27
0.52
0.52
14.14
2.88
6.68
0.52
0.52
20.66
16.83
18.12
16.36
16.52
21.19
9.93
13.73
7.56
7.72
7,500
6,100
6,600
6,000
6,000
7,700
3,600
5,000
2,800
2,800
Reverse Osmosis
1
15
30
Bromination
Chlorination
Electro-Katadyn
Ultraviolet
Ultraviolet
Bromination
Chlorination
Electro-Katadyn
Ultraviolet
Bromination
Chlorination
Electro-Katadyn
Ultraviolet
19-35
138-917
66
6.2
31
19-35
138-917
66
31
29.9-35
138-917
66
31
4.59
4.59
4.59
4.59
4.59
29.3
29.3
29.3
29.3
58.62
58.62
58.62
58.62
0.08
0.08
0.08
0.07
0.23
0.08
0.08
0.08
0.23
0.08
0.08
0.08
0.23
4.67
4.67
4.67
4.66
4.82
29.38
29.38
29.38
29.53
58.7
58.7
58.7
58.85
0.9
0.9
0.9
0.9
0.9
3.04
3.04
3.04
3.04
12.56
12.56
12.56
12.56
2.83
0.58
1.34
0.52
0.52
42.42
8.64
20.05
0.52
84.84
17.28
40.09
0.52
8.4
6.15
6.91
6.08
6.24
74.84
41.06
52.47
33.09
156.1
88.54
111.35
71.93
3,100
2,200
2,500
2,200
2,300
27,300
15,000
19,200
12,100
57,000
32,300
40,600
26,300
                                                                3-16

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                   Section 4-
Feasibility of Design- Case Studies
                                                                        SECTION 4
	FEASIBILITY OF DESIGN - CASE STUDIES

       Section 4 presents an assessment of PWGs that are commercially available for vessel use
and that could feasibly be used to generate potable water sufficient for ballasting. It assesses
whether the equipment size, weight, and system operating/maintenance space requirements of
these PWGs are suitable for use on smaller vessels, and considers vessel space and access
limitations, piping considerations, impacts to vessel stability, and impacts to vessel energy usage.
Because every vessel is ultimately unique in its machinery space design and equipment
placement, a naval architect conducted a series of specific vessel case studies to analyze these
design criteria and engineering considerations.

       EPA requested vessel design and equipment drawings from vessel owners and operators,
specifically for this study, and looked for drawings in published sources. Using these drawings,
EPA conducted PWG retrofit analyses for one research vessel (the R/VPelican), one inland river
towboat (a 150-ft, U.S. Army Corps of Engineers (USAGE) towboat), and a Fast Support Vessel
(FSV) class vessel (the Oscar Dyson). These analyses are discussed in Sections 4.1 through 4.3.
Section 4.4 provides an extrapolation analysis assessing PWG feasibility for small vessel classes
in general.

4.1    RESEARCH VESSEL

       This section provides a brief characterization of the R/V Pelican and its machinery
arrangement, as well as an analysis of PWG retrofit requirements and impacts on space, stability,
and PWG service connections. This vessel operates in the Mississippi River, Mississippi River
Delta,  and in coastal and open ocean waters.

4.1.1  Vessel Characteristics

       The R/VPelican is a research vessel operated by the Louisiana Universities Marine
Consortium (LUMCON) and is used to perform a variety of oceanographic research functions.
The vessel measures roughly 116 by 27 ft (length and beam, respectively) and has an internal
volume of 261 GRT. The vessel is equipped with two diesel engines and a twin-screw propulsion
system. Table 4-1 summarizes relevant vessel characteristics and mechanical systems.

                        Table 4-1. Summary of R/V Pelican Vessel
                         Characteristics and Mechanical Systems
Vessel Characteristic
Length (overall)
Beam
Depth
Draft (full load)
Displacement
Gross registered tonnage
Dimension or Mechanical
System Description
116.3ft
26.5 ft
12ft
9.5ft
514.6 long tons
261
                                          4-1

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                   Section 4-
Feasibility of Design- Case Studies
                        Table 4-1. Summary of R/VPelican Vessel
                         Characteristics and Mechanical Systems
Vessel Characteristic
Total persons aboard
Fresh water tank volume
Ballast tank volume
Fuel tank volume
Propellers
Propulsion system
Power
Generators
Dimension or Mechanical
System Description
21
6,231 gal
15,656 gal (59 m3)
18,499 gal
2 (twin-screw propulsion)
2 geared, 3412 Caterpillar diesel
engines
850 horsepower (425 per engine)
2, 99-kilowatt diesel generators
                   Sources: ABS, 2014a; LUMCON, no date

       Machinery Space

       The Pelican has two adjacent machinery spaces, the main machinery space and the
auxiliary machinery space (Figure 4-1). The main machinery space is located just aft of
amidships. Vessel diagrams provided by LUMCON (ERG, personal communications, September
3, 2013) indicate that this room is 26 ft long and spans the breadth of the boat. The auxiliary
machinery space is located immediately forward of the main machinery space, and has
dimensions of 10 by 13.5 ft (length and breadth, respectively).

       The machinery arrangement for both spaces (Figure 4-2) is in many ways representative
of similarly sized and powered vessels of various types (e.g.,  fishing and small passenger
vessels). The machinery space is somewhat larger than similar vessels in order to accommodate
hydraulic power units required for its oceanographic mission.

       The main machinery space contains the following major items, as shown in Figure 4-2:
              Two main engines (including their associated gear boxes).
              Two diesel generators.
              Fuel oil system (including pumps, filters, and manifold).
              Bilge system (including pumps and manifold).
              Ballast system (including ballast and fire pump and manifold).
              Air compressor (including air storage tanks).
              Electrical switchboard.
              Steering gear hydraulic system.
              Mission hydraulic systems (including hydraulic power units and hydraulic control
              panel).

       As shown in Figure 4-2, the auxiliary machinery space contains the following major
items:
                                           4-2

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Feasibility and Efficacy of Using Potable Water Generators                                     Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

       •      Sewage system.
       •      Potable water system (including PWG, pressure tank, and water heater).
       •      Refrigeration machinery.
       •      Transducer housings (for sonar and other scientific instruments).
       •      Workbench.

       Ballast System

       The Pelican holds five ballast tanks, which are located aft of the main machinery space
(Figure 4-1), and have a combined volume of 15,656 gal (ABS, 2014a). The corresponding
ballast capacity ranges from 58.3 long tons (59.3 metric tons) (fresh water) to 59.8 long tons
(60.8 metric tons) (salt water) based on  standard conversion factors.5'6 All ballast piping is run to
the ballast manifold located in the forward port corner of the main machinery space. Also located
in this area are the ballast pump and the seachest serving the ballast system.

       PWG System

       The Pelican currently has a 0.6-gpm, Sea Recoveryฎ PWG (ERG, personal
communications, September 3, 2013), which is located on the aft bulkhead of the auxiliary
machinery space (Figure 4-2). The potable water tanks are located outboard (port and starboard)
of the auxiliary  machinery space.
5 This document uses the following standard conversion factors provided by the Society of Naval Architects and
Marine Engineers: 8.34 pounds per gallon (Ib/gal) for fresh water and 8.56 Ib/gal for salt water. These densities are
taken at 60ฐF and, for salt water, at a salinity of 3.5 percent (Comstock, 1967).
6 Fresh water: (15,656 gal)(8.34 lb/gal)/(2,240 Ib/longton) = 58.3 long tons.
 Salt water: (15,656 gal)(8.56 lb/gal)/(2,240 Ib/long ton) = 59.8 long tons.
                                             4-3

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Feasibility and Efficacy of Using Potable Water Generators

as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                                                Section 4-

                                                                                          Feasibility of Design- Case Studies
                                             ,— HV3RALLIC OIL TK
                                               DIRTY OIL TK
                                               (BUM
                                             — LUBE OIL TK
                                                           POT WATER (ABV)
                                                             VOID (BLW)
                                                               o       o


                                                   MAIN  MACHINERY  SPACE
                              AFT FUEL, OIL TANK (P)
                                                                                 AUXILIARY
                                                                                MACHINERY
                                                                                  SPACE
COyPARTMEM";
                                                                                          - sฑ-+-+-+
                                                                                            ->/^.      10
                                              -+-*-+-+-+"*--
                              AFT FUEL. OILJANK (S)
                                                                                               2 PERSON
                                                                                               STATEROOM
                                                                                  X
                                                                                  POT WATER
                                                                                  (ABV & BWL)
        AFT BALLAST TANK (
                                           Figure 4-1. Hold Arrangement for the R/VPelican
                                                                      4-4

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                                                              Section 4-
                                                                                                   Feasibility of Design- Case Studies
                     HYDRAULIC OIL TR4N5FER
                     PUMP (AflV)
                                                                                                                         .
                                                                                                                         X
                                                                                                                       VOID
                                                                                                                       POTABLE WATER TK (3LW) (P)
      BILCE UW.IFOLD-1            /
                     BILGE =UMPJ
	DECK CRANE HPU
                                                                                                                   rSEA WATER/    X
                                                                                                                   PRESSURE'SET      X     ,
                                                                                                                                     X   1
                                                                               HYDRAJLIC CONTROL
                                                                               PANEL
                                                       BCP TK            ^XP TKJ
                                                       ;ABV)            /  
                                                                                                                   ,<  TK C3L  BOTTOM) '•
                                                                                                                                  DY^WCON    f'
                                                                                                                                  ELEC ENCLOSURE
                                                         HYD POWER JNIT (S)
                                 HVDRAUUC STEERING  UNIT
                                                 U-JIT
                                                                              MIDAS SYSTEM P..WPS
                                                                                       (2 QTY)
                                                                              SESCHEST
                                                                          (WIDAS SYSTE1/;
                                                                                     POTABLE WATER SU^PLV TK (ABV) (S)
                                                                                     POTABLE ,XATER j;K (BLW)  (S)
 PJEL OIL TMNSFE
                                                                                                               DYMACON
                                                                                                               FILTER HACK
                                                                                                                                                       ^-enAn\e
                                                                                                                    •;E*'iRE PUMP
                                                                                                                       ( IN VOID)
                                                                                                                                                          '.'Oil!
                                                    ,J             I
                                                         FO MANIFOLD
                               Figure 4-2. Machinery Arrangement for Existing Equipment on the R/VPelican
                                                                                   4-5

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits        Feasibility of Design - Case Studies

4.1.2   PWG Retrofit Analysis

       The PWG retrofit analysis for this vessel evaluated the following considerations:

       •      Machinery space - consideration of PWG space requirements, accessibility to the
              intended installation space, and PWG accessibility to any existing ballast and
              potable water systems.
       •      Service requirements - consideration of PWG accessibility to electrical power,
              sea water, and brine discharge connections.
       •      Stability and trim - consideration of PWG installation impacts on vessel weight
              and center of gravity.

       For the purpose of this study, the PWG must be sized to allow ballasting at a rate equal to
that of the vessel's fuel consumption rate, plus any additional capacity needed to meet existing
potable water demands. In this case, the vessel's reported fuel consumption rate is 0.4 gpm of
diesel fuel (ERG, personal communications, September 3, 2013), which is equivalent to 2.9
pounds per minute (Ib/min) based on an assumed No. 2 diesel oil density of 7.2 Ib/gal. The
equivalent PWG rate necessary to offset 2.9 Ib/min would be 0.35 gpm (2.89 lb/min/8.34 Ib/gal).
The existing PWG generates potable water at a rate of 0.6 gpm (ERG, personal  communications,
September 3, 2013). Therefore, the total PWG production capacity needed to compensate for fuel
consumption and existing PWG capacity would be 1.0 gpm (i.e.,  0.35 gpm for fuel consumption
plus 0.6 for existing PWG capacity).

       The reported fuel consumption of 0.4 gpm represents a typical consumption rate. A
conservative estimate would consider the vessel's maximum fuel consumption rate. The
maximum fuel consumption rate for the engines would be 0.4 pounds per horsepower hour
(Ib/hp-hr) (Caterpillar, 2008). Based on the installed power of 850 horsepower (hp), the engines'
fuel consumption rate would be 5.66 Ib/min [(850 hp)(0.4 lb/hp-hr)/(60 min/hr)]. Using the  same
conservative assumption for the two 99-kilowatt (kW) diesel generators, EPA estimates a
generator fuel  consumption rate of 1.77 Ib/min [(198 kW)/(0.746 hp/kW)(0.4 lb/hp-hr)/(60
min/hr)]. Therefore, the maximum fuel consumption rate for the vessel is 7.43 Ib/min (i.e., 5.66
Ib/min for the  engines plus 1.77 Ib/min for the generators).

       The equivalent PWG rate necessary to offset 7.43 Ib/min would be 0.9 gpm (7.43
lb/min/8.34 Ib/gal). As stated previously, the existing PWG generates potable water at a rate of
0.6 gpm; therefore, the total PWG production capacity needed to compensate for fuel
consumption and existing PWG capacity would be 1.5 gpm (i.e.,  0.9 gpm for fuel consumption
plus 0.6 for existing PWG capacity).

       Machinery Space

       Based on the typical and conservative fuel consumption scenarios discussed above, the
Pelican would require a PWG capable of producing 0.95 gpm to  1.5 gpm. A representative PWG
used in the marine industry is the Axeon S-3 Series Reverse Osmosis System (AXEON Water
Technologies,  2013a). This unit can be configured to provide 0.4 to 1.5 gpm, depending on  the
number of membranes provided with the unit. All configurations have the same overall
dimensions and approximately the same weight. The PWG has a  length of 48 inches (in), a depth

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

of 14 in, and a height of 27 in. The vendor recommends clearances of two ft on each side of the
unit and two to three ft in front of the unit. No clearance is required behind the unit. This analysis
uses the four-membrane S3-4125 model configuration, which provides up to 1.5 gpm. While this
analysis assumes four membranes, vessel operators may choose to select systems with redundant
capacity (i.e., additional membrane filters, beyond the minimum required). This would allow the
system to operate below 100 percent capacity and would increase pump, seal, and membrane
life.

       An issue that could impact PWG technology selection is the environment in which the
vessel operates. In river and commercial ports, the water can include chemical contaminants and
hydrocarbon products. Most operating procedures require RO systems to be used only in clean
waters; therefore, adding an oil separator and one-micron filter would need to be considered for
any proposed configuration.

       The new PWG would replace the existing unit and would be located in the same
approximate location, as shown in Figure 4-3. In addition to the PWG,  a chlorinator is included
in the study to ensure potable water quality. The chlorinator consists of a cylindrical, 30-gal tank
with a peristaltic pump mounted on top of the tank. The tank has a 21-in diameter and a height of
36 in. The vendor recommends a clearance of two ft above the tank and two to three ft in front of
the tank. No clearance is required on the sides or rear of the tank. The chlorinator would be
located outboard of the PWG above the grating, which provides access to the transducer housing
(Figure 4-3). The chlorinator would be mounted on the bulkhead to allow access beneath the
unit.

       Given the dimensions of the PWG and chlorinator systems, and the vessel's available
machinery space, there is  sufficient clearance to remove the existing PWG and install the new
PWG and chlorinator units. Access to the space would be through the main machinery ladder
way and the watertight door into the auxiliary machinery space. Piping from the chlorinator to
the ballast system would be routed through the watertight bulkhead at frame 27, athwartships
through the void located under the operating level between frames 27 and 28, and then to the
ballast manifold.

       Stability and Trim

       The combined weight of both the PWG and the chlorinator is 545 Ib. This is the sum of
the PWG weight (175 Ib (AXEON Water Technologies, 2013 a)) and the chlorinator tank weight,
including water (370 Ib). The weight of the chlorinator tank is based on the assumption that the
30-gal tank is constructed of Vi-in steel (80 Ib) and includes miscellaneous fittings (20 Ib), a 20-
Ib pump, and 30 gal of water (250 Ib; 30 gal x 8.34 Ib/gal). The weight of the existing PWG is
approximately 200 Ib, based on a review of similarly rated Sea Recovery PWGs. The lightship
weight of the Pelican is approximately 280 long tons,  or 627,200 Ib, based upon data for
similarly sized vessels. Therefore, the total weight change (sum of additions and subtractions)
from PWG retrofitting is only 0.1 percent of the total lightship weight [(545 Ib - 200 lb)/627,200
Ib)]. Such a change would have negligible impact on vessel stability and trim.
                                           4-7

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                         Section 4-
Feasibility of Design- Case Studies
                                                                                                              VOID
                                                                                                              POTABLE WATER TK (BLW) (P)
                                                                                                          SEA WATER/    \      FREEZER
                                                                                                                               (BLW)
                                                                                                                                  REFER AC UNIT
                                                                                                                                  (ASV;
                                                   LEXP TK            EXP TK
                                                    (AJ3V)            / (AW)
                                                    HYD  POWER UNIT (P)-'
                                                                                                           SYSTEM| (NEW)
                                                                                                                 25
                                                                                                             5EW*GE 4 WASTE HOLDIf
                                                                                                             •'CTi3Lฃ WATER SUPPLY TK (ABV) (S)
                                                                                                             POTABLE WATER JK (BLW)  (S)
                                FUEL OIL TRANSFE
                       TRANSFORMERS-1
                                     FUEL OIL PREFILTER^           /
                                                     FO MANIFOLD7
                                   Figure 4-3. Machinery Arrangement after Retrofitting the R/VPelican
                                                                             4-8

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

       PWG service requirements

       Because the new unit is replacing the existing unit at the same location, tying into the
existing potable water system would be straightforward since it would use the current PWG's
existing electrical, seawater, and brine connections. The new PWG draws 11.5 to 12.5 amps at
220 volts (AXEON Water Technologies, 2013a), resulting in a connected load of just less than 3
kW (12.5 amps x 220 volts = 2,750 watts). This load would account for approximately 1.5
percent of the vessel's current electrical capacity of 198 kW (LUMCON, no date).

4.1.3   Alternative Arrangement

       An alternative arrangement would retain the existing PWG and install a new unit,
independent of the existing potable water system (Figure 4-4). In this  case, the new PWG could
be installed on a rack above the bilge manifold, with the new chlorinator located adjacently. This
arrangement would have the advantage of grouping together all ballast-related components and
would avoid the  possibility of contaminating the onboard potable water system. Further, this
alternative would allow the Pelican to produce potable water at a greater overall rate, assuming
installation of the 0.4- to 1.5-gpm PWG discussed previously. Installing the new PWG in this
manner, while retaining the existing system, also would eliminate costs associated with removing
the existing PWG. The disadvantages associated with having two PWGs  onboard would be the
increased power consumption and greater frequency of PWG maintenance operations.

4.1.4   Conclusion

       Overall, the analysis demonstrates it is feasible to retrofit the R/VPelican with a PWG
capable of generating potable water at rates that would compensate for fuel consumption  and that
also would meet additional potable water demands met by the currently installed PWG. The
machinery space provides sufficient clearance for PWG installation and subsequent
operation/maintenance. The impact on vessel stability and trim from the weight differential
associated with the retrofit would be negligible since it would result in a change of only 0.1
percent. Finally,  the PWG electrical load is relatively small compared to the vessel's electrical
capacity.

       The total capital investment cost for retrofitting the Pelican, based on a linear
interpolation of Table 3-9  cost data for 1.0- and  15-gpm PWG-chlorination systems, would be
$53,000. The daily O&M cost would be approximately $7 per day, or approximately $2,600 per
year (assuming 365 days per year). The O&M costs are similarly derived from linear
interpolation of Table 3-10 cost data.
                                           4-9

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                      Section 4-
Feasibility of Design- Case Studies
                                                                  CHLDRINATDR (MEW)
                                                                     LDl'ATED ABOVE
                                       REVERSE DS^DSIS SYSTEM fMEV;      BaLLAST ^
                                    LOCATED ABOVE BALLAST MAMFDLC^
                                                            BALLAST UAMFCU3'    BALLAST P,'UPJ'
                 Figure 4-4. Machinery Arrangement after Retrofitting the R/VPelican (Alternate Arrangement)
                                                                  4-10

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                   Section 4-
Feasibility of Design- Case Studies
4.2    INLAND RIVER TOWBOAT

       This section provides a brief characterization of a 150-ft towboat owned by the USAGE,
its machinery arrangement, and an analysis of PWG retrofit requirements and impacts on space,
stability, and PWG service connections.

4.2.1   Vessel Characteristics

       The USAGE vessel operates in the Great Lakes, western rivers, and other inland
waterways and ports, and is representative of commercial towboats of its size operated on the
inland river system of the United States. It measures roughly 150 by 42 ft (length and beam,
respectively). The vessel is propelled by twin propellers, each driven by a geared diesel engine.
Table 4-2  summarizes relevant vessel characteristics and mechanical systems.

                         Table 4-2. Summary of USACE Vessel
                        Characteristics and Mechanical Systems
Vessel
Characteristic
Length (overall)
Beam
Depth
Draft (full load)
Displacement
Gross registered tonnage
Total persons aboard
Fresh water tank volume
Ballast tank volume
Fuel tank volume
Propellers
Propulsion system
Shaft Horsepower
Generators
Dimension or
Mechanical System
Description
150.0ft
42.0ft
11.7ft
Unknown
736 long tons
Unknown
14
12,500 gal
Unknown
60,000 gal
Two (twin-screw propulsion)
Geared diesel engines
2,320 each shaft, 4,640 total
Two 175-kW generators
                     Source: ERG, personal communications, December 24, 2013

       Machinery Space

       The USACE vessel has a main machinery room and two auxiliary machinery rooms
located below the main deck, as well as an auxiliary machinery room located on the main deck,
as indicated in Figure 4-5. The main machinery room is located about amidships. Vessel
diagrams provided by USACE indicate that this room has dimensions of 34 by 34 ft (length and
breadth, respectively). Auxiliary machinery rooms are located immediately aft of the main
machinery space, forward of the main machinery room, and on the main deck level. Their
respective lengths and breadths are 20 by 30 ft, 16 by 30 ft, and 40 by 30 ft.
                                          4-11

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                     Section 4-
Feasibility of Design- Case Studies
                                                                        SCALE IN FEET
                                                                             I
                                                                0       10       20
                                                                                         30
                                                                    MAIN  DECK
                              Figure 4-5. Hold and Main Deck Arrangement for the USAGE Vessel
                                                                4-12

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits        Feasibility of Design - Case Studies

       The main machinery room contains the following major items:
       •      Two diesel engines.
       •      Two reduction gears.
       •      Fuel oil system (including pumps and strainers).

       The aft auxiliary machinery room contains the following major items:

       •      Two air receivers.
       •      Two propulsion shafts.
       •      Ballast system (pumps).

       The forward auxiliary machinery room contains the following major items:

       •      Marine sanitation device.
       •      Potable water system (pumps, pressure tank, and water heater).

       The auxiliary machinery room located on the main deck has cutouts for the main engines,
       which are located in the deck below, and contains the following major items:
              Two diesel generators.
              Exhaust system for main engines.
       The existing equipment on the main machinery room and aft auxiliary machinery room is
shown in Figure 4-6.

       Ballast System

       The vessel has six ballast tanks as shown in Figure 4-5. All ballast piping is run to the aft
auxiliary machinery space. Also located in this area are two ballast/fire pumps.

       PWG System

       The vessel currently does not have a PWG. Operating on inland rivers, the vessel has
ready access to municipal water supplies, which it uses to fill its potable water tanks.
                                          4-13

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                     Section 4-
Feasibility of Design- Case Studies
                                                                                  SCALE IN  FEET
                                                               DIRTY OIL  PUMP AMONT VALVF
                                                                                 FUEL SERVICE  PUMP
                                                                                                              — FUEL TRANSFER PUMP
                                                                                     CAT 3606
                                                                                   DIESEL ENGINE
                                                             GEAR COOLING PUMP
                                                          OILY BILGE PUMP
                                                            O
                                                            LUBE OIL PUMP
                                                             GEAR COOLING PUMP
                                                                                     CAT 3606
                                                                                   DIESEL ENGINE
                                                                                                              — FUEL TRANSFER PUMP
                                                                                 FUEL SERVICE  PUMP
                                                                   LUBE OIL PUM
                                                                                             AMONT VALVE
                       Figure 4-6. Machinery Arrangement for Existing Equipment on the USAGE Vessel
                                                                 4-14

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits        Feasibility of Design - Case Studies

4.2.2   PWG Retrofit Analysis

       The PWG retrofit analysis for this vessel evaluated the following considerations:

       •      Machinery space - consideration of PWG space requirements, accessibility to the
              intended installation space, and PWG accessibility to any existing ballast and
              potable water systems.
       •      Stability and trim - consideration of PWG installation impacts on vessel weight
              and center of gravity.
       •      Service requirements - consideration of PWG accessibility to electrical power,
              seawater, and brine discharge connections.

       For the purpose of this study, the PWG must be sized to allow ballasting at a rate equal to
that of the vessel's fuel consumption rate, plus any additional capacity needed to meet existing
potable water demands. Specific fuel consumption for the main engines is 0.33 Ib/hp-hr
(Caterpillar, 2002). Therefore, main engine fuel consumption is 1,540 Ib/hr (2,320 hp/engine x 2
engines x 0.33 Ib/hp-hr). This is equal to 25.7 Ib/min (1,540 lb/hr/60 min/hr) or 3.6 gpm based on
an assumed No. 2 diesel oil density of 7.2 pounds per gallon (Ib/gal). The full load fuel
consumption for each diesel generator is 12.8 gal/hr, or 0.2 gpm (12.8 gpm/60 min/hr). Based
upon two generators and a typical load factor of 50 percent, the fuel consumed by the  generators
is 2 x 0.2 x 0.5 = 0.2 gpm. The load factor is based on the fact that the ship's service generators
are usually sized to allow the complete load to be carried with one generator off-line.

       Overall fuel consumption for the vessel is 3.8 gpm (3.6 gpm for the main engines plus 0.2
gpm for the generators). This rate is equivalent to 27.1 Ib/min based on an assumed No.  2 diesel
oil density of 7.2 Ib/gal. The equivalent PWG rate necessary to offset 27.1 Ib/min would be 3.3
gpm (27.1 lb/min/8.3 Ib/gal). There is no existing PWG generator. Therefore, the total PWG
production needs only to compensate for fuel consumption, which is 3.3 gpm.

       Machinery Space

       Based on the fuel consumption scenario discussed above, the USAGE vessel would
require a PWG capable of producing 3.3 gpm. A representative PWG used in the marine industry
is the Axeon R2 Series Reverse  Osmosis System (AXEON Water Technologies, 2013b). This
unit can be configured to provide from 1 to 6.3 gpm, depending on the number of membranes
provided with the unit. All configurations have the same overall dimensions and approximately
the same weight. The PWG has  a length of 32 in, a depth of 26 in, and a height of 61 in. This
analysis considered the four-membrane, R2-4140 model configuration, which provides up to 4.2
gpm. While this analysis assumes four membranes, vessel operators may choose to select
systems with redundant capacity (i.e., additional membrane filters, beyond the minimum
required). This would allow the  system to operate below  100 percent capacity and would
increase pump, seal, and membrane life.
                                          4-15

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                     Section 4-
Feasibility of Design- Case Studies
                                                                                   SCALE IN FEET
                                                                                          P

                                                               DIRTY  OIL PUMP AMONT VALVE/*
                                                                                 FUEL SERVICE PUMP
                                                             GEAR COOLING  PUMP
                                                                                                               — FUEL TRANSFER PUMP
                                                                                                                 PUMP
                                                         VCLEAN BILGE\PUMP
                                                         	  	    1\ i  i i
                                                           OILY BILGE PUMP
                                                            O
                                                            LUBE  OIL PUMP
                                                             GEAR COOLING  PUMP
                                                                                                         PRELUB
                                                                                 FUEL SERVICE PUMP-
                                                                    LUBE OIL PUMP-,
                                                                                  \
                                                                                              AMONT VALVE
                            Figure 4-7. Machinery Arrangement after Retrofitting the USAGE Vessel
                                                                 4-16

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits        Feasibility of Design - Case Studies

       Figure 4-7 shows where the new PWG would be located in the aft auxiliary machinery
space near the existing ballast pumps. In addition to the PWG, a chlorinator is included in the
study to ensure potable water quality. The chlorinator consists of a cylindrical, 30-gal tank with a
peristaltic pump mounted on top of the tank. The tank has a 21-in diameter and a height of 36 in.
The vendor recommends a clearance of two ft above the tank and  two to three ft in front of the
tank. No clearance is  required on the sides or rear of the tank. The new chlorinator would be
located between the new PWG and the ballast pumps.

       Given the dimensions of the PWG and chlorinator systems, and the USAGE vessel's
arrangement, it appears as if there is sufficient clearance to install the new PWG and chlorinator
unit. Access to the space would be through the ladder way providing access to the aft auxiliary
machinery space.

       Stability and Trim

       The combined weight of both the PWG and the chlorinator is 1,020 Ib. This is the sum of
the PWG weight (650 Ib (AXEON Water Technologies, 2013b)) and the chlorinator tank weight,
including water (370  Ib). The weight of the chlorinator tank is based on the assumption that the
30-gal tank is constructed of Vi-in steel (80 Ib) and includes miscellaneous fittings (20 Ib), a 20-
Ib pump, and 30 gal of water (250 Ib; 30 gal x 8.3 Ib/gal).  The lightship weight of the USAGE
vessel is approximately 466 long tons, or 1,043,800 Ib. The lightship weight was estimated by
subtracting deadweight items (193 long tons of fuel, 47 long tons  of fresh water, and 30 long
tons for miscellaneous deadweight items) from the displacement of 736 long tons. Miscellaneous
deadweight items  include crew and effects, stores, spares, towing  gear, and sewage. Therefore,
the total weight addition from PWG retrofitting is only 0.1 percent of the total lightship weight
[(1,020 lb)/l,043,800 Ib)]. Such a change would have negligible impact on vessel stability and
trim.

       PWG Service Requirements

       The new unit is located near the existing ballast pumps. Therefore, tying into the ballast
system would be straightforward. Electrical, seawater,  and brine connections would have to be
provided. Seawater would be supplied from the vessel's main seawater suction, which is located
in the same compartment as the new PWG. Brine would be piped to an overboard discharge. The
new PWG draws 13.6 amps at 220 volts (normal operating amps,  AXEON Water Technologies,
2013b), resulting in a connected load of just less under 3kW (13.6 amps x 220 volts = 2,992
watts). This load would account for approximately  1 percent of the vessel's current electrical
capacity of 350 kW (ERG, personal communications, December 24, 2013).

       Existing Potable Water System

       The USAGE vessel does not have an existing PWG. Potable water is supplied from a
tank, which is filled from municipal water. The new PWG proposed in this analysis would be
used exclusively for ballast and would not be connected to the existing potable water system.
                                          4-17

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                    Section 4-
Feasibility of Design- Case Studies
4.2.3   Conclusion

       Overall, this analysis demonstrates that it is feasible to retrofit the USAGE vessel with a
PWG capable of generating potable water at rates that would compensate for fuel consumption.
The machinery space provides sufficient clearance for PWG installation and subsequent
operation/maintenance. The impact on vessel stability and trim from the weight differential
associated with the retrofit would be negligible since it would result in a change of well under 1
percent. Finally, the PWG electrical load is relatively small compared to the vessel's electrical
capacity.

       The total capital investment cost for retrofitting the USAGE vessel, based on a linear
interpolation of Table 3-9 cost data for 1.0- and 15-gpm PWG-chlorination systems, would be
$66,400. The daily O&M cost would be approximately $12 per day, or approximately $4,400 per
year (assuming 365 days per year). The O&M costs are similarly derived from linear
interpolation of Table 3-10 cost data.

4.3    RESEARCH CLASS VESSEL

       This section provides a brief characterization of the Oscar Dyson and its machinery
arrangement, as well as an analysis of PWG retrofit requirements and impacts on space, stability,
and PWG service connections.

4.3.1   Vessel Characteristics

       The Oscar Dyson is a fisheries survey vessel owned and operated by the National
Oceanic and Atmospheric Administration (NOAA). The primary mission of the vessel  is to
perform fisheries  surveys. This vessel's homeport is in Kodiak, AK, and is a support platform to
study and monitor Alaskan pollock and other fisheries, as well as oceanography in the Bering
Sea and the Gulf of Alaska. The Oscar Dyson measures roughly 208 by 49 ft (length and beam,
respectively) and  has an internal volume  of 2,139 GRT. The vessel is propelled by a single
propeller driven by two electric motors and four diesel generators that power the electric motors.
Table 4-3 summarizes relevant vessel characteristics and mechanical systems.

                        Table 4-3. Summary of Oscar Dyson Vessel
                         Characteristics and Mechanical Systems
Vessel
Characteristic
Length (overall)
Beam
Depth
Draft (full load)
Displacement
Gross registered tonnage
Total persons aboard
Fresh water tank volume
Ballast tank volume
Dimension
Mechanical System
or
Description
206.7 ft
49.2 ft
28.4 ft
19.7 ft
2,400 long tons
2,139
39
9,300 gal
38,900 gal (147 m3)
                                          4-18

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                   Section 4-
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                       Table 4-3. Summary of Oscar Dyson Vessel
                         Characteristics and Mechanical Systems
Vessel
Characteristic
Fuel tank volume
Propellers
Propulsion system
Shaft Power
Generators
Dimension or
Mechanical System Description
113, 100 gal
One (single-screw propulsion)
Single-screw diesel electric
Two 1,125-kW electric motors on
single shaft (2,250 kW total)
Two 1,360-kW generators and two
960-kW generators. Total electrical
generating capability of 4,540 kW.
                   Sources: ABS, 2014b; NOAA, no date c

       Machinery Space

       As indicated in Figure 4-8, the Oscar Dyson has a main machinery room, an auxiliary
machinery room, and a domestic equipment space.  The main machinery room is located just aft
of amidships. Vessel diagrams provided by NOAA indicate that this room is 45 ft long and spans
the breadth of the boat. The auxiliary machinery room is located immediately forward of the
main machinery space on a single level and has dimensions of 20 by 41 ft (length and breadth,
respectively). The domestic equipment space is located immediately forward of the auxiliary
machinery room and has dimensions of 20 ft by 28 ft (length and breadth, respectively).

       The main machinery room has two levels. The  lower level contains the following major
items, as shown in Figure 4-9:

       •      Four diesel generators.
       •      Two electric propulsion motors.
       •      Two propulsion transformers.
       •      Two ship's service transformers.
       •      Main seawater system (including pumps and strainers).
       •      Bilge manifold.

       The upper level contains the following major items as shown in Figure 4-10:

       •      Air conditioner chiller plant and pumps.
       •      Diesel generator expansion tanks and heat exchangers.
       •      Distilling units.
       •      Diesel generator exhaust system (not shown on drawing).

       Each level also contains various electrical panels.

       The auxiliary machinery room is located on a single level and contains the following
major items:
                                          4-19

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Feasibility and Efficacy of Using Potable Water Generators                                    Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

       •      Fuel oil system (including purifier, pumps, and manifold).
       •      Engineer's workshop (with various pieces of workshop equipment).
       •      Ballast manifold.
       •      Storage area.

       This space also contains various electrical panels.

       The domestic  equipment space contains the following major items:

       •      Potable water system components (ultraviolet purifiers, pressure tank, and hot
              water system).
       •      Marine sanitation device.
       •      Bow thruster drive transformers and  controller.

The existing equipment in the auxiliary machinery room and domestic equipment space is shown
in Figure 4-11.

       Diesel electric propulsion systems for vessels of this size are common, with applications
including offshore service vessels and small passenger vessels. However, overall machinery
space on the Oscar Dyson is larger than that found on many similar sized vessels due to the low-
noise features found on the vessel. These features include the large propulsion motors located in
the main machinery space and the resilient mounting of much  of the machinery. A more common
arrangement would locate the propulsion motors outside the main machinery  space using Z-drive
units. The diesel generators are resiliently mounted  on a large  steel frame, which in turn is
resiliency mounted to the ship. This intermediate frame results in a larger space requirement than
a more common installation.

       Since the additional space requirements are compensated for with a larger overall
machinery space (which includes the auxiliary machinery room), EPA believes that the
challenges of the PWG installation aboard the Oscar Dyson are typical of other vessels of its
size.

       Ballast System

       The Oscar Dyson has four ballast tanks, which have a combined volume of 38,900 gal
(147 cubic meters) (ABS, 2014b). The corresponding ballast capacity ranges  from 144.7 long
tons (147.1 metric tons) (fresh water) to 148.5 long  tons (150.9 metric tons) (salt water) based  on
standard conversion factors.7'8 All ballast piping is run to the ballast manifold located in the
7 This document uses the following standard conversion factors provided by the Society of Naval Architects and
Marine Engineers: 8.34 Ib/gal for fresh water and 8.56 Ib/gal for salt water. These densities are taken at 60ฐF and,
for salt water, at a salinity of 3.5% (Comstock, 1967).
8 Freshwater: (15,656 gal)(8.34 lb/gal)/(2,240 Ib/longton) = 58.3 long tons.
 Salt water: (15,656 gal)(8.56 lb/gal)/(2,240 Ib/long ton) = 59.8 long tons.
                                           4-20

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Feasibility and Efficacy of Using Potable Water Generators                                     Section 4—
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forward port corner of the auxiliary machinery room. Also located in this area is one of the
vessel's bilge/ballast/fire pumps.

       PWG System

       The Oscar Dyson currently has two Alfa-Laval JWP-16-C-40 distillation units to
generate fresh water. Each unit is rated at 1.3 gpm (NOAA, no date c). Heat for the units is
supplied by the diesel engine jacket water cooling system supplemented with electric heaters.
The units  are located port and starboard on the upper level of the main machinery room. Fresh
water is stored in two tanks with a total capacity of 9,300 gal and is disinfected by an ultraviolet
purifier located in the domestic equipment space.
                                            4-21

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Feasibility and Efficacy of Using Potable Water Generators
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                   Section 4-
Feasibility of Design- Case Studies
                                                                                                   SCALE IN FEET
                                                                     AUXILIARY
                                                              -,  MACHINERY ROOM
                                                                         (P/S)
     DOMESTIC
     EQUIPMENT
       SPACE
DIES EL GENERATOR      ฉ
                           MAIN MACHINERY ROOM
                                (LOWEFUEVEL)
                               Figure 4-8. Machinery Space Locations for the Oscar Dyson
                                                        4-22

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Feasibility and Efficacy of Using Potable Water Generators
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                     Section 4-
Feasibility of Design- Case Studies
                                                                              SCALE IN FEET
                                         THRUST BEARING

—


1\







_
COOLING PUMP
1
ELECTRIC
PROPULSION
SYSTEM

II 11

a












o

ii i — i ii


ZTf
[^ 	


i

r OILY WA
                                                                                                        LGE MANIFOLD
                                                                                                     WASTE OIL
                                                                                                     MANIFOLD
                  Figure 4-9. Main Machinery Room (Lower Level) for Existing Equipment on the Oscar Dyson
                                                                 4-23

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Feasibility and Efficacy of Using Potable Water Generators
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                      Section 4-
Feasibility of Design- Case Studies
                                                                   SCALE IN FEET
                                                OPEN "TO BELOW
A/CCt-
iLLER PLANT
AC Ch
1LLER PLANT
                                                OPEN TO BELOW
                                                  EXHAUST
                                                SYSTEM ABOVE
                                                                           DIESEL GEN. SET
                                                                           EXPANSION TANK
                                                                - DIESEL GEN. SET
                                                                 HEATEACHANGER
                                               LIGHTING TRANSFORMER
                                                                                             - SCIENTIFIC TRANSFORMER
                  Figure 4-10. Main Machinery Room (Upper Level) for Existing Equipment on the Oscar Dyson
                                                                   4-24

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Feasibility and Efficacy of Using Potable Water Generators
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                     Section 4-
Feasibility of Design- Case Studies
                                                                            SCALE IN FEET
                                             BALLAST/SI LGBFIRE
                                                BALLAST MANIFOLD


TRANS/INPUT
K ^~~~--

i
o
pj

o


INVERTER
                                                                  BOW THRUSTER DRIVE
                                                                    TRANSFORMERS  WASTE WATER
                                                                            TRANSFER PUMP
MARINE
SANITATION
DEVICE
5
            Figure 4-11. Auxiliary Machinery Room and Domestic Equipment Space for Existing Equipment on the
                                                           Oscar Dyson
                                                                4-25

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits        Feasibility of Design - Case Studies

4.3.2   PWG Retrofit Analysis

       The retrofit analysis for this vessel evaluated the following considerations:

       •      Machinery space - consideration of PWG space requirements, accessibility to the
              intended installation space, and PWG accessibility to any existing ballast and
              potable water systems.
       •      Stability and trim - consideration of PWG installation impacts on vessel weight
              and center of gravity.
       •      Service requirements - consideration of PWG accessibility to electrical power,
              seawater, and brine discharge connections.

       To simplify installation and minimize costs, it is recommended that the existing distillers
remain in place and in operation to  service the vessel's domestic potable water requirements.
Therefore, for the purpose of this study, the PWG must be sized to allow ballasting at a rate
equal to that of the vessel's fuel consumption rate only. In this case, the reported fuel
consumption rate for the Oscar Dyson is 1.7 gpm of diesel fuel (ERG, personal communications,
August 1, 2013), which is equivalent to 12.6 Ib/min, based on an assumed No. 2 diesel oil
density of 7.2 Ib/gal. The equivalent PWG rate necessary to offset 12.6 Ib/min would be 1.5 gpm
(12.6 lb/min/8.3 Ib/gal).

       The reported fuel consumption of 1.7 gpm represents a typical consumption rate. A more
conservative estimate would consider the vessel's maximum fuel consumption rate. The
maximum fuel consumption rate for the engines would be 66.9 gal/hr for each Cat 3508 unit and
90.9 gal/hr for each Cat 3512 unit (Caterpillar, no date). Based on an estimated overall generator
load factor of 75 percent, the fuel consumption would be (66.9 gal/hr x 2 + 90.9 gal/hr x 2) x
0.75,  or 236.7 gal/hr. The load factor represents the vessel's worst-case electrical load, from
trawling in 13-ft seas. This is equal to 28.5 Ib/min (236.7 gal/hr x 7.2 lb/gal/60 min/hr). The
equivalent PWG rate necessary to offset 28.5 Ib/min would be 3.4 gpm (28.5 lb/min/8.3 Ib/gal).

       Machinery Space

       Based on the typical and conservative fuel consumption scenarios discussed above, the
Oscar Dyson would require a PWG capable of producing 1.7 gpm to 3.4 gpm.

       Two different representative PWG units were considered for this analysis:

       •      The Axeon R2 Series Reverse Osmosis System (AXEON Water Technologies,
              2013b). This unit can be configured to provide from 1 to 6.3 gpm, depending on
              the number of membranes provided with the unit. All configurations have the
              same overall dimensions and approximately the same weight. This analysis
              considered the four-membrane, R2-4140  model configuration, which provides up
              to 4.2 gpm. The PWG has a length of 32 in, a depth of 26 in, and a height of 61 in.
       •      The Sea Recovery Coral Sea System (Sea Recovery, 2013). This unit can be
              configured to provide 1.9 to 4.7 gpm, depending on the membrane configuration.
              This system can accommodate up to six membrane filters. All configurations have
                                          4-26

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits        Feasibility of Design - Case Studies

              approximately the same dimensions and weight. This analysis considered the
              5200/4V model, which provides 3.6 gpm. This PWG has a length of 30 in, a depth
              of 35 in, and a height of 53 in.

       This feasibility analysis uses the Coral Sea system and assumes the system would have
six membranes. The system has been designed to allow the system to operate below 100 percent
capacity and would increase pump, seal, and membrane life.

       It should be noted that the Coral Sea System is also available in a modular configuration.
Though not selected in this analysis, the modular configuration allows the control unit, pumps,
filters, and membrane vessels to be separately located, and would allow the system to be
installed in locations without the space for an integrated unit.

       There are three potential locations for the PWG installation:

       •      On the upper level of the main machinery room where the existing distiller units
              are located.
       •      In the auxiliary machinery room adjacent to the ballast manifold.
       •      In the domestic equipment space adjacent to components of the existing potable
              water system.

       Locating the new PWG in place of the existing distiller units is not practical due to the
way the existing distiller is located between the diesel generators' heat exchangers and expansion
tanks. There is not sufficient space for the new PWG elsewhere in the main machinery room.

       Locating the new PWG in the domestic equipment space is not practical due to lack of
sufficient space in the area for additional equipment. Accordingly, the new PWG would be
located on the port side of the auxiliary machinery room adjacent to the ballast manifold. This
space also contains an electrical workbench, various electrical panels, and has an area designated
as storage.  It should be noted that the new PWG would take up some of the existing storage
space, which may be limited on a vessel of this type and size.

       In addition to the PWG, a chlorinator is included in the study to ensure potable water
quality. The chlorinator consists of a cylindrical, 30-gal tank with a peristaltic pump mounted on
top of the tank. The tank has a 21-in diameter and a height of 36 in. The vendor recommends a
clearance of two ft above the tank and two to three ft in front of the tank. No clearance is
required on the sides or rear of the tank. The new chlorinator would be located outboard of the
ballast manifold near the existing ballast pump. Figure 4-12 shows the recommended locations
for a new PWG and chlorinator.

       Given the dimensions of the PWG and chlorinator systems, and the vessel's arrangement,
it appears as if there is sufficient clearance to install the new PWG and chlorinator unit.  Access
to the space would be  through the ladder way going into the auxiliary machinery room. Seawater
piping from the chlorinator to the ballast system would be straightforward as the chlorinator is
located within a few feet of the ballast manifold.
                                          4-27

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Feasibility and Efficacy of Using Potable Water Generators
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                      Section 4-
Feasibility of Design- Case Studies
                                                                                SCALE IN FEET
                                                                     BOW THRUSTERDRIVE
                                                                       TRANSFORMERS  WASTE WATER -i
                                                                               TRANSFER PUMP  \
                            Figure 4-12. Auxiliary Machinery Room after Retrofitting the Oscar Dyson
                                                                   4-28

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits        Feasibility of Design - Case Studies

       Stability and Trim

       The combined weight of both the PWG and the chlorinator is 1,120 Ib. This is the sum of
the PWG weight 750 Ib (Sea Recovery, 2013) and the chlorinator tank weight, including water
(370 Ib). The weight of the chlorinator tank is based on the assumption that the 30-gal tank is
constructed of Vi-in steel (80 Ib) and includes miscellaneous fittings (20 Ib), a 20-lb pump, and
30 gal of water (250 Ib; 30 gal x 8.3  Ib/gal). The lightship weight of the Oscar Dyson is
approximately 1,750 long tons, or 3,920,000 Ib, based upon data for similarly sized vessels.
Therefore, the total weight addition from PWG retrofitting is only 0.03 percent of the total
lightship weight [(1,120 lb)/(3,920,000 Ib)]. Such a change would have negligible impact on
vessel stability and trim.

       PWG Service Requirements

       The new unit would be located near the existing ballast manifold; therefore, tying into the
ballast system would be straightforward. Electrical, seawater, and brine connections would have
to be added. Seawater would be supplied from the vessel's main seawater system located in the
main machinery room (lower level), with brine being discharged overboard by way of the
auxiliary machinery room. The new PWG draws 36.6 amps at 220 volts (normal operating amps,
Sea Recovery, 2013), resulting in a connected load of just over 5 kW (36.6 amps x 220 volts =
8,052 watts). This load would account for approximately 0.2 percent of the vessel's current
electrical capacity of 4,540 kW (NOAA, no date c).

4.3.3   Conclusion

       Overall, this analysis demonstrates it is feasible to retrofit the Oscar Dyson with a PWG
capable of generating potable water  at rates that would compensate for fuel consumption and that
also would meet additional potable water demands met by the currently installed PWG. The
machinery space provides sufficient clearance for PWG installation and subsequent
operation/maintenance. The impact on vessel stability and trim from the weight differential
associated with the retrofit would be negligible since it would result in a change of well under 1
percent. Finally, the PWG electrical load is relatively small compared to the vessel's electrical
capacity.

       The total capital investment cost for retrofitting the Oscar Dyson, based on a linear
interpolation of Table 3-9 cost data for 1.0- and 15-gpm PWG-chlorination systems, would be
$67,200. The daily O&M cost would be approximately $12 per day, or approximately $4,400 per
year (assuming 365 days per year). The O&M costs are similarly derived from linear
interpolation of Table 3-10 cost data.

4.4    PARAMETRIC ANALYSIS TO EXTRAPOLATE THE CASE-STUDY FINDINGS

       Parametric  design data are often used in the marine industry by naval architects and
marine engineers in early stages of ship design. A  parametric analysis uses vessel design
characteristics, such as vessel length, beam, hull coefficients, required power, and weights, and
presents these characteristics as a function of other vessel characteristics, either in a graphical
form or by mathematical formulas. In this way, data from previously designed and built vessels
or previously conducted design studies can be used for comparison to other vessel designs.


                                           4^29

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

Parametric relationships defined by mathematical formulas are particularly useful for computer-
assisted design studies.

       EPA, in consultation with a naval architect,  conducted a parametric analysis to determine
whether the conclusions of the three case studies described in Sections 4.1 through  4.3 can be
applied to other vessels. The analysis approach determines if the size of the machinery space of
the vessels used for the case studies are representative of other vessels.

4.4.1   Meaningful Design Parameters

       The most significant factor in determining if it is practical to install a particular piece of
equipment within a machinery space is the required deck area that the piece of equipment
requires. (The required deck area is the footprint of the equipment plus any clearances to meet
operational or maintenance requirements.) A secondary factor is the volume requirement of the
equipment.

       As discussed in Sections 4.1.4, 4.2.3, and 4.3.3, EPA's PWG retrofit analyses indicated
that weight and power requirements were not driving factors in determining whether a PWG
could be installed in an existing vessel. Therefore, EPA did not address those characteristics as
part of the parametric study.

4.4.2   Designs Used for EPA's Parametric Analysis

       The data used for the parametric analysis were derived from vessel drawings. The
drawings either were provided by vessel owners, specifically for this study, or were found in
published sources. For a limited number of designs, EPA used proprietary drawings and masked
the specific vessel names in these instances to allow for presentation of the data. In total, the
parametric analysis used data from 23 vessel designs to determine suitable parametric
relationships. This included data from research vessels, towboats, tugboats, passenger vessels,
and offshore supply vessels. The sizes of the vessels included in  this study ranged in length from
50 to 350 ft.

       Data for certain vessel types, such as passenger and fishing vessels, were not readily
available for this analysis. However, EPA believes that the parametric relationships developed
based on other vessel types may be applicable to them as discussed in the following sections.

       The data collected for each design were length (overall), length (between perpendiculars),
beam, depth, draft, displacement, number of propellers, number of engines, propulsion
horsepower, number of generators, and total  installed generating capacity. Machinery space deck
area and machinery space volume were determined from the available drawings.

       Guidelines used to determine machinery space areas and volumes included:

       •      Excluded separate control rooms in the machinery space areas.
       •      Included auxiliary machinery spaces only if they were adjacent to the main
              machinery  space.
                                           4-30

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Feasibility and Efficacy of Using Potable Water Generators
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                    Section 4-
Feasibility of Design- Case Studies
       •     Based machinery space volumes on projected deck areas from the deck plates to
             the molded line of the deck above.

       Table 4-4 lists the vessels used for the parametric analysis along with their principal
characteristics and machinery space deck areas and volumes. The three vessels chosen for the
case studies (the R/VPelican, the USAGE towboat, and the Oscar Dyson) appear in bold. The
references section includes notes regarding the source of the vessel information used in the
parametric study.
                  Table 4-4. Vessel Data Used in the Parametric Analysis
Vessel
Type/Name
Length,
Overall
(ft)
Beam
(ft)
Depth
(ft)
Displace-
ment
(long
tons)
Propulsion
Horsepower
(hp)
Cubic
Number1
(CN)
Machinery
Space Deck
Area
(ft2)
Machinery
Space
Volume
(ft3)
Research
Pelican
Tagos
Oscar Dyson
Savannah
Sharp
Sikuliaq
116.3
224.0
206.7
92.0
150.0
242.0
26.5
43.0
49.2
27.0
32.0
52.0
12.0
20.0
28.4
12.8
14.0
27.5
515
2,262
2,400
329
N/A
3,394
850
1,600
2,976
880
1,283
6,000
370
1,926
2,888
317
672
3,461
772
4,485
3,179
520
1,384
3,794
6,946
32,858
39,457
4,112
12,692
41,726
Towboat
Grand Tower
George C
Grugett
Creve Coeur
USAGE Vessel
Prairie du
Rocher
Shorty Baird
Replacement
Ted Cook
65.0
114.0
77.4
150.0
51.0
95.0
83.0
24.0
35.0
32.0
42.0
19.0
39.0
34.0
8.5
10.3
10.0
11.7
8.5
10.0
10.0
164
510

736
88
N/A
N/A
1,100
3,000
1,280
4,640
880
2,600
2,000
133
409
248
735
82
371
282
1,238
1,390
838
2,316
384
1,492
903
10,146
13,409
8,032
27,092
3,489
13,100
9,526
Passenger
Unnamed
Passenger
Vessel
350.0
54.0
20.0
3,200
5,000
3,847
4,823
49,256
Tugboat
Harbor Tug
Sause Brothers
China Tug
Great Lakes
Tug
78.0
135.4
100.4
135.3
34.0
46.0
35.4
49.0
12.3
21.3
14.8
26.0
N/A
N/A
566
1,550
5,080
8,000
3,500
9,280
327
1,324
524
1,724
820
1,280
1,020
2,677
8,405
17,920
9,282
30,646
                                           4-31

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Feasibility and Efficacy of Using Potable Water Generators
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                    Section 4-
Feasibility of Design- Case Studies
                  Table 4-4. Vessel Data Used in the Parametric Analysis
Vessel
Type/Name
Length,
Overall
(ft)
Beam
(ft)
Depth
(ft)
Displace-
ment
(long
tons)
Propulsion
Horsepower
(hp)
Cubic
Number1
(CN)
Machinery
Space Deck
Area
(ft2)
Machinery
Space
Volume
(ft3)
Offshore Support Vessel (OSV)
Supply Boat
Dive Support
Vessel
Trinity OSRV
Bender OSRV
116.3
250.0
208.5
210.0
54.0
50.0
44.0
45.0
19.0
22.0
17.0
17.0
N/A
N/A
2,514
2,570
6,200
5,000
2,560
3,000
1,193
2,750
1,560
1,607
1,274
1,760
1,152
1,300
19,110
28,160
15,600
15,600
Fishing Vessel
Bay Islander
78.0
22.0
12.0
N/A
650
206
228
2,282
N/A - Not Available
1 The cubic number is the product of the length, beam, and depth divided by 100.

4.4.3  Parametric Relationships

       The primary variable of interest is machinery space deck area, with machinery space
volume of secondary interest. Therefore, for this analysis they are the meaningful dependent
variables, which are the function of some independent variable. The goal is to select an
independent variable, a function of which will accurately predict the value of the dependent
variables. The independent variable selected should not only result in a good fit of the available
data, but should also make sense from an engineering standpoint.

       Potential independent variables evaluated for this study included propulsion horsepower,
length (overall), displacement, and cubic number (CN) (CN is defined as the product of the
length, beam, and depth (in ft) divided by 100).  For each potential independent variable,
machinery space deck area and machinery space volume were evaluated using various curve fit
types (i.e., linear, polynomial, exponential, etc.). It was concluded that a linear fit was most
appropriate type to use for the data set evaluated. In each case, the coefficient of determination,
R2, was calculated.

       Machinery-related parametric design data, particularly for machinery weight, is often
presented as a function of installed horsepower. Therefore, that was the initial variable chosen
for this  study. However, as seen from the Figure 4-13, the relationship between propulsion
horsepower and machinery space deck area is very poor, with a R2 of around 0.1.
                                           4-32

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Feasibility and Efficacy of Using Potable Water Generators
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                                                                    Section 4-
                                                Feasibility of Design- Case Studies
                5,000
             *  4,000
             sS
             II
             1
                3,000
                2,000
                1,000
                                                        R2 = 0.1381
fit.
                               2,000      4,000      6,000       8,000      10,000
                                      Propulsion Horsepower, hp

            Figure 4-13. Machinery Space Deck Area vs. Propulsion Horsepower

       Using the dimensional variables indicated in the following figures achieves a much better
*: 4,000
sS
B
I 3,000
P
o
sS
0)
>! 1,000
n -




+

*s^+




^
^
^


*

• ^x^
^^


I

*
^
R2 = 0.5493





                      0
                  1,000         2,000         3,000

                      Displacement, long tons

Figure 4-14. Machinery Space Deck Area vs. Displacement
4,000
                                             4-33

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Feasibility and Efficacy of Using Potable Water Generators
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                                                                       Section 4-
                                                  Feasibility of Design- Case Studies
                 5,000
            ซ   4,000
            et
            u
            sS

                 3,000
                 2,000
                 1,000
                    0
                                                  x7
                                                   R2 = 0.6413
                                    100
                                  200
300
400
                                            Length Overall, ft
                Figure 4-15. Machinery Space Deck Area vs. Length Overall

             II


             U
             sS
                 5,000
                 4,000
                 3,000
                 2,000
                 1,000
                    0
                                                                  R2 = 0.6649
                      0
                   5,000         10,000        15,000

                           Length \ Beam, ft2

Figure 4-16. Machinery Space Deck Area vs. Length x Beam
            20,000
                                              4-34

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                      Section 4-
                                                  Feasibility of Design- Case Studies
            sS
            II
            sS
            8.
II
1
                5,000
                4,000
                3,000
                2,000
                1,000
                   0
                                     ปป
                                                              R2 = 0.6805
                     0
                                                 ,000
4,000
                                 1,000         2,000
                                         Cubic Number

               Figure 4-17. Machinery Space Deck Area vs. Cubic Number

       With R2 values of 0.66 and 0.68, respectively, length x beam and cubic number represent
the best fits of the vessel data. This indicates that machinery space deck area is a function of
overall vessel size. Although not presented here, the results for machinery space volume are
similar to those for machinery space deck area. For machinery space volume, R2 ranged from
0.25 based on horsepower to 0.85 based on cubic number.

       The machinery space deck area vs. length x beam was chosen as the most appropriate
parameter for the parametric analysis due to the linear fit and the match of units between the
dependent and independent variables (i.e., machinery space  deck area and length x beam both
have units of ft2). Figure 4-18 presents the same data set as Figure 4-16 but also identifies the
various vessel types contained in the data set. It should be noted that the four OSV vessels used
in the study are all below the linear fit trend line. Removing the OSV vessels from the data set
would increase the value of R2 to 0.86. This is discussed further in Section 4.4.5.
                                           4-35

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                          Section 4-
                                      Feasibility of Design- Case Studies
J.,\J\J\J
% A nnn
€\
sS
B
*?j ^ nnn
Q
o
sS
r^" o nnn
0)
2
i i nnn
n -



vf*
-.*
*

• .x^
ซ ^


>x>^

X

/-"




^Research
•Pushboat
A Passenger
•Tug
XOSV
•Fishing
+ Trend Line
            0            5,000          10,000          15,000          20,000

                                   Length \ Beam, ft2

   Figure 4-18. Machinery Space Deck Area \s. Cubic Number (Vessel Types Identified)

4.4.4  Case Studies vs. Parametric Data

       The vessels used for the case studies were chosen to obtain a variety in vessel size and
type, as permitted by the availability of suitable drawings. Figure 4-19 identifies the case study
vessels compared to the other linear trend line and other vessels in the data set.
      4,000

  II

  U
  sS
      1,000



mj&
<^t
ป
c
X
X ^s*^
X S'^
X ^/^

X
X
X
X S^
'
X

AX
^



^J Case Study Vessels



* Research
• Pushboat
A Passenger
• Tug
X OSV
• Fishing
+ Trend Line
— i- - Trend Line
(No OSV)
5,000           10,000

           Length \ Beam, ft2
                                                        15,000
20,000
     Figure 4-19. Machinery Space Deck Area vs. Length x Beam (Case Study Vessels
                                         Identified)
                                            4-36

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

       The two larger case study vessels (the USAGE towboat and Oscar Dyson) are above the
trend line while the smallest of the case study vessels (the Pelican) is below the trend line.
Removing the four OSV vessels from the data set results in a different trend line with a better fit
as previously discussed. All three case study vessels lie very close to this trend line. This
indicates that, with the exception of OSV type vessels, the results of the case studies are likely
representative of other vessels in this size range regarding machinery space size and indicate it is
generally possible to retrofit vessels with  suitable PWG units.

4.4.5   Application of Case Study Results to Retrofitting Various Vessel Types

       Based on the results of the case studies and parametric data analysis, the different vessel
types were analyzed to evaluate which ones could feasibly be retrofitted for PWG installation.
Due to the varying designs of vessel types, it is not possible to make definitive vessel-specific
conclusions; however, it is possible to draw general conclusions based upon the following:

       •      Machinery space deck area (the case studies indicate that deck areas equal to or
              above the data set trend line can accommodate PWG installation).
       •      Machinery space deck area demands for particular vessel types.
       •      Power density (as discussed below).

       Power density is defined as propulsion horsepower divided by the cubic number, and
represents the propulsion power compared to the  overall size of the vessel. Since the parametric
data suggest that length x beam is the most significant independent variable for machinery space
deck area, the power density becomes a secondary factor in understanding machinery space size
and, more importantly, the space that may be available for installation of additional equipment,
such as PWG units. A high power density means  that not only will the main engines be larger,
but ancillary equipment, which supports the main engines such as fuel, cooling, and exhaust
systems, will also be larger.

       Below is a discussion of the application of the parametric analysis by vessel type.

Oceanographic Research Vessels

       An oceanographic research vessel is defined as one used for instruction or research in the
fields of limnology or oceanography. This includes marine geophysical or geological surveys,
atmospheric research, and biological research. They are often fitted with a number of winches
and lifting devices (such as cranes or A-frames) to enable scientific gear to be placed over the
side. Vessels intended to conduct fisheries research are outfitted with trawling or other fishing
gear. The number of persons aboard includes scientific personnel, often significantly increasing
the number of persons over the vessel's operating crew.

       Research vessels generally do not carry any variable loads except for fuel, fresh water,
and possibly wastewater. Ballast water, if required, is used to compensate for fuel burn.

       Compared to other vessel types, the machinery spaces of research vessels may differ due
to the following:
                                           4-37

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
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       •      Additional hydraulic power take-offs or power packs to service the winches and
              lifting devices.
       •      Additional seawater pumps to provide seawater for scientific purposes.
       •      Additional capacity to accommodate the larger number of persons aboard such as:
              -  Increased generator capacity.
              -  Increased fresh-water-making capacity.
              -  Increased size of marine sanitation device.
       •      For vessels engaged in fisheries surveys or research, equipment to meet low
              radiated noise requirements:
              -  Diesel electric propulsion.
              -  Noise treatment for many pieces of machinery including the main engines and
                 generators.
       •      Low power density; the six research vessels included in the data set average just
              1.4hp/CN.

       The net effect of these differences means that research vessels typically contain smaller
main engines but more, and/or larger, auxiliary equipment than other types of vessels of similar
size.

       EPA included several research vessels ranging in length from 92 to 242 ft in the  data set
used for this analysis,  and used two for the case studies. Based on those case studies, it appears
generally feasible to retrofit PWG units into research vessels for use in ballasting operations.

Towboats

       A towboat is designed to push a barge or group of barges. They generally have a barge
shape when viewed from above instead of the ship-shape found in most other vessel types. They
are most often used in protected waters and are most common on the U.S. inland river system.
Towboats are generally twin-screw, high powered for their size, and have rudders located  both
forward and aft of their propellers to assist in maneuvering while pushing a group of barges. The
number of persons aboard consists solely of a small operating crew. Towboats typically do not
have PWGs, but instead take potable water aboard from municipal water sources along their
routes.

       Towboats generally do not carry variable loads  except for fuel, fresh water, and possibly
wastewater. Ballast water, if required, is used to compensate for fuel burn and to provide
acceptable trim.

       Compared to other vessel types, the machinery spaces of towboats may differ due the
following:

       •      Rectangular shape of machinery spaces.
       •      No competition for main deck space below other than for tankage.
                                          4-38

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
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       •      Machinery space extending to above the main deck with generators or other
              auxiliary equipment located above the main deck.
       •      Large propulsion hp compared to other types  of vessels of comparable size; the
              seven towboats included in the data set had an average power density of 6.9
              hp/CN.

       The net effect of these differences means that towboats will typically have somewhat
more available machinery space deck area than other types of vessels of similar size.

       Several towboats ranging in length from 51 to 150 ft  were included in the data set used
for this analysis, with the largest used for one of the case studies. Based on this case study, and
the machinery space deck areas typically found in this type of vessel, it is appears generally
feasible to retrofit PWGs into towboats for use in ballasting operations.

Tugboats

       A tugboat is designed to push, tow, or haul alongside another vessel. Unlike towboats,
they are generally ship-shaped when viewed from above. There are several types of tugboats:

       •      Harbor tugs, which are used primarily to help dock large ships. They are designed
              to be highly maneuverable and have an exceptionally large amount of power for
              their size. Accommodations are minimal. They generally have a small operating
              area, such as within a particular port. They typically do not have a PWG aboard
              and instead fill their potable water tanks from available municipal water.
       •      Ocean-going tugs are larger than harbor tugs.  They have a large amount of power
              for their size.  Accommodations are provided for a crew suitable for an extended
              voyage.
       •      Integrated tug-barge tugs are similar to ocean-going tugs but are designed to push
              a barge using a notch built into the barge. They are most often used on coastal
              trades.

       Propulsion  type varies depending on the design and includes single or twin propellers,
single or twin Z-drive propellers, or one or multiple vertical cycloidal drive (Voith Schneider)
propulsion units.

       Tugboats generally do not carry any variable loads except for fuel, fresh water, and
possibly wastewater. Ballast water, if required,  is used to compensate for fuel burn and to
provide acceptable trim.
following
Compared to other vessel types, the machinery spaces of tugboats may differ due the
ne:
              Confined space due to typical tug hull shape.
              Large propulsion hp compared to other types of vessels of comparable size; the
              four tugboats included in the data set had an average power density of 6.6 hp/CN.
                                          4-39

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

       The net effect of these differences means that tugboats will typically have less available
machinery space deck area than other types of vessels of similar size. For example, from Table
4-4, the towboat George C. Grugett is of similar dimensions and horsepower as the tugboat
China Tug. However, the tugboat has a machinery space deck area 36 percent smaller than the
similarly sized and powered towboat. The  USAGE towboat has installed power similar to Tug #1
in Table 4-4, but the towboat is much larger in overall dimensions and has a machinery space
deck area 280 percent greater than the tugboat. Due to the typical  tugboat hull shape and large
power machinery installed, it may be challenging to retrofit PWGs into tugboats for ballasting
operations.

Offshore Support Vessels (OSV)

       Offshore support vessel is a term that includes a variety of vessel types supporting the
offshore oil industry.  Although designed for various missions as described below, these vessels
tend to have commonalities in their configurations regarding overall arrangement and machinery
space location and design. OSVs typically are designed with a forecastle, accommodations and
pilothouse located forward, and a large open aft deck. The machinery is located in a confined
space aft of amidships, with exhausts leading forward to avoid stacks interfering with the aft
deck.  OSVs have evolved from being fairly simple and low-cost designs to very sophisticated
vessels with complicated dynamic positioning systems that include bow and stern thrusters and
Z-drive propulsion.

       Major types of OSVs include the following:

       •      Vessels that transport materials and equipment to offshore installations.
       •      Anchor handling and towing vessels, which handle anchors for offshore
             installations and also tow them from location to location.
       •      Diving and remote operating vehicle (ROV) support vessels, which provide
             support for diving systems and ROVs.
       •      Oil spill recovery vessels, which are equipped to respond to oil spills.

       Although OSVs comprise a range of vessel types, some general observations can be made
that apply to many  of these vessels. Compared to other vessel types, the machinery spaces of
OSVs may differ due to the following:

       •      Confined space due to other demands for below-deck space (particularly for
             offshore supply boats where the space is required for mud tanks and ballast
             tanks).
       •      Space demands for mud pumps for offshore supply vessels.
       •      Space demands for larger generators required for dynamic positioning systems.
       •      Modest propulsion hp compared to other types of vessels of comparable size; the
              four OSVs included in the data set have an average power density of 2.4 hp/CN.

       OSVs, depending on their type, may carry significant variable loads in addition to fuel,
fresh water, and possibly wastewater. Offshore supply vessels in particular carry drilling pipe,
                                          4-40

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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits        Feasibility of Design - Case Studies

drilling mud, and other materials that are offloaded to the offshore platform. Ballast water, when
required for stability, has to be added at a rate equal to the rate of the unloading of pipe and mud;
in gpm, that amount of ballast water is outside the practical limits of what an onboard PWG
could provide.

       It is noted that each of the four OSVs included in the data set have machinery space deck
areas  significantly lower than the overall trend line, which is in some ways an aberration from
the rest of the data. (Removing the four OSVs from the data set significantly increases the
R2value from 0.66 to 0.86). This indicates the machinery spaces of the OSVs are more crowded
than for the other vessel types. Based on the relatively small machinery space size and possible
need for a large rate of ballasting, it may be challenging to retrofit PWGs into OSVs for
ballasting operations.

Passenger Vessels

       Passenger vessels in the data set vary widely in the type of service they provide and
number of passengers aboard. In terms of ballasting practices, they can be divided into two
general types: day service or overnight service.

       Vessels in day service include ferries, dinner vessels, and tour and excursion boats. These
boats  generally operate in limited geographic areas and commonly return to their point of
departure. Per Part 2.2.3.5.3 of the VGP, vessels are exempt from ballast water management
requirements if they:

       •       Are engaged in short-distance voyages that operate or take on and discharge
              ballast water exclusively in one COTP zone or
       •       Do not travel more than 10 nautical miles and cross no physical barriers or
              obstructions (USEPA, 2013a).

Given the limited geographic area associated with their service, day-service passenger vessels
are likely to be exempt from the VGP's ballast water management requirements.

       Vessels in the size range of this study engaged in overnight service are typically small
cruise ships with a passenger capacity ranging from fewer than 49 to several hundred. They
include ships designed for either coastal service or inland river service. In almost all cases, the
vessels have either geared diesel  or diesel electric propulsion.

       Compared to other vessel types, the machinery spaces of overnight passenger vessels
may differ due to the following:

       •       Space demands for marine sanitation devices and  wastewater holding tanks.
       •       Space demands for air conditioning and other HVAC equipment.
       •       Space demands for larger generators needed for passenger service electrical
              needs.
                                           4-41

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Feasibility and Efficacy of Using Potable Water Generators
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                    Section 4-
Feasibility of Design- Case Studies
       •      Lower propulsion hp compared to other types of vessels of comparable size.
       •      Below-deck space demands for storage and service spaces.

       The evaluation of six American small cruise ships indicates a power density ranging from
1.3 to 2.1 hp/CN, with an average of 1.8 hp/CN (Table 4-5). EPA identified the ships in Table
4-5 through the supplemental search and review of internet sources and industry publications.
This is a low power density and is comparable to the power density for oceanographic research
vessels of 1.4 hp/CN (discussed above), indicating that it should be feasible to install PWGs for
use in ballasting operations in overnight passenger vessels.

             Table 4-5. Vessel Characteristics for Various Small Cruise Ships
Vessel Name
Unnamed Passenger
Vessel
Queen of the Mississippi
Kennicott
Niagara Prince
Grande Caribe
Independence
Average
Length
(ft)
350
230
382
177
183
223
258
Beam
(ft)
54
50
85
39
40
50
53
Depth
(ft)
20
12
26
9
9
8
14
Propulsion
Power
(hp)
5,000
2,600
13,380
1,142
1,300
2,842
4,377
Cubic
Number1
(CN)
3,780
1,323
8,280
625
662
1,331
2,667
Power
Density
(hp/CN)
1.3
2.0
1.6
1.8
2.0
2.1
L8
Source
OA, 2014
SSC, no date
ABS, 2014c
Blount, no date
Blount, no date
Workboat, 2011

  1 The cubic number is the product of the length, beam, and depth divided by 100.

Fishing Vessels

       Fishing vessels vary widely in size range and type of fishing operations. In almost all
cases, the vessels have geared diesel propulsion with single screw configuration being the most
common.

       Although fishing vessels comprise a range of vessel types, some general observations can
be made that apply to many of these vessels. Compared to other vessel types, the machinery
spaces of fishing vessels may differ due to the following:

       •       Space demands for hydraulic power units required for fishing gear.
       •       Below-deck space demands for fish holds.
       •       Space demands for refrigeration equipment (for vessels with chilled fish holds).

       The fishing vessel included in the parametric analysis has noticeably less  machinery
space deck area than the overall trend line for all vessels would suggest, and has a power density
of 3.1 hp/CN. Analysis of 13  other recently built or modified fishing vessels (Table 4-6) indicate
power densities ranging from 2.4 to 4.2 hp/CN, with an average of 3.0 hp/CN. EPA identified
these ships through the supplemental review of industry publications. These power densities are
comparable to that of the fishing vessel included in the parametric analysis. Due to the small
deck area observed in both the parametric and supplemental analyses, it appears that it generally
may be challenging to install  a PWG in fishing vessels.
                                           4-42

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Feasibility and Efficacy of Using Potable Water Generators
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                    Section 4-
Feasibility of Design- Case Studies
               Table 4-6. Vessel Characteristics for Various Fishing Vessels
Vessel Name (Service)
Unnamed Vessel (Combination
Scalloper and Trawler)
Arctic Prowler (Longliner)
Pursuit (Combination Scalloper
and Trawler)
Unnamed Vessel (Shrimper)
Raiders (Scalloper)
Rappahannock (Menhaden
Steamer)
Norseman (Scalloper)
Araho (Trawler)
Bella Skye (Longliner)
Fleeton (Menhaden Steamer)
Bay Islander (Trawler)
Concordia (Scalloper)
Miss Emily (Combination
Shrimper, Crabber, and
Tenderer)
Average
Length
(ft)
86
136
88
105
98
196
95
194
75
184
78
95
72
116
Beam
(ft)
24
40
24
27
27
40
28
49
20
38
22
28
28
30
Depth
(ft)
12
15
11
13
14
14
13
16
8
14
12
15
13
13
Propulsion
Power
(hp)
600
2,000
600
1,000
1,000
3,000
1,050
4,000
500
3,000
650
1,000
660
1,466
Cubic
Number1
(CN)
248
816
239
369
370
1,098
346
1,284
120
979
206
386
262
517
Power
Density
(hp/CN)
2.4
2.5
2.5
2.7
2.7
2.7
3.0
3.1
4.2
3.1
3.2
2.6
2.5
3.0
Source
Chowning, 2013a
Crowley, 2013a
Chowning, 2014a
Chowning, 2012
Chowning, 2013b
Crowley, 2013b
Chowning, 2014b
Chowning, 2013c
QAS, no date
Crowley, 2013b
McKernan, 2006
Crowley, 2012
Chowning, 2013d

1 The cubic number is the product of the length, beam, and depth divided by 100.

4.4.6  Conclusions

       A general conclusion from this parametric analysis is that machinery space deck area is
best predicted as a function of the vessel's length x beam. In addition, the impact of
incorporating a PWG capable of producing enough water ballast to compensate for fuel
consumption is much more a function of vessel size than of vessel horsepower. Based on this
parametric analysis, it generally appears feasible to retrofit PWG units into research vessels,
towboats, and small overnight passenger vessels; it generally appears less feasible to retrofit
PWG units into tugboats, offshore support vessels, and fishing vessels.

4.5    NEW DESIGN vs. RETROFITTING

       The case studies described in Sections 4.1  through 4.3 were based on looking at existing
machinery space arrangements and determining if there was sufficient space to install a suitably
sized PWG for ballast water production within the existing machinery space. This section looks
at the impact on a new vessel design if the PWG installation was one of the design requirements.
For this assessment, EPA assumes that any additional PWG units would be sized to provide
ballast water at a rate equal to the vessel's fuel burn.

       In a new vessel design, particularly in the size range of EPA's analysis, space is often at a
premium with machinery, fuel and ballast tankage, cargo, and possibly passenger and crew
spaces all needing to fit in a limited amount of below-deck space. It is the job  of the naval
                                           4-43

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                    Section 4-
Feasibility of Design- Case Studies
architect, in cooperation with the owner, to make trade-offs between these various demands in
both determining the overall dimensions of the vessel and in allocating space for each function.

       Based upon the parametric analysis and information regarding available PWG units, it
can be determined, on an average basis, how much the vessel dimensions need to be increased to
accommodate the PWG units. A basic assumption, verified by the case studies, is that machinery
space deck area is the critical variable in determining whether a machinery space can
accommodate a PWG unit.

4.5.1   Parametric Data for PWGs

       The dimensions of six available PWG models were used to develop a relationship
between PWG capacity and required deck area. Clearances of 2 ft on each side and 2 ft in front
of each unit were included as part of the required area. In addition, the area required for a
chlorinator consisting of a 21-in diameter tank with a 2-ft clearance in front of the unit was
included. The required  clearances were based on information from the respective vendors. No
additional clearance is required at the rear of the PWG units. The chlorinator does not require
clearances at the sides or rear.

       Table 4-7 presents the PWG deck area requirements for the six available PWG models
noted above. Figure 4-20 shows the relationship between the required PWG deck area and PWG
capacity (in gpm).

                   Table 4-7. Deck Area Requirements by PWG Model
PWG
Model
Axeon S3
Axeon M2
Coral Sea
Tasman Sea
Axeon R2
Coral Sea
Model
Configuration
Horizontal
Horizontal
Horizontal
Vertical
Vertical
Vertical
PWG
Max
Rating
(gpm)
1.5
25
4.7
16.5
6.3
4.7
PWG Dimensions
Length (ft)
PWG
4
8.3
5.1
6.4
3.1
2.4
Clearance
4
4
4
4
4
4
Total
8
12.3
9.1
10.4
7.1
6.4
Width (ft)
PWG
2
2.6
2.9
3.8
2.2
2.9
Clearance
2
2
2
2
2
2
Total
4
4.6
4.9
5.8
4.2
4.9
Deck Area (ft2)
PWG
32
56.5
44.2
59.9
29.5
31.3
DS
8
8
8
8
8
8
Total
40
64.5
52.2
67.9
37.5
39.3
                                           4-44

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Feasibility and Efficacy of Using Potable Water Generators
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                           Section 4-
       Feasibility of Design- Case Studies
           u
           1)
           Q
           •a
           c-
80



60



40



20

10
                                                    R
! = 0.7268
                                     10       15       20

                                     PWG Capacity, gpm
       25
                                                    30
                Figure 4-20. PWG Required Deck Area vs. PWG Capacity

       A linear trend line was fit to the data with a R2 factor of 0.73. The impact of the smaller
deck footprint of the vertical configuration units is largely diluted by the additional requirements
of clearance areas and the chlorinator area.

4.5.2   Impact on Vessel Characteristics

       In theory, adding any additional piece of equipment to a design will result in a larger
ship. In practice, a designer can often accommodate some amount of additional equipment by
using a more efficient design or by making tradeoffs involving access, operational efficiency, or
convenience to operating personnel.

       The greatest impact on the vessel design occurs when vessel dimensions are increased to
accommodate additional equipment without making additional design tradeoffs. This study looks
at the impact on vessel design using this approach, as it demonstrates the most severe potential
impact of the additional equipment, and as such "bounds the problem." In cases where the vessel
design makes other tradeoffs to accommodate additional equipment, the impact on the  overall
vessel dimensions will be less than that indicated in this study.

       Figure 4-16 gives the relationship, based on the data set available, between machinery
space deck area and length x beam. This relationship indicates that each increase in the product
of length x beam of 1,000 would increase the machinery space deck area by 280 ft2. (This is
derived from the linear trend line of Y = .2798X + 225.3, where Y is deck area and X is length x
beam). Conversely,  a desired increase in machinery space deck area of 100 ft2 will require an
increase of length x beam of 100/0.2798, or 357. (Note that the trend line discussed here
excludes the four OSVs from the data set.)
                                          4-45

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Feasibility and Efficacy of Using Potable Water Generators
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                    Section 4-
Feasibility of Design- Case Studies
       The required additional PWG capacity is based on fuel consumption, which is a function
of installed power (both for the propulsion engines and auxiliary engines such as diesel
generators). As all vessels in the parametric data set use diesel engines, it is appropriate to select
diesel engine fuel consumption values for this analysis. Modern medium speed diesel engines
have published fuel-specific fuel consumption rates ranging from 0.33 to 0.37 Ib/hp-hr
(Caterpillar, 2008).  This analysis uses a conservative fuel consumption rate of 0.4 Ib/hp-hr. Table
4-8 presents a calculation of the impact on length x beam of adding a requirement to  install a
PWG with a capacity to generate water to compensate for fuel consumption.

        Table 4-8. Required Increase in Length x Beam due to PWG Requirements
Total Installed
Horsepower
(hp)
500
1,000
1,500
2,000
2,500
3,000
4,000
5,000
6,000
7,000
8,000
9,000
10,000
Total Fuel
Consumption
(Ib/hr)
200
400
600
800
1,000
1,200
1,600
2,000
2,400
2,800
3,200
3,600
4,000
Total Fuel
Consumption
(Ib/min)
3.33
6.67
10.00
13.33
16.67
20.00
26.67
33.33
40.00
46.67
53.33
60.00
66.67
Required
PWG Rate
(gpm)
0.40
0.80
1.20
1.60
2.00
2.40
3.20
4.00
4.80
5.60
6.39
7.19
7.99
Required
PWG Area
(ft2)1
38.6
39.1
39.7
40.2
40.8
41.3
42.4
43.6
44.7
45.8
46.9
48.0
49.1
Corresponding
Length x Beam
Increase (ft2)
137.8
139.8
141.8
143.8
145.7
147.7
151.7
155.7
159.6
163.6
167.6
171.6
175.5
    1 Includes maintenance clearances and space for chlorinator.

       The impact of the PWG on a vessel is much greater for smaller vessels than for larger
ones for a given horsepower (see Table 4-8). For example, one of the smaller vessels in the data
set, the R/VPelican, has a length x beam of 3,082 ft2. Even the lowest horsepower in the table
(500) results in an increase in required length x beam of over 10 percent. In contrast, for the
Oscar Dyson, one of the larger vessels in the data set with a length x beam of 10,170 ft2, adding
a PWG suitable to support a total installed horsepower of 10,000 would increase the length x
beam requirement by less than 2 percent.

       It is likely that naval architects faced with a 10 percent increase in vessel size would find
other alternatives to deal with the issue of ballast water management. For instance, they might
consider increasing the vessel's beam or lowering its center of gravity (perhaps by adding
permanent solid ballast) to eliminate the need for ballast water altogether. Alternatively, as
illustrated in previous case studies, existing free space on  a vessel can sometimes be utilized to
accommodate new equipment.

       Another potential impact in incorporating PWGs into new vessel designs would be on the
arrangement of ballast tanks. It is generally current practice  (with the exception of peak tanks) to
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Feasibility and Efficacy of Using Potable Water Generators                                    Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

keep ballast tanks either full or empty. This approach minimizes the adverse effects on stability
that are associated with partially full tanks. In a new design, where it is known that the practice
would be to fill ballast tanks incrementally, the naval architect would likely maximize stability
by using narrow or baffled tanks and wing tanks in lieu of double bottom tanks for water ballast.

       Although the decision-making process will  differ with each design, it is possible to make
some general observations for various vessel types  as discussed below.

Oceanographic Research Vessels

       Oceanographic research vessels generally do not carry variable loads except for fuel,
fresh water, and wastewater. Ballast, if required, is  used to compensate for fuel consumption.
Based on observations from the case studies and parametric analysis of existing vessels, it
appears that using PWGs for ballast water for newly designed Oceanographic research vessels
may be feasible. These vessels typically have research-specific auxiliary systems that are located
either in the main machinery space or, as needed, in a separate auxiliary machinery space.
Adding a PWG makes it more likely that new vessel designs would further utilize and potentially
expand the footprint of the auxiliary machinery space.

Towboats

       Towboats generally do not carry variable loads except for fuel, fresh water, and
wastewater. Ballast water, if required, is used to compensate for fuel burn and to provide
acceptable trim. The hull geometry of towboats results in machinery spaces with large deck
areas. Further, without other demands for below-deck spaces,  suitably sized PWGs could be
installed despite the large installed horsepower typical for these vessels. Based on observations
from the case studies and parametric analysis of existing vessels, it appears that the using PWGs
for ballast water for newly designed towboats may  generally be feasible.

Tugboats

       Tugboats generally do not carry variable loads except for fuel, fresh water, and
wastewater. Ballast water, if required, is used to compensate for fuel burned and to provide
acceptable trim. However, because of the hull shape and large propulsion horsepower that is
typical of this vessel type, new vessel designs would require increasing the overall vessel size.
Based on this and observations from the case studies and parametric analysis of existing vessels,
it appears that using PWGs for ballast water for newly designed tugboats may be challenging
without increasing vessel dimensions.

Offshore Support Vessels (OSVs)

       OSVs, depending on their type, may carry significant variable loads in addition to fuel,
fresh water, and wastewater. Offshore supply vessels in particular carry drilling pipe,  drilling
mud, and other materials that are offloaded at offshore platforms. When required for stability, the
intake of ballast water must occur at a rate equal to that of the cargo unloading rate. The required
ballast water intake rates would be significant and outside the practical limits of what a PWG
could supply. Also, OSV machinery spaces are more limited than in other vessel types, posing
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Feasibility and Efficacy of Using Potable Water Generators                                   Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

further barriers to feasibility. Based on observations from the case studies and parametric
analysis of existing vessels, it appears that using PWGs for ballast water for newly designed
OSVs may not be feasible without increasing the overall vessel size by a  significant amount.

Small Overnight Passenger Vessels

       Small overnight passenger vessels generally have a low power density comparable to that
of oceanographic research vessels (see discussion in Section 4.4.5). Therefore, it appears that
using PWGs in newly designed vessels may generally be feasible. Small overnight passenger
vessels typically have HVAC and waste management systems, which are located either in the
main machinery space or, as needed, in a separate auxiliary machinery space. Adding a PWG
makes it more likely that new vessel designs would further utilize and potentially expand the
footprint of the auxiliary machinery space.

Fishing Vessels

       Fishing vessels generally have small deck areas, as observed in Section 4.4.5. The limited
deck area of this vessel type adversely impacts the overall feasibility of including PWGs in new
vessels. However, their use may be feasible in some cases.  Fish-hold volume and auxiliary
equipment space requirements are vessel-specific and depend on the type of fishery involved. It
would be more feasible to install PWGs on vessels that have less  demand for fish-hold volumes
and auxiliary equipment.

4.5.3   Economic Considerations

       One unique aspect of newly designed vessels is that vessel designers can generally
eliminate or reduce the need to ballast by designing wider vessels. The broader beam (i.e., width)
will stabilize the vessel, thus reducing reliance on a PWG or eliminating its need altogether. The
greater beam, however, would pose greater capital costs compared to that of a traditional vessel
design, due to added construction and material costs. Also, the greater vessel  size would likely
result in increased operating costs, as the wider hull shape will increase hydrodynamic drag,
thereby increasing fuel consumption, subsequent fuel costs, and greenhouse gas emissions.

       Another unique aspect of PWG use in newly designed vessels is the costs savings
generated over the life of the vessel from using potable water in the ballast tanks. Using sea or
brackish water as ballast can cause deterioration of ballast tank protective coatings and corrosion
of the ballast tank itself, ultimately requiring replacement of steel within the ballast tank. Using
fresh water generated  from the PWG would be expected to generally reduce corrosion in the
ballast tank.

4.5.4   Extrapolation to Other Vessel Types and Sizes

       Based on available data, EPA limited the  parametric analysis to smaller vessel types.
However, it is possible to project the results to larger vessel types. Clearly, it is not practical to
produce potable water onboard at rates great enough to compensate for large, rapid changes in
displacement as is seen in  cargo operations of many ship types, such as bulk carriers or tankers.
However, it may be technically feasible (although perhaps not economically feasible) for these
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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                    Section 4-
Feasibility of Design- Case Studies
ships to ballast with potable water provided shore-side (i.e., a municipal water supply) while
discharging cargo, and then using PWGs to provide ballast water for fuel compensation purposes
during their voyage.

       In addition, using potable water generated onboard for ballast may be feasible for larger
vessels that do not have rapidly changing loads. Vessel types fitting this category would include
large passenger vessels (e.g., medium and large cruise ships) and some types of military vessels.
One of the conclusions of this study is that the feasibility of retrofitting PWGs capable of
producing enough water ballast to compensate for fuel consumption is much more a function of
vessel  size than of horsepower. Therefore, larger vessel types, particularly those with modest
horsepower, may be candidates for this type of system.

       One type of larger ship that might feasibly use PWGs for ballast water is large passenger
ships such as cruise ships. These ships usually have large capacity distilling units to provide
sufficient fresh water for hotel services (i.e., passengers, crew, wash water, etc.).

       Table 4-9 provides data on three cruise ships for which published information concerning
PWGs and installed power is publicly available. Large-capacity distilling units are installed in
each ship. Based on installed horsepower and an assumed fuel consumption rate of 0.4 Ib/hp-hr,
EPA calculated the corresponding ballast rates required for fuel consumption compensation. The
ballast rates range from 44  to  104 gpm. It should be noted that the assumed fuel consumption
rate is  conservative, given that the large diesel engines typically used in these vessels are more
efficient than those used in smaller vessels. Therefore, the potable water production rates in
Table 4-9 represent an upper bound for each vessel.

            Table 4-9. Vessel and PWG Characteristics for Select Cruise Ships
Vessel Characteristics
Installed PWGs
Production Capacity (gpm)
Passengers and Crew
Gallons per Person per Day
Installed Power (hp)
Specific Fuel Consumption
(Ib/hp-hr)
Fuel Consumption (Ib/hr)
Required Ballast Water (gpm)
Required PWG Production
Capacity Increase
Oasis of the Seas
Hamworthy MSF
825/8
606
7,700
113
130,000
0.4
52,000
104
17%
Queen Victoria
Wartsila Serk
Como MSF
312
2,900
155
85,000
0.4
34,000
68
22%
MSC Fantastica
Hamworthy MSF
950-8 MSF
349
4,874
103
54,892
0.4
21,960
44
13%
       Sources: Kable, 2014; MP, 2010; Wartsila, 2014; Veristar, 2013

       The calculation indicates that the overall water-making capacity for these large cruise
ships would need to increase by 13 to 22 percent to provide sufficient fresh water for ballast to
compensate for fuel use. In a new design, additional or larger distilling units would be installed
to provide this additional potable water. Since these ships are already equipped with large
capacity distilling units, the impact on both costs and overall ship operations of increasing their
capacity will be less than for other types of vessels that do not have large, potable-water-
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Feasibility and Efficacy of Using Potable Water Generators                                     Section 4—
as an Alternative Option for Meeting Ballast Water Discharge Limits         Feasibility of Design - Case Studies

generating capabilities. The additional cost of the larger distillers would be at least partially
offset by eliminating the need for other ballast water management methods and by eliminating
the corrosive effect of salt water in ballast tanks. Hence, using potable water generated onboard
for ballasting may be feasible for medium and large cruise ships.
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Feasibility and Efficacy of Using Potable Water Generators        Section 5-Efficacy of P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits       Systems for Ballast Water Generation

                                                                      SECTION 5
        EFFICACY OF PWG AND DISINFECTION SYSTEMS FOR
	BALLAST WATER GENERATION

       A critical consideration in evaluating the utility of using a PWG ballast  option is whether
the resulting discharges would meet existing numeric discharge limits in EPA's 2013 VGP.
These limits are the same as those finalized by the USCG in its 2012 ballast water rule. The
standards are generally similar to those contained within the 2004 International Maritime
Organization (IMO) Ballast Water convention. The 2013  VGP (76 FR 76716) and USCG ballast
water discharge standards require:

       •     Organisms >50 micrometers (|im): <10 organisms/m3
       •     Organisms <50 |im,  but >10 |im: <10 organisms/milliliter (ml).
       •     Organisms <10 |im:
             -     Toxicogenic  Vibrio cholera: <1 colony-forming units (CFU)/100 ml.
                    Escherichia coli: <250 CFU/100 ml.
                    Intestinal enterococci <100 CFU/100 ml.
       The following sections describe tested PWG and disinfection system treatment efficacies,
and whether they are capable  of meeting numeric treatment limits at least as stringent as those in
EPA's 2013 VGP. EPA's determination is based on a review of the scientific literature as well as
a "proof of concept" field test conducted in partnership with MARAD and with technical  support
from the Maritime Environmental Resource Center (MERC) and Eastern Research Group, Inc.
(ERG). The goal of the field test was to generate primary data on the organism  treatment efficacy
of such a system. The proof of concept testing occurred at MERC's ballast water testing facility
in Baltimore, MD.

5.1    LITERATURE DATA ON TREATMENT EFFICACY OF PWG SYSTEMS

5.1.1   Literature Search Methodology

       EPA conducted a literature search for existing information on PWG treatment efficacy
data for organisms. EPA focused its literature search using the following methodology:

       •     Searched vendor websites and vendor system names identified through EPA's
             PWG research to look for existing efficacy data for these specific systems.
       •     Searched industry, government, and academic sources using Google Scholar to
             identify other articles, reports, or studies that might contain PWG and/or PWG
             with disinfection efficacy data.
       •     Searched the aforementioned sources using the following key words and
             combinations of key words: potable water, reverse osmosis, disinfection,
             treatment efficacy, treatment efficiency, CFU, and E. coli.
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Feasibility and Efficacy of Using Potable Water Generators         Section 5-Efficacy of P WG and Disinfection
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       •      Investigated the references noted in articles and reports found through the initial
              search to identify other potential sources of interest and looked for any type of
              pollutant removal data (not just organisms).
5.1.2   Overview of Literature Data on PWG Treatment Efficacy

       PWG vendor websites and system information indicated that, while system
specifications, including system treatment rates, are often publicly available, these materials do
not include performance data for organisms. For the current design and marketing of PWGs, the
user dictates the performance of the PWG and disinfection technology when they order the
equipment from the system manufacturer. For example, when evaluating disinfection through
chlorination, the vendor offers systems of various sizes that are able to treat ranges of water
throughput (e.g., gpm), but the user would need to  specify the level of performance required,
which would then dictate the chemical addition rates.

       Articles identified through technical journals (e.g., Desalination,  Water Resources, and
Water Research) spoke to the use of membrane technologies for potable water treatment. In
Desalination, EPA identified several articles and studies focused on using membrane systems
(e.g., RO) for potable water supplies.  Most of the articles on treatment performance addressed
the removal of arsenic and demonstrated removal rates of 40 to 99 percent (Kang et al., 2000;
Ning, 2002; and Gholami et al., 2006). One article studied the effect of solution pH and generally
observed that a higher pH correlated with greater removal rates (Kang et al., 2000). Another
demonstrated organic matter removal rates of up to 85 percent (Pryor et al., 1998). Yet another
observed the onset of membrane filter biofouling and scaling after approximately 6,000 hours of
operation, with rapid biofouling and scaling occurring at approximately 11,000 hours (Kruithof
etal., 1998).

       Though EPA did not find specific treatment efficacy data for Vibrio cholera, E. coli, or
intestinal enterococci, the Agency did identify a review paper providing the following efficacy
data for other organisms:

       •      Siveka (1966) reported RO removal of coliform bacteria from feed water
              containing 1,500 to greater than 11,000 CFU per ml. The product water contained
              less than 3 CFU per 100 ml (as cited in Madaeni, 1999).
       •      Regunathan et al. (1983) reported RO removal of coliform bacteria from feed
              water containing 3.0 x 104 to 4.7 x 107 CFU per 100 ml. The product water
              contained less than 1 per 100 ml (as cited in Madaeni,  1999).
       •      Cooper and Straube (1979) studied RO removal efficacy of viruses from sewage.
              They observed complete removal of plaque-forming units (pfu) from feed water
              containing 105 to 107 pfu/gal. They also observed a 7- and 5-log removal of
              poliovirus and coliphage, respectively (as cited in Madaeni, 1999).

       •      Adham et al. (1998) conducted a bench-scale study to evaluate the removal
              effectiveness of the MS2 bacteriophage using five different RO membranes.  They
              observed a virus reduction of 2.7 to more than 6.5 logs (as cited in WHO, 2004).
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Feasibility and Efficacy of Using Potable Water Generators         Section 5-Efficacy of P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits        Systems for Ballast Water Generation

       The World Health Organization (WHO) (2004) noted in its review of the literature that
RO systems are seldom used to remove living organisms from water sources because other forms
of filtration (e.g., microfiltration, ultrafiltration) are more cost effective and can achieve a similar
degree of removal. WHO also noted a lack of literature on RO system efficacy, which is
consistent with EPA's observations during the literature review.

5.1.3   Conclusion

       EPA did not find PWG treatment efficacy data that was specific to zooplankton,
phytoplankton, Vibrio cholera, E. coli, or intestinal enterococci. However, values reported for
other organisms suggest that PWG systems may provide pathogen reductions in the broad range
of 3 to 7 logs.

5.2     ENGINEERING ASSESSMENT OF PWG AND DISINFECTION SYSTEM TREATMENT
       EFFICACY

       In light of the lack of literature data on PWG effectiveness for removing waterborne
organisms, EPA conducted an engineering assessment to determine what removal  or inactivation
efficiencies can be reasonably expected from PWG-disinfection systems. The following sections
summarize EPA's findings and conclusions for PWG systems that use RO or distillation, as well
as for chemical and physical disinfection systems (i.e., chlorine, bromine, silver ion (chemical),
or UV radiation (physical)).

5.2.1   RO Treatment Mechanism and Expected Effect on Living Organisms

       Unlike most other filtration methods, RO separation is not a size exclusion-based process.
It is a pressure-driven process that reverses the chemical potential across a semipermeable
membrane (i.e., RO systems operate by applying pressure across a semipermeable membrane).
The pressure exerts a driving force that sends solvent molecules through the membrane.
However, dissolved ions and suspended particles, which do not experience this driving force, are
unable to permeate though the membrane.

       Typically, RO systems utilize a prefiltration process to prevent fouling of the
semipermeable membrane. Prefiltration processes include granular media and bag and cartridge
filtration. The extent to which these pretreatment processes are used by an RO system depends
on the quality of the water source. Granular media can include coal, sand, garnet, and activated
carbon, and can remove organisms as small as 0.01 jim. Bag and cartridge filters remove
contaminants and pathogens in the 0.2- to  10-|im range (WHO, 2004).

       As discussed in Section 5.1, there is a lack of biological treatment efficacy data for RO
systems; therefore, EPA is unable to quantify RO removal efficiencies based on existing
literature alone for zooplankton, phytoplankton, V. cholera, E. coli,  and intestinal enterococci.
The reported RO removal efficiencies discussed in Section 5.1 suggest that RO systems could
yield 3- to 7-log reductions of V. cholera, E. coli, or intestinal enterococci. Comparing organism
sizes against typical RO system pore sizes (Figure 5-1) confirms that RO systems should be
highly effective at removing living organisms in general, including bacteria, phytoplankton, and
zooplankton, particularly when combined with pre-filtration.  The figure shows that bacteria are,
at a minimum, two orders of magnitude larger than even the largest RO membrane filter pores.

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Feasibility and Efficacy of Using Potable Water Generators         Section 5-Efficacy of P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits        Systems for Ballast Water Generation

Therefore, it is reasonable to expect that RO systems can meet numeric treatment limits at least
as stringent as those specified in EPA's 2013 VGP.
        Filtration
        processes
        (pore size of
        filter medium)
        Mlcroblal
        particles
                                                                DE
                filters
    UF
                                            Granular filtration*
              MF
                                         Viruses
                                                        Bacteria
                                                                    Algae
                                                            Pnotoaoan cysts
                                i i  i ii ni   i i i
                                             **
                                            mill
              * •*
icr10
ir*     ion7      itr6
      Size (m) (log scale)
                                                                         icr1
      DE - diatomaceous earth; MF - microfiltration; NF - nanofiltration; UF - ultrafiltration
      Source: WHO, 2004

 Figure 5-1. Comparison of Organism Sizes against Filter Pore Sizes for Various Filtration
                                         Processes

       Statistical data published by the American Water Works Association Research
Foundation (AWWARF) (Nieminksi and Ballamy,  2000) indicates that E. coli concentrations in
U.S. waters range from 30.4 to 173.9 CFU/100 ml at the 95 percent confidence interval. At the
reduction minimum for this technology (i.e., 3 logs), it appears that it is likely to meet treatment
limits at least as stringent as those specified in the 2013 VGP. At a concentration of 173.9
CFU/100 ml, a 3-log reduction would yield ballast water containing approximately 0.2 CFU/100
ml, well below the E.  coli limit of 250 CFU/100 ml. EPA was unable to identify similar data for
V. cholera and intestinal enterococci. Using theE1.  coli data as a surrogate, it is reasonable to
                                            5-4

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Feasibility and Efficacy of Using Potable Water Generators         Section 5-Efficacy of P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits        Systems for Ballast Water Generation

conclude that RO systems could also meet the limits for both V. cholera (<1 CFU/100 ml) and
intestinal enterococci (<100 CFU/100 ml).

       In type-approved ballast water treatment systems, mechanical filtration is the most
commonly used treatment technology component. These filters are typically fully automatic,
self-cleaning screen or disk filters with a pore size of 50 jim to remove larger organisms and
sediments (fflS Maritime, 2013; ABS, 2011; USEPA, 201 Ib; Albert et al., 2010). In comparison,
the pore size of RO membrane filters is more than five orders of magnitude smaller than filters
typical of ballast water treatment systems capable of removing organisms much smaller than 50
|im as discussed  above. USEPA,  201 Ib discusses that media filters or membrane filters would
need to be used to improve mechanical separation for ballast water treatment, but acknowledges
that such devices have not yet been practically applied to ballast water treatment.

5.2.2   Distillation Treatment Mechanism and Expected Effect on Living Organisms

       Distillation-based PWGs operate  on the principle that seawater (or brackish or fresh
water) can be evaporated under vacuum at temperatures as low as 40ฐC. Feed water starts
evaporating immediately upon entry into the technology. The heat source used for this process is
waste heat produced by the vessel's main engines. Approximately half of the seawater is
evaporated to distillate water vapor, which is then condensed as potable water. The remaining
half of the seawater (brine) is discharged upon generation. A demister removes entrained water
droplets from the distillate water vapor and routes it to the brine discharge.

       While the distillate water  vapor is likely to be free of living organisms, fine entrained
water droplets that are not completely removed by the demister have the potential to contain
living organisms and other contaminants. Accordingly, water temperature and the time of
treatment at that  temperature are critical variables affecting organism mortality. Time-
temperature studies and trials performed  onboard vessels found 90 to 100 percent reduction of
phytoplankton and zooplankton at 35 to 38ฐC for 20 hours (Rigby et al., 1999) and 100 percent
zooplankton mortality at 38ฐC for 12 hours (Quilez-Badia et al., 2008; Mountfort et al., 2001).
High-temperature treatment (55 to 80ฐC) for short periods (up to a few seconds) are also
effective for phytoplankton and zooplankton (McCollin and Shanks, 2003; Quilez-Badia et al.,
2003; Reavie et al., 2010). However, another study (Cao et al., 2014) indicates that a temperature
of 80ฐC within 60 seconds of heating time is needed to kill bacteria such as E. coli.

       Ballast water can be disinfected using waste heat provided by the ship's engines, or
external sources  such as  steam or microwave heating (Gregg et al., 2009). Balaji et al. (2014)
considers using heat treatment as part of a combination ballast water treatment system, citing a
variety of studies of candidate combination technologies and their effectiveness, but
acknowledges that issues remain. Review of available guides to ballast water treatment (MS
Maritime, 2013;  ABS, 2011) did  not identify any internationally type-approved ballast water
treatment systems incorporating this technology.

       A key consideration concerning the efficacy of distillation-based PWGs is that they apply
a vacuum to permit distillation at lower temperatures.  Such temperature reductions are likely to
limit the overall efficacy of this technology. Based on the studies discussed above, distillation-
based PWGs will likely treat zooplankton and phytoplankton, but may not have high removal
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Feasibility and Efficacy of Using Potable Water Generators         Section 5-Efficacy of P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits       Systems for Ballast Water Generation

efficiencies for some or many types of bacteria. This is particularly apparent when comparing
distillation system operating temperatures, which can run as low as 40ฐC, to the 80ฐC kill
temperature Cao et al (2014) reported for E. coli.

       In addition to temperature, EPA also considered how operating pressures affect overall
organism reductions. EPA's literature search did not identify any studies that exclusively
investigated the relationship between pressure and achievable organism reductions. The literature
describes temperature as the primary means of disinfection because it denatures organisms'
enzymes (Csuros and Csuros, 1999). This principle appears to hold true even with autoclaves, an
analogous technology where complete disinfection occurs under elevated pressures. The
technology utilizes elevated pressures for the sole purpose of achieving higher disinfection
temperatures than would otherwise be achievable at lower pressures; the elevated pressures in
and of themselves do not directly translate to organism reductions (Csuros and Csuros, 1999). It
is therefore reasonable to conclude that the lower pressures associated with distillation-based
PWGs would provide negligible organism reductions.

5.2.3   Biocide Disinfection Treatment Mechanism and Expected Effect on Living
       Organisms

       Chemical disinfectants inactivate organisms by destroying or damaging cellular
structures, interfering with metabolism, and hindering biosynthesis and growth (USEPA, 2006).
Chlorine, bromine, and silver ions can be used as chemical disinfectants; however, bromine and
silver ion disinfection have not gained widespread acceptance compared to chlorine (WHO,
2004).

       Chemical disinfectants are delivered to potable water sources using a variety of chemical
forms. Chlorine is added either as a pure gas or as tablets or solutions containing chloride salts
(e.g., sodium hypochlorite or calcium hypochlorite).  Once added to the water, chlorine reacts to
form hypochlorous acid (HOC1) and hypochlorite anions (OC1~). Bromine is added as a pure
liquid or an aqueous solution, and, similar to chlorine, forms an acid (hypobromous acid
(HOBR)) and an anion (hypobromite anions (OBr~))  when added to water. Silver is added
directly to a potable water  source through the electrolysis of a silver anode. The electrolytic
reaction liberates silver ions from the anode, which in turn dissolve into the water source.

       It is important to note that water quality affects the chemistry of disinfection chemicals,
particularly when using chlorine and bromine. For example, sodium hypochlorite is most
effective at low pH values  that favor formation of hypochlorous acid (MEPC, 2010). At a pH of
8, the concentration of hypochlorous acid is 20 percent, whereas at a pH of 7, the concentration
increases to 70 percent (Daniels and Selby, 2007). Bromine is similarly affected by pH; however,
the effect is not as dramatic as with chlorine (MDE, 2012). Temperature can also affect the
efficacy. For example, higher temperatures increase hypochlorite toxicity, thus  increasing the
biocidal efficacy of sodium hypochlorite (MESB 2002; Sano et al. 2004). Large quantities of
compact sediment can negate the efficacy of chemical biocides, as they can provide refuge for
aquatic  species and prohibit full permeation of biocides (Electrichlor, 2002; Gray et al., 2006).

       Table 5-1 lists bacterial reductions reported in the literature for chlorine (as sodium
hypochlorite), silver, and bromine. Reported biocide reductions are >85 percent for sodium
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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Section 5-Efficacy of PWG and Disinfection
      Systems for Ballast Water Generation
hypochlorite, >99.99 percent for silver, and 100 percent for bromine. It is important to note that
the reductions in Table 5-1 are a function not only of the biocide dose and contact time, but also
the quality of the potable water source. As noted previously, pH, temperature, and sediment
loading will impact treatment efficacy. Therefore, actual reductions achieved onboard vessels are
expected to be highly variable and will require adjustments to biocide concentrations, contact
times, or both depending on source water characteristics. For this reason, EPA's focus is to
establish a rough order of magnitude for the treatment efficacy of chlorine, silver, and bromine
by aggregating the values reported in Table 5-1. In this regard, 85 to 100 percent reductions are
likely when using the types of biocides listed below. This is equivalent to an approximate
reduction of 1 to 5 logs, excluding those sources reporting 100 percent (i.e., infinite log)
reductions.

 Table 5-1. Reported Organism Reductions for Sodium Hypochlorite, Silver, and Bromine
                                      Disinfection
Residual Biocide
Contact
Time
(Hours)
Reported Organism
Reduction
Source
Sodium hypochlorite
7 to 10 ppm
4 to 6 ppm
5 ppm
2
24
24
>90%
(indigenous bacteria in
seawater ballast)
99.6% (zooplankton);
100% (phytoplankton);
99.9% (bacteria)
100% (V. cholera);
85% (E. coli)
BMT Fleet Technology, 2002
Reynolds etal, 2008
Zhang et al., 2003
Silver ion
0.05 to 0.2 ppm
30 ug/L
(also included 30 ug/L
hydrogen peroxide)
38 ug/L
(also included 100 ug/L chlorine
and 380 ug/L copper)
1.5
1
0.03
>99.99 (E. coli)
99.999% (E. coli)
99.999% (E. coli)
Jung, et al., 2008
Pedahzuretal., 1995
(as cited in WHO, 2004)
Thurman and Gerba, 1989
(as cited in WHO, 2004)
Bromine
150 ug/L
0.5
100% (E. coli)
Tanner and Pitner, 1939
(as cited in NAS, 1980)
       The reductions noted above occurred in addition to organism removal during prior RO or
distillation steps. For RO, literature values suggest 3- to 7-log reductions (see Section 5.2.1);
therefore, the net reduction achieved through RO and subsequent biocide disinfection is likely to
range from 4 to 12 logs. As discussed in Section 5.2.2, vacuum distillation systems may not
effectively treat bacteria. Therefore, EPA conservatively assumes reductions will only occur
during the subsequent biocide disinfection step, yielding 1- to 5-log reductions.

       Assuming an E. coli concentration of 173.9 CFU/100 ml  for U.S. waters, (Nieminksi and
Ballamy, 2000) and assuming a minimum net reduction of 4 logs, it appears that a combined
RO/biocide disinfection technology would yield ballast water containing approximately 0.02
CFU/100 ml, which is well below VGP treatment limits. Even in cases where E. coli ambient
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concentrations may be much higher, such as where there are combined sewer overflow
discharges adjacent to the port or in certain non-U.S. waters where wastewater treatment may not
be as developed, RO/biocide disinfection technology should produce treated water below the
VGP limits. However, for the distillation/biocide disinfection technology, the ability to meet
treatment limits is likely to be case-specific. Additionally, these concentrations do not factor in
issues such as regrowth or cross contamination, which might increase concentrations prior to
discharge. The estimated minimum net reduction for biocide disinfection (1 log) would generate
water containing approximately 17.4 CFU/100 ml. This would be sufficient to meet theE1. coli
limit. However, the system may be challenged to meet limits without disinfection in events
where ambient E.coli concentrations could be orders of magnitude higher. EPA was unable to
identify similar data for V. cholera and intestinal enterococci; however, it is reasonable to expect
these systems would reduce their concentrations by the same order of magnitude.  Therefore,
these systems are likely to meet the limits for both V. cholera (<1 CFU/100 ml) and intestinal
enterococci (<100 CFU/100 ml).

       In type-approved ballast water treatment systems, ballast water is commonly disinfected
using electrolysis and electrochlorination, whereby hypochlorite is generated by electrolytic
processes using seawater as the source of ions (IHS Maritime, 2013; ABS,  2011; USEPA,
201 Ib; Albert et al., 2010). Hypochlorite concentrations are measured as total residual oxidant
(TRO). Based on a review of applications for approval of more than 10 ballast water
management systems that make use of Active Substances (G9), EPA observed a range of active
substance dosages that were generally greater than 6 mg/L TRO but less than 12 mg/L TRO.
Free active chlorine stays in the water, continuing disinfection for several hours to several days,
depending on initial concentration and ballast water characteristics such as  salinity, temperature,
organic-matter content, motions of the vessel, and ballast tank and venting  system configuration
(USEPA, 20lib).

       Chlorine residual management for onboard PWGs emphasizes maintaining adequate
chlorine residual throughout the distribution system to prevent contamination. For example, the
United States Navy (United Sates Navy, 2005) requires chlorination (or bromination) to provide
at least 0.2 halogen residual after a 30-minute contact time. The Centers for Disease Control and
Prevention, Vessel Sanitation Program (voluntarily applicable to cruise ships), requires
continuous halogenation to maintain a free halogen of greater than 0.2 mg/L and less than 5
mg/L throughout the distribution system (CDC, 2011).

       The biocide disinfection systems that EPA identified for use in potable water generation
are typically configured by vessel operators because specific dosage requirements vary by water
source and operating conditions. These systems, however,  are capable of providing residual
concentrations that meet or exceed that of currently marketed ballast water treatment systems.
Therefore, it is likely that the treatment efficacy of these disinfection systems would be
comparable or more effective than currently available ballast water treatment systems, and thus
are likely to meet VGP effluent limits.
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as an Alternative Option for Meeting Ballast Water Discharge Limits        Systems for Ballast Water Generation

5.2.4   Physical Disinfection Treatment Mechanism and Expected Effect on Living
       Organisms

       UV radiation inactivates organisms by destroying the nucleic acids that make up their
genetic coding, thereby preventing them from replicating (USEPA, 2006). Nucleic acids absorb
UV light at wavelengths ranging from 200 to 300 nm, with peak absorption at about 260 nm
(USEPA, 2006; WHO, 2004).

       The effectiveness of UV radiation can be impaired  by poor water quality. Water sources
with high turbidity and particulate matter concentrations absorb or shield UV radiation, thus
reducing the UV intensity delivered directly to the organism. UV effectiveness is  further affected
by the type of organism, as some are more resistant than others. Generally, viruses are most
resistant to UV radiation, followed by bacteria, cryptosporidium oocysts, and Giardia cysts
(USEPA, 2006). Table 5-2 lists bacterial reductions reported in the literature for UV disinfection
at a given intensity and suggests UV disinfection systems typically achieve 1- to 4-log
reductions.

        Table 5-2. Reported Organism Reductions for Disinfection by UV Radiation
UV Intensity
(mJ/cm2)
20
0.65
3.0 to 8.4
6.7 to 8.4
2.2 to 2.9
Organism Reduction
99.99% (E. coli)
99.99% (F. cholera)
90 to 99.99% (E. coli)
99.9 to 99.99% (E. coli)
99.9 to 99.99% (F. cholera)
Source
WHO, 2004
WHO, 2004
USEPA, 2006
USAPHC, 2011
USAPHC, 2011
                   mJ - millijoules

       The reductions noted above occur in addition to what is achieved during RO or
distillation. The net reduction from RO and subsequent UV radiation is likely to range from 4 to
11 logs. For distillation and subsequent UV disinfection, EPA conservatively assumes reductions
will occur only during the disinfection step, yielding likely reductions of 1 to 4 logs.

       Assuming an E. coli concentration of 173.9 CFU/100 ml for U.S. waters, (Nieminksi and
Ballamy, 2000), using a combined RO-UV disinfection system would yield a minimum
reduction of 4 logs. This would generate water with approximately 0.02 CFU/100 ml, thus
meeting the VGP treatment limits. However, at its minimum, distillation/UV disinfection could
provide only a 1-log reduction. These systems would produce water  containing approximately
17.4 CFU/100 ml, which would be sufficient to meet the E.  coli limit. EPA was unable to
identify similar data for V. cholera and intestinal enterococci; however, it is reasonable to expect
these systems would reduce their concentrations by the same order of magnitude. Therefore,
these systems are likely to meet the limits for both V. cholera (<1 CFU/100 ml) and intestinal
enterococci (<100 CFU/100 ml).

       UV disinfection is the second most common disinfection technology used by type-
approved ballast water treatment  system  (fflS Maritime, 2013; ABS, 2011; USEPA, 201 Ib;
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as an Alternative Option for Meeting Ballast Water Discharge Limits       Systems for Ballast Water Generation

Albert et al., 2010). The major advantage of UV disinfection is that the technology does not
require using active substances and does not generate toxic byproducts. The major disadvantage
of UV disinfection is that turbidity in ballast water scatters or absorbs light rays and reduces
transmissivity, reducing the effectiveness of the treatment. Pretreatment,  such as filtration to
remove smaller particles, improves UV's performance; accordingly, all UV-based ballast water
treatment systems to date use front-end separation processes to improve UV transmission (Albert
etal.,2010).

       Type-approved ballast water treatment systems use one of two types of UV lamps. Low-
pressure UV lamps emit monochromatic UV radiation at 254 nm, which is close to the optimum
germicidal wavelength of 260 nm. Medium-pressure UV lamps emit polychromatic UV radiation
over a broad spectrum ranging from 200 to 400 nm, including wavelengths in the germicidal
range. The systems differ in energy efficiency, power rating, size, lamp service life, etc.;
however, both systems are highly effective for removing microorganisms and many larger
organisms when properly designed and operated. Because UV radiation does  not produce
residual oxidant, UV treatment is performed at both ballast water intake and discharge to  reduce
problems associated with bacterial regrowth or contamination (IHS Maritime, 2013; ABS, 2011).

       All of the UV disinfection systems EPA identified as being used for potable water
generation utilize low-pressure UV lamps. These lamps can provide UV treatment at levels that
are comparable to the UV lamps used in ballast water treatment systems. It is likely that the
treatment efficacy of PWG UV disinfection lamps and ballast water treatment system lamps
would be comparable.

5.2.5   Conclusions

       Based on the literature, it appears RO systems are likely to be highly effective at
removing living organisms, given that bacteria are, at a minimum, two orders of magnitude
larger than even the largest RO membrane filter pores. RO removal efficiency data suggest that
RO systems could yield 3- to 7-1 og reductions of V. cholera, E. coli, or intestinal enterococci. It
also is reasonable to expect that these systems would be highly effective against  larger
organisms, such as zooplankton and phytoplankton.

       The vacuum distillation technology found in PWG systems will likely treat zooplankton
and phytoplankton, yielding 90 to  100 percent reductions, but they may not be as effective in
removing bacteria given the lower operating temperatures generally associated with the
technology. EPA's review of available guides to ballast water treatment did not identify any
type-approved ballast water treatment systems that incorporate vacuum distillation.

       Literature values for organism reductions from disinfection with biocides indicate that
reductions of 85 to 100 percent, or approximately 1 to 5 logs, are likely. Reductions from
physical disinfection (i.e., UV) treatments are likely to range from 1 to 4 logs for microbiological
organisms. When coupled with reverse osmosis, the net reduction from PWG and subsequent
disinfection  is likely to reach 4 to 12 logs. However,  for vacuum  distillation systems, the net
reductions for microbiological organisms are expected to be lower, likely 1 to 4 logs since
treatment predominantly will occur during disinfection given the lower operating temperatures
generally associated with vacuum distillation systems.
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Feasibility and Efficacy of Using Potable Water Generators         Section 5-Efficacy of P WG and Disinfection
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       Applying these log values to the E. coli concentration reported by Nieminksi and
Ballamy (2000) shows that the RO-disinfection technology is capable of meeting VGP treatment
limits. EPA estimated a 4-1 og reduction minimum regardless of the disinfection system utilized
(i.e., biocides or UV radiation). Therefore, this technology is likely to generate ballast water
containing approximately 0.02 CFU/100 ml, which would meet the VGP treatment limit for E.
coli. EPA was unable to identify similar data for V.  cholera and intestinal enterococci; however,
it is reasonable to expect these systems would reduce their concentrations by the same order of
magnitude. Therefore, these systems would also meet the limits for both V. cholera (<1 CFU/100
ml) and intestinal enterococci  (<100 CFU/100 ml).

       The distillation-disinfection technology preliminarily appears capable of meeting VGP
discharge limits. As discussed above, the minimum organism reduction achievable through
biocides or UV  radiation technologies is one log. Applying this minimum to the E. coli
concentration reported by Nieminksi and Ballamy (2000) of 174 CFU/100 ml reveals that
distillation-disinfection systems would produce ballast water containing approximately 17.4
CFU/100 ml. This would meet the VGP treatment limit for El. coli. EPA was unable to identify
similar data for  V. cholera and intestinal enterococci; however, it is reasonable to expect these
systems would reduce their concentrations by the same order of magnitude. Therefore, these
systems would be likely to meet the limits for both  V. cholera (<1 CFU/100 ml) and intestinal
enterococci (<100 CFU/100 ml).

5.3    "PROOF OF CONCEPT" EVALUATION OF PWG-DISINFECTION SYSTEM EFFICACY

5.3.1   Background

       MERC is a state of Maryland initiative that provides test facilities, information, and
decision tools to address environmental issues facing the maritime industry. The Center's
primary focus is to evaluate ballast water treatment systems based on their mechanical and
biological efficacy and associated costs, as well as the economic impacts of ballast water
regulations and  management approaches.

       MERC,  in partnership  with MARAD and EPA, tested a PWG system using
methodologies generally consistent with EPA's Experimental Technology Verification (ETV)
Program ballast water protocols. The PWG used in  the proof of concept evaluation was an RO
system that generated approximately 12 gpm. The RO  system also included a media prefiltration
and chlorination system. The prefiltration system consisted of a multimedia granular filter bed
and bag and cartridge filters. Feed water was initially fed through a filter bed containing
anthracite, garnet, flint, sand, and gravel filter media. The filtrate then passed through a 5-\i filter
bag and, finally, a 10-|i cartridge filter. The filter sizes were intentionally configured in this
manner to maximize particulate filtration prior to the cartridge filter, reducing the frequency of
cartridge filter changes, which were labor intensive compared to bag filter changes. The water
was then pumped through the RO membrane and disinfected with a 12.5 percent sodium
hypochlorite solution (1 ppm dose). The pH of the water product was then neutralized by passing
the water through two calcite tanks.

       The PWG used a spiral-wound membrane filter made of a polyamide thin-film
composite.  The  filter membrane, manufactured by Dow Chemical Company, has an active
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Feasibility and Efficacy of Using Potable Water Generators         Section 5-Efficacy of P WG and Disinfection
as an Alternative Option for Meeting Ballast Water Discharge Limits        Systems for Ballast Water Generation

surface area of 440 ft2 (41 m2) and a salt rejection range of 99.65 to 99.80 percent. The
manufacturer has not assigned pore size values for individual membranes, but indicates a general
pore size range of 0.1 to 2.5 nm (Dow Chemical Company, 2013).

       To evaluate the performance characteristics of the PWG-chlorination system, MERC
conducted four biological efficacy trials at its mobile test platform in Baltimore Harbor, MD.
The trials focused on all EPA- and USCG-regulated taxonomic categories, including live
organisms >50 um; live organisms <50 um, but >10 um; and culturable organisms <10 um.
MERC also conducted whole effluent toxicity testing, chlorinated byproducts analyses, and
water quality analyses, including total suspended solids, particulate organic carbon, dissolved
organic carbon, and chlorophyll. The following section summarizes MERC's results, which
focus specifically on the taxonomic EPA- and USCG-regulated categories. Appendix C contains
a complete copy of MERC's report.

       Each of the four trials conducted by MERC occurred over five to six days. Over this
period, the PWG-chlorination system filled a test tank with a minimum of 150 m3 of potable
water, which was held in the tank until the end of the trial period. At the end of the period, the
potable water was discharged into Baltimore Harbor. During discharge, MERC collected
samples of the potable water using methods generally consistent with the EPA ETV protocol.
However, because the PWG provided significantly lower flow rates than a typical ballast water
treatment system, it was necessary to slightly modify certain elements of the standard ETV
testing protocols. Protocols and modifications are discussed in detail in Appendix C.

       During the proof of concept evaluation, the PWG-disinfection system encountered  an
unexpected system failure that prevented MERC from conducting the fifth and final trial. The
system failure was caused by ruptures in two of the three prefiltration media filtration vessels.
The evaluation was subsequently concluded and the system returned to the vendor. Upon
conducting a failure analysis, it was concluded that the ruptures were the result of a siphoning
effect that occurred within the media prefiltration discharge line during backwashing. The  siphon
created an unintended vacuum leading upstream to the media prefiltration tanks and exerted
sufficient vacuum pressure to rupture them (ERG, personal communications, July 1, 2014).

       Typically, the vendor installs a vacuum breaker on the discharge line to prevent
appreciable buildups in vacuum pressure.  The vendor noted that most of their units include
vacuum breakers; however, the specific older unit provided did not. Given that the system  failure
is specific to the unit, and that the vendor noted most other units include a vacuum breaker, EPA
believes that the system failure is likely a case-specific occurrence that is not representative of
performance expectations for PWG-disinfection systems in general. See MERC discussion in
Appendix C for additional  discussion.

5.3.2   Summary of Results

       This section summarizes the key results for PWG treatment efficacy for living organisms.
Appendix C provides a detailed summary and discussion of these, and other results.  These
results, reproduced in Table 5-3, indicate the PWG-chlorination system produced potable water
containing almost no living organisms >50 um; no  detectable living organisms <50 um, but >10
um; and no culturable organisms <10 um. E. coli and enterococci concentrations were below 1
                                          5-12

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                      Section 5-Efficacy of P WG and Disinfection
                                                           Systems for Ballast Water Generation
CFU/100 ml, while no colonies of V. cholera were detected. The residual total chlorine measured
during discharge sampling ranged from 0.09 to 0.14 mg/1 ฑ 0.03 mg/1. Please see Appendix C for
a complete background of the MERC facility, description of methods and results, and additional
discussion regarding the proof of concept testing.

   Table 5-3. MERC Evaluation Results for Key Parameters Related to PWG Treatment
                             Efficacy for Living Organisms
Trial
ID
PW-1
PW-2
PW-3
PW-4
LO,
>50jim
(cells/m3)
0.14
0
0
0
LO,
>10to
<50 jim
(cells/ml)
BDL
BDL
BDL
BDL
THE
(cells/10 ml)
0
0
0
0
E. coli
(CFU/
100 ml)
ND
<1
<1
<1
Enterococci
(CFU/
100 ml)
<1
<1
<1
<1
V. cholera
(No. of
colonies)
0
0
0
0
Total
Chlorine
(mg/1)
0.10 ฑ0.01
ND
0.14 ฑ0.01
0.09 ฑ0.02
      BDL - Below detection limit (0.04 cells/ml)
      LO - Live organisms
      ND - No data
      THE - Total heterotrophic bacteria

5.3.3   Conclusions

       The proof of concept evaluation demonstrated that PWG-chlorination systems are
capable of meeting each of the VGP numeric discharge limits. The tested system reduced the
presence of organism to levels well below that required by the VGP limitations. The potable
water discharge,  however, contained residual chlorine at or slightly above the maximum ballast
water effluent limit for residual biocides (i.e., 0.1 mg/L for total residual chlorine (TRC))
contained  in the VGP. However, these concentrations were below the EVIO limit of 0.2 mg/L for
TRC. This suggests that vessels would need to monitor TRC concentrations in their ballast water
tanks and adjust chlorine dosing accordingly to ensure compliance with the limit when
deballasting, or apply a neutralizing agent.

       It is important to note that although the evaluation demonstrated the capability of PWGs
to meet VGP  numeric limits, subsequent contamination downstream of the PWG could cause
vessel discharges to exceed those limits. For example, microorganisms could reside and grow
within the ballast system,  where, depending on water conditions and residence times,
microorganism levels could increase and even exceed the numeric limits upon discharge. This
suggests that vessel owners/operators may need to monitor discharges to ensure compliance with
the limits or implement measures to avoid contamination, such as those required at Part
2.2.3.5.1.3 of the VGP for vessels using public supply water for ballast (i.e., clean ballast tanks
and supply lines and never subsequently introduce them to ambient water).

5.4     COMPARISON OF PWG-DISINFECTION SYSTEM TREATMENT EFFICACIES AGAINST 2013
       VGP NUMERIC TREATMENT LIMITS

       EPA's literature search for existing information on PWG treatment efficacy data for
organisms did not yield information specific to zooplankton, phytoplankton, Vibrio cholera,  E.
                                          5-13

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Feasibility and Efficacy of Using Potable Water Generators         Section 5-Efficacy of P WG and Disinfection
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co//', or intestinal enterococci. However, values reported in the literature for other organisms
provide a preliminary indication that PWG systems may reduce pathogens and other organisms
sufficient to meet the VGP numeric limitations for ballast water discharges.

       Subsequent technology-specific engineering assessments indicated that PWG and
disinfection systems can conceptually reduce organism concentrations to levels below those
required by the VGP. The analysis indicated that RO systems are likely to be highly effective at
removing V. cholera, E. coli, and intestinal enterococci. It also appears that these systems would
be highly effective against larger organisms such as zooplankton and phytoplankton. Distillation-
based PWG systems will  likely treat zooplankton and phytoplankton; however, they may not
treat bacteria. Subsequent disinfection will yield additional organism reductions. Combined, the
net reduction achieved  from PWGs and their subsequent disinfection systems is likely to be 4 to
12 logs.

       The proof of concept evaluation demonstrated the capability of an RO-based PWG-
chlorination system to meet and exceed the VGP numeric discharge limits. Table 5-4 compares
the evaluation results to the EPA and USCG numeric limits. As the table shows,  the system
generated potable water with organism levels that were well below their respective limits. These
evaluation results corroborate the conclusions drawn from the literature and engineering
assessment, and further suggest that these systems are likely to be highly effective at reducing
organism concentrations.

     Table 5-4. Comparison of Numeric Ballast Water Discharge Limits against MERC
                                   Evaluation Results
Taxonomic Classification
Organisms >50 um
Organisms <50 um, but >10 um
EPA and USCG
Numeric Limit
<10 organisms/m3
<10 organisms/ml
Evaluation Results
(Range)
Oto0.14cells/m3
Below limit of detection
(O.04 cell/ml)
Organisms <10 um
Toxicogenic V. cholera
E. coli
Intestinal enterococci
<1 CFU/100 ml
<200 CFU/100 ml
<100 CFU/100 ml
No colonies detected
<1 CFU/100 ml
<1 CFU/100 ml
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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                  Section 6-Conclusions

                                                                        SECTION 6
    CONCLUSIONS REGARDING THE FEASIBILITY OF USING
	PWGS FOR BALLAST OPERATIONS

       The largest driver of PWG feasibility is a vessel's required ballasting rate. The vessels
evaluated by EPA had ballast rates ranging from approximately 155 to 800 gpm. In contrast, the
maximum PWG production rate identified by EPA did not exceed 400 gpm. Only 5 percent of
the PWGs reviewed by EPA are capable of producing water within the range of vessel ballast
rates.  The remaining 95 percent can produce water only at or below 30 gpm. A direct comparison
of vessel ballasting and PWG production rates indicates that using PWGs as an all-purpose
ballast water management alternative is not likely to be feasible without also utilizing other
ballasting management strategies (e.g., internal ballasting, public water supply water),
particularly for vessels requiring ballasting at a rate of hundreds of gallons per minute.

       Although PWGs cannot feasibly support the ballasting needs of all vessels, there appear
to be  several applications where using a PWG may be feasible. For example, it may be feasible
for vessels to use PWGs to compensate for fuel burn off. EPA estimated fuel burn rates for
various types of vessels ranging from 0.3 to 18.3 gpm, well within the water production range
achievable with PWGs.

       EPA considered whether other feasibility issues would arise, such as during PWG
retrofitting into existing vessels or installation into new vessels. The retrofit case studies that
EPA conducted on a research vessel, a towboat, and a fast support vessel demonstrated that it
was feasible to retrofit PWGs and disinfection systems into all three vessels, and that the PWG
could provide sufficient water to meet ballasting needs associated with fuel burn off
compensation. The case studies also indicated that system weight and power requirements are
feasible, as the weight and electrical load differentials were negligible (0.03 to 0.1 percent of
total weight, and 0.2 to 1 percent of total electrical capacity). The costs associated with retrofits
or installations do not appear to be prohibitive; total capital investment costs ranged from
approximately $53,000 to $67,200, while annual O&M costs ranged from approximately $2,600
to $4,400 per year  (assuming 365 days per year).

       EPA's parametric design data analysis suggests that the case study results apply to other
types  of vessels beyond those immediately covered in the case studies. In general, it appears
feasible to retrofit or install PWG units into research vessels, towboats, and  small overnight
passenger vessels. However, it may be more challenging to retrofit or install PWG units  into
tugboats, offshore support vessels, and many fishing vessels.

       Finally, EPA, in partnership with MARAD and MERC, evaluated the ability of a PWG
system to reduce the concentration of living organisms in the discharge, including whether the
discharge would be at or below the numeric ballast water discharge limits in the 2013 VGP.
EPA's review of existing literature and engineering assessment suggest that PWGs can reduce
organism concentrations to the concentrations at or below those required by the VGP. The proof
of concept evaluation led by MERC provided land-based testing results, generally consistent
with the ETV protocols, which demonstrated the capability of an RO-based PWG-chlorination
system to produce potable water that meets the VGP limits. The results of the evaluation
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Feasibility and Efficacy of Using Potable Water Generators
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indicated that resulting organism concentrations were below the numeric limits contained in
EPA's 2013 VGP.
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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                   Section 7-References

                                                                     SECTION 7
	REFERENCES

ABS (American Bureau of Shipping). 2011. Ballast Water Treatment Advisory, (www.eagle.org/
       eagleExternalPortalWEB/ShowPropertv/BEA%20Repositorv/References/ABS%20Advis
       ories/BWTreatmentAdv).

ABS. 2014a. ABS Eagle Record Online Database, IMO Number 8517009.
       (www.eagle.org/safenet/record/record vesselsearch).

ABS. 2014b. ABS Eagle Record Online Database, IMO Number 9270335.
       (www.eagle.org/safenet/record/record vesselsearch).

ABS. 2014c. ABS Eagle Record Online Database, EVIO Number 9145205.
       (www.eagle.org/safenet/record/record vesselsearch).

Albert, R., R. Everett, J. Lishman, and D.  Smith. 2010. Availability and Efficacy of Ballast
       Water Treatment Technology: Background and Issue Paper. Prepared for EPA Science
       Advisory Board (June).

Allied Transportation Company. 2012. Comments on Vessel General Permit for Discharges
       Incidental to the Normal Operation of Vessels. EPA Comment Number EPA-HQ-OW-
       2011-0141-0539-A2.

Anonymous. 2012. Comments on Vessel General Permit for Discharges Incidental to the Normal
       Operation of Vessels. EPA Comment Number EPA-HQ-OW-2011-0141-0495-A1.

APA, FLC, and GFF (At-sea Processors Association, Freezer Longline Coalition, and
       Groundfish Forum). 2012. Comments on Vessel General Permit for Discharges Incidental
       to the Normal Operation of Vessels. EPA Comment Number EPA-HQ-OW-2011-0141-
       0504-Al.

Aquafides. No date. The Electro-Katadyn Method - Disinfection and Conservation of Water
       with Silver Ions, (http://katadvnch.vs31.snowflakehosting.ch/fileadmin/user  upload/
       aquafides/Downloads/Flyer_Elektro_Katadyn_EN_web.pdf).

Argosy Cruises. 2008. Comments on Vessel General Permit for Discharges Incidental to the
       Normal Operation of Vessels. EPA Comment Number EPA-HQ-OW-2008-0055-0289.

Argosy Cruises. 2012. Our Fleet, (www.argosycruises.com/general/fleet.cfm).

ARTCO (American River Transportation Co.). 2012. Comments on Vessel General Permit for
       Discharges Incidental to the Normal Operation of Vessels. EPA Comment Number EPA-
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                                        7-1

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                   Section 7-References

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BMT Fleet Technology.  2002. Ballast Water Treatment Evaluation Using Copper and Sodium
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                                         7-2

-------
Feasibility and Efficacy of Using Potable Water Generators
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Chowning, L. 2013a. Ala. Yard Building Combo Boat; Buy Boats Still Earn Their Keep.
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Chowning, L. 2014b. Florida Yard Turns Out Scallopers; Oyster Company Offers Boat Tours.
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                                         7-3

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                   Section 7-References

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                                          7-4

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                   Section 7-References

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Kruithof, J.C., J.C. Schippers, P.C. Kamp, H.C. Folmer, and J.A.M.H. Hofman. 1998. Integrated
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LUMCON (Louisiana Universities Marine Consortium). No date. R/V Pelican - Oceanographic
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Maryland's Pride. 2008. Comments on Vessel General Permit for Discharges Incidental to the
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McCollin, T. and A. Shanks. 2003. Biological Assessment, Phytoplankton Results, DTR-3.7.2-
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MEPC (Marine Environment Protection Committee). 2010. Harmful Aquatic Organisms in
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      25).
                                         7-5

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                   Section 7-References

MESB (Michigan Environmental Science Board). 2002. Critical Review of a Ballast Water
       Biocides Treatment Demonstration Project Using Copper and Sodium Hypochlorite,
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Mountfort, D., T. Dodgshun, and M. Taylor. 2001. Ballast Water Treatment by Heat - New
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                                         7-6

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                   Section 7-References

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                                          7-7

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                   Section 7-References

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                                         7-8

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                   Section 7-References

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                                          7-9

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                     APPENDIX A:

     TECHNICAL SPECIFICATIONS FOR PWG AND DISINFECTION SYSTEMS

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-l. PWG Weights and Physical Dimensions
System Technology
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Vendor No.
Vendor 1
Vendor 1
Vendor 1
Vendor 1
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor
System No.
System 1
System 2
System 3
System 4
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 11
System 12
Production Rate (gpm)
Min
2.9
4.6
0.6
1.3
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
7.3
11.0
1.1
4.6
0.1
0.1
0.2
0.3
0.4
0.6
0.7
1.0
1.4
2.1
3.1
4.6
5.5
7.3
9.2
11.0
7.3
11.0
1.8
3.7
5.6
7.3
9.0
Weight
(Ib)
1,808
2,006
1,543
1,676
140
140
160
160
160
200
230
240
—
—
—
1,222
2,222
3,111
3,333
4,222
6,000
6,444
1,100
1,200
3,100
3,200
3,300
Dimensions (ft)
Height
4.5
4.5
4.5
4.5
2.0
2.0
2.0
2.0
2.0
2.0
2.0
4.3
—
—
—
4.6
3.9
5.6
5.6
6.6
7.9
9.2
3.6
4.6
5.6
5.6
5.6
Width
2.8
2.8
2.8
2.8
1.7
1.7
1.7
1.7
1.7
1.7
1.7
2.0
—
—
—
4.3
5.2
5.2
5.2
5.2
5.9
5.9
4.3
4.3
5.3
5.3
5.3
Depth
5.8
7.1
3.8
4.5
2.0
2.0
1.7
1.7
1.7
1.7
1.7
2.0
—
—
—
5.2
5.6
7.9
7.9
7.9
10.5
10.5
5.2
5.3
7.9
7.9
7.9
Volume
(ft3)
73.4
90.0
48.3
56.7
6.7
6.7
5.6
5.6
5.6
5.6
5.6
17.3
—
—
—
102.8
115.3
230.5
230.5
271.2
488.2
569.6
80.8
104.8
234.5
234.5
234.5
                                                                     A-l

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-l. PWG Weights and Physical Dimensions
System Technology
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor
System No.
System 13
System 14
System 15
System 16
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 1
System 2
System 3
System 4
System 5
System 6
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
11.1
5.0
8.3
11.7
8.3
12.5
16.7
20.8
25.0
1.0
2.1
3.1
4.2
5.2
6.3
2.0
2.7
0.4
0.8
1.3
1.5
5.5
7.3
9.2
11.0
13.8
14.7
Weight
(Ib)
3,700
10,000
15,000
18,000
1,260
1,350
1,460
1,550
1,650
560
590
620
650
680
700
250
265
145
155
165
165
1,650
1,950
6,544
6,544
5,420
5,070
Dimensions (ft)
Height
6.6
9.6
9.6
9.6
2.6
2.6
2.6
2.6
2.6
2.3
2.3
2.3
2.3
2.3
2.3
5.0
5.0
4.0
4.0
4.0
4.0
6.1
6.1
6.1
12.7
13.0
13.0
Width
5.3
9.7
9.7
9.7
8.3
8.3
8.3
8.3
8.3
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.0
2.0
2.0
2.0
4.0
4.0
4.0
5.0
5.3
5.3
Depth
7.9
7.3
7.3
7.3
5.3
5.3
5.3
5.3
5.3
5.1
5.1
5.1
5.1
5.1
5.1
4.0
4.0
1.5
1.5
1.5
1.5
3.5
3.5
3.5
5.3
7.7
7.9
Volume
(ft3)
276.3
671.6
671.6
671.6
114.8
114.8
114.8
114.8
114.8
24.8
24.8
24.8
24.8
24.8
24.8
43.3
43.3
12.3
12.3
12.3
12.3
85.2
85.2
85.2
332.5
531.6
548.9
                                                                     A-2

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-l. PWG Weights and Physical Dimensions
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor
System No.
System 7
System 8
System 9
System 10
System 11
System 12
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 19
System 20
System 21
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
17.2
22.0
36.7
55.0
78.0
128.8
0.8
1.3
0.2
0.3
0.4
0.6
0.8
1.3
0.4
1.3
1.7
2.2
3.0
3.8
5.2
6.6
6.9
8.7
11.1
13.2
15.6
Weight
(Ib)
10,234
6,520
6,800
7,160
8,830
11,298
184
199
144
150
159
174
192
207
177
398
416
421
529
572
655
724
—
—
—
—
—
Dimensions (ft)
Height
15.0
19.3
19.6
19.6
23.8
26.7
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Width
6.7
7.5
5.0
5.0
6.7
8.3
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Depth
9.0
7.0
6.7
6.7
7.3
7.5
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Volume
(ft3)
900.0
1,015.0
652.8
652.8
1,161.1
1,666.7
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
                                                                     A-3

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-l. PWG Weights and Physical Dimensions
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Distillation
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 7
Vendor 7
Vendor 7
Vendor 7
Vendor 7
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor
System No.
System 22
System 23
System 24
System 25
System 26
System 27
System 28
System 1
System 2
System 3
System 4
System 5
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 11
System 12
System 13
System 14
System 15
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
20.8
24.0
26.7
29.9
7.6
13.2
16.7
1.7
2.5
3.3
4.2
5.0
2.1
4.2
5.6
6.9
10.4
13.9
18.3
21.9
185
100
75
60
45
30
19
Weight
(Ib)
—
—
—
—
—
—
—
1,333
1,371
1,391
1,427
1,447
1,200
1,900
2,500
2,600
3,000
3,500
4,700
5,800
5,900
3,500
3,200
3,200
2,400
2,200
1,800
Dimensions (ft)
Height
—
—
—
—
—
—
—
4.7
4.7
4.7
4.7
4.7
1.3
5.0
5.0
5.0
5.5
5.5
5.5
5.5
7.4
7.4
7.4
7.4
6.0
6.0
5.7
Width
—
—
—
—
—
—
—
4.5
4.5
4.5
5.4
5.4
3.9
9.6
9.6
9.6
11.0
11.0
11.0
11.3
25.8
14.0
14.0
14.0
14.0
14.0
10.0
Depth
—
—
—
—
—
—
—
4.6
4.6
4.6
4.6
4.6
2.1
5.0
5.0
5.0
5.0
5.5
5.5
6.0
6.0
2.7
2.7
2.7
2.7
2.7
2.7
Volume
(ft3)
—
—
—
—
—
—
—
94.9
94.9
94.9
114.3
114.3
10.9
239.6
239.6
239.6
302.5
332.8
332.8
371.3
1,149.6
276.9
276.9
276.9
224.0
224.0
151.1
                                                                     A-4

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-l. PWG Weights and Physical Dimensions
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Vendor No.
Vendor 8
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor
System No.
System 16
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 19
System 1
System 2
System 3
System 4
System 5
System 6
System 7
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
7
0.3
0.4
0.6
0.8
0.4
0.7
1.0
1.4
1.8
2.5
3.1
3.7
4.7
5.7
6.9
9.7
18.1
27.8
55.6
0.1
0.4
0.8
1.4
2.1
2.6
3.5
Weight
(Ib)
1,100
170
180
200
210
295
321
321
360
520
551
580
820
900
980
1,060
1,300
3,200
—
—
125
250
410
625
970
2,100
2,250
Dimensions (ft)
Height
5.7
1.8
1.8
1.8
1.8
1.5
1.5
1.5
1.8
1.9
1.9
2.4
2.6
2.6
2.6
—
2.6
—
8.0
7.7
1.9
2.2
2.6
2.6
3.7
5.4
5.4
Width
9.2
4.0
4.2
4.2
4.4
4.3
4.6
4.6
4.6
5.0
5.1
5.1
9.0
9.0
9.0
—
9.7
10.2
19.0
18.6
0.9
1.7
1.8
2.0
2.4
o o
J.J
3.5
Depth
2.7
1.8
1.8
1.8
1.8
2.8
2.8
2.8
2.8
2.5
2.5
2.5
3.8
3.8
3.8
—
5.0
10.3
8.2
9.5
1.7
3.0
3.6
4.5
4.3
4.6
4.6
Volume
(ft3)
138.5
12.7
13.4
13.3
13.9
18.2
19.2
18.6
22.8
23.9
24.7
30.9
87.9
89.5
89.5
—
124.0
—
1,253.8
1,361.7
2.9
10.8
17.0
23.3
38.4
80.7
86.9
                                                                     A-5

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-l. PWG Weights and Physical Dimensions
System Technology
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor
System No.
System 8
System 9
System 10
System 11
System 12
System 13
System 14
System 15
System 16
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
5.2
7.6
10.4
0.7
1.4
2.1
2.8
3.5
4.2
1.9
2.5
2.9
3.6
4.3
4.7
1.9
2.5
2.9
3.6
4.3
4.7
4.5
8.3
11.1
13.2
16.0
8.3
Weight
(Ib)
2,900
4,800
5,600
340
375
435
480
525
580
—
—
—
—
—
—
—
—
—
—
—
—
1,900
2,100
2,200
2,400
2,400
3,700
Dimensions (ft)
Height
5.7
5.7
6.3
5.5
5.5
5.5
5.5
5.5
5.5
4.9
4.9
4.9
4.9
4.9
4.9
2.7
2.7
2.7
2.7
2.7
2.7
4.1
4.1
4.1
4.1
4.1
5.5
Width
3.7
4.2
5.4
2.3
2.8
2.8
2.8
2.8
2.8
2.4
2.4
2.4
2.4
2.4
2.4
4.6
4.6
4.6
4.6
4.6
4.6
6.4
6.4
6.4
6.4
6.4
13.2
Depth
6.8
7.7
7.9
2.2
2.2
2.8
2.8
2.8
2.8
2.4
2.4
2.4
2.4
2.4
2.4
2.4
2.4
2.4
2.4
2.4
2.4
3.8
3.8
3.8
3.8
3.8
6.2
Volume
(ft3)
142.0
181.0
271.6
26.8
32.8
42.9
42.9
42.9
42.9
28.7
28.7
28.7
28.7
28.7
28.7
29.5
29.5
29.5
29.5
29.5
29.5
98.3
98.3
98.3
98.3
98.3
450.7
                                                                     A-6

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-l. PWG Weights and Physical Dimensions
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor
System No.
System 19
System 20
System 21
System 22
System 23
System 24
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 19
System 20
System 21
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
15.6
19.5
27.1
32.5
32.5
36.0
5.6
8.3
11.1
16.7
22.2
33.3
44.4
50.0
66.7
77.8
94.4
116.7
136.1
155.6
175.0
194.4
220.1
291.7
347.2
0.3
0.5
Weight
(Ib)
4,000
4,300
4,800
5,400
5,400
6,300
2,600
2,600
2,700
3,200
4,200
5,600
6,500
12,000
13,000
14,000
15,000
17,500
17,500
17,200
18,000
19,000
21,000
21,000
22,000
220
230
Dimensions (ft)
Height
5.5
5.5
5.5
5.5
5.5
5.5
10.0
13.3
16.3
13.3
16.3
23.3
16.3
23.3
23.3
29.2
23.3
29.2
29.2
29.2
29.2
29.2
29.2
29.2
29.2
4.3
4.3
Width
13.2
13.2
13.2
13.2
13.2
13.2
3.5
3.5
5.0
5.0
6.0
6.0
6.0
6.0
6.0
6.0
6.0
6.0
6.0
6.0
6.0
6.0
7.1
7.1
7.1
1.8
1.8
Depth
6.2
6.2
6.2
6.2
6.2
6.2
6.0
6.0
6.0
6.0
6.0
6.0
6.0
6.7
6.7
6.7
6.7
6.7
6.7
6.6
6.6
6.6
6.7
6.7
6.8
2.5
2.5
Volume
(ft3)
450.7
450.7
450.7
450.7
450.7
450.7
210.0
280.0
487.5
400.0
585.0
840.0
585.0
933.3
933.3
1,166.7
933.3
1,166.7
1,166.7
1,152.1
1,152.1
1,152.1
1,377.3
1,377.3
1,394.5
18.6
18.6
                                                                     A-7

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-l. PWG Weights and Physical Dimensions
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor
System No.
System 22
System 23
System 24
System 25
System 26
System 27
System 28
System 29
System 30
System 3 1
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
0.3
0.3
—
0.3
Max
0.7
0.9
0.8
1.5
2.1
2.6
3.3
3.9
4.2
5.3
0.3
0.4
0.6
0.8
1.0
3.5
15.3
0.3
0.6
0.8
1.0
2.8
1.7
—
1.7
Weight
(Ib)
250
290
395
500
360
500
750
850
970
1,050
96
103
110
121
134
500
2,000
80
92
103
115
250
250
250
250
Dimensions (ft)
Height
4.3
4.3
5.1
5.1
5.1
5.1
5.1
5.1
5.1
5.1
1.0
1.0
1.0
1.0
1.0
1.8
1.8
—
—
—
—
1.2
1.2
1.2
1.2
Width
1.8
1.8
2.8
2.8
2.8
2.8
2.8
2.8
2.8
2.8
2.0
2.0
2.0
2.0
2.0
3.5
3.5
—
—
—
—
2.2
2.2
2.2
2.2
Depth
2.5
2.5
4.2
4.2
4.2
4.2
4.2
4.2
4.2
4.2
1.2
1.2
1.2
1.2
1.2
2.7
2.7
—
—
—
—
1.5
1.5
1.5
1.5
Volume
(ft3)
18.6
18.6
60.0
60.0
60.0
60.0
60.0
60.0
60.0
60.0
2.3
2.3
2.3
2.3
2.3
17.1
17.1
—
—
—
—
3.9
3.9
3.9
3.9
                                                                     A-8

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Vendor No.
Vendor 1
Vendor 1
Vendor 1
Vendor 1
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor
System No.
System 1
System 2
System 3
System 4
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 11
System 12
Production Rate (gpm)
Min
2.9
4.6
0.6
1.3
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
7.3
11.0
1.1
4.6
0.1
0.1
0.2
0.3
0.4
0.6
0.7
1.0
1.4
2.1
3.1
4.6
5.5
7.3
9.2
11.0
7.3
11.0
1.8
3.7
5.6
7.3
9.0
Heat Input
Requirement
(kW)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
750
1,050
1,400
1,750
2,100
1,000
1,400
350
525
1,050
1,400
1,750
Heat Input
Requirement
(BTU/hr)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
2,559,000
3,583,000
4,777,000
5,971,000
7,165,000
3,412,000
4,777,000
1,194,000
1,791,000
3,583,000
4,777,000
5,971,000
Electrical Requirements
Voltage
(V)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Amperage
(A)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Power
(kW)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
                                                                   A-9

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor
System No.
System 13
System 14
System 15
System 16
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 1
System 2
System 3
System 4
System 5
System 6
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
11.1
5.0
8.3
11.7
8.3
12.5
16.7
20.8
25.0
1.0
2.1
3.1
4.2
5.2
6.3
2.0
2.7
0.4
0.8
1.3
1.5
5.5
7.3
9.2
11.0
13.8
14.7
Heat Input
Requirement
(kW)
2,100
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Heat Input
Requirement
(BTU/hr)
7,165,000
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Electrical Requirements
Voltage
(V)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Amperage
(A)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Power
(kW)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
11
19
19
19
21
22
                                                                  A-10

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor
System No.
System 7
System 8
System 9
System 10
System 11
System 12
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 19
System 20
System 21
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
17.2
22.0
36.7
55.0
78.0
128.8
0.8
1.3
0.2
0.3
0.4
0.6
0.8
1.3
0.4
1.3
1.7
2.2
3.0
3.8
5.2
6.6
6.9
8.7
11.1
13.2
15.6
Heat Input
Requirement
(kW)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Heat Input
Requirement
(BTU/hr)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Electrical Requirements
Voltage
(V)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Amperage
(A)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Power
(kW)
26
28
49
100
140
180
2.3
2.3
1.5
1.5
1.5
1.5
2.3
2.3
2.3
3.1
4.6
6.5
6.5
6.5
8.4
8.4
15.3
15.3
15.3
15.3
15.3
                                                                  A-ll

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Distillation
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 7
Vendor 7
Vendor 7
Vendor 7
Vendor 7
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor
System No.
System 22
System 23
System 24
System 25
System 26
System 27
System 28
System 1
System 2
System 3
System 4
System 5
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
20.8
24.0
26.7
29.9
7.6
13.2
16.7
1.7
2.5
3.3
4.2
5.0
2.1
4.2
5.6
6.9
10.4
13.9
18.3
21.9
185
100
75
60
45
30
19
Heat Input
Requirement
(kW)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Heat Input
Requirement
(BTU/hr)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Electrical Requirements
Voltage
(V)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Amperage
(A)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Power
(kW)
30.5
30.5
30.5
30.5
30.5
30.5
30.5
—
—
—
—
—
7.5
10
16.5
20
22
40
40
48
—
—
—
—
—
—
~
                                                                  A-12

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 8
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor
System No.
System 16
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
Production Rate (gpm)
Min
—









Max
7
0.3
0.4
0.6
0.8
0.4
0.7
1.0
1.4
1.8
Heat Input
Requirement
(kW)
—









Heat Input
Requirement
(BTU/hr)
—









Electrical Requirements
Voltage
(V)
—
110,
220
110,
220
110,
220
110,
220
110,
220,
230,
380,
460
110,
220,
230,
380,
460
110,
220,
230,
380,
460
110,
220,
230,
380,
460
230,
380,
460
Amperage
(A)
—
18.7,
9.3
18.7,
9.3
25.4,
12.7
25.4,
12.7
13.6,
6.8,
6.8,
4.1,
3.4
23.7,
11.9,
11.6,
7.0,
5.8
23.7,
11.9,
11.6,
7.0,
5.8
23.7,
11.9,
11.6,
7.0,
5.8
27.2,
16.5,
13.6
Power
(kW)
—
2.1
2.1
2.8
2.8
1.5
2.6
2.6
2.6
6.3
                                                                  A-13

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Vendor No.
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor
System No.
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 19
System 1
System 2
System 3
System 4
System 5
System 6
Production Rate (gpm)
Min








—
—
—
—
—
—
—
—
Max
2.5
3.1
3.7
4.7
5.7
6.9
9.7
18.1
27.8
55.6
0.1
0.4
0.8
1.4
2.1
2.6
Heat Input
Requirement
(kW)








—
—






Heat Input
Requirement
(BTU/hr)








—
—
75,000
250,000
500,000
832,000
1,250,000
1,430,000
Electrical Requirements
Voltage
(V)
230,
380,
460
230,
380,
460
230,
380,
460
230,
380,
460
230,
380,
460
230,
380,
460
230,
380,
460
230,
380,
460
—
—
—
—
—
—
—
—
Amperage
(A)
27.2,
16.5,
13.6
27.2,
16.5,
13.6
47.2,
28.6,
23.6
47.2,
28.6,
23.6
74.8,
45.3,
37.4
74.8,
45.3,
37.4
74.8,
45.3,
37.4
145.2,
87.9,
72.6
—
—
—
—
—
—
—
—
Power
(kW)
6.3
6.3
10.9
10.9
17.2
17.2
17.2
33.4
—
—
0.8
2.9
2.9
6.5
6.5
0.6
                                                                  A-14

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor
System No.
System 7
System 8
System 9
System 10
System 11
System 12
System 13
System 14
System 15
System 16
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
3.5
5.2
7.6
10.4
0.7
1.4
2.1
2.8
3.5
4.2
1.9
2.5
2.9
3.6
4.3
4.7
1.9
2.5
2.9
3.6
4.3
4.7
4.5
8.3
11.1
13.2
16.0
Heat Input
Requirement
(kW)




—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Heat Input
Requirement
(BTU/hr)
1,950,000
2,900,000
4,250,000
5,800,000
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Electrical Requirements
Voltage
(V)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Amperage
(A)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Power
(kW)
0.6
1.6
1.6
1.6
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
                                                                  A-15

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor
System No.
System 18
System 19
System 20
System 21
System 22
System 23
System 24
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 19
System 20
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Max
8.3
15.6
19.5
27.1
32.5
32.5
36.0
5.6
8.3
11.1
16.7
22.2
33.3
44.4
50.0
66.7
77.8
94.4
116.7
136.1
155.6
175.0
194.4
220.1
291.7
347.2
0.3
Heat Input
Requirement
(kW)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Heat Input
Requirement
(BTU/hr)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Electrical Requirements
Voltage
(V)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Amperage
(A)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Power
(kW)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
                                                                  A-16

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor
System No.
System 21
System 22
System 23
System 24
System 25
System 26
System 27
System 28
System 29
System 30
System 3 1
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—








	
Max
0.5
0.7
0.9
0.8
1.5
2.1
2.6
3.3
3.9
4.2
5.3
0.3
0.4
0.6
0.8
1.0
3.5
15.3
0.3
0.6
Heat Input
Requirement
(kW)
—
—
—
—
—
—
—
—
—
—
—








	
Heat Input
Requirement
(BTU/hr)
—
—
—
—
—
—
—
—
—
—
—








	
Electrical Requirements
Voltage
(V)
—
—
—
—
—
—
—
—
—
—
—
115,
230
115,
230
115,
230
115,
230
115,
230
208,
230,
460
190,
380,
400
115,
230
115,
230
Amperage
(A)
—
—
—
—
—
—
—
—
—
—
—
14.0,
7.0
14.0,
7.0
14.0,
7.0
16.6,
8.3
20.8,
10.4


14.0,
7.0
14.0,
7.0
Power
(kW)
—
—
—
—
—
—
—
—
—
—
—
1.61
1.61
1.61
1.91
2.39


1.6
1.6
                                                                  A-17

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                            Table A-2. PWG Heat and Power Requirements
System Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor
System No.
System 10
System 1 1
System 12
System 13
System 14
System 15
Production Rate (gpm)
Min


0.3
0.3

0.3
Max
0.8
1.0
2.8
1.7

1.7
Heat Input
Requirement
(kW)






Heat Input
Requirement
(BTU/hr)






Electrical Requirements
Voltage
(V)
115,
230
115,
230
115,
230
230
208,
230,
460
208,
230,
460
Amperage
(A)
16.6,
8.3
20.8,
10.4
12.8,
6.4
13.2
9,
8.6,
4.3
15,
13.2,
6.6
Power
(kW)
1.9
2.4
1.5
3.0
1.9
3.1
                                                                  A-18

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                  Table A-3. PWG Equipment, Installation, and Annual O&M Costs
System
Technology
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Vendor No.
Vendor 1
Vendor 1
Vendor 1
Vendor 1
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 2
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor
System No.
System 1
System 2
System 3
System 4
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
Production Rate (gpm)
Min
2.9
4.6
0.6
1.3
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Max
7.3
11.0
1.1
4.6
0.1
0.1
0.2
0.3
0.4
0.6
0.7
1.0
1.4
2.1
3.1
4.6
5.5
7.3
9.2
11.0
7.3
11.0
1.8
3.7
5.6
7.3
9.0
Equipment
Cost
—
—
—
—
$4,975
$5,575
$6,350
$6,750
$7,450
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Installation
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Annual
O&M Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Notes



























                                                                  A-19

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                  Table A-3. PWG Equipment, Installation, and Annual O&M Costs
System
Technology
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 3
Vendor 3
Vendor 3
Vendor 3
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 4
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor
System No.
System 13
System 14
System 15
System 16
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 1
System 2
System 3
System 4
System 5
System 6
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Max
11.1
5.0
8.3
11.7
8.3
12.5
16.7
20.8
25.0
1.0
2.1
3.1
4.2
5.2
6.3
2.0
2.7
0.4
0.8
1.3
1.5
5.5
7.3
9.2
11.0
13.8
14.7
Equipment
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Installation
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Annual
O&M Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Notes



























                                                                  A-20

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                  Table A-3. PWG Equipment, Installation, and Annual O&M Costs
System
Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 5
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor
System No.
System 7
System 8
System 9
System 10
System 1 1
System 12
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 19
System 20
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—
~
Max
17.2
22.0
36.7
55.0
78.0
128.8
0.8
1.3
0.2
0.3
0.4
0.6
0.8
1.3
0.4
1.3
1.7
2.2
3.0
3.8
5.2
6.6
6.9
8.7
11.1
13.2
Equipment
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
$73,000
—
—
Installation
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—
~
Annual
O&M Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
$2, 190 to
$7,300
—
—
Notes























Assumed to be 3 to 10% of
equipment cost.


                                                                  A-21

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                   Table A-3. PWG Equipment, Installation, and Annual O&M Costs
System
Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Distillation
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 6
Vendor 7
Vendor 7
Vendor 7
Vendor 7
Vendor 7
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor
System No.
System 21
System 22
System 2 3
System 24
System 2 5
System 26
System 27
System 2 8
System 1
System 2
System 3
System 4
System 5
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
Production Rate (gpm)
Min

—
—
—

—
—
—

—
—
—

—
—
—
—
—
—
—
—
—
—
—
—
Max
15.6
20.8
24.0
26.7
29.9
7.6
13.2
16.7
1.7
2.5
o o
J.J
4.2
5.0
2.1
4.2
5.6
6.9
10.4
13.9
18.3
21.9
185
100
75
60
Equipment
Cost
$95,000
—
—
—
$152,845
—
—
—
$30,000 to
$50,000
—
—
—
$45,000 to
$50,000
—
—
—
—
—
—
—
—
—
—
—
—
Installation
Cost

—
—
—

—
—
—
$10,000 to
$15,000
—
—
—
$50,000 to
$100,000
—
—
—
—
—
—
—
—
—
—
—
—
Annual
O&M Cost
$2,850 to
$9,500



$4,585 to
$15,285
—
—
—

—
—
—

—
—
—
—
—
—
—
—
—
—
—
—
Notes
Assumed to be 3 to 10% of
equipment cost.



Assumed to be 3 to 10% of
equipment cost.




















                                                                  A-22

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                   Table A-3. PWG Equipment, Installation, and Annual O&M Costs
System
Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Distillation
Distillation
Distillation
Distillation
Vendor No.
Vendor 8
Vendor 8
Vendor 8
Vendor 8
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 9
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor
System No.
System 13
System 14
System 15
System 16
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 19
System 1
System 2
System 3
System 4
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—
—
~
Max
45
30
19
7
0.3
0.4
0.6
0.8
0.4
0.7
1.0
1.4
1.8
2.5
3.1
3.7
4.7
5.7
6.9
9.7
18.1
27.8
55.6
0.1
0.4
0.8
1.4
Equipment
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
$10,600
—
—
—
Installation
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—
—
~
Annual
O&M Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
$212
—
—
—
Notes























Assumed to be 2% of
equipment cost.



                                                                  A-23

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                   Table A-3. PWG Equipment, Installation, and Annual O&M Costs
System
Technology
Distillation
Distillation
Distillation
Distillation
Distillation
Distillation
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 10
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor
System No.
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
Production Rate (gpm)
Min
—

—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Max
2.1
2.6
3.5
5.2
7.6
10.4
0.7
1.4
2.1
2.8
3.5
4.2
1.9
2.5
2.9
3.6
4.3
4.7
1.9
2.5
2.9
3.6
4.3
4.7
4.5
8.3
11.1
Equipment
Cost
—
$100,000
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Installation
Cost
—

—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Annual
O&M Cost
—
$2,000
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Notes

Assumed to be 2% of
equipment cost.

























                                                                  A-24

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                   Table A-3. PWG Equipment, Installation, and Annual O&M Costs
System
Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 1 1
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor
System No.
System 16
System 17
System 18
System 19
System 20
System 21
System 22
System 2 3
System 24
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 15
System 16
System 17
System 18
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Max
13.2
16.0
8.3
15.6
19.5
27.1
32.5
32.5
36.0
5.6
8.3
11.1
16.7
22.2
33.3
44.4
50.0
66.7
77.8
94.4
116.7
136.1
155.6
175.0
194.4
220.1
291.7
Equipment
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Installation
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Annual
O&M Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Notes



























                                                                  A-25

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                  Table A-3. PWG Equipment, Installation, and Annual O&M Costs
System
Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 12
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor
System No.
System 19
System 20
System 21
System 22
System 2 3
System 24
System 2 5
System 26
System 27
System 2 8
System 2 9
System 30
System 3 1
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
Production Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—

—

—
—
—
—
Max
347.2
0.3
0.5
0.7
0.9
0.8
1.5
2.1
2.6
o o
J.J
3.9
4.2
5.3
0.3
0.4
0.6
0.8
1.0
3.5
15.3
0.3
0.6
0.8
1.0
Equipment
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
$11,000
—
$37,000
—
—
—
—
Installation
Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
$4,000 to
$8,000
—
$10,000
—
—
—
—
Annual
O&M Cost
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
$450 to
$570
—
$1,410
—
—
—
—
Notes

















Assumed to be 3% of
equipment and installation
costs.

Assumed to be 3% of
equipment and installation
costs.




                                                                  A-26

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                                  Table A-3. PWG Equipment, Installation, and Annual O&M Costs
System
Technology
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Reverse Osmosis
Vendor No.
Vendor 13
Vendor 13
Vendor 13
Vendor 13
Vendor
System No.
System 12
System 13
System 14
System 15
Production Rate (gpm)
Min
0.3
0.3
—
0.3
Max
2.8
1.7
—
1.7
Equipment
Cost


—
..
Installation
Cost


—
..
Annual
O&M Cost


—
..
Notes




                                                                  A-27

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                       Table A-4. Disinfection System Power Requirements, Weights, and Physical Dimensions
System
Technology
Ultraviolet
Ultraviolet
Electro-Katadyn
Electro-Katadyn
Electro-Katadyn
Electro-Katadyn
Electro-Katadyn
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
Vendor No.
Vendor 14
Vendor 14
Vendor 15
Vendor 15
Vendor 15
Vendor 15
Vendor 15
Vendor 16
Vendor 16
Vendor 16
Vendor 16
Vendor 16
Vendor 16
Vendor 16
Vendor 16
Vendor 16
Vendor
System No.
System 1
System 2
System 1
System 2
System 3
System 4
System 5
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
Disinfection
Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
80.0
80.0
80.0



Max
13.2
66.0
35.2
70.4
105.7
140.9
211.3
—
—
—
3,960
3,960
3,960
15,000
15,000
15,000
Power
(W)
—
—
40
40
40
40
40
45
45
—


—



Weight
(lb)
23.2
—
18.7
41.6
42.4
43.3
44.9
19.0
28.0
36.0
26.0
34.0
40.0
14.0
22.0
28.0
Dimensions (ft)
Height
1.8
—
1.6
2.0
2.0
2.0
2.0
1.5
1.8
2.3
1.0
1.4
2.3
1.0
1.4
2.3
Width
1.4
—
0.2
0.5
0.5
0.5
0.5
1.0
1.2
1.7
1.5
1.7
1.7
1.7
1.7
1.7
Depth
0.5
—
0.2
0.5
0.5
0.5
0.5
1.3
1.6
2.0
1.5
1.7
1.7
2.0
2.0
2.0
Volume
(ft3)
1.3
—
0.1
0.4
0.4
0.4
0.4
2.0
3.8
7.6
2.3
4.0
6.3
3.3
4.8
7.6
Notes










Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.

Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
                                                                 A-28

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                       Table A-4. Disinfection System Power Requirements, Weights, and Physical Dimensions
System
Technology
Chlorination
Chlorination
Chlorination
Ultraviolet
Ultraviolet
Ultraviolet
Bromination
Bromination
Bromination
Bromination
Bromination
Bromination
Bromination
Bromination
Chlorination
Chlorination
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Vendor No.
Vendor 16
Vendor 16
Vendor 17
Vendor 17
Vendor 17
Vendor 17
Vendor 18
Vendor 18
Vendor 18
Vendor 18
Vendor 18
Vendor 18
Vendor 18
Vendor 18
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor
System No.
System 10
System 1 1
System 1
System 2
System 3
System 4
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 1
System 2
System 3
System 4
System 5
System 6
Disinfection
Rate (gpm)
Min
70.0
1.0
528.3
3.5
17.6
28.6
16.0
—
—
—
15.0
0.7
8.4
8.4
—
—
—
—
—
~
Max
42,000
158,500
2,641.7
5.3
28.2
45.3
35.0
19.0
19.0
19.0
25.0
8.3
16.0
16.0
—
—
13.2
26.4
39.6
70.4
Power
(W)


37
90
90
180
—
—
—
—
—
—
—
—
—
—
30
80
130
200
Weight
(lb)
70.0
70.0
22.1
4.4
52.9
55.1
44.0
119.0
133.0
141.0
45.0
30.0
37.0
141.0
—
—
—
—
—
—
Dimensions (ft)
Height
2.9
2.9

3.1
2.7
2.7
2.3
3.7
3.7
3.7
2.3
—
—
—
2.4
3.1
3.2
3.2
3.2
4.1
Width
3.3
3.3

0.7
1.6
1.6
3.1
1.2
1.2
1.2
2.0
—
—
—
—
—
0.7
0.8
0.8
1.2
Depth
2.0
2.0

0.7
1.0
1.0
1.3
1.7
1.7
1.7
0.7
—
—
—
—
—
0.7
0.7
0.7
1.0
Volume
(ft3)
19.3
19.3

1.6
4.4
4.4
8.7
7.2
7.2
7.2
3.1
—
—
—
—
—
1.6
1.8
1.8
4.8
Notes
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.

















                                                                 A-29

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                       Table A-4. Disinfection System Power Requirements, Weights, and Physical Dimensions
System
Technology
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Chlorination
Electro-Katadyn
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Vendor No.
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor
System No.
System 7
System 8
System 9
System 10
System 11
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
Disinfection
Rate (gpm)
Min
—
—
—
—
—
—
—
—
—
—
—
—
—
—
2.6
3.7
7.1
11.0
15.2
24.7
38.1
52.6
Max
—
—
—
—
—
—
—
—
—
—
—
—
—
66.0
6.2
8.7
20.2
30.7
55.0
69.9
106.1
190.2
Power
(W)
300
400
600
600
800
900
1,200
1,800
2,400
3,000
3,600
4,500
—
—
35






290
Weight
(lb)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
33.1






55.1
Dimensions (ft)
Height
5.6
4.3
5.6
4.3
4.3
5.6
4.3
6.2
6.2
6.2
6.2
6.2
—
—







	
Width
—
—
—
—
—
—
—
—
—
—
—
—
—
—







	
Depth
—
—
—
—
—
—
—
—
—
—
—
—
—
—







	
Volume
(ft3)
—
—
—
—
—
—
—
—
—
—
—
—
—
—







	
Notes














Vendor claims UV dosage of 36,000
W-s/cm2.
Vendor claims UV dosage of 36,000
W-s/cm2.
Vendor claims UV dosage of 36,000
W-s/cm2.
Vendor claims UV dosage of 36,000
W-s/cm2.
Vendor claims UV dosage of 36,000
W-s/cm2.
Vendor claims UV dosage of 36,000
W-s/cm2.
Vendor claims UV dosage of 36,000
W-s/cm2.
Vendor claims UV dosage of 36,000
W-s/cm2.
                                                                 A-30

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                       Table A-4. Disinfection System Power Requirements, Weights, and Physical Dimensions
System
Technology
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Vendor No.
Vendor 21
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor
System No.
System 1
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 11
System 12
System 13
System 14
System 15
System 16
System 17
System 18
System 19
System 20
System 21
System 22
System 23
System 24
System 25
System 26
Disinfection
Rate (gpm)
Min
88.1
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Max
735.3
5.3
11.9
15.9
19.8
22.5
26.4
35.1
61.6
88.0
132.1
176.1
286.2
352.2
594.4
880.6
1,100.7
1,519.0
242.2
308.2
484.3
660.4
968.6
1,408.9
1,805.2
2,421.6
2,993.9
Power
(W)
—
30
40
40
80
80
480
120
160
200
320
400
480
640
800
960
1,200
1,440
600
750
900
1,200
1,500
1,800
2,250
2,700
3,300
Weight
(lb)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Dimensions (ft)
Height
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Width
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Depth
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Volume
(ft3)
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
~
Notes



























                                                                 A-31

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
                       Table A-4. Disinfection System Power Requirements, Weights, and Physical Dimensions
System
Technology
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
Chlorination
Vendor No.
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 23
Vendor 23
Vendor 23
Vendor 23
Vendor 23
Vendor 23
Vendor
System No.
System 27
System 28
System 29
System 30
System 3 1
System 32
System 3 3
System 34
System 1
System 2
System 3
System 4
System 5
System 6
Disinfection
Rate (gpm)
Min
—
—
—
—
—
—
—
—
45.8
137.5
45.8
137.5
45.8
137.5
Max
176.1
396.3
572.4
1,100.7
1,541.0
2,201.4
3,302.2
5,283.4
916.7
2,775.0
916.7
2,775.0
916.7
2,775.0
Power
(W)
—
—
—
—
—
—
—
—






Weight
(lb)
—
—
—
—
—
—
—
—
18.0
18.0
27.0
27.0
35.0
35.0
Dimensions (ft)
Height
—
—
—
—
—
—
—
—
1.6
1.6
2.1
2.1
3.1
3.1
Width
—
—
—
—
—
—
—
—
1.7
1.7
1.7
1.7
1.7
1.7
Depth
—
—
—
—
—
—
—
—
1.7
1.7
1.7
1.7
1.7
1.7
Volume
(ft3)
—
—
—
—
—
—
—
—
4.8
4.8
6.1
6.1
9.1
9.1
Notes








Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
Disinfection capacity will depend on
solution strength and chloride dosing.
Estimate assumes use of 12% sodium
hypochlorite solution dosed at 2 ppm.
                                                                 A-32

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs
System
Technology
Ultraviolet
Ultraviolet
Electro-
Katadyn
Electro-
Katadyn
Electro-
Katadyn
Electro-
Katadyn
Electro-
Katadyn
Chlorination
Chlorination
Chlorination
Chlorination
Vendor No.
Vendor 14
Vendor 14
Vendor 1 5
Vendor 1 5
Vendor 15
Vendor 15
Vendor 1 5
Vendor 16
Vendor 16
Vendor 16
Vendor 16
Vendor
System No.
System 1
System 2
System 1
System 2
System 3
System 4
System 5
System 1
System 2
System 3
System 4
Disinfection
Rate (gpm)
Min
__
__





__
__
__
80.0
Max
13.2
66.0
35.2
70.4
105.7
140.9
211.3
__
__
__
3,960
Expected Life of Consumables
Bromination
(gal/cartridge)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Ultraviolet
(hr/lamp)
	
	
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Elect ro-
Katadyn
(gal/anode)
N/A
N/A
1,056,690
1,056,690
1,056,690
1,056,690
1,056,690
N/A
N/A
N/A
N/A
Equipment
Cost
__
__





__
__
__

Installation
Cost
__
__





__
__
__

Annual
O&M
Cost
	
	





—
—
—

Notes
	
	
Anode life: 4,000 m3 at 0.05
ppmAg+; 2,0000m3 at 0.1
ppm Ag+
Anode life: 4,000 m3 at 0.05
ppm Ag+; 2,0000m3 at 0.1
ppm Ag+
Anode life: 4,000 m3 at 0.05
ppm Ag+; 2,0000 m3 at 0.1
ppmAg+
Anode life: 4,000 m3 at 0.05
ppm Ag+; 2,0000m3 at 0.1
ppmAg+
Anode life: 4,000 m3 at 0.05
ppm Ag+; 2,0000m3 at 0.1
ppm Ag+
—
—
—
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
                                                                 A-33

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs



System
Technology








Chlorination








Chlorination








Chlorination




Vendor No.








Vendor 16








Vendor 16








Vendor 16



Vendor
System No.








System 5








System 6








System 7
Disinfection
Rate (gpm)


Min








80.0








80.0








-


Max








3,960








3,960








15,000

Expected Life of Consumables

Bromination
(gal/cartridge)








N/A








N/A








N/A

Ultraviolet
(hr/lamp)








N/A








N/A








N/A
Elect ro-
Katadyn
(gal/anode)








N/A








N/A








N/A



Equipment
Cost








—








—








-



Installation
Cost








—








—








-


Annual
O&M
Cost








—








—








-




Notes
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
                                                                A-34

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs



System
Technology








Chlorination








Chlorination








Chlorination




Vendor No.








Vendor 16








Vendor 16








Vendor 16



Vendor
System No.








System 8








System 9








System 10
Disinfection
Rate (gpm)


Min








—








—








70.0


Max








15,000








15,000








42,000

Expected Life of Consumables

Bromination
(gal/cartridge)








N/A








N/A








N/A

Ultraviolet
(hr/lamp)








N/A








N/A








N/A
Elect ro-
Katadyn
(gal/anode)








N/A








N/A








N/A



Equipment
Cost








—








—








-



Installation
Cost








—








—








-


Annual
O&M
Cost








—








—








-




Notes
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
                                                                A-35

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs
System
Technology
Chlorination
Chlorination
Ultraviolet
Ultraviolet
Ultraviolet
Bromination
Bromination
Bromination
Vendor No.
Vendor 16
Vendor 17
Vendor 17
Vendor 17
Vendor 17
Vendor 18
Vendor 18
Vendor 18
Vendor
System No.
System 1 1
System 1
System 2
System 3
System 4
System 1
System 2
System 3
Disinfection
Rate (gpm)
Min
1.0
528.3
3.5
17.6
28.6
16.0


Max
158,500
2,641.7
5.3
28.2
45.3
35.0
19.0
19.0
Expected Life of Consumables
Bromination
(gal/cartridge)
N/A
N/A
N/A
N/A
N/A
55,000
55,000
55,000
Ultraviolet
(hr/lamp)
N/A
N/A
9,000
9,000
9,000
N/A
N/A
N/A
Elect ro-
Katadyn
(gal/anode)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Equipment
Cost


	
	
—
$6,577
$13,278

Installation
Cost


	
	
—



Annual
O&M
Cost


	
	
—



Notes
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
	
	
—
Cartridge life assumes Br
dosing at 1 ppm. Equipment
cost is $6,577 for 16- to 24-
gpm and 25- to 35-gpm
units. Vendor estimated
installation cost is assumed
to be 10 to 15% of
equipment cost. Each
cartridge costs $108.
Cartridge life assumes Br
dosing at 1 ppm; each
cartridge costs $108.
Cartridge life assumes Br
dosing at 1 ppm; each
cartridge costs $108.
                                                                A-36

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs
System
Technology
Bromination
Bromination
Bromination
Bromination
Bromination
Chlorination
Chlorination
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Vendor No.
Vendor 18
Vendor 18
Vendor 18
Vendor 18
Vendor 18
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor 19
Vendor
System No.
System 4
System 5
System 6
System 7
System 8
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 1 5
Disinfection
Rate (gpm)
Min

15.0
0.7
8.4
8.4
__
__
__
__
__
__
__
__
__
__
__
__
—
—
—
Max
19.0
25.0
8.3
16.0
16.0
__
__
13.2
26.4
39.6
70.4
—
—
	
	
	
	
—
—
—
Expected Life of Consumables
Bromination
(gal/cartridge)
55,000
55,000
55,000
55,000
55,000
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Ultraviolet
(hr/lamp)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
—
—
—
—
—
—
	
	
	
	
—
—
—
Elect ro-
Katadyn
(gal/anode)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Equipment
Cost


$5,392

$19,311
__
__
__
__
__
__
__
__
__
__
__
__
—
—
—
Installation
Cost





__
__
__
__
__
__
__
__
__
__
__
__
—
—
—
Annual
O&M
Cost





__
__
__
__
__
__
__
__
__
__
__
__
—
—
—
Notes
Cartridge life assumes Br
dosing at 1 ppm; each
cartridge costs $108.
Cartridge life assumes Br
dosing at 1 ppm; each
cartridge costs $108.
Cartridge life assumes Br
dosing at 1 ppm; each
cartridge costs $108.
Cartridge life assumes Br
dosing at 1 ppm; each
cartridge costs $108.
Cartridge life assumes Br
dosing at 1 ppm; each
cartridge costs $108.
__
__
__
__
__
__
__
__
__
__
__
__
—
—
—
                                                                A-37

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs
System
Technology
Ultraviolet
Ultraviolet
Ultraviolet
Chlorination
Electro-
Katadyn
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Vendor No.
Vendor 19
Vendor 19
Vendor 19
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor 20
Vendor
System No.
System 16
System 17
System 18
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
Disinfection
Rate (gpm)
Min
__
__
__


2.6
3.7
7.1
11.0
15.2
24.7
Max
	
	
	

66.0
6.2
8.7
20.2
30.7
55.0
69.9
Expected Life of Consumables
Bromination
(gal/cartridge)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Ultraviolet
(hr/lamp)
	
	
	
N/A
N/A






Elect ro-
Katadyn
(gal/anode)
N/A
N/A
N/A
N/A

N/A
N/A
N/A
N/A
N/A
N/A
Equipment
Cost
__
__
__
$13,560
$4,300
$2,550


$3,550


Installation
Cost
__
__
__
$1,356
$430
$225


$355


Annual
O&M
Cost
	
	
	








Notes
	
	
	
Installation cost is assumed
to be 10% of equipment
cost.
Vendor estimated
installation cost is assumed
to be 10% of equipment
cost. Each anode costs $980.
Vendor estimated
installation cost is assumed
to be 10% of equipment
cost.
Vendor estimated
installation cost is assumed
to be 10% of equipment
cost.
Vendor estimated
installation cost is assumed
to be 10% of equipment
cost.
Vendor estimated
installation cost is assumed
to be 10% of equipment
cost.
Vendor estimated
installation cost is assumed
to be 10% of equipment
cost.
Vendor estimated
installation cost is assumed
to be 10% of equipment
cost.
                                                                A-38

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs
System
Technology
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Vendor No.
Vendor 20
Vendor 20
Vendor 21
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor
System No.
System 9
System 10
System 1
System 1
System 2
System 3
System 4
System 5
System 6
System 7
System 8
System 9
System 10
System 1 1
System 12
System 13
System 14
System 1 5
System 16
System 17
System 18
System 19
Disinfection
Rate (gpm)
Min
38.1
52.6
88.1
—
—
—
—
—
—
—
—
	
	
	
	
	
—
—
—
—
—
—
Max
106.1
190.2
735.3
5.3
11.9
15.9
19.8
22.5
26.4
35.1
61.6
88.0
132.1
176.1
286.2
352.2
594.4
880.6
1,100.7
1,519.0
242.2
308.2
Expected Life of Consumables
Bromination
(gal/cartridge)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Ultraviolet
(hr/lamp)


—
—
—
—
—
—
—
—
—
	
	
	
	
	
—
—
—
—
—
—
Elect ro-
Katadyn
(gal/anode)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Equipment
Cost

$6,100
__
__
__
__
__
__
__
__
__
__
__
__
__
__
—
—
—
—
—
—
Installation
Cost

$610
__
__
__
__
__
__
__
__
__
__
__
__
__
__
—
—
—
—
—
—
Annual
O&M
Cost


__
__
__
__
__
__
__
__
__
__
__
__
__
__
—
—
—
—
—
—
Notes
Vendor estimated
installation cost is assumed
to be 10% of equipment
cost.
Vendor estimated
installation cost is assumed
to be 10% of equipment
cost.
__
__
__
__
__
__
__
__
__
__
__
__
__
__
—
—
—
—
—
—
                                                                A-39

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs
System
Technology
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Ultraviolet
Chlorination
Vendor No.
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 22
Vendor 23
Vendor
System No.
System 20
System 21
System 22
System 23
System 24
System 25
System 26
System 27
System 28
System 29
System 30
System 3 1
System 32
System 33
System 34
System 1
Disinfection
Rate (gpm)
Min
	
	
	
—
—
—
—
—
—
—
—
—
—
—
—
45.8
Max
484.3
660.4
968.6
1,408.9
1,805.2
2,421.6
2,993.9
176.1
396.3
572.4
1,100.7
1,541.0
2,201.4
3,302.2
5,283.4
916.7
Expected Life of Consumables
Bromination
(gal/cartridge)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Ultraviolet
(hr/lamp)
	
	
	
—
—
—
—
—
—
—
—
—
—
—
—
N/A
Elect ro-
Katadyn
(gal/anode)
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Equipment
Cost
	
	
	
—
—
—
—
—
—
—
—
—
—
—
—
$674
Installation
Cost
	
	
	
—
—
—
—
—
—
—
—
—
—
—
—

Annual
O&M
Cost
	
	
	
—
—
—
—
—
—
—
—
—
—
—
—

Notes
	
	
	
—
—
—
—
—
—
—
—
—
—
—
—
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
                                                                A-40

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs


System
Technology


Chlorination


Chlorination


Vendor No.


Vendor 23


Vendor 23


Vendor
System No.


System 2


System 3
Disinfection
Rate (gpm)

Min


137.5


45.8

Max


2,775.0


916.7

Expected Life of Consumables

Bromination
(gal/cartridge)


N/A


N/A

Ultraviolet
(hr/lamp)


N/A


N/A
Elect ro-
Katadyn
(gal/anode)


N/A


N/A


Equipment
Cost





$712


Installation
Cost





	

Annual
O&M
Cost





	


Notes
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
                                                                A-41

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix A
         Table A-5. Expected Life of Disinfection System Consumables and Equipment, Installation, and Annual O&M Costs



System
Technology








Chlorination








Chlorination








Chlorination




Vendor No.








Vendor 23








Vendor 23








Vendor 23



Vendor
System No.








System 4








System 5








System 6
Disinfection
Rate (gpm)


Min








137.5








45.8








137.5


Max








2,775.0








916.7








2,775.0

Expected Life of Consumables

Bromination
(gal/cartridge)








N/A








N/A








N/A

Ultraviolet
(hr/lamp)








N/A








N/A








N/A
Elect ro-
Katadyn
(gal/anode)








N/A








N/A








N/A



Equipment
Cost








—








—








$765



Installation
Cost








—








—








--


Annual
O&M
Cost








—








—








--




Notes
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
O&M activities replace
pump tube per year, clean
out point of injection.
Disinfection capacity will
depend on solution strength
and chloride dosing.
Estimate assumes use of
12% sodium hypochlorite
solution dosed at 2 ppm.
    N/A - Not Applicable
                                                                 A-42

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                    APPENDIX B:

                  SUMMARIES OF INFORMATION GATHERED IN
              TELEPHONE CONVERSATIONS WITH PWG VENDORS

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix B
INTRODUCTION

       EPA contacted eight vendors for information about their potable water generation or
disinfection systems. This included technical specifications, costs, and their overall perspective
on the feasibility of using PWGs as a source of ballast water. The summaries are presented by
interview date. EPA has not identified vendors by name, instead using their corresponding
vendor numbers from Appendix A.

VENDOR 13 (APRIL 3,2012)

       The vendor believed that it could be feasible to use RO systems as a source of ballast
water. As an example of this potential, the vendor indicated that seagoing tugs typically generate
1,500 gal/day of potable water and that factory ships generate 10,000 to 100,000 gal/day.
However, the vendor also indicated that the generation rate of potable water would depend on the
space available onboard the vessel. For example, while oil platforms can produce millions of
gallons of potable water per day, the equipment used to generate that amount of water likely
would not fit into small vessels. For vessels of about 300 GRT, the vendor believed that a
realistic size for an RO  system would be about 5,000 gal/day, while for larger commercial
vessels the upper limit would be roughly 25,000 gal/day.

       When asked if there were any specific features that would make RO systems
technologically or economically infeasible, the vendor indicated that their systems could be
retrofitted into tugs or fishing boats with relative ease. The vendor also pointed out that many of
their systems are installed on vessels that do not already have preexisting RO systems installed
onboard.

       In terms of energy demand, the vendor commented that, as a general rule of thumb, RO
systems require roughly 1 hp to generate 1,000 gal/day of potable water. The vendor also
mentioned that RO systems draw their power directly from vessel generators powered by vessel
engines.

       The vendor provided cost information for RO systems (Table B-l). The vendor estimated
annual O&M costs to be roughly 3 percent of equipment and installation costs. The vendor could
not provide an estimate for energy-related costs, as the vendor believes there are too many
factors to allow for accurate estimation.  The vendor also indicated that systems generating more
than 10,000 gal/day would need to be custom built. Systems producing more than 20,000-gal/day
would require specialized equipment, such as multistage centrifugal units. Annual O&M costs
for these systems could be as great as 10 percent of equipment and installation costs.

    Table B-l. Summary of Vendor's Equipment, Installation, and Annual O&M Costs
Capacity
(gal/day)
1,500
10,000
Equipment Cost
$11,000
$37,000
Installation Cost
$4,000 to $8,000
$10,000
Annual
O&M Cost
$450 to $570
$1,410
             Note: For each system, annual O&M cost is assumed to be 3% of equipment and
             installation costs.
                                          B-2

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                           Appendix B

       If RO systems were used solely for ballasting purposes and not for potable water
production, then filtration requirements could be reduced to allow for greater water production
rates.  The vendor noted that water temperature would affect generation rates. For example, a
temperature drop from 70 to 30ฐF would reduce production rates by roughly half.

       When asked about how RO  and distillation systems compare, the vendor indicated that
the overall size and maintenance requirements of distillation systems would make them a bigger
commitment. The vendor also indicated that distillation system maintenance would be more
expensive due to scaling and fouling.

       The vendor commented that despite their potential drawbacks, the vendor believes
distillation systems would be a great alternative for vessels that generate a lot of waste heat.
However, the vendor also noted that vessels are becoming more energy-efficient, meaning less
waste heat would be available to power distillation systems. Because of this trend, the vendor
believes vessels are using RO systems to a greater extent than in the past.

       For RO systems, the potable water recovery is roughly 10 to 40 percent of the total
volume processed by the system. The remaining 60 to 90 percent is brine discharge containing a
salt concentration of roughly 40,000 ppm.

VENDOR 7 (APRIL 3,2012)

       The vendor believes PWG feasibility would depend on the size of the vessel.  Larger
commercial vessels (e.g., cargo tankers and boat carriers) could use such a large volume of water
that it would be difficult for distillation-based systems to keep up with ballasting demands. In
such cases, vessels most likely would be incapable of supplying sufficient waste heat to the
evaporator. The vendor estimated that vacuum distillation could produce 30 to 50 tons/day of
potable water, although they only manufacture units capable of producing 10 to 30 tons/day.

       The vendor noted that distillation systems use waste heat provided by vessel engines;
they do not use dedicated heat sources such as boilers. The vendor also noted that the overall
design of older vessels might not allow for efficient use of waste heat, making the potential for
distillation systems less promising.  Also, smaller and newer vessels  are likely to generate
insufficient waste heat, either because their engines operate more efficiently or because the
evaporator must share the waste heat with other units (e.g., super or turbo chargers).

       With regard to deck space requirements, the vendor indicated that distillation systems can
be retrofitted into small vessels easily, and that their systems frequently are sold as retrofits. The
vendor estimated that units capable of producing  1 to 5 tons/day of potable water could be
retrofitted into smaller vessels such as tugs or fishing vessels. Units producing 100 or more
tons/day  could be retrofitted into larger commercial vessels.

       The vendor provided cost information for distillation systems (Table B-2). Based on the
vendor's estimates, the cost of purchasing and installing a distillation system would range from
$40,000 to $150,000, depending on the overall production capacity of the system and the level of
effort required to install the system. The vendor was unable to provide O&M cost estimates.
                                           B-3

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                           Appendix B

           Table B-2. Summary of Vendor's Equipment and Installation Costs
Capacity
(tons/day)
10
30
Equipment Cost
$30,000 to $50,000
$45,000 to $50,000
Installation Cost
$10,000 to $15,000
$50,000 to $100,000
       According to the vendor, the U.S. market is favoring RO systems over distillation. To this
extent, the vendor estimated that 70 percent of U.S. vessels use RO systems while the remaining
30 percent use distillation systems. The vendor also noted that distillation systems are becoming
less common because vessels operate more efficiently, resulting in less available waste heat to
supply to distillation systems.

VENDOR 9 (APRIL 3,2012)

       The vendor stated that RO systems could provide 400 to several hundreds of thousands of
gallons per day. However,  the production capacity would depend on what a vessel could
accommodate. The vendor estimated that RO units  producing 400 gal/day would be roughly the
size of a microwave appliance, while the largest units would occupy a space equivalent to four
automobiles parked side-by-side.

       The vendor referred EPA to the company's website for literature specifying typical
energy demands for RO systems. The vendor was unable to provide specific information on
capital or O&M costs.

VENDOR 1 (APRIL 3 AND 5,2012)

       The vendor does not believe it would be feasible for vessels to ballast using onboard
PWGs. For large vessels (i.e., tankers or cruises), the vendor estimated that they generate
roughly 20 to 25 ton/day of potable water. Cruise ships would need to produce roughly 400 to
500 ton/day of potable water to replace spent fuel. Given the significant difference, the vendor
believes that it would be difficult for large vessels to produce water at rates that would be
adequate for ballasting.

       The vendor also commented that compared to RO systems, distillation systems would not
be feasible for small vessels. For a hypothetical ballasting rate of 20 gpm, the required
distillation system would not fit into a small vessel. Furthermore, small vessels would not be able
to provide sufficient waste heat to power the systems.

       On large vessels, the vendor does not expect the size of the distillation system to be an
issue because it would be smaller than the alternative (i.e., ballast water treatment systems).
However, the vendor does  not believe that distillation systems can produce potable water at rates
adequate for meeting ballasting needs.

       The vendor estimated that generating potable water at a rate of 10 ton/day would require
300 kW of waste heat. For a 300-GRT vessel, the vendor does not believe this would be an issue,
as they generate roughly 2,000 kW, of which 1,000 kW is waste heat.  The vendor expects that
1,600-GRT vessels would generate roughly 4 to 5 MW of power, of which 60 to 70 percent is
waste heat (i.e., 2.4 to 3.5 MW).
                                          B-4

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix B
       The vendor was unable to provide information on capital or O&M costs.

VENDOR 10 (APRIL 4,2012)

       The vendor believes using distillation systems for ballasting could be feasible depending
on the overall ballasting rates required. The vendor noted that their distillation systems only
support a production capacity of 200 to 50,000 gal/day.

       The vendor provided characteristic weights, dimensions, and energy requirements for the
200- and 7,500-gal/day distillation systems (Table B-3). The corresponding energy requirements
range from 75,000 to 2,900,000 BTU/hr. The vendor noted that engine waste heat powers the
distillation systems, rather than dedicated heat sources (i.e., boilers).

            Table B-3. Summary of Vendor's Distillation System Specifications
Capacity
(gal/day)
200
7,500
Weight
(Ib)
125
2,900
Dimensions,
L x W x H (in)
20x11x23
82 x 44 x 68
Energy
Requirement
(BTU/hr)
75,000
2,900,000
       The vendor also provided the equipment and O&M cost estimates in Table B-4. The cost
of purchasing a distillation system would range from $10,600 to $100,000. The vendor estimated
annual O&M costs would be roughly 2 percent of the equipment cost, yielding an annual O&M
cost ranging from $212 and $2,000. The vendor could not provide cost estimates for system
installation.

              Table B-4. Summary of Vendor's Equipment and O&M Costs
Unit Capacity
(gal/day)
200
7,500
Equipment
Cost
$10,600
$100,000
Annual
O&M Cost
$212
$2,000
                    Note: For each system, annual O&M cost is assumed to be 2%
                    of equipment cost.

       The vendor noted that the feasibility of retrofitting distillation systems into an existing
vessel would depend on engine room accessibility. If a vessel's engine room were equipped with
access doors, the system could be loaded into the vessel with relative ease. However, if engine
room access is limited,  it would be necessary to cut hole into the hull of the vessel to load the
distillation system into  the engine room.

       The vendor also commented that RO systems typically are used in vessels that cannot
generate sufficient waste heat to utilize a distillation system. The vendor believes that 60 percent
of all vessels use RO systems and that the remaining 40 percent use distillation systems.

VENDOR 6 (APRIL 4,2012)

       The vendor believes it would be feasible to use RO systems for ballasting purposes, since
they would provide a continuous supply of potable water. The vendor also noted that energy  for
                                           B-5

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix B
powering these systems is coincidentally generated during vessel operation; therefore, power
requirements would not adversely affect vessel operations. Overall, the power requirements,
provided by the vendor, range from 3 to 30 kW, depending on the size of the system (Table B-5).
The vendor also noted that power requirements will vary, depending on the number of filter
membranes in the system, the feed water quality, and the types of pumps and motors used in the
engine room.

            Table B-5. Summary of Vendor's RO System Power Requirements
Unit Capacity
(gal/hr)
284
500
938
1,792
Power
Requirement
(kW)
3
15
15
30
       The vendor also provided information on equipment and annual O&M costs (Table B-6).
The equipment costs range from $73,000 to $152,845, depending on the size of the system. The
vendor was not able to estimate installation costs, stating that it is too case-specific to allow for
accurate estimates. The vendor estimated O&M costs to range from 3 to 10 percent of the
installation cost, depending on the degree to which the equipment is kept in good working
condition.

              Table B-6. Summary of Vendor's Equipment and O&M Costs
Capacity
(gal/hr)
284
500
938
1,792
Equipment
Cost
Not Provided
$73,000
$95,000
$152,845
Annual O&M
Cost
Not Provided
$2,190 to $7,300
$2,850 to $9,500
$4,585 to $15,285
                     Note: For each system, annual O&M cost is assumed to be 3
                     to 10% of equipment cost.

       The vendor also noted that for RO systems, water quality would affect production rates.
Feedwater with a relatively high degree of salinity would reduce overall production rates.
Therefore, a vessel's ability to generate potable water would vary by geography. Feedwater
temperature also would affect production rates, in that colder water reduces overall production
rates.

       When asked about the degree to which RO systems can filter out organisms, the vendor
indicated that it would depend on the membrane filter installed in the RO system, noting that the
system could be adjusted as needed. The vendor also indicated that, to produce potable water, it
would be necessary to install a disinfection system downstream from the RO system. Product
water from the RO system typically is disinfected using chlorination or UV systems. UV systems
can disinfect 5 to 6 gpm on smaller vessels (i.e., 50 to 60 ft in length). The vendor expects
smaller vessels would use chlorination  while larger vessels would use UV  systems.

VENDOR 24 (APRIL 5,2012)
                                          B-6

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix B
       Water disinfection on vessels generally utilizes chlorination, electro-katadyn, or UV
technologies. The vendor, who specializes in UV systems, noted that they primarily sell their
systems to yachts measuring 100 to 200 ft in length.

       For chlorination and electro-katadyn technologies, the disinfection system would be
installed between the PWG and the water storage tank. UV disinfection systems would be
installed downstream from the storage tank.

       The vendor commented that the vendor does not believe it is feasible to generate potable
water at the rates required for ballasting. Furthermore, the quality of source water can impact the
effectiveness of the disinfection system. For example, water with high turbidity would adversely
impact the effectiveness of UV disinfection systems.

       The vendor provided installation and O&M costs for UV sterilizers (Table B-7). The
annual O&M cost assumes a typical UV lamp life of 2 years and a typical lamp cost of $600.

              Table B-7. Summary of Vendor's Equipment and O&M Costs
Capacity
(gal/hr)
83
Installation Cost
$3,000
Annual O&M Cost
$300
VENDOR 20 (APRIL 9,2012)

       The vendor provided the equipment specifications in Table B-8. The vendor believes it
could be feasible for small vessels to generate potable water at a rate sufficient to meet ballasting
needs. However, the vendor does not believe it would be feasible for large vessels.

                Table B-8. Summary of Vendor's Equipment Specifications
System Type
Chlorination
Electro-Katadyn
Ultraviolet
Ultraviolet
Ultraviolet
Vendor
System No.
System 1
System 2
System 3
System 6
System 10
Capacity (gal/day)
253,605
95,102
6,732 to 9,588
28,356 to 44,880
148,920 to 271,320
Dimensions (mm)
800 x 800 x 2,640
48x480x150
200x471x80
300x471x120
300 x 927 x 200
Power
(W)
250
<30
35
80
290
       The vendor also provided equipment and installation costs for some chlorination, electro-
katadyn, and UV disinfection systems (Table B-9). The vendor assumed installation costs to be
10 percent of equipment costs. The vendor was unable to estimate annual O&M costs, stating it
would depend on the volume of water disinfected by the vessel over the course of a year.

              Table B-9. Summary of Vendor's Equipment and O&M Costs
System
Technology
Chlorination
Electro-Katadyn
Ultraviolet
Ultraviolet
Ultraviolet
Vendor
System No.
System 1
System 2
System 3
System 6
System 10
Capacity (gal/day)
253,605
95,102
6,732 to 9,588
28,356 to 44,880
148,920 to 271,320
Equipment
Cost
$13,560
$3,995
$2,550
$3,550
$6,100
Installation
Cost
$1,356
$400
$255
$355
$610
                                          B-7

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                           Appendix B

         Note: For each system, the installation cost is assumed to be 10% of equipment costs.

       The vendor noted that system consumables include chlorine, silver anodes, and UV lamps
for chlorination, electro-katadyn, and UV disinfection systems, respectively. The vendor was not
able to estimate how much chlorine would be required per gallon of disinfected water,  as they do
not sell chlorine to their customers. Silver anodes for electro-katadyn systems would require
replacement after disinfecting roughly 1,850,000 gallons and each electrode costs approximately
$850. Replacement lamps for UV disinfection systems would be necessary every 8,000 hrs of
operation. The total cost for replacing the lamps would depend on how many are in the system. It
would vary by model as follows:

       •      System 3: $195 (one lamp required);
       •      System 6: $195 (four lamps required); and
       •      System 10: $217 (five lamps required).
                                           B-8

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                   APPENDIX C:

   PROOF OF CONCEPT EVALUATION OF PWGs AS OPTIONS FOR MANAGING
                    BALLAST WATER FOR TARGET VESSELS

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
   Proof of Concept Evaluation of Potable Water Generators as Options for
                   Managing Ballast Water for Target Vessels
                     Maritime Environmental Resource Center
                                   September 2014
                    Questions and comments should be directed to:
                         Dr. Mario Tamburri
                         Maritime Environmental Resource Center
                         Chesapeake Biological Laboratory
                         University of Maryland Center for Environmental Science
                         PO Box 38/146 Williams Street
                         Solomons, Maryland 20688, USA
                         Email: tamburri(S>umces.edu
                                         C-2

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                          Appendix C

                                      Table of Contents

                                                                              Page
  1.   Background and Objectives of MERC Technology Evaluations                 C-3
  2.   Introduction to Technology                                                 C-4
  3.   Summary of Ballast Water Discharge Standards                               C-4
  4.   Summary of Test Protocols and Sampling Design                             C-4
      4.1. Test Protocols                                                        C-4
      4.2. Sampling Design Overview                                            C-6
  5.   Deviations from ETV Sample Handling and Analyses                         C-9
      5.1. Live Organisms >50 jim                                                C-9
      5.2. Live Organisms >10-<50 |im                                          C-9
      5.3. Culturable Organisms <10 jim                                          C-9
      5.4. Freshwater Toxicity Tests                                              C-9
  6.   Sampling and Analysis of Discharge Chemicals Including By-Products         C-10
      Compounds
  7.   Summary of Discharge Results                                            C-ll
      7.1. Summary of Freshwater Toxicity Test Results                           C-ll
      7.2. Discharge Chemistry Including By-Products Compounds                  C-13
  8.   Trial PW-1 Results                                                       C-13
  9.   Trial PW-2 Results                                                       C-19
  10.  Trial PW-3 Results                                                       C-24
  11.  Trial PW-4 Results                                                       C-29
  12.  Quality Assurance and Quality Control                                      C-34
  13.  Acknowledgments and Approvals                                          C-34


 Appendix A. MERC Analysis of PWG Media Tank Failure                        C-35
 Appendix B. MERC PWG Test Plan                                             C-3 8
 Appendix C. Chemistry Including By-Products Compounds - Full Analyses          C-38
  Table 1.   Uptake sample volumes collected.                                      C-8
  Table 2.   Discharge sample volumes collected.                                   C-8
  Table 3.   Overview of toxicity tests performed on PWG treated water.              C-10
  Table 4.   Discharge data summary for live organisms                            C-ll
  Table 5.   Discharge data summary for chlorine concentrations                     C-ll
  Table 6.   Whole effluent toxicity test results for potable water during uptake and    C-12
           discharge events.
  Table 7.   Concentrations of detectable by-products and other compounds           C-13
           substances found in the four potable water discharge samples
                                         C-3

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                           Appendix C

1. Background and  Objectives of MERC Technology Evaluations
       The Maritime Environmental Resource Center (MERC) is a State of Maryland initiative
that provides test facilities, information, and decision tools to address key environmental issues
facing the international  maritime industry. The Center's primary focus is to evaluate the
mechanical and biological efficacy, associated costs, and logistical aspects of ballast water
management  systems (BWMSs) and  the economic impacts of ballast water regulations and
management approaches. A full description of MERC's structure, products, and services can be
found at www.maritime-enviro.org.
       To address the need for effective, safe, and reliable BWMSs to prevent the introduction of
non-native species, MERC has developed as a partnership between the Chesapeake Biological
Laboratory/University of Maryland Center for Environmental Science (CBL/UMCES), Maryland
Port  Administration  (MPA),   U.S.  Maritime  Administration   (MARAD),  Smithsonian
Environmental  Research Center  (SERC),  University of  Maryland, College Park, (UMCP),
University of Maryland Wye Research and Education Center (UMD/WREC) and Old Dominion
University (ODU) to  provide independent performance testing and to help facilitate the transition
of new treatment technologies to shipboard implementation  and operations.
       MERC evaluated the performance characteristics of a potable water generator (PWG)
through objective and quality assured land-based testing. The goal of this specific evaluation was
to provide information on the performance of a standard marine PWG under  the conditions
specified in the test plan and to explore if the use of potable water generated onboard a vessel
might be used as ballast for vessels that need to compensate for fuel consumption. The data and
information on performance characteristics of the PWG are similar to an assessment of a BWMSs
and compare numbers of live organisms in  potable water discharged from mimic ballast tanks
against the U.S. Coast Guard regulations and EPA's  Vessel General  Permit requirements for
ballast water discharge.
       It is important to note that MERC  does  not certify technologies nor guarantee that a
treatment will always, or under circumstances other than those used in testing, operate at the levels
verified.  Our goal is  not to conclude if this specific PWG is acceptable or unacceptable for use in
producing ballast for  targeted vessels.  However, tests and results are in a format consistent with
ballast water regulations (USCG and EPA) so the  data can be used to determine compliance with
discharge regulations. Sampling and analytical procedures  utilized by the MERC team are also
consistent with the EPA Environmental Technology Verification (ETV) Protocols (2010) and the
current U.S. Federal Standards under the auspices  of the U.S. Coast Guard. Final reports on PWG
performance have been provided to the EPA and MARAD for review prior to public release.
                                          C-4

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                           Appendix C

2. Introduction to Technology
       The PWG utilized a pre-filtration system consisting of a multimedia granular filter bed
and bag and cartridge filters. Feed water was initially fed through a filter bed containing
anthracite, garnet, flint, sand, and gravel filter media. The filtrate passed through a 5-micron
filter bag and finally through a canister containing five 10-micron candle filters. The filter sizes
were intentionally configured in this manner to maximize particulate filtration prior to the
cartridge filter. This was done for the purpose of reducing the frequency of cartridge filter
changes, which were labor intensive compared to bag filter changes.  The pretreated water was
then fed through a reverse osmosis (RO) membrane, disinfected with a 12.5% sodium
hypochlorite solution  (1 ppm dose), and then passed through two tanks containing calcite to
neutralize the pH of the final product.
       The PWG utilized a spiral-wound RO membrane filter made of a polyamide thin-film
composite. The filter membrane, manufactured by Dow Chemical Company, has an active
surface area of 440 ft2 (41 m2) and a salt rejection range of 99.65 to 99.80%  (cited from the
United States Environmental Protection Agency (EPA), Onboard Potable  Water Generator
(PWG) Feasibility Analysis Report, unpublished draft, 2014).
3. Summary of Ballast Water Discharge Standards
       USCG Regulations and EPA Vessel General Permit both include the following ballast
discharge standards:
    1) Less than 10 live organisms per m3, greater than or equal to 50 jim in minimum dimension;
    2) Less than 10 live organisms per ml, less than 50 |im in minimum dimension and greater than
      or equal to 10 jim in minimum dimension; and
    3) Culturable live organisms less than 10 microns, including the following:
       1.  Toxigenic Vibrio cholerae (serogroups Ol and O139), less than one colony forming unit
          (cfu) per 100ml;
       2.  Escherichia coli, less than 250 cfu per 100 ml;
       3.  Intestinal Enterococci, less than 100 cfu per 100 ml.
This report refers to and incorporates  specifics requirements found in the ETV Generic Protocols
for the Verification of Ballast Water Treatment Technologies, EPA/600/R-10/146 (2010).
4. Summary of Test Protocols and Sampling Design

4.1. Test Protocols
       This report presents the results for the MERC performance evaluation of the PWG. Details
on program policies and testing  approaches/methodologies can be found in the MERC Quality
Management Plan (QMP),  Quality Assurance  Project  Plan (QAPP)  and various  Standard
Operating Procedures (SOPs). These documents are available upon request. Additional details
about the test protocol and sampling design can be found in the Test Plan (Appendix A).
       MERC offers land-based testing on a Mobile Test Platform (MTP) that allows BWMSs to
be evaluated in Baltimore Harbor, Maryland (salinity 5-12 PSU) and/or Norfolk, Virginia
(salinity 20  - 25 PSU) with one system installation (Figure 1). Only Baltimore was used for this
evaluation of the PWG.  Some key facility features include:
    •   Testing tanks - Two with capacity 310m3 each;
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       Pumps and piping - Two 60 hp centrifugal pumps with two 8-in (20.3 cm) piping systems
       for versatility in moving ballast water;
       Flow rates - Minimum of 100 m3/hr and maximum of 310 m3/hr for each pump;
       Pump discharge pressure - up to 50 psi;
       Working space - onboard office, laboratory (for live  analyses,  calibrations  and  water
       quality analyses), plus, sampling and storage containers; additional space minutes away;
       Capacity to amend intake challenge water to intensify challenge conditions;
       Facility sanitation before and between test cycles;
       High quality in-line  and/or in-tank sampling; and
       WET testing and chemical analyses.
                        Figure 1. MERC Mobile Land-Based Test Facility.

       Valve position and pump setting govern ballast water movement on the MTP. The system
is variably configured for the various operational modes available and is controlled/monitored by
an integrated monitoring and control (EVIAC) system. EVIAC employs industrial process software
to provide a graphic/numerical user-interface  for pipe and pump  set-up as well as  to initiate
logging, plus manage, store,  and present logged data on flow-rates, pressures, volumes, sampling,
challenge condition modification, and valve-position. Depending upon the parameter, logging
occurs in 15-second to one-minute intervals. Control and treated water quality are also monitored
and recorded using in-tank multi-parameter  sondes (temperature,  salinity,  dissolved oxygen,
turbidity, chlorophyll, and pH).
       Sample water for water quality and biological analysis is generally collected continuously
throughout each intake and discharge operation via the facility's in-line sample points. Discrete
samples for water chemistry and water quality  analysis can also be  collected during intake, tank
retention and discharge.  Onboard laboratories provide enough  space to support time sensitive
analyses  associated with MERC land-based tests, including live analysis of organisms > 50 jim
(i.e., zooplankton). The laboratories are climate-controlled and have enough bench space to allow
for simultaneous analysis of samples by multiple personnel. Other analyses are conducted  in the
laboratories of SERC, WREC, UMCES and UMCP with the longest transit time of 90 minutes.
       Due to the significant flow rate differential between the PWG and a typical ballast water
management system, modifications were made to the standard ETV testing protocols,  consistent
with the requirements of ETV.  Modifications for this evaluation are described below.

4.1.1. Commissioning and Training
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       Prior to biological testing, mechanical commissioning of the PWG system was conducted
in collaboration with an  engineer  from the PWG provider to assure  appropriate treatment
operations  onboard the  MERC MTP.  A commissioning trial identified and corrected initial
mechanical  and operating issues.   The  parameters  examined included:  testing the power
connections, testing the compressed air actuated valve system on the media tank skid, making the
sodium hypochlorite solutions then adjusting the injection rate to specs, and checking all meters
for accuracy.
       The PWG provider engineer trained MERC and ERG personnel in the standard operating
procedures and basic maintenance of this system. The trainer and trainees signed a customer
training form. After the PWG system commissioning was completed and accepted by the provider,
the engineer submitted a formal statement stating that the PWG was ready  for biological testing.

4.1.2. Operations and Maintenance
       In general, after the training period and with some consultations with the PWG provider,
MERC staff found the system operations and maintenance (O&M) procedures clear and easy to
follow. As stated  in the PWG O&M manual, MERC staff recorded O&M data each  day that
MERC personnel were on site for either testing or maintenance. When off-site, MERC staff could
check daily for operations data including flow rate into the test tank and test tank levels using a
remote connection.
       The delivery rate of potable water by the PWG to the MERC test tank was 12 ฑ  1 GPM.
During uptake, the  PWG system drew 25 Amps of electricity at 480 volts,  3-phase power. Using
approved maintenance procedures, bag  and cartridge filters were changed when the differential
pressure reached a  designated value. The bag filters were also changed out whenever the system
was to be left running unattended for more than 1-2 days.  The timing depended upon the existing
concentrations of plankton and total suspended solids (TSS) in the ambient water.
       The PWG system normally ran 24/7. However, since the timing between test 1 and test 2
was greater than 3 days, MERC stopped the PWG system and preserved the RO membranes using
approved maintenance procedures and with the guidance of PWG provider by phone.  MERC
restarted the system the morning of the second test using the approved procedures  for returning
the system to normal operation, and then followed the normal startup procedures.
       During the uptake event for Trial PW-4, one of the three media tanks on the PWG failed.
MERC was able to finish Trial PW-4;  however, Trial PW-5 was  canceled because of a PWG
system failure. See appendix B for details.

4.1.3. Biological Efficacy Trials
       MERC conducted a total of four biological efficacy trials  focused on all USCG and EPA
regulated taxonomic categories, including live organisms (LO) > 50 um, LO >10 -  <50  um, and
culturable organisms <10 um.
4.2. Sampling Design Overview
       Water was collected for biological examination for the following parameters: > 50um size
fraction (nominally zooplankton), >10 to <50 um size fraction (nominally phytoplankton), <10
um culturable organisms, whole effluent toxicity testing, chlorinated by-products analyses, and
water quality analyses, including TSS, particulate organic carbon (POC), dissolved organic carbon
(DOC) and chlorophyll (Chi).
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       During the PWG trials, only one MERC pump/pipe system and one test tank were used.
The test tank was filled to a minimum of 150 m3 over a 5 or 6-day period using a 1-inch hose
connected between the PWG RO supply pipe and a bottom flange-connection on the MERC test
tank.
       At the completion of each discharge event, the MERC pump/piping system and test tank
were immediately flushed with fresh municipal water prior to conducting a subsequent trial. The
test tank was scrubbed clean to remove any remaining particles.  See SOPs for additional details
on test operations and discharge sampling. See below for uptake sampling protocols. The analyses
of all samples (regardless of how collected) followed the ETV Protocols and MERC SOPs.

4.2.1. Water quality measurements
1. In Situ measurements:  During the entire testing period, a calibrated YSI 6600V2-4 multi-
parameter water quality sonde was deployed from the MTP at a depth of one meter. The sonde
collected challenge water data  every  15  minutes.   Data included temperature, conductivity,
salinity, dissolved oxygen, pH, turbidity (NTU), and chlorophyll fluorescence. Post-calibration
detected any drifting of parameter readings.

2. Discrete measurements:  During each uptake, a YSI Pro Plus multi-parameter instrument was
used to collect challenge and potable water measurements of temperature, conductivity,  salinity,
and dissolved oxygen. Free and total chlorine were measured using a HF Scientific chlorine pocket
photometer. Litmus paper was used to estimate pH.

3. Test tank measurements: At the start of the uptake, a YSI 6600V2-4 multi-parameter sonde
was placed into the test tank. Every  15 minutes the sonde measured temperature, conductivity,
salinity, dissolved  oxygen,  oxygen reduction potential,  pH, chlorophyll and turbidity. It was
removed from the test tank just prior to discharge.

4.2.2. Uptake event sampling
       To characterize both the challenge water and the potable water generated during a tank
uptake event, discrete samples were collected both upstream (challenge water) and downstream
(potable water) of the PWG. This once-per-day uptake sampling occurred on three uptake days
(start day, a midpoint day and the final uptake  day). The  sample methods were modified to
accommodate  the  slow  flow rates  (12  GPM), which  did not allow  for the  ETV protocol
recommended time-integrated isokinetic sampling.

1. Uptake challenge water (UT  Challenge): Ambient, non-augmented Baltimore Harbor water
supplied to the PWG  system. For UT Challenge water sample collection, MERC deployed a
submersible pump and hose next to and at the exact depth of the PWG uptake submersible pump.
The sample collection hose free-flowed during sample collection. These two pumps were located
on the forward port corner of the MTP.

2. Uptake potable water (UT Potable): Potable water coming from the PWG system. Samples were
collected at a port located just after the PWG product pipe, and before going into the test ballast
tank. For PW-1-UT1 only, this sampling point was located a distance away from the PWG product
pipe. After PW-1-UT1, the sample point was relocated immediately after the PWG product pipe.

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Feasibility and Efficacy of Using Potable Water Generators
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Appendix C
       A specific volume of sample water was pumped into carboys and bottles as described in
Table 1 below.

Table  1.  Uptake sample volumes collected.

>50 Live Organisms
>10 - <50 Live Organisms
Microbial (all tests)
*Water Chemistry - Chi, TSS, DOC,
and POC
Free/Total Chlorine
Temperature/Conductivity/Salinity
Dissolved Oxygen
PH
Whole Effluent Toxicity
UT Challenge
1 20L carboy
3 500 ml bottles
3 1L bottles
2 7L carboys
1 1L bottle
YSI instrument
Litmus paper
Glass carboys as needed
UT Potable
1 20L carboy
3 500 ml bottles
3 1L bottles
3 7L carboys
1 1L bottle
YSI instrument
Litmus paper
Glass carboys as needed
*2-L max per filter pad for potable water chemistry samples

4.2.3. Discharge event sampling
       Sampling of the potable water upon discharge (DC Potable) occurred after a 5 to 6-day
hold time in the MERC test ballast tank. All samples were obtained through the MERC MTP
piping system set in the discharge  configuration at 150 to 250 m3/hr. Discharge and discharge
sampling of the potable water test tank followed ETV techniques. Statistically-validated (Miller et
al., 2011), continuous, time-integrated samples were collected through sample ports located on the
system pipes.  All sample ports include a valve and sample tube with a 90ฐ bend towards the
direction of flow, placed in the center of the piping system (based on the design developed and
validated by the US Naval Research Laboratory, Key West Florida, see ETV protocols). Sample
volumes  and details of the physical, chemical, and biological analyses  for each sample are
described in Table 2 below. During the discharge events, samples were also collected for whole
effluent toxicity testing and chlorinated by-products analyses.

Table 2.  Discharge sample volumes collected.

>50 Live Organisms
>10 - <50 Live Organisms
Microbial (all tests)
Water Chemistry - Chi, POC, DOC
Water Chemistry - TSS
Free/Total Chlorine
Temp/Cond/DO
PH
Chemical by-products
Whole Effluent Toxicity
DC Potable
7 m3 filtered through 37 p.m mesh net
integrated over the entire discharge
3 500 ml bottles from *IS cylinder
3 1L bottles from IS cylinder
3 7L carboys from IS cylinder
2 7L carboys from sample port, 3 time points
1 1L bottle from IS cylinder
YSI instrument - 3 time points
Litmus paper - 3 time points
2-L carboy from toxics IS cylinder
Glass carboys from IS toxics cylinder

  ntegrated sample cylinder

5. Deviations from ETV Sample Handling and Analyses
       Due to the significant flow rate differential between the PWG and a typical ballast water
management system, modifications were made to the standard ETV testing protocols, consistent
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with the requirements of ETV. Modifications for this evaluation are described below.  Also,
since the PWG product was fresh water and not salt water, the tests used to culture live
organisms >10 microns and to perform toxicity tests were also modified to reflect this alteration.

5.1. Live Organisms >50 um
Uptake events only
       Each 20L sample was filtered through a 37-micron mesh sieve and examined live under a
microscope.

5.2. Live Organisms >10 - <50 um
Uptake events only
1. Challenge water: Ambient water was analyzed using standard methods.  A dilution series was
used  at 1/10 for each ambient  sample. The entire dilution (100  jil) was analyzed on  standard
Sedgewick rafter (each grid is 1 mm square).

2. Potable water: using a 2.0 uM membrane filter,  500 mis of sample was gently filtered into a
clean flask.  The membrane was then placed into a 30 ml bottle along with 20 mis of filtrate and
shaken to dislodge the organisms from the filter. The 1 mL subsample was counted completely.

5.3. Culturable Organisms  <10 um
Potable water samples during uptake and discharge events
       Freshwater media, R2A, was used to test the growth of total heterotrophic bacteria (THE)
from the potable water sample. Analysis followed Standard Methods for the Examination of Water
and Wastewater, 20th Edition, Method 9215 with R2A Medium. IDEXX Colilert was used to
measure the growth of E. coli in the potable water sample. Analysis followed Standard Methods
for the Examination of Water and Wastewater, 20th Edition, Methods 922ID and 922IE. Although
these specific MERC trials were examining ballast water, these analyses are also used for  drinking
water

5.4. Freshwater Toxicity Tests
       Water  samples treated with PWG RO  system were tested  for chronic toxicity with three
freshwater species:  a fish (Pimephales promelas), an invertebrate (Ceriodaphnia dubid) and an
algae (Selenastrum capricornutum). Details of toxicity test methods and results can be found in a
separate report (PWG Toxicity Testing Report, University of MD/WREC, Report No. WREC-14-
37). Treated water samples from a total of four treatment events (PW-1 through PW-4) were tested
with fish, daphnia, and algae.
       Toxicity tests were conducted on discharge water after holding time (PW-X-DC) for all
trials, while uptake water (PW-X-UT) was only tested during the first trial  (PW-1).  Ceriodaphnia
were not tested in samples from the second trial (PW-2-DC) due to  problems with cultures leading
up to the trial.
       All three species were also used to  test  a de-chlorinated uptake  sample (PW-l-UT
Dechlor).  The uptake sample  was de-chlorinated with a  nominal dose of sodium  thiosulfate
thought to be in excess of any residual chlorine remaining in the treated sample.
       Finally, algae toxicity tests were conducted on de-chlorinated (also with nominal sodium
thiosulfate addition) discharge samples from the final three trials, PW-2 through
PW-4.
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Table 3  Overview of toxicity tests performed on PWG treated water.
Event
PW-1


PW-2

PW-3

PW-4

Start Date
5/13/14


5/28/14

6/3/14

6/10/14

Sample
PW-l-UT
PW-1-UTDechlor
PW-1 -DC
PW-2-DC
PW-2-DC Dechlor
PW-3 -DC
PW-3 -DC Dechlor
PW-4-DC
PW-4-DC Dechlor
Tests Performed
all
all
all
fish and algae only
algae only
all
algae only
all
algae only
6. Sampling and Analyses of Discharge Chemicals Including By-Products Compounds
       Potable water samples were collected during each discharge event from the integrated
sample  toxics cylinder for analysis of  21  by-product compounds. MERC  used sampling
methodology supplied by  the  analytical company,  Analytical  Laboratory  Services  (ALS)
Environmental.  The analytical methods used by ALS are summarized below. More information
can be found on the following websites: www.alsglobal.com or www.caslab.com.
    - Trihalomethanes: THMs (5 compounds), VOCs EPA Method 524.2
    - Haloacetic Acids: HAAs (8 compounds), Method 552.2 (subcontracted to Eurofms\Eaton
     Analytical)
    - Acetonitriles:  ACETOCNs  (5  Compounds), Method  551  (subcontracted to  Week
     Laboratories Inc.).
    - Sodium, Method 200.7
    - Bromate/chlorate, Method EPA 300.1; sodium, bromate and chlorate concentrations are used
     to calculate sodium chlorate and sodium bromate concentrations.
    - Dalapon, herbicide, EPA Method 515.3

       All samples were initially shipped overnight to ALS Environmental (Middletown, PA,
USA). ALS performed chemical analysis on nine substances (bromodichloromethane,
bromoform,  chlorodibromomethane, chloroform, 1,2,3-trichloropropane, dalapon, bromate,
chlorate and sodium (total)) for all four discharge samples (PW-1-DC through PW-4-DC).
       Additional analysis was performed by two subcontract laboratories, Week Laboratories
Inc. (Middletown, PA, USA) and Eurofms|Eaton Analytical (South Bend, IN, USA). Week
Laboratories analyzed for ten substances (l,l,l-trichloro-2-propanone, l,l-dichloro-2-
propanone, bromochloroacetonitrile, chloral hydrate,  chloropicrin, dibromoacetonitrile,
dichloroacetonitrile, trichloroacetonitrile, bromoacetonitrile, and chloroacetonitrile). Eurofins
Analytical analyzed for eight haloacetic acids (bromochloroacetic acid, chlorodibromoacetic
acid, dibromoacetic acid, dichloroacetic acid, monobromoacetic acid, monochloroacetic acid,
tribromoacetic acid, and trichloroacetic acid).
       ALS performed analysis on nine substances  (see above) for all four samples (PW-1-DC
through PW-4-DC). Week Laboratories performed analysis  on ten substances (see above) for
samples  PW-l-DC,  PW-3-DC,  and PW-4-DC  while  only five  substances   (chloropicrin,
dibromoacetonitrile,  dichloroacetonitrile,  bromoacetonitrile,   and   chloroacetonitrile)  were
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Feasibility and Efficacy of Using Potable Water Generators
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Appendix C
analyzed for PW-2-DC sample.  Eurofins analyzed for eight HAAs (see above) for samples PW-
1-DC through PW-3-DC while no analysis of HAAs was conducted on the PWG-4-DC sample.
7. Summary of Discharge Results
       MERC conducted four land-based trials of the PWG system during the spring of 2014. This
performance evaluation was based on the physical and biological characterization of challenge
versus potable water. During the fourth trial, one of the three PWG media tanks cracked and failed
on uptake day 3.  As a result, samples for PW-4-UT5 (third uptake sample collection) were not
collected. However, the discharge event (PW-4-DC) was possible since the MERC test tank was
full enough to discharge. The fifth trial of the PWG was canceled.  See Appendix B for further
discussion concerning causes of the failure and implications for results.

Table 4. Discharge data summary for live organisms"
Trial


PW-1
PW-2
PW-3
PW-4
LO
>50
^m/m3
0.14
0
0
0
LO
>10-<50
^m/ml
BDL
BDL
BDL
BDL
THE
(cells/
10ml)
0
0
0
0
E.coli
(cfu/
100 ml)
DQS
<1
<1
<1
Entercocci
(cfu/
100 ml)
<1
<1
<1
<1
V. cholerae
(#of
colonies)
0
0
0
0
*See tables 1 and 2 above for sample volumes.
DQS: Data did not meet MERC quality standards.
BDL: Below detection limits of 0.04 cells/ml
LO: Live organisms

Table 5.  Discharge data summary for chlorine concentrations
Trial
PW-1
PW-2
PW-3
PW-4
Free Cl (mg/1)
0.06 ฑ0.01
ND
0.20 ฑ0.03
O.lliO.Ol
Total Cl (mg/1)
O.lOiO.Ol
ND
0.14ฑ0.01
0.09 ฑ0.02
7.1 Summary of Freshwater Toxicity Test Results
       Results showed that water samples were toxic when tested immediately after treatment
(PW-l-UT) with a negative effect on survival or growth for all test species. De-chlorination with
nominal amounts of sodium thiosulfate (PW-l-UT Dechlor) decreased the toxic effect with all
three tested species, although some toxicity remained in fish and daphnia tests. Toxicity tests on
discharge water with a holding period after treatment (DC samples) revealed a reduction in toxic
effects in most cases compared to uptake sample toxicity tests with the same species.
       All toxicity tests on discharge samples (PW1-DC through PW4-DC) showed an absence of
toxic effects with fish. Toxicity of discharge samples with daphnia and algae tests was reduced in
most cases compared to uptake samples from the first trial (PW-l-UT). However, all daphnia and
algal toxicity tests revealed some level of toxicity for all discharge samples.

Table 6. Whole effluent toxicity test results for potable water during uptake and discharge
events. Overview of toxicity results of potable water samples directly  after treatment (UT) and
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Feasibility and Efficacy of Using Potable Water Generators
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Appendix C
after tank holding time (DC).  IC25S are for endpoint (i.e. survival, reproduction, growth or cell
density) with the lowest observed effect.

Event
PW-1








PW-2


PW-3



PW-4



Organism
Fish


Ceriodaphnia


Algae


Fish
Algae
Algae
Fish
Ceriodaphnia
Algae
Algae
Fish
Ceriodaphnia
Algae
Algae
Sample
PW-l-UT
PW-1-UTDechlor
PW-1 -DC
PW-l-UT
PW-1-UTDechlor
PW-1 -DC
PW-l-UT
PW-1-UTDechlor
PW-1 -DC
PW-2-DC
PW-2-DC
PW-2 -DC Dechlor
PW-3 -DC
PW-3 -DC
PW-3 -DC
PW-3 -DC Dechlor
PW-4-DC
PW-4-DC
PW-4-DC
PW-4-DC Dechlor
Survival
Effect
(Y/N)
Y
N
N
Y
N
Y
n/a
n/a
n/a
N
n/a
n/a
N
N
n/a
n/a
N
N
n/a
n/a
NOEC
56%
100%
100%
32%
100%
56%
n/a
n/a
n/a
100%
n/a
n/a
100%
100%
n/a
n/a
100%
100%
n/a
n/a
Growth
Effect
(Y/N)
N
Y
N
N
Y
N
Y
N
Y
N
Y
N
N
Y
Y
Y
N
Y
Y
N
NOEC
56%
<100%
100%
32%
<100%
56%
18%
100%
<100%
100%
32%
100%
100%
32%
18%
<100%
100%
32%
56%
100%
Lowest
effect
IC25
71.0%
n/a
>100%
38.2%
n/a
68.9%
22.4%
>100%
5.41%
>100%
34.7%
n/a
>100%
25.6%
25.1%
<100%
>100%
45.9%
73.6%
>100%
n/a: Not available because of type or lack of test concentrations.
NOEC: No Observed Effect Concentration - The highest concentration of toxicant to which organisms are exposed
in a full life-cycle or partial life-cycle test, which causes no statistically significant adverse effect on the observed
parameters (usually hatchability, survival, growth, and reproduction).
IC25: Concentration of effluent which has an inhibitory effect on 25% of the test organisms for the monitored effect,
as compared to the control (expressed as % effluent).
<100%: NOEC when toxicity tests was only conducted on 100% treated sample.
7.2 Discharge Chemistry Including By-Products Compounds
       Chlorate and sodium were found in all  samples  (PW-1-DC through PW-4-DC) while
bromoform was only found in PW-2-DC, PW-3-DC, and PW-4-DC. All other analytes were below
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Feasibility and Efficacy of Using Potable Water Generators
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Appendix C
detection limits (BDL).  The average concentrations were 43.1 ug/L, 1.06 ug/L, and 6.2 mg/L for
chlorate, bromoform and sodium, respectively (Table 6).

Table 7. Concentrations of detectable by-products and other compounds substances found
in the four potable water discharge samples  All other substances were *BDL for all samples
Sample
PW-l-DC
PW-2-DC
PW-3-DC
PW-4-DC
Mean concentration
Chlorate (ug/L)
34.2
40.9
49.6
47.7
43.1
Bromoform
(HS/L)
BDL*
1.2
0.57
1.4
1.06
Sodium (mg/L)
4.4
7.4
5.6
7.4
6.2
BDL* Below detection limit- Not used in calculating mean concentration.

8. Trial PW-1 Results
See Sections 4.2.2. and 4.2.3. for definitions of UT Challenge, UT Potable and DC Potable.

Water Quality Conditions
Challenge and potable water quality conditions

Temperature (ฐC)
Conductivity (uS)
Salinity (psu)
DO (mg/1)
DO (%)
pH
UT
Challenge
17.4
7,864.8
4.1
11.2
119.0
8.0
UT
Potable
18.0
76.7
0.0
11.4
120.0
8.0
DC
Potable
19.9
66.0
0.03
10.8
118.0
7.8
Average water quality conditions of the test tank PWG-treated water 5h after uptake.
Test Tank
Temperature (ฐC)
Salinity (psu)
DO (mg/1)
DO (%)
Turbidity (NTU)
Mean ฑ SD
16.8 ฑ0.47
0.02 ฑ0.00
7.7ฑ0.1
78. 8 ฑ 1.5
0.02 ฑ0.04
Max
17.5
0.03
7.9
82.3
0.10
Min
16.1
0.02
7.5
77.3
0.00
Average water conditions of the test tank PWG-treated water up to 5h prior to discharge.
Test Tank
Temperature (ฐC)
Salinity (psu)
DO (mg/1)
DO (%)
Turbidity (NTU)
Mean ฑ SD
19.5 ฑ0.04
0.02 ฑ0.00
11.0ฑ0.1
120.1 ฑ0.6
0.00 ฑ0.00
Max
19.6
0.02
11.1
121.0
0.00
Min
19.5
0.02
10.9
119.0
0.00
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Appendix C
Chlorine measurements from the test tank, challenge water, and potable water prior to entering
the test tank. Chlorine samples were not collected from the tank on UT1 or from the challenge
sample port on discharge.

Free chlorine
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Tank
Mean ฑ SD
(mg/1)
0.25 ฑ0.06
0.01 ฑ0.01
0.11 ฑ0.03
0.05 ฑ0.02
Challenge
Mean ฑ SD
(mg/1)
0.01 ฑ0.01
0.00 ฑ0.01
0.14 ฑ0.02
N/A
Potable
Mean ฑ SD
(mg/1)
0.30 ฑ0.01
0.32 ฑ0.01
0.31 ฑ0.02
0.06 ฑ0.01
Total chlorine
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Tank
Mean ฑ SD
(mg/1)
0.22 ฑ0.01
0.01 ฑ0.01
0.10ฑ0.01
0.10 ฑ0.00
Challenge
Mean ฑ SD
(mg/1)
0.02 ฑ0.00
0.03 ฑ 0.00
0.10 ฑ0.01
N/A
Potable
Mean ฑ SD
(mg/1)
0.33 ฑ0.02
0.32 ฑ0.02
0.35 ฑ0.02
0.10 ฑ0.01
Total Suspended Solids (TSS) content of challenge water and potable water during the 5-day
uptake.  Potable water TSS samples were collected at three different time points:  beginning,
middle, and end (1, 2, and 3, respectively) during the discharge.
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC 1
2
3
Challenge
Mean ฑ SD
(mg/1)
3.1ฑ0.1
5.0 ฑ0.2
9.2 ฑ0.3
N/A
N/A
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
BDL
BDL
BDL
BDL: Below Detection Limit
TSS maximum detection limit: 2.4 mg/1
                                           C-15

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                   Appendix C
Dissolved Organic Carbon (DOC) content of challenge water and potable water during the 5-
day uptake. On discharge, samples were collected from the time-integrated sampling cylinder.
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(mg/1)
3.0ฑ0.1
2.5 ฑ0.1
2.9ฑ0.1
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
BDL
BDL: Below Detection Limit
DOC maximum detection limit: 0.24 mg/1
Particulate Organic Carbon (POC) content of challenge water and potable water during the 5-
day uptake. On discharge, samples were collected from the time-integrated sampling cylinder.
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(mg/1)
0.41 ฑ0.01
1.00 ฑ0.02
2.50 ฑ0.01
N/A
Potable
Mean ฑ SD
(mg/1)
0.06 ฑ0.00
BDL
BDL
BDL
BDL: Below Detection Limit
PC maximum detection limit: 0.0633 mg/1
Active Chlorophyll content of challenge water and potable water during the 5-day uptake.  On
discharge, sam
jles were collected from the time-integrated sampling cylinder.
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(US/0
4.1 ฑ0.2
20.1 ฑ0.7
53.2 ฑ0.4
N/A
Potable
Mean ฑ SD
(US/0
BDL
BDL
BDL
BDL
BDL: Below Detection Limit
Chi (active) maximum detection limit: 0.18 ug/1

Live Organisms >50 urn
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(LO/m3)
165,050 ฑ6,240
193,352 ฑ4,085
67,565 ฑ 3,603
N/A
Potable
Total (LO/m3)
0
0
0
0.14
                                           C-16

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
Taxa and observations
Eight (8) taxa were present in the challenge sample. These were copepod nauplii, barnacle nauplii,
eggs, Rotifera, bivalves, Calanoida, diatoms, and  Cyclopoida. One taxa, a live bivalve veliger
larvae, was observed in the discharge samples. Rust, flakes, and fibers were present in all samples.
Live Organisms >10 - <50 um
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(cells/ml)
1,409ฑ 176
6,707 ฑ 1,083
49,863 ฑ 1,154
N/A
Potable
Total
(cells/ml)
DRC
BDL
BDL
BDL
DRC: Data rejected due to contamination.  See note below.
BDL: Below Detection Limits
LO >10 - <50 um detection limit is 0.04 cells/ml

Taxa and observations
UT1 - small unknown flagellates many pennate diatoms
UT2 - Bloom begins, P. minimum dominant (harmful algal bloom (HAB) species) but many cells
of G.  estuarale.  Also  detected numbers of centric  and pennate  diatoms,  small  chains  of
Chaetoceros sp., and a few chains of Asterionella sp.
UTS - Bloom takes off over weekend with warm weather (P. minimum still dominant)
G. estuarale still  present in moderate numbers Thalassiosira sp.  and Chaetoceros sp. in small
chains. Asterionella sp. observed in partial formations.

       NOTE:  Suspected contamination came  from RO sampling hose, first located some
distance from the RO discharge pipe. This potential  problem was eliminated before PW-1-UT2
sampling by changing the sample location to directly after the PWG RO supply pipe. No further
contamination was observed.
Culturable Organisms < 10 um
HPC-Total heterotrophic bacteria (THE) - Marine (marine media)
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(cfu/10 ml)
800 ฑ419
838 ฑ 105
3,550 ฑ 1,078
(cfu/lOOmL)
N/A
                                          C-17

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
HPC-Total heterotrophic bacteria (THB) - R2A (freshwater media)
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(cfu/10 ml)
1,200 ฑ96
4,717 ฑ788
(cfu/lOOml)
4,833 ฑ 1,366
(cfu/lOOml)
N/A
Potable
Mean ฑ SD
(cfu/10 ml)
0
0
0
0
Enterococci
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(cfu/100 ml)
<1
0
<1
N/A
Potable
Mean ฑ SD
(cfu/100 ml)
<1
0
<1
<1
E. coli - IDEXX Colilert-18 (marine media)
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(cfu/100 ml)
<1
5ฑ2
2ฑ 1
N/A
E. coli - IDEXX Colilert (freshwater media)
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(cfu/100 ml)
2ฑ<1
3ฑ2
3ฑ0
N/A
Potable
Mean ฑ SD
(cfu/ 100 ml)
<1
<1
<1
DQS
DQS: Data rejected because it did not meet MERC quality standards. See note below.
One of the replicates in this sample had unusually high counts. The data was considered outside of MERCs data quality
objectives and was therefore discarded.
                                             C-18

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
Vibrio cholerae - DF A
Trial
PW-1-UT1
PW-1-UT2
PW-1-UT5
PW-l-DC
Challenge
Mean ฑ SD
(#colonies)
0
0
0
N/A
Potable
Mean ฑ SD
(#colonies)
0
0
0
0
Whole Effluent Toxicity
Uptake water sample
       The PW-1 uptake water sample (taken after the PWG, but before entering the test ballast
tank) was toxic to all three species tested.  For the fish toxicity test, the 100% uptake water sample
had a survival of only 37.5% (Table 6) with no additional  survival or growth effect for lower
dilutions (18% -  56%). Daphnia tests resulted in reduced survival of adults in the top two dilutions
with survival of 20 and 0% for 56% and 100% dilutions, respectively.  The algae, Selenastrum
capricornutum, were  the most sensitive  species with a reduction in growth down to the 32%
dilution treatment. This resulted in an NOEC of 18% and an 1C25 of 22.4%

De-chlorinated uptake water sample
       De-chlorination with sodium thiosulfate either eliminated toxicity (algae test) or reduced
toxicity (fish and daphnia tests). Toxicity testing with all three species was only conducted on a
100% de-chlorinated  sample (i.e. no dilution series).  The fish toxicity test had a slight, but
statistically significant, effect on larval growth.  There was also a similar slight but significant
effect on the daphnia neonate production. No toxicity was observed in the algae test.

Discharge sample testing
       No survival or growth effect was observed in the fish test for PW-l-DC sample. Daphnia
tests resulted in a survival effect in the 100% discharge sample with a 7-d survival of only 30%.
Algae tests sample revealed toxicity  in the 56 and  100% treatments.  In fact, the NOEC was
unbounded as there was an effect at the lowest test dilution of 56%.
                                           C-19

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
Toxicity Test Results Summary

Event
PW-1








Organism
Fish


Ceriodaphnia


Algae


Sample
PW-l-UT
PW-1-UTDechlor
PW-1 -DC
PW-l-UT
PW-1-UTDechlor
PW-1 -DC
PW-l-UT
PW-1-UTDechlor
PW-1 -DC
Survival
Effect
rv/pn
Y
N
N
Y
N
Y
n/a
n/a
n/a
NOEC
56%
100%
100%
32%
100%
56%
n/a
n/a
n/a
Growth
Effect
rv/pn
N
Y
N
N
Y
N
Y
N
Y
NOEC
56%
<100%
100%
32%
<100%
56%
18%
100%
<100%
Lowest
effect
IC25
71.0%
n/a
>100%
38.2%
n/a
68.9%
22.4%
>100%
5.41%
Discharge Chemistry Including By-Product Compounds
       Chlorate and sodium were the only substances found above the minimum detection limit.
Chlorate concentration was 34.2 |ig/L and sodium was 4.4 mg/L.

9. Trial PW-2 Results
See Sections 4.2.2. and 4.2.3. for definitions of UT Challenge, UT Potable and DC Potable.

Water Quality Conditions
Challenge and potable water quality conditions

Temperature (ฐC)
Conductivity (uS)
Salinity (psu)
DO (mg/1)
DO (%)
pH
UT
Challenge
19.9
9,677.3
5.5
7.4
84.0
7.5
UT
Potable
20.5
82.5
0.0
6.5
72.3
7.7
DC
Potable
21.2
78.9
0.04
7.5
78.0
7.5
Average water quality conditions of the test tank PWG-treated water 5h after uptake.
Test Tank
Temperature (ฐC)
Salinity (psu)
DO (mg/1)
DO (%)
Turbidity (NTU)
Mean ฑ SD
18. 8 ฑ0.3
0.03 ฑ0.00
5.2 ฑ0.2
56.2 ฑ2.4
1.9ฑ0.1
Max
19.4
0.03
5.7
60.9
2.1
Min
18.5
0.02
4.9
52.8
1.9
                                          C-20

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
Average water conditions of the test tank PWG-treated water up to 5h prior to discharge.
Test Tank
Temperature (ฐC)
Salinity (psu)
DO (mg/1)
DO (%)
Turbidity (NTU)
Mean ฑ SD
21.0 ฑ0.02
0.03 ฑ0.00
7.4 ฑ0.04
83.1 ฑ0.4
1.8 ฑ0.04
Max
21.0
0.03
7.5
83.6
1.8
Min
20.9
0.03
7.3
82.1
1.7
Chlorine measurements from the test tank, challenge water, and potable water prior to going into
the test tank. Chlorine samples were not collected from the tank on UT1 or from the challenge
sample port on discharge.

Free chlorine: No data due to contaminated reagent

Total chlorine
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Tank
Mean ฑ SD
(mg/1)
N/A
0.17 ฑ0.00
ND
ND
Challenge
Mean ฑ SD
(mg/1)
0.04 ฑ0.01
0.04 ฑ0.01
ND
ND
Potable
Mean ฑ SD
(mg/1)
0.23 ฑ0.01
0.27 ฑ0.03
ND
ND
ND: no data due to contaminated reagent
Total Suspended Solids (TSS) content of challenge water and potable water during the 6-day
uptake. Challenge water samples were not collected on discharge. Potable water TSS samples were
collected at three different timepoints, beginning, middle, and end (1,2, and 3, respectively) during
the discharge.
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC 1
2
3
Challenge
Mean ฑ SD
(mg/1)
6.67 ฑ0.06
4.03 ฑ0.12
3.03 ฑ0.06
N/A
N/A
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
BDL
BDL
BDL
BDL: Below Detection Limit
TSS maximum detection limit: 2.4 mg/1
                                           C-21

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                   Appendix C
Dissolved Organic Carbon (DOC) content of challenge water and potable water during the 6-
day uptake. On discharge, samples were collected from the time-integrated sampling cylinder.
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(mg/1)
2.8 ฑ0.2
2.6 ฑ0.2
2.5 ฑ0.3
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
BDL
BDL: Below Detection Limit
DOC maximum detection limit: 0.24 mg/1
Particulate Organic Carbon (POC) content of challenge water and potable water during the 6-
day uptake. On discharge, samples were collected from the time-integrated sampling cylinder.
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(mg/1)
1.17ฑ0.01
1.15 ฑ0.03
0.79 ฑ0.01
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
BDL
BDL: Below Detection Limit
PC maximum detection limit: 0.0633 mg/1

Active Chlorophyll content of challenge water and potable water during the 6-day uptake.  On
discharge, sam
jles were collected from the time-integrated sampling cylinder.
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(ปg/l)
16.3 ฑ0.5
12.1 ฑ0.2
7.5 ฑ0.2
N/A
Potable
Mean ฑ SD
fag/1)
BDL
BDL
BDL
BDL
BDL: Below Detection Limit
Chi (active) maximum detection limit: 0.18 ug/1
Live Organisms >50 urn
Trial


PW-2-UT1
PW-2-UT5
PW-2-UT6
Challenge
Mean ฑ SD
(LO/m3)
270,965 ฑ 14,881
418,960 ฑ26,553
293,960 ฑ37,271
Potable
Total
(LO/m3)
0
0
0
                                           C-22

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                        Appendix C
  PW-2-DC
N/A
0
Taxa and observations
       Nine (9) taxa were present in the challenge sample: Rotifera, copepod nauplii, diatoms,
tintinnid, barnacle nauplii, Calanoida, polychaete, bivalves, and trochophore.
Rust, flakes, and fibers were present in all samples.

Live Organisms >10 - <50 urn
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(cells/ml)
12,520 ฑ 1,412
3,490 ฑ853
3,280 ฑ450
N/A
Potable
Total
(cells/ml)
BDL
BDL
BDL
BDL
BDL: Below Detection Limits
LO >10 - <50 urn detection limit is 0.04 cells/ml

Taxa and observations
UT1 - G. estuarale dominated the sample. Large numbers of small, unknown dinoflagellates and
diatoms.  Small chains of Chaetoceros sp., some Amphidium sp. and a few tintinnids, both live and
empty lorica, were observed.
UTS - P.  minimum was again dominant (start of second bloom occurred between UT1 and UTS).
G. estuarale observed in small numbers,  short chains of Chaetoceros sp. and few small
unknown pennate diatoms were observed.
UT6 -P. minimum still dominant; little change from UTS.
Culturable Organisms <10 um
HPC-Total heterotrophic bacteria (THB) - Marine (marine media)
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(cfu/10 ml)
1,205 ฑ 103
273 ฑ 61
143 ฑ37
N/A
HPC-Total heterotrophic bacteria (THB) - R2A (freshwater media)
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(cells/10 ml)
1,353 ฑ 158
1,168 ฑ207
723 ฑ 179
N/A
Potable
Mean ฑ SD
(cells/10 ml)
1ฑ 1
0
0
0
                                         C-23

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
Enterococci
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(cells/100 ml)
1ฑ 1
<1
<1
N/A
Potable
Mean ฑ SD
(cells/ 100 ml)
0
<1
<1
<1
E. coli - IDEXX Colilert-18 (marine media)
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(cells/100 ml)
42 ฑ42
6ฑ0
2ฑ 1
N/A
E. coli - IDEXX Colilert (freshwater media)
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(cells/100 ml)
25 ฑ4
3ฑ2
3ฑ3
N/A
Potable
Mean ฑ SD
(cells/ 100 ml)
<1
<1
<1
<1
Vibrio cholerae - DF A
Trial
PW-2-UT1
PW-2-UT5
PW-2-UT6
PW-2-DC
Challenge
Mean ฑ SD
(#colonies)
0
0
0
N/A
Potable
Mean ฑ SD
(#colonies)
0
0
0
0
Whole Effluent Toxicity
Discharge sample testing
       No statistically significant survival or growth effect was observed in the fish test. Algae
tests revealed significant toxicity in the top two treatments, 56 and 100%. There was also a dose
dependent reduction in algal growth in each successive treatment as the dilution percentage of
                                           C-24

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
discharge water increased. The reduction in algal growth resulted in an NOEC of 32% and an
1C25 of 34.7%.

De-chlorinated discharge water sample
       There was a statistically significant decrease in cell density in the de-chlorinated sample
compared to the control density of 3.31x106 cells/ml.

Event
PW-2


Organism
Fish
Algae
Algae
Sample
PW-2-DC
PW-2-DC
PW-2-DC Dechlor
Survival
Effect
rv/pn
N
n/a
n/a
NOEC
100%
n/a
n/a
Growth
Effect
rv/pn
N
Y
N
NOEC
100%
32%
100%
Lowest
effect
IC25
>100%
34.7%
n/a
Discharge Chemistry Including By-Product Compounds
       Chlorate, bromoform and  sodium were the only substances found above the minimum
detection limit.  Chlorate concentration was 40.9 |ig/L, bromoform concentration was 1.2 |ig/L
and sodium was 7.4 mg/L.
10. Trial PW-3 Results
See Sections 4.2.2. and 4.2.3. for definitions of UT Challenge, UT Potable and DC Potable.

Water Quality Conditions
Challenge and potable water quality conditions

Temperature (ฐC)
Conductivity (uS)
Salinity (psu)
DO (mg/1)
DO (%)
PH
UT
Challenge
20.4
8,904.3
5.0
8.0
91.0
7.8
UT
Potable
20.9
74.6
0.0
7.2
81.3
8.0
DC
Potable
21.2
63.7
0.03
8.4
93.3
7.5
Average water quality conditions of the test tank PWG-treated water 5h after uptake.
Test Tank
Temperature (ฐC)
Salinity (psu)
DO (mg/1)
DO (%)
Turbidity (NTU)
Mean ฑ SD
18.3 ฑ0.5
0.03 ฑ0.0
7.0 ฑ0.3
74.7 ฑ2.9
1.4ฑ0.1
Max
19.5
0.0
7.7
80.8
1.7
Min
17.8
0.0
6.6
71.1
1.3
                                          C-25

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
Average water conditions of the test tank PWG-treated water up to 5h prior to discharge.
Test Tank
Temperature (ฐC)
Salinity (psu)
DO (mg/1)
DO (%)
Turbidity (NTU)
Mean ฑ SD
21.1 ฑ0.02
0.03 ฑ0.00
8.3 ฑ0.04
93. 5 ฑ0.5
1.2 ฑ0.02
Max
21.2
0.03
8.4
94.1
1.3
Min
21.1
0.03
8.2
92.6
1.2
Chlorine measurements from the test tank, challenge water, and potable water prior to going into
the test tank. Chlorine samples were not collected from the tank on UT1 or from the challenge
sample port on discharge.

Free chlorine
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Tank
Mean ฑ SD
(mg/1)
N/A
0.19 ฑ0.02
0.06 ฑ0.01
0.19 ฑ0.02
Challenge
Mean ฑ SD
(mg/1)
0.02 ฑ 0.02
0.07 ฑ0.06
0.06 ฑ0.01
N/A
Potable
Mean ฑ SD
(mg/1)
0.33 ฑ0.02
0.25 ฑ 0.06
0.26 ฑ 0.02
0.20 ฑ0.03
Total chlorine
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Tank
Mean ฑ SD
(mg/1)
N/A
0.21 ฑ0.03
0.15 ฑ0.01
0.17 ฑ0.02
Challenge
Mean ฑ SD
(mg/1)
0.06 ฑ0.03
0.01 ฑ0.02
0.07 ฑ0.02
N/A
Potable
Mean ฑ SD
(mg/1)
0.35 ฑ0.03
0.45 ฑ0.13
0.27 ฑ0.01
0.14 ฑ0.01
Total Suspended Solids (TSS) content of challenge water and potable water during the 5-day
uptake. Challenge water samples were not collected on discharge. Potable water TSS samples were
collected at three different timepoints, beginning, middle, and end (1,2, and 3, respectively) during
the discharge.
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC

1
2
Challenge
Mean ฑ SD
(mg/1)
7.1 ฑ0.2
4.1ฑ0.1
6.3 ฑ0.5
N/A
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
BDL
BDL
                                          C-26

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Feasibility and Efficacy of Using Potable Water Generators
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                                                                    Appendix C
                          N/A
                              BDL
BDL: Below Detection Limit
TSS maximum detection limit: 2.4 mg/1
Dissolved  Organic Carbon (DOC) content of challenge water and potable water during the 5-
day uptake. On discharge, samples were collected from the time-integrated sampling cylinder.
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Challenge
Mean ฑ SD
(mg/1)
2.89 ฑ0.05
IM
IM
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
IM
IM
IM
BDL: Below Detection Limit
IM: Instrument malfunction during analysis; data flagged as suspect
DOC maximum detection limit: 0.24 mg/1

Particulate Organic Carbon (POC) content of challenge water and potable water during the 5-
day uptake. On discharge, samples were collected from the time-integrated sampling cylinder.
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Challenge
Mean ฑ SD
(mg/1)
1.45 ฑ0.03
1.32ฑ0.01
2.21 ฑ0.04
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
BDL
BDL: Below Detection Limit
PC maximum detection limit: 0.0633 mg/1

Active Chlorophyll content of challenge water and potable water during the 5-day uptake.  On
discharge, sam
jles were collected from the time-integrated sampling cylinder.
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Challenge
Mean ฑ SD
(US /I)
16.1 ฑ2.3
17.0 ฑ 1.0
30.4 ฑ0.7
N/A
Potable
Mean ฑ SD
(US/0
BDL
BDL
BDL
BDL
BDL: Below Detection Limit
Chl-a (active) maximum detection limit: 0.18 ug/1

Live Organisms >50 urn
Trial


PW-3-UT1
PW-3-UT2
Challenge
Mean ฑ SD
(LO/m3)
208,298 ฑ 18,720
412,111 ฑ 18,611
Potable
Total
(LO/m3)
0
0
                                           C-27

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Appendix C
PW-3-UT5
PW-3-DC
497,213 ฑ25,593
N/A
0
0
Taxa and observations
Nine (9) taxa were present in the  challenge sample. These  were Rotifera, copepod nauplii,
tintinnid, diatoms, trochophore, polychaete, harpacticoid,  bivalves,  and barnacle nauplii. Rust,
flakes,  detritus and fibers were present in all samples.
Live Organisms >10 - <50 um
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Challenge
Mean ฑ SD
(cells/ml)
3,830 ฑ423
6,060 ฑ 1,486
9,253 ฑ 709
N/A
Potable
Total
(cells/ml)
BDL
BDL
BDL
BDL
BDL: Below Detection Limits
LO >10 - <50 um detection limit is 0.04 cells/ml

Taxa and observations
UT1 - P. minimum still dominant and increasing in density. G. estuarale was observed in small
numbers
UT2 - P. minimum still dominant and increasing in density.  G. estuarale decreasing in density
(though one detected live in PWG sample rep 2)
UTS - Same numbers increasing
During UT2 and UTS, cells of G. estruale and P. minimum were detected in small numbers (1-3
cells) in the potable water samples.
Culturable Organisms <10 um
HPC-Total heterotrophic bacteria (THB) - Marine (marine media)
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Challenge
Mean ฑ SD
(cfu/10 ml)
1,292ฑ 162
892 ฑ 755
183 ฑ22
N/A
HPC-Total heterotrophic bacteria (THB) - R2A (freshwater media)
Trial
PW-3-UT1
Challenge
Mean ฑ SD
(cfu/10 ml)
5,450 ฑ647
(cfu/lOOml)
Potable
Mean ฑ SD
(cfu/10 ml)
0
                                          C-28

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Appendix C
PW-3-UT2
PW-3-UT5
PW-3-DC
1,062 ฑ 168
510 ฑ94
N/A
0
0
0
Enterococci
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Challenge
Mean ฑ SD
(cfu/100 ml)
3ฑ2
1
<1
N/A
Potable
Mean ฑ SD
(cfu/100 ml)
<1
<1
<1
<1
E. coli - IDEXX Colilert-18 (marine media)
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Challenge
Mean ฑ SD
(cells/100 ml)
45 ฑ 1
11ฑ2
<1
N/A
E. coli - IDEXX Colilert (freshwater media)
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Challenge
Mean ฑ SD
(cells/100 ml)
16ฑ6
3ฑ 1
3ฑ2
N/A
Potable
Mean ฑ SD
(cells/100 ml)
<1
<1
<1
<1
Vibrio cholerae -DFA
Trial
PW-3-UT1
PW-3-UT2
PW-3-UT5
PW-3-DC
Challenge
Mean ฑ SD
(#colonies)
0.2 ฑ0.4
0
0
N/A
Potable
Mean ฑ SD
(#colonies)
0
0
0
0
Whole Effluent Toxicity

Discharge sample testing
                                           C-29

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Appendix C
       No survival or growth effect was observed in the fish test. Daphnia tests resulted in a
reduction in neonate production in the top two treatments (56 and 100%) while there was no
survival effect.  This resulted in an NOEC of 32% and an 1C25 of 25.6%.  Algae tests revealed a
significant reduction in growth in the top three dilutions. The reduction in algal growth resulted
in an NOEC of 18% and an 1C25 of 25.1%.

De-chlorinated discharge water sample
       The algal growth  rate in the 100% de-chlorinated  sample (PW-3-DC Dechlor) was
substantially  greater than without de-chlorination (PW-3-DC).   However,  there was still  a
statistically significant decrease in cell density in the in the de-chlorinated sample compared to the
control density of 3.49xl06 cells/ml.

Event
PW-3



Organism
Fish
Ceriodaphnia
Algae
Algae
Sample
PW-3-DC
PW-3-DC
PW-3-DC
PW-3-DC Dechlor
Survival
Effect
rv/pn
N
N
n/a
n/a
NOEC
100%
100%
n/a
n/a
Growth
Effect
rv/pn
N
Y
Y
Y
NOEC
100%
32%
18%
<100%
Lowest
effect
IC25
>100%
25.6%
25.1%
<100%
Discharge Chemistry Including By-Product Compounds
       Chlorate, bromoform and sodium were the only substances found above the minimum
detection limit. Chlorate concentration was 49.6 |ig/L, bromoform concentration was 0.57 |ig/L
and sodium was 5.6 mg/L.
11. Trial PW-4 Results
See Sections 4.2.2. and 4.2.3. for definitions of UT Challenge, UT Potable and DC Potable.

Water Quality Conditions
Challenge and potable water quality conditions

Temperature (ฐC)
Conductivity (uS)
Salinity (psu)
DO (mg/1)
DO (%)
PH
UT
Challenge
22.2
9,189.0
4.6
7.4
87.5
7.5
UT
Potable
22.7
80.7
0.04
5.8
68.0
7.5
DC
Potable
23.3
70.5
0.03
7.4
85.7
7.0
Average water quality conditions of the test tank PWG-treated water 5h after uptake.
  Test Tank             I  Mean ฑ SD  I   Max   I   Miii
                                          C-30

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Appendix C
Temperature (ฐC)
Salinity (psu)
DO (mg/1)
DO (%)
Turbidity (NTU)
22.9 ฑ0.2
0.03 ฑ0.00
8. 5 ฑ0.2
98. 8 ฑ2.1
1.2 ฑ0.02
23.2
0.03
8.8
102.4
1.2
22.7
0.03
8.3
96.6
1.1
Average water conditions of the test tank PWG-treated water up to 5h prior to discharge.
Test Tank
Temperature (ฐC)
Salinity (psu)
DO (mg/1)
DO (%)
Turbidity (NTU)
Mean ฑ SD
23.1 ฑ0.01
0.03 ฑ0.0
7.6 ฑ0.01
88. 5 ฑ0.1
1.0ฑ0.1
Max
23.1
0.03
7.6
88.6
1.0
Min
23.1
0.03
7.6
88.3
0.9
Chlorine measurements from the test tank, challenge water, and potable water prior to going into
the test tank. Chlorine samples were not collected from the tank on UT1 or from the challenge
sample port on discharge.

Free chlorine
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Tank
Mean ฑ SD
(mg/1)
N/A
0.14ฑ0.01
0.07 ฑ0.01
Challenge
Mean ฑ SD
(mg/1)
0.08 ฑ 0.02
0.05 ฑ 0.02
N/A
Potable
Mean ฑ SD
(mg/1)
0.24 ฑ 0.02
0.33 ฑ0.01
0.11 ฑ0.01
Total chlorine
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Tank
Mean ฑ SD
(mg/1)
N/A
0.17ฑ0.01
0.09 ฑ0.01
Challenge
Mean ฑ SD
(mg/1)
0.15 ฑ0.02
0.03 ฑ0.01
N/A
Potable
Mean ฑ SD
(mg/1)
0.25 ฑ 0.03
0.29 ฑ0.00
0.09 ฑ0.02
Total Suspended Solids (TSS) content of challenge water and potable water during the 3-day
uptake. Challenge water samples were not collected on discharge. Potable water TSS samples were
collected at three different timepoints, beginning, middle, and end (1,2, and 3, respectively) during
the discharge.
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
1
Challenge
Mean ฑ SD (mg/1)
11.5ฑ0.1
3. 8 ฑ0.3
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
                                          C-31

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                                                                   Appendix C



2
3
N/A
N/A
BDL
BDL

BDL: Below Detection Limit
TSS maximum detection limit: 2.4 mg/1

Dissolved Organic Carbon (DOC) content of challenge water and potable water during the 3-
day uptake.  On discharge, samples were collected from the time-integrated sampling cylinder.
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Challenge
Mean ฑ SD
(mg/1)
2.9ฑ0.1
2.9ฑ0.1
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
BDL: Below Detection Limit
DOC maximum detection limit: 0.24 mg/1
Particulate Organic Carbon (POC) content of challenge water and potable water during the 3-
day uptake. On discharge, samples were collected from the time-integrated sampling cylinder.
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Challenge
Mean ฑ SD
(mg/1)
2.55 ฑ0.07
0.78 ฑ0.01
N/A
Potable
Mean ฑ SD
(mg/1)
BDL
BDL
BDL
BDL: Below Detection Limit
PC maximum detection limit: 0.0633 mg/1
Active Chlorophyll content of challenge water and potable water during the 3-day uptake. On
discharge, sam
jles were collected from the time-integrated sampling cylinder.
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Challenge
Mean ฑ SD
(ปg/l)
30.7 ฑ5.3
6.3 ฑ0.2
N/A
Potable
Mean ฑ SD
fag/1)
BDL
BDL
BDL
BDL: Below Detection Limit
Chi (active) maximum detection limit: 0.18 ug/1
Live Organisms >50 urn
Trial


PW-4-UT1
PW-4-UT2
Challenge
Mean ฑ SD
(LO/m3)
193, 144 ฑ 13,268
147,743 ฑ 4,766
Potable
Total
(LO/m3)
0
0
                                           C-32

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                                                         Appendix C
  PW-4-DC
N/A
0
Taxa and observations
Ten (10) taxa were present in the challenge sample. These were copepod nauplii, polychaete,
diatoms, Calanoida, barnacle nauplii, Rotifera, Cyclopoida,  tintinnid, bivalves, and trochophore.
Rust, flakes, mineral grains, detritus and fibers were present  in all samples.

Live Organisms >10 - <50 um
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Challenge
Mean ฑ SD
(cells/ml)
14,573 ฑ319
3,790 ฑ 572
N/A
Potable
Total
(cells/ml)
0.2 ฑ0.1
0 ฑ 0.02
BDL
BDL: Below Detection Limits
LO >10 - <50 urn detection limit is 0.04 cells/ml

Taxa and observations
UT1 -P.  minimum dominated the sample. Small numbers of G. estuarale were observed. (Peak of
second bloom likely occurred over weekend.)
UT2 - Same species number in decline.
Culturable Organisms <10 um
HPC-Total heterotrophic bacteria (THB) - Marine (marine media)
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Challenge
Mean ฑ SD
(cfu/10 ml)
1,537 ฑ 180
162 ฑ41
N/A
HPC-Total heterotrophic bacteria (THB) - R2A (freshwater media)
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Challenge
Mean ฑ SD
(cfu/10 ml)
3,367 ฑ638
(cfu/lOOml)
183 ฑ78
N/A
Potable
Mean ฑ SD
(cfu/10 ml)
0
0
0
Enterococci
Trial
PW-4-UT1
Challenge
Mean ฑ SD
(cells/100 ml)
<1
Potable
Mean ฑ SD
(cells/100 ml)
<1
                                         C-33

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Appendix C
PW-4-UT2
PW-4-DC
<1
N/A
<1
<1
E. coli - IDEXX Colilert-18 (marine media)
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Challenge
Mean ฑ SD
(cells/100 ml)
3 ฑ0.1
2ฑ 1
N/A
E. coli - IDEXX Colilert data (freshwater media)
Trial
PW-4-UT1
PW-4-UT2
PW-4-DC
Challenge
Mean ฑ SD
(cells/100 ml)
3ฑ 1
3ฑ 1
N/A
Potable
Mean ฑ SD
(cells/100 ml)
<1
<1
<1
Vibrio cholerae - DF A
Trial

PW-4-UT1
PW-4-UT2
PW-4-DC
Challenge
Mean ฑ SD
(#colonies)
0
0
N/A
Potable
Mean ฑ SD
(#colonies)
0
0
0
Whole Effluent Toxicity
Discharge sample testing
       No statistically significant survival or growth effect was observed in the fish test. Daphnia
tests resulted in a reduction in neonate production in the top two treatments with 21.2 and 18.0
neonates per adult for 56 and 100% dilutions, respectively. This resulted in an NOEC of 32% and
an 1C25  of 45.9% for 7-d daphnia reproduction endpoint.  Algae tests revealed a significant
reduction in growth  in only the 100% treatment.  The reduction in algal growth resulted in an
NOEC of 56% and an 1C25 of 73.6%.
                                          C-34

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Feasibility and Efficacy of Using Potable Water Generators
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Appendix C
De-chlorinated discharge water sample
       There was no significant reduction in growth for the de-chlorinated sample.

Event
PW-4



Organism
Fish
Ceriodaphnia
Algae
Algae
Sample
PW-4-DC
PW-4-DC
PW-4-DC
PW-4-DC Dechlor
Survival
Effect
rv/pn
N
N
n/a
n/a
NOEC
100%
100%
n/a
n/a
Growth
Effect
rv/pn
N
Y
Y
N
NOEC
100%
32%
56%
100%
Lowest
effect
IC25
>100%
45.9%
73.6%
>100%
Discharge Chemistry Including By-Product Compounds
       Chlorate, bromoform and sodium were the only substances found above the minimum
detection limit. Chlorate concentration was 47.7 |ig/L, bromoform concentration was 1.4 |ig/L
and sodium was 7.4 mg/L.
12. Quality Assurance and Quality Control
       Quality Assurance and Quality Control policies and procedures, data recording processing
and storage, and detailed roles and responsibilities are found in the MERC QMP, QAPP and SOPs.
There were no adverse findings in data collection and reporting  or at either the test facility or
associated laboratories. There were a few minor modifications to the Test Plan due to operational
requirements of the PWG system  being evaluated, which did not affect the  overall test. These
modifications were documented by MERC test personnel in accordance with MERC QAPP.
13. Acknowledgements and Approvals
       The MERC Testing Team for the PWG trials included: E. Bailey, J. Barnes, M. Carroll, T.
Mullady, G. Ruiz, G. Smith, D. Sparks, M. Tamburri, G. Ziegler, and K. Ziombra. MERC thanks
the U.S. Maritime Administration for funding and supporting this performance evaluation and
Edward Viveiros and Debra Falatko from Eastern Research Group (ERG) for their guidance and
support.
                                         C-35

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Feasibility and Efficacy of Using Potable Water Generators
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                  Appendix A.  MERC Analysis of Media Tank Failure

System Problem(s) and Findings
One (of three) media tanks failed on the PWG provided system (see attached photos). The fourth
MERC test was halted.  Thus,  samples for PW-4-UT5 (third out of three uptake sample collection
dates for PW-4) were not collected. PW-4-DC (discharge) was possible since the MERC test tank
was full enough for a discharge.  The full PW5 test was canceled.

Possible Causes and Major Area/Situations Investigated
The following three causes were discussed with the engineer from the PWG provider:
1. Direct hit to the media tank.
2. High vacuum to the media tank.
3. High pressure to the media tank.

Findings and Causes from Investigation
Upon inspection MERC  observed the following:

Findings (see attached photos and details)
A skid was fitted with 3 cylindrical reinforced and painted fiberglass media tanks, which were
domed-shaped at the top  and bottom ends. Each tank sat in its own stand and was further stabilized
at the top with wood, line and piping.  When MERC personnel remotely observed by computer
that the PWG system had automatically shut down, MERC personnel drove to the MTP to change
the filters (the usual reason for a shutdown) and restart the system. When the submersible pump
was turned on to re-prime the PWG system, water was observed flowing vigorously out of the top
of one of the media tanks. The submersible pump was quickly shut off.

Upon inspection, MERC personnel observed that one-half of the top fiberglass dome of the
forward-most media tank was cracked open. The  fiberglass cracked in eggshell fashion with very
jagged edges. The crack traveled horizontally %-way around the domed top, but did not extend
down into the sides of the tank. A jagged section of the upper portion of the fiberglass was lifted
up just enough so that blue reinforcement material could be observed.

Possible Causes
1. Direct hit to the media tank by an obj ect. There is no clear evidence of a direct hit to the top of
the media tank.  However,  MERC speculates that even a minor hit in the right place (such as
directly on the top pipe fitting when the tanks were not in the skid) might weaken the fiberglass.

Note that MERC was on board  during the skid loading by crane by McLean.  Loading was
accomplished carefully and gently.  MERC does not know about historical movements.

2.  High vacuum to the media tank.  The PWG engineer stated that a vacuum  pressure could
possibly have been created via reverse suction from the discharge hose, which was submerged 3-
4 feet into the ambient water. However, the  engineer also observed that the media tank would
have exhibited signs of implosion, which was not the case. Plus, the engineer would have expected
an implosion to most likely occur at the center of a tank and not at the top.  The  PWG engineer
                                         C-36

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Feasibility and Efficacy of Using Potable Water Generators
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also noted at the time that he thought safety valves were in place to prevent the hose from reverse
suction into the media tanks (See the Findings section below).
3. Excessive positive pressure to the media tank.  The PWG engineer speculated that this was the
most probable cause; however the exact mechanism is still to be determined by the PWG provider
and reported to ERG, the firm contracted by EPA to rent the potable water system.

Four possible causes for excessive positive pressure are:
3.1.  The submersible pump providing water to the media tanks could send too much pressure to
the media tanks.
Observations: This specific pump deadheads at 120 psi. Each media tank is rated to 150 psi (tank
label), but are supposed to withstand 4 times that pressure or 600 psi (manufacturer's website via
personal communication with ERG).

3.2. The media tanks were outdated  and had deteriorated.
Observations: The tanks were constructed in 2008 (tank label) with  a 5-year warranty (website
observation by ERG personnel). However, the PWG engineer thought that the paint on the outside
of the tanks would prevent the fiberglass from deteriorating.

3.3. Malfunction of one or more of the compressed air-actuated valves located on the media skid
used during back-flush cycle to clean the tanks.
Observations: MERC could not test the valves. This was to be determined upon inspection when
the system was returned to the PWG provider.

3.4. Malfunction of one or more  of the two manual valves located on the RO skid, with hoses
running between the media and RO  skids.
Observations: These valves were positioned in-line and appeared to be working when MERC
tested them.  As  stated  above,  the maximum pressure  would have been 120  psi from  the
submersible pump.

Note:  A 2-3 inch crack  was observed on  a second tank in the same location.  No  water was
observed leaking from that tank. However, the tank still may be compromised.
Conclusion and Corrective Action

Conclusion
As of 27 June 2014, the equipment was in transit to PWG provider. When the company received
the shipment, they trouble-shot the tank failure.

Corrective Action(s)
PWG provider offered to 2-day ship a new media skid to MERC at no cost.  However, MERC or
ERG/EPA would have incurred the expenses of moving the MTP, unloading the old media skid
and loading the new media skid.  Also, ERG's rental contract with PWG provider would have to
be extended. EPA and MERC decided the costs were not worth the benefit of conducting a fifth
test.
                                         C-37

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Feasibility and Efficacy of Using Potable Water Generators
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Appendix C
Followup
Follow-up with PWG provider was conducted by ERG who emailed the findings to EPA and
MERC. See the Findings Section below.  This MERC report notes that the third uptake of PW4
(UTS) and all of the fifth trial (PW5) were canceled.

Findings
Email from ERG engineer dated 1 July 14

"I wanted to forward a quick summary of what caused the PWG tank rupture, based on my
understanding from conversations with PWG [sic] Engineer. The short version of the story is that
the tanks ruptured because of a buildup in vacuum pressure in the overboard discharge line.

To help with visualizing how this happened, "I have provided the  attached schematic for the
potable water generator" (See ERG report). (I copied this schematic  directly from the operation
manual PWG provider provided; see page 9 of the manual for a complete version of the schematic).
I highlighted in red the portions of the system that come into play. As the discharge line drains, it
has a siphoning affect all the way up the line and into the media tanks. Depending on the vertical
height of the discharge line,  it is possible to create enough of a vacuum to rupture the media tanks.

Typically, the tanks can withstand this stress if/when such  a vacuum occurs. However, ours did
not,  and it is likely because of their age. To prevent tanks from rupturing in this manner, PWG
provider typically installs a vacuum breaker on the discharge line (as reflected in the PWG provider
schematic). However, our system [the system tested by MERC] was an older unit that did not have
one installed. Also, based conversations they had with us, PWG provider did not expect there to
be an appreciable height differential in the discharge line, and thus did not expect that it would
produce enough of a vacuum to compromise the integrity of the tank."
Photos of the cracked media tank.
                                          C-38

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Feasibility and Efficacy of Using Potable Water Generators
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Appendix C
                 Appendix B. MERC Potable Water Generator Test Plan
                  Test Plan for a Proof of Concept Evaluation of
                   A Potable Water Generator as an Option for
                    Managing Ballast Water for Target Vessels
                          Maritime Environmental Resource Center
                                    August 20, 2013
                    Questions and comments should be directed to:
                                      Dr. Mario Tamburri
                                      Maritime Environmental Resource Center
                                      Chesapeake Biological Laboratory
                                      University of Maryland Center for Environmental Science
                                      PO Box 38 /146 Williams Street
                                      Solomons, Maryland 20688, USA
                                      Email: tamburri(S)umces.edu
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                                     Table of Contents

                                                                             Page No

       l.  BACKGROUND AND OBJECTIVES OF MERC TECHNOLOGY EVALUATIONS	1
  2.  Background and Goals of the Proof of Concept Evaluation	2

  3.  Introduction to Technology	3

  4.  Overview of Test Facilities	3

  5.  Basic Evaluation Approach	3

  6.  Summary of Land-based Testing and Sampling Design	5

  7.  Test Trials	10

  8.  Data Analysis	11

  9.  Evaluation Schedule	11

  10. References	11
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1. Background and  Objectives of MERC Technology Evaluations
       The Maritime Environmental Resource Center (MERC) is a State of Maryland initiative
that provides test facilities, information, and decision tools to address key environmental issues
facing the international maritime industry. The Center's primary focus is to evaluate the
mechanical and biological efficacy, associated costs, and logistical aspects of ballast water
treatment systems and the economic impacts of ballast water regulations and  management
approaches.  A full description of MERC's structure, products, and services can be found at
www.maritime-enviro.org.

       To address the need for effective, safe, and reliable ballast water treatment systems to
prevent the introduction of non-native species, MERC has developed as a partnership between
the Maryland Port Administration (MPA), Chesapeake Biological Laboratory/ University of
Maryland  Center for Environmental Science (CBL/UMCES), U.S. Maritime  Administration
(MARAD), Smithsonian Environmental Research Center (SERC), University of Maryland
(UMD), and Old Dominion University to provide independent performance testing and to help
facilitate the transition of new treatment technologies to shipboard implementation and
operations.

       The following protocols describe how MERC will evaluate the performance
characteristics of a Potable Water Generator (PWG) through objective and quality assured land-
based testing. The goal of this specific evaluation is to provide Eastern Research  Group (ERG)
and U.S. Environmental Protection Agency (EPA) with information on the performance of a
PWG under the conditions specified in the test plan. The data and information on performance
characteristics will cover PWG performance information that users need and  will  compare
numbers of live organisms in potable water discharged from mimic ballast tanks against the U.S.
Coast Guard regulations and EPA's Vessel General Permit requirements for ballast water for
ballast water discharge.

       MERC does not certify technologies nor guarantee that a treatment will always, or under
circumstances other than those used in testing,  operate at the levels verified.  Treatment systems
are not labeled or listed as acceptable or unacceptable but tests and results are in a format
consistent with that requested by specific regulations (e.g., EVIO D2, G8 and G9)  so that can be
used to determine compliance by Administrations and classification societies. Sampling and
analytical  procedures utilized by the MERC team are also consistent with the EPA
Environmental Technology Verification (ETV) Protocols (2010).  Draft and final  reports on
PWG performance will be provided to ERG and complete raw datasets will be made available
upon request. All specific terms of a testing program associated with a particular technology,
including management of test findings, are outlined in the contract executed between ERG and
MERC/University of Maryland Center for Environmental Science (UMCES).

2. Background and  Goals of the Proof of Concept Evaluation
       Inland and Seagoing Vessels less than 1600 gross registered tons (3000 gross tons) are
not required to meet the numeric treatment limits in Section 2.2.3.5 of the Final Vessel General
Permit (VGP). EPA found that technologies to treat ballast water from this size class of vessels
are not currently Best Available Technology (BAT) within the meaning of the Clean Water Act.
An inland vessel means a vessel that operates exclusively on inland waters, typically in
freshwater environments. This means that numeric ballast water limits are not currently
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applicable for the majority of vessels operating on the Great Lakes.  EPA encouraged vessels in
this size class to use alternate measures to reduce the number of living organisms in their ballast
water discharges,  including use of those measures found in Part 2.2.3.5 of the VGP and use of
onboard potable water generators. However, EPA did not feel comfortable mandating these
requirements because the Agency did not have sufficient information about the availability and
efficacy of these management approaches for these vessels. EPA concluded that, although
technologies are promising for future development, they did not support the conclusion that
numeric ballast water discharge limits for small inland and seagoing vessels represents BAT at
this time or over the life of the permit. For example, most ballast water treatment systems have
been designed for larger vessels and/or vessels which only uptake or discharge ballast water on
either end of longer voyages.

       Some smaller vessels, because of their unique designs and operations, such as those
crossing the Chicago Sanitary Canal connecting the Great Lakes to the Mississippi River Basin,
might be able to use onboard potable water for ballasting. This is particularly true for vessels that
use ballast to compensate for fuel burn off and sewage generation. Additionally, some larger
vessels may be able to use onboard potable water for ballasting if they have smaller ballast tank
volumes and/or flow rates, or their operations  allow for such an approach. This task is designed
to thoroughly evaluate whether such systems can be used as an effective form of ballast water
management for these vessels, and if so, whether they are environmentally effective. If shown to
be effective  and their use is practicable, the potential use of the technologies  could conceptually
reduce the spread and dispersion of ANS within and into the Great Lakes and in other U.S. (and
international waters).

       EPA is seeking to test potable water generators as option for managing ballast water for
small vessels. ERG has selected MERC to perform a proof of concept series  of land-based tests
of a potable  water generator and disinfection system to evaluate its efficacy for preventing the
discharge of living organisms from ballast water tanks. This proof of concept is part of a larger
assessment of the feasibility of PWGs to produce ballast for vessels working  in freshwater
(particularly the Great Lakes), coastal, and open ocean environments.  A final report will discuss
the performance of a PWG for this new application in terms of (a) mechanical reliability, (b)
reducing the number of living organisms, and  (c) the production of toxic conditions of residual
byproducts.  Although the test shall generally follow the test protocols provided in ETV Generic
Protocol for the Verification of Ballast Water Treatment Technology (EPA/600/R-10/146), the
objectives are limited to a general evaluation of a PWG and some deviations  from the ETV
Protocols will be required because PWG produce potable water at much slower flow rates than
typical ballast water management systems are  able to treat water.  It is also important to note that
the PWG will not be identified and the data resulting from this proof of concept study can not
used for the  certification or approval of any specific technology.  The test PWG system will  be
selected and provided by ERG.

3. Introduction to Technology
       The PWG utilized a pre-filtration system consisting of a multimedia granular filter bed
and bag and cartridge filters. Feed water was initially fed through a filter bed containing
anthracite, garnet, flint, sand, and gravel filter media. The filtrate passed through a 5-micron
filter bag and finally through a canister containing five 10-micron candle filters. The filter sizes
were intentionally configured in this manner to maximize particulate filtration prior to the
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cartridge filter. This was done for the purpose of reducing the frequency of cartridge filter
changes, which were labor intensive compared to bag filter changes. The pretreated water was
then fed through a reverse osmosis (RO) membrane, disinfected with a 12.5% sodium
hypochlorite solution (1 ppm dose), and then passed through two tanks containing calcite to
neutralize the pH of the final product.

       The PWG utilized a spiral-wound RO membrane filter made of a polyamide thin-film
composite. The filter membrane, manufactured by Dow Chemical Company, has an active
surface area of 440 ft2 (41 m2) and a salt rejection range of 99.65 to 99.80% (cited from the
United States Environmental Protection Agency (EPA), Onboard Potable  Water Generator
(PWG) Feasibility Analysis Report, unpublished draft, 2014).

4. Overview of Test Facilities
       The following is a summary of the MERC land-based ballast water management system
test facility. However, not all components described will be used as part of the PWG evaluation.
To take advantage of the diverse physical, chemical and biological conditions found in the
Chesapeake Bay, MERC has developed a Mobile Test Platform. With one installation, a test
ballast water treatment system can be evaluated with the same protocols, by the same facility and
staff, under varying natural salinities and associated ambient communities, by moving the barge-
based test facility to different locations.

       The barge is 155' x 50' with a draft of 2' when tanks  empty and 5'  when tanks full.  The
Mobile Test Platform has two identical steel 310m3 test tanks (with typical internal tank coating)
and two identical 60 hp centrifugal pumps, with two eight-inch piping systems for versatility in
moving ballast water and for tank filling and discharge. Test tanks serve as mimic ballast tanks.
Testing flow rates can vary from a minimum of 100 m3/hr and maximum of 350 m3/hr for each
pump and flow pressure of up to 60 psi can be achieved. Three power connections are provided
for treatment systems: 1. 100 Amps 480V, 60 Hz, 3 phase, 2. 50 Amps, 480V, 60 Hz, 3 phase,
and 3. 30 Amps, 120V, 60 Hz. The test facility is operated by an integrated monitoring and
control system for remote control of variable speed drives, flow rates and pressure, plus data
logging of valve positions, tank levels/volume, power quality, flow rate, pressure, sampling
system operations, and treatment system status. The barge has an onboard office, dry and wet
labs, plus sampling and storage containers.

5. Basic Evaluation Approach
       Please note that this Test Plan describes the specifics  for the MERC proof of concept
evaluation of the Potable Water Generator (PWG). Details on program policies and testing
approaches/methodologies can be found in the MERC Quality Management Plan (QMP), Quality
Assurance Project Plan (QAPP) and various Standard Operating Procedures (SOPs) available on
the MERC website (www.maritime-enviro.org).  This Plan also refers to, and incorporates
specifics guidelines and requirements found in:

       •      International Maritime Organization (2008) Resolution MEPC. 174 (58)
              Guidelines for Approval of Ballast Water Management Systems (G8); and
       •      ETV Generic Protocols for the Verification of Ballast Water Treatment
              Technologies, (2010) EPA/600/R-10/146.
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       The fundamental approach of MERC is to conduct independent, scientifically-sound,
rigorous, and quality assured evaluations of ballast water treatment systems using the framework
provided in the G8 guidelines and specific methodologies found in ETV protocols.  As a general
rule, MERC relies on challenging ambient conditions found in the Chesapeake Bay, and
typically does not artificially augment test waters organisms in most evaluations to  avoid
artifacts and the potential for overestimation of treatment system performance (see Table 1).  For
example, rapid changes in physical conditions (such as salinity or total suspended solids) as
supplemental organisms are being added to influent ballast water may cause significant
mortality, independent of treatment.

       In cases where ambient challenge conditions fall substantially short of the G8  guidelines
and/or ETV protocols, MERC has the ability to augment total suspended solids (TSS),
particulate organic carbon (POC) and dissolved organic carbon (DOC), plus, phytoplankton, and
zooplankton. However, while physical, chemical and biological conditions  will be  documented,
no augmentation of challenge water will take place as part of this PWG proof of concept study.

Table 1.  Comparison of USEPA-ETV and G8 Recommended Challenge Conditions to Ranges of
Various Physical, Chemical and Biological Parameters in Ambient Water from  the MERC
Facility, Baltimore, MD during the BWMS testing season (March - December, 2008 - 2013).
Parameter

Temperature (ฐC)
Salinity (psu)
Total Suspended Solids
(mg/L)
Mineral Matter
(mg/L)
Particulate Organic
Carbon (mg/L)
Dissolved Organic
Carbon (mg/L)
Live Organisms > 50
|im/m3
Live Organisms 10 -
50 |im/ml
Culturable Bacteria
cfu/ml
USEPA
ETVt

4-35
0-36
Min. 24
Min. 20
Min. 4
Min. 6
Min. 100,000
Min. 1,000
Min 1,000
Recommended IMO
G8*

No Requirement
Two salinities, >10 psu
difference
>50
No Requirement
>5
> 5
> 100,000
> 1,000
>1,000
MERC Facility
Baltimore
Ambient Ranges

6.1 -28.6
1.5-14.9
3.3-38.3
Ave = 10
2.4-32.8
0.5 - 10.2
Ave = 1
2.4-4.6
Ave = 3-4
31, 175* -4,555,042
258** -36,497
E.coli: 0 - 162
Enterococci: 0-114
THBA: 146-31,833
fETV Generic Protocol for the Verification of Ballast Water Treatment Technologies, 2010.
{IMO Guidelines for the Approval of Ballast Water Management Systems (G8) 2008, MEPC. 174 (58).
*Typically > 100,000/m3, this one low value comes from one trial where an additional 90,000/m3
zooplankton were present but just under 50 um in size then grew to > 50 um during the 5-day hold time.
** Typically > 1,000/ml, ambient concentrations below 900/ml have occurred during 0.08% of the trials.
A Total heterotrophic bacteria based on cultured plate counts.
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       Prior to any formal testing, one mechanical commissioning run of the PWG system will
be conducted with the system manufacturer, to assure appropriate treatment operations onboard
the MERC Mobile Test Platform (see below). This run will identify and correct initial
mechanical or operating issues. After the PWG system commissioning has been completed and
accepted by the manufacturer, MERC and ERG, the manufacturer will submit a formal statement
that the PWG is ready for evaluations reliability and efficacy.

       MERC will conduct a series of three to five biological efficacy trials focused on all
USCG, EPA and EVIO regulated taxonomic categories, including live organisms > 50  um, 10 -
50 um, and culturable bacteria. See descriptions below and in the MERC QAPP and SOPs.

       The uptake event of each trial will be modified from MERC's typical protocol to
accommodate the unique design and slow fill rate of the PWG.  Each uptake event will utilize
ambient challenge water with no augmentation.  One mimic ballast tank will be filled  to at least
150 m3 over a 4 to 5 day period using a 2-inch hose connected directly from the PWG to a
bottom pipe on the tank. Fill rate and times will be determined by the specific PWG selected by
EPA-ERG and the amount of downtime required to perform normal maintenance on the system
(such as changing out pre filters). To characterize the challenge water and generated potable
water during the fill time, discrete samples will be collected before (upstream) and after
(downstream) the PWG once per day, on 3 different days (beginning, middle and end) of the tank
filling period. The samples collected before and after the PWG during tank filling will follow
the modified approach described below because the flow rates will not allow for the ETV
Protocol  recommenced time-integrated isokinetic sampling.

       Sampling of the potable water upon discharge (after 4 to 5-day filling and hold time) will
be through the MERC Mobile Test Platform piping system, set in the discharge configuration at
150 to 200 m3/hr, and will be consistent  with the ETV Protocol. The analyses of all samples
(regardless of how collected) will follow the ETV Protocols and MERC SOPs.

6. Summary of Land-Based Testing and Sampling Design
       The simulated ballast system of the MERC Mobile Test Platform has been designed to
allow for water to be  split equally, and delivered simultaneously, to a "control" (untreated) tank
and a "treated" tank (passing first through the treatment system).  However, for the PWG trials,
only one piping system  and one test tank (hereafter referred to as the potable tank) will be used.
Detailed  drawings of the MERC Mobile Test Platform and ballast system can be found in the
MERC QAPP and QMP.

       During uptake, discrete samples of both the challenge water (before the PWG) and the
potable water (after the PWG) will be analyzed for concentrations of live organisms and water
quality parameters. Upon discharge, statistically-validated (Miller et al., 2011), continuous,
time-integrated samples will be collected through sample ports located on the system pipes. All
sample ports include  a valve and sample tube with a 90ฐ bend towards the direction of flow,
placed in the center of the piping system (based on the design developed and validated by the US
Naval Research Laboratory, Key West Florida, see ETV protocols). Sample volumes and details
of the physical, chemical, and biological analyses for each sample are described below.
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       Samples for biological examination will include the >50|im size fraction (nominally
zooplankton), the 10-50 jim size fraction (organisms less the 10 jim will be noted), culturable
bacteria, and water quality (total suspended solids (TSS), paniculate organic carbon (POC),
dissolved organic carbon (DOC) and Chlorophyll (Chi)). During the discharge events, if the
PWG utilizes chlorine disinfection, samples will also be collected for whole effluent toxicity
testing and the evaluation of chlorinated by-products.  See Table 2 for the list of samples to be
collected, with corresponding volumes and purpose.

       At the completion of each trial, the MERC piping system is immediately flushed with
fresh municipal water prior to conducting a subsequent trial. See SOPs for additional  details on
test operations and sampling.
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Table 2. MERC will be collecting a variety of data on physical, chemical, biological, and
toxicologicalparameters during this evaluation. Table 2 describes samples collected and
analyzed.
Parameter
Water Quality (temp,
salinity, oxygen,
turbidity, chlorophyll
fluorescence)
Total Suspended
Solids (TSS) mg/L
Particulate Organic
Matter (POC) mg/L
Dissolved Organic
Matter (DOC) mg/L
Chlorophyll-a (ig/L
Viable Organisms >
50 |im/m3
Viable Organisms
10-50 |im/ ml
Culturable Bacteria
cfu/ml
Toxicity (if
chlorinating)
Sample ID
During tank potable
water filling and
hold time
a. Uptake Challenge
b. Uptake Potable
c. Discharge Potable
a. Uptake Challenge
b. Uptake Potable
c. Discharge Potable
a. Uptake Challenge
b. Uptake Potable
c. Discharge Potable
a. Uptake Challenge
b. Uptake Potable
c. Discharge Potable
a. Uptake Challenge
b. Uptake Potable
c. Discharge Potable
a. Uptake Challenge
b. Uptake Potable
c. Discharge Potable
a. Uptake Challenge
b. Uptake Potable
c. Discharge Potable
Discharge Potable
Purpose
Quantify challenge
and potable water
Quantify challenge
and potable water
Quantify challenge
and potable water
Quantify challenge
and potable water
Quantify challenge
and potable water
Quantify live
organisms > 50 |im
Quantify live
organisms 10-50
|im
Quantify regulated
indicator pathogens
and total
heterotrophic
bacteria
Quantify whole
effluent toxicity and
chlorinated by-
products
MERC Sample Volume/Time
points
Direct measurements, every 15
minutes, using multi-parameter
instruments.
Uptake: 1 - 4L subsamples from
20 L sample on each of the 3
day sampling events, Discharge:
3 time points.
Uptake: 2L subsample from 20
L sample on each of the 3 day
sampling events. Discharge: 2L
subsamples from the 75 L time-
integrated sample.
Uptake: 2L subsample from 20
L sample on each of the 3 day
sampling events. Discharge: 2L
subsamples from the 75 L time-
integrated sample.
Uptake: 2L subsample from 20
L sample on each of the 3 day
sampling events. Discharge: 2L
subsamples from the 75 L time-
integrated sample.
Uptake: 20 L sample on each of
the 3 day sampling events.
Discharge: 7 m3 time-integrated
samples
Uptake: 250 ml subsamples
from 20 L sample on each of the
3 day sampling events.
Discharge: 250 ml subsamples
from the 75 L time -integrated
sample.
Uptake: 1L subsamples from 20
L sample on each of the 3 day
sampling events. Discharge: 1L
subsamples from the 75 L time-
integrated sample.
Discharge: 75 L time-integrated
sample.
 Uptake and challenge = the process of filling a mimic ballast tank.
 Discharge potable = the process of emptying a mimic ballast tank.
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Viable Organisms >50|im in size

Uptake Sampling
       Since the uptake event is spread over several days, on each of three tank uptake (fill)
days, MERC will collect a 20 L discrete sample (using MERC SOPs) of challenge water (before
the PWG) and potable water (after the PWG). The sample will be processed using the nets and
canisters mentioned below in the discharge paragraph.

Discharge Sampling
       The MERC ETV sampling system consists of paired canisters,  each designed to
accommodate a 35 jim (50 jim diagonally) mesh plankton net used to collect the >50 jim size
fraction. One pair handles water from the potable water ballast tank. The paired sampling
canister/net arrangement allows for the residual from the cod-end of one net from each pair to be
processed for examination while filtration continues via the other net, thereby avoiding clogging.
In this  way, unimpaired filtration back and forth between each pair of nets continues until a total
of 7 m3 has been processed from the discharge water stream. The sampling canisters are designed
to allow complete immersion of each net during the filtration process, thereby minimizing
trauma to filtered organisms.

Uptake and Discharge Analyses
       The proportion and total concentration of live  versus dead organisms > 50 |im will  be
determined using standard movement and response to stimuli techniques,  and this live/dead
analysis will take place within three hours of collecting the individual samples.  A volume of 3
m3 is collected for ambient water (high numbers of live organisms) and 7  m3 is  collected for
filtered water (presumably very few live organisms).  Depending upon concentrations,
quantification of organisms > 50 |im in ambient samples may require analysis of sub-samples
and extrapolation to the entire 3 m3.  The > 50 |im samples will then also be fixed with buffered,
10% formalin in 500ml Nalgene bottles and transported to the Smithsonian Environmental
Research Center (SERC) for additional taxonomic evaluation. Total counts and general
taxonomic classification will be conducted under a dissecting microscope at 25X, except for
some taxa, which will be removed and identified using a compound microscope. Larval forms of
invertebrates will be identified to higher taxonomic levels such as order (e.g., Decapoda)
suborder (e.g., Balanomorpha) or class (e.g., Bivalvia).  Adults will be identified to species in
most cases. The counts will be separated into 3  size classes:  total >50-|im (#/m3), >75 jim to
<120|im, and around  1 mm.

Viable Organism 10-50 f^rn in size
Uptake Sampling
       Since the uptake event is spread over several days, on each of three tank uptake (fill)
days, MERC will take 20L discrete samples (using MERC SOPs) for both challenge and potable
water.  Two liters from these well-mixed, integrated samples will be subject to three distinct
analyses and counts (described briefly below and in detail in SOPs)

Discharge Sampling
       A 75 L time integrated sample will be collected as an unfiltered split sample in parallel
with the > 50 jim fraction. This sample will be the source water for all other analyses including
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the 10-50 |im fraction. Two (2) liters from this well-mixed, integrated sample will be subject to
three distinct analyses and counts (described briefly below and in detail in SOPs).

Uptake and Discharge Analyses
       All live unfiltered samples will be processed or examined within three hours of collection
on the MERC Mobile Test Platform or at nearby partner laboratories.  All preserved samples are
also transported to MERC partner laboratories, for further analyses and taxonomic identification.

       One 250 ml sub-sample will be stained using a combination of CMFDA (5-
chloromethylfluorescein diacetate) and FDA (fluorescein diacetate) as a selective live/viable
indicator. Samples stained with CMFDA+FDA, are incubated and observed on a Sedgewick
Rafter slide using a Olympus IX-51 inverted phase/fluorescent microscope . Cells are scored as
live when showing strong fluorescence signature under excitation (some cells also show
motility). This approach has been validated for use in the Chesapeake Bay (Steinberg et al.,
2011) and provides the data for comparison to discharge standards. The counts will be separated
into 2 size classes: total >10 jim - >50 jim (#/ml), and <10 jim.

       As supporting information, two other sub-samples are analyzed. A second 250 ml is
collected and fixed with standard Lugol's solution in amber Nalgene bottles to estimate total cell
abundances (but not live versus dead) and for species identification under an inverted compound
microscope using grid settlement columns and phase contrast lighting. A third sub-sample is
filtered (Whatman GF/F 0.7 um pore, 47 mm diameter membrane) and frozen (-20ฐC) until
analysis of total active chlorophyll-a by the CBL/UMCES Nutrient Analytical Services
Laboratory using US EPA Methods 445.0 for extractive/fluorometric techniques.

Viable Bacteria and Indicator Pathogens

Uptake Sampling
       Since the uptake  event is spread over several days, on each of three tank uptake (fill)
days, MERC will take 20L discrete samples (using MERC SOPs) for both challenge and potable
water.  An unfiltered 1 L sample will be analyzed to determine concentrations of total
heterotrophic bacteria and three  specific indicator pathogens, E. coli, intestinal Enterococci, and
toxigenic Vibrio cholera (described briefly below and in detail in SOPs).

Discharge Sampling
       An unfiltered 1 L sample of water sub-sampled from an integrated 75 L sample will be
analyzed to determine concentrations of total heterotrophic bacteria and three specific indicator
pathogens, E. coli, intestinal Enterococci, and toxigenic Vibrio cholera (described briefly below
and in detail in SOPs).

Uptake and Discharge Analyses
       Total heterotrophic bacteria will be enumerated by spread plate method using MA or
R2A agar according to Standard Methods for the Examination of Water and Wastewater (21st
edition, 2005). The presence and abundance of E. coli and intestinal Enterococci is determined
using a commercially available chromogenic substrate method (IDEXX Laboratories, Inc.;  Noble
et al. 2003) and 10 ml and 100 ml water sample aliquots. Additionally, concentrations of
culturable E. coli and intestinal Enterococci are determined using a standard US EPA 1603
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method, namely, membrane filtration on mTEC agar (E. coif) (1 ml, 10 ml and 100 ml) and mEA
agar (Enter ococcus} (10 ml and 100 ml).  Finally, the abundance of total and toxigenic V.
cholerae will be determined by filtration and selection on TCBS agar and enumerated using
species-specific RNA colony blot (500 ul to 1 ml) and ctxA DNA colony blot (1-10 ml). Viable
toxigenic cells of V. cholerae are assayed with a commercial DFA kit specific for serogroup Ol
(New Horizons Diagnostics) using monoclonal antibodies tagged  with fluorescein isothiocyanate
(FITC) (Hasan et al. 1994).

Quantifying Physical Conditions
       During an uptake event, a muliparameter water quality instrument, deployed from the
barge at a depth of one meter, will  collect challenge water data every 15 minutes. Live data will
include temperature, salinity, dissolved oxygen, turbidity (NTU),  and chlorophyll fluorescence.
A barge-mounted weather station records data from air temp, pressure, wind speed and other
data.  Continuous live water quality and weather data can also be viewed at the MERC Mobile
Test Facility location in Baltimore can be viewed at www.maritime-enviro.org/Live.php.

       In the potable tank, temperature, salinity, dissolved oxygen, chlorophyll fluorescence,
and turbidity (NTU) will be measured every 15 minutes during the test trials using a multi-
parameter instrument (calibrated before each trial according to manufacturer's specifications)
deployed into the tank.

       During the discharge events, a hand-held instrument will also be used to measure
temperature, salinity, and dissolved oxygen of the filtered water in the zooplankton canisters 3
times during the event (beginning,  mid and end points).

Quantifying Water Quality Conditions

Uptake Sampling
       Since the uptake event is spread over several days, on each of three tank uptake (fill)
days, MERC will take 20L discrete samples (using MERC SOPs) for both challenge and potable
water.  Water will be processed to determine concentrations of total suspended solids (TSS),
particulate organic carbon (POC), and dissolved organic carbon (DOC). See MERC SOPs.

Discharge Sampling
       Water sub-sampled from an integrated 75 L sample will be processed to determine
concentrations of particulate organic carbon (POC), and dissolved organic carbon (DOC).
Subsamples will be collected at three time points (beginning, mid, near-end) to be processed for
concentrations of total suspended solids (TSS). See MERC SOPs.

Uptake and Discharge Analyses
       Frozen samples are transported to UMCES-CBL. Water chemistry analyses are
conducted by the UMCES-CBL Nutrient Analytical Services Laboratory (NASL) using EPA
methods (see MERC  SOPs).
                                          C-50

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                           Appendix C

Treatment Toxicity

Whole Effluent Toxicity Testing
       If the PWG employs chlorine disinfection, MERC will conduct one set of toxicity tests
for each discharge event. The testing is designed to meet IMO G9 requirements and uses test
methods and species employed by the EPA for Whole Effluent Toxicity (WET) testing of
effluents (EPA 2002 and ASTM 2006).

       A fish, an invertebrate and a plant (algae) will be used in all ballast discharge tests.
Because this study is evaluating the  use of potable water generators, primarily as a mechanism to
manage ballast water that will be discharged into the freshwaters of the Great Lakes and other
inland waters, freshwater organisms will be used in these tests. The vertebrate species used in
the test will be the fathead minnow (Pimephelaspromelas); the invertebrate species will be a
water flea (Ceriodaphnia dubia); and the microalgal species will be Pseudokirchneriella
subcapitata (formerly Selenastrum capricornutum), all listed as freshwater test species in EPA's
Short-term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to
Freshwater Organisms, Fourth Edition (EPA, 2002).

       Both acute and chronic data will be generated for each test. A dilution series, using deep
well water, will be run for each species. A total of 38 L samples will be collected at the time of
discharge from the potable tank.  This includes enough water to  do all of the test  renewals. Test
water will be stored in large HDPE containers and held at 4ฐC in the dark to retain as much of
the initial toxicity as possible. All of the tests will be conducted at the University of Maryland
Wye Research and Education Center toxicology laboratory and will be initiated within three to
four hours of the completion of a specific trial.

       Toxicity endpoints will include  survival in acute fish and invertebrate  tests, survival and
growth in chronic fish and invertebrate tests, and population growth in chronic algal tests as
required in Section 5.2.4 of the G9 document (IMO, 2008).  Tests are  designed with a dilution
series to allow calculation of daily LC50 (concentration yielding 50% lethality) values from
acute and chronic mortality data.  In addition,  chronic tests will include sufficient treatment
replication to allow calculation of NOEC  (no observable effect concentration), LOEC (lowest
observable effect concentration) and EC25 (percent concentration yielding a 25% effect) values
for all toxicity endpoints as required in  Section 5.2.5 of the G9 (IMO,  2008).  Statistical analyses
will be performed using ToxCalc  statistical software (TSS, 2006) according to methods from
USEPA (2002) and ASTM (2006) guidance documents.  A test trial will be considered a failure
on the grounds of residual toxicity upon discharge if acute lethality (as indicated  by
determination of an LC50 of less than 100%) occurs in any test species.

Evaluation of Chlorinated By-Products
       If the PWG employs chlorine disinfection, MERC will take samples for one set of
analyses for chlorinate by-products for  each discharge event. The analyses will be subcontracted
to ALS Environmental.

7. Test Trials
       MERC will conduct 3 to 5 replicate land-based testing trials of the PWG as a proof of
concept evaluation. With the anticipated 4 to 5 days required to fill a mimic ballast tank to
                                           C-51

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
approximately 150 m3 of potable water, the individual trial weekly schedule will involve: (a)
starting the PWG and first sample day on a Thursday, (b) followed by a second uptake sampling
day on Friday, (c) the PWG system would then continue to produce potable water and fill the
tank on Saturday and Sunday, (d) with a final uptake sampling day on Monday and the PWG
shutdown, and (e) the discharge sampling would then take place on Tuesday.  Required
maintenance (TBD) will take place as needed throughout the trial period and individual test trials
would be scheduled for every other week during the study period.

              Table 3. A summary of the trials to be conducted.
Trial #
Coml
1
2
3
4*
5*
Treatment
Potable Water Generator
Potable Water Generator
Potable Water Generator
Potable Water Generator
Potable Water Generator
Potable Water Generator
Trial Type
Commissioning
Biological
Biological
Biological
Biological
Biological
              *To be determined

8. Data Analysis
       As noted above, continuous time-integrated samples will be taken. Consequently, please
note that although certain assays employ replicates or sub-samples during analysis, to avoid
pseudo-replication, the unit of replication for statistical analyses is each trial (n = 4 or 5. We
assume that all measures for a single trial provide one estimate of treatment efficacy. Thus,
treatment efficacy for any biological parameter is estimated as changes found before and after
filtration (percent reduction), and as the difference in concentration between filtered water and
discharge standards. This approach controls for variation due to temporal changes in
environmental conditions.

       Quality Assurance and Quality Control policies and procedures, data recording
processing and storage, and detailed roles and responsibilities can be found in the MERC QMP,
QAPP and SOPs.

9. Evaluation Schedule (planned dates based on current plan and may vary):
    •  MERC Test Plan for the PWG system finalized and approved by ERG [DATE].
    •  Delivery and installation of PWG system, [DATE].
    •  MERC evaluation  of PWG system in Baltimore MD initiated by [DATE].
    •  MERC will complete sample analysis and compile data from the evolution by [DATE].
    •  MERC will distribute a draft report on the performance of the PWG system for review
       ERG and EPA [DATE].
    •  MERC will submit a final summary report to ERG and EPA by 28 Feb 2014.

10. References
ASTM. 2006. Standard Guide for Conducting Static Toxicity Tests with
       Microalgae. Designation E 1218-04. Annual Book of ASTM Standards Section Eleven
       Water and Environmental Technology Volume 11.06 Biological Effects and
       Environmental Fate; Biotechnology. ASTM International, West Conshohocken, PA.
                                         C-52

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                           Appendix C

Environmental Protection Agency. 2002. Guidelines establishing test procedures for the analysis
       of pollutants; whole effluent toxicity test methods. 40 CFR Part 136. Rules and
       Regulations Vol. 67, No. 223.

Environmental Protection Agency. 2002. Short Term Methods for Estimating the Chronic
       Toxicity of Effluents and Receiving Waters to Freshwater Organisms. Fourth Edition
       EPA-821-R-02- 013 (2002).

Guillard, R. L. 1975. Culture of phytoplankton for feeding marine invertebrates, pp. 29-60. In:
       Culture of Marine Invertebrate Animals. W.  L. Smith and M. H. Changley, eds., Plenus
       Publishing Corp., New York

Hasan, J. A., Huq, A., Tamplin, M. L., Siebeling, R. J. and R.R. Colwell. (1994). A novel kit for
       rapid detection of Vibrio cholerae Ol. JClinMicrobiol. 32: 249-252.

Miller, A.W., M. Frazier, G.E. Smith, E.S. Perry, G.M. Ruiz, andM.N. Tamburri, 2011.
       Enumerating Sparse Organisms in Ships' Ballast Water: Why Counting to 10 is Difficult?
       Environ. Sci. Tech., 45:3539-3546.

Steinberg, M.K., EJ. Lemieux, and L.A. Drake, 2011. Determining the viability of marine
protists using a combination of vital, fluorescent stains. Mar Biol 158:1431-1437.
                                          C-53

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                            Appendix C

        Appendix C.  Chemistry Including By-Products Compounds - Full Analyses

Full analysis results are provided on the following pages.
                                           C-54

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                    Appendix C
                   Environmental
     34 Dogwood Lane • Middletown, PA 17057 •  Phone: 717-9dd-55d1 • Fax: 717-9Jd-1430 i www.al5global.com

                               N E LAP Certifications: Nj PA010 , NY 11759 , PA 22-293  DoD E LAP: A2LA 0818.01
                                   State Certifications: DE ID 11 , MAPA0102, MD 128 , VA 460157, WV 343


         August 26, 2014
             Ms. Janet Barnes
             University of MD-UMCES - Solomons, MD
             P.O. Box 38
             146 Williams Street
             Solomons, MD 20688
                                         Certificate  of Analysis
      Project Name:      2014-MD BRACKISH WATER STUDY   Workorder:    2006708
      Purchase Order:                                         Workorder ID:  2014-MD BRACKISH WATER STUDY
      Dear Ms. Barnes:

        Enclosed are the analytical results for samples received by the laboratory on Wednesday, May 14, 2014.

        The ALS Environmental laboratory in Middletown, Pennsylvania is a National Environmental Laboratory
        Accreditation Program (NELAP) accredited laboratory and as such, certifies that all applicable test results meet the
        requirements of NELAP.

        If you have any questions regarding this certificate of analysis, please contact Ms. Debra J. Musser (Project
        Coordinator) at (717) 944-5541.

        Analyses were performed according to our laboratory's NELAP-approved quality assurance program and any
        applicable state requirements. The test results meet requirements of the current NELAP standards or state
        requirements, where applicable. Fora specific list of accredited analytes, refer to the certifications section of the
        ALS website at www.alsglobal.com/en/Our-Services/Life-Sciences/Environmental/Downloads.

        This laboratory report may not be  reproduced, except in full, without the written approval of ALS Environmental.

        ALS Spring City:  10 Riverside Drive, Spring City, PA 19475  610-948-4903
                                                                                                     -V.
      This page is included as part of the Analytical Report and                        Ms. Debra J. Musser
      must be retained as a permanent record thereof.                               Project Coordinator



                               ALS Environmental Laboratory Locations Across North America
       Canada: Burlington - Calgary - Centre of Excellence • Edmonton  Fort McMurray • Fort St. John • Crande Prairie • London - Mississauga • Richmond Hill - Saskatoon • Thunder Bay
      Vancouver Waterloo • Winnipeg Yellowknife United States: Cincinnati • Everett • Fort Collins • Holland • Houston • Middletown • Salt Lake City • Spring City • York Mexico: Monterrey

     Report ID: 2006708 - 8/26/2014                                                                                Page 1 of 26
                                                         C-55

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Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                          Appendix C
                      Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 •  Phone:717-944-5541 •  Fax: 717-944-1430 •  www.alsglobal.com

                                    NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                         State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                          SAMPLE SUMMARY


       Workorder: 2006708 2014-MD BRACKISH WATER STUDY

       Lab ID             Sample ID                           Matrix             Date Collected      Date Received      Collected By

       2006708001        Distribution 714 4260 Evergreen Ave     Water             5/13/201411:09    5/14/201410:15     Collected by Client

        Notes
         — Samples collected by ALS personnel are done so in accordance with the procedures set forth in the ALS Field Sampling Plan (20 -
             Field Services Sampling Plan).
         — All Waste Water analyses comply with methodology requirements of 40 CFR Part 136.
         — All Drinking Water analyses comply with methodology requirements of 40 CFR Part 141.
         -- Unless otherwise noted, all quantitative results for soils are reported on a dry weight basis.
         — The Chain of Custody document is included as part of this report.
         - All Library Search analytes should be regarded as tentative identifications based on the presumptive evidence of the mass spectra.
            Concentrations reported are estimated values.
         - Parameters identified as "analyze  immediately" require analysis within 15 minutes of collection. Any "analyze immediately" parameters
            not listed under the header "Field Parameters" are preformed in the laboratory and are therefore analyzed out of hold time.
         - Method references listed on this report beginning with the prefix "S" followed by a method number (such as S2310B-97)
            refer to methods from "Standard Methods for the Examination  of Water and Wastewater".

        Standard Acronyms/Flags
           J     Indicates an estimated value between the Method Detection Limit (MDL) and the Practical Quantitation Limit (PQL) for the analyte
           U     Indicates that the analyte was Not Detected (ND)
           N     Indicates presumptive evidence of the presence of a compound
         MDL    Method Detection Limit
          POL    Practical Quantitation Limit
          RDL    Reporting Detection Limit
           ND    Not Detected - indicates that the analyte was Not Detected at the RDL
          Cntr    Analysis was performed using this container
        RegLmt  Regulatory Limit
          LCS    Laboratory Control Sample
           MS    Matrix Spike
         MSD    Matrix Spike Duplicate
         DUP    Sample Duplicate
         %Rec   Percent Recovery
         RPD    Relative Percent Difference
          LOD    DoD Limit of Detection
         LOQ    DoD Limit of Quantitation
           DL    DoD Detection  Limit
                                     ALS Environmental Laboratory Locations Across North America
         Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon -  Thunder Bay
       Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City •  Spring City • York Mexico: Monterrey

      Report ID: 2006708-8/26/2014                                                                                               Page 2of26
                                                                  C-56

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                        Appendix C
                     Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 •  Fax: 717-944-1430 •  www.alsglobal.com

                                  NELAP Certifications: Nj PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                       PROJECT SUMMARY


      Workorder: 2006708 2014-MD BRACKISH WATER STUDY


       Workorder Comments

            Please see the attached EPA551 results analyzed by Week Laboratories, Inc. DJM
            Please see the attached EPA552 results analyzed by Eurofins. DJM

       Sample Comments

       Lab ID: 2006708001            SamP|e ID: Distribution 714 4260      Samp,e Type: SAMPLE
                                   Evergreen Ave
            Assuming that all bromate present in the sample is in the form of sodium bromate, the sodium bromate concentration is <5.9ug/L.
            Assuming that all chlorate present in the sample is in the form of sodium chlorate, the sodium chlorate concentration is 43.6 ug/L.
                                   ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London -  Mississauga - Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States; Cincinnati • Everett - Fort Collins • Holland •  Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey

      Report ID: 2006708 - 8/26/2014                                                                                         Page 3 of 26
                                                               C-57

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Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                    Environmental
      34 Dogwood Lane • Middletowri, PA 17057 • Phono: 717-944-5541 •  Fax: 717-9J4-1430  •  www.al5global.com

                                 NELAP Certifications: NJ  PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                     State Certifications:  DE ID 11 , MAPA0102, MD 128 , VA 460157 , WV 343

                                                   ANALYTICAL RESULTS
      Workorder: 2006708 2014-MD BRACKISH WATER STUDY
Lab ID: 2006708001
Date Collected: 5/13/201411:09 Matrix: Water
Sample ID: Distribution 714 4260 Evergreen Ave
Parameters
VOLATILE ORGANICS
Bromodichloromethane
Bromoform
Chlorodibro mo methane
Chloroform
1 ,2,3-Trichloropropane
Surrogate Recoveries
1 ,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
HERBICIDES
Dalapon
Surrogate Recoveries
2,4-Dichlorophenylacetic
acid (S)
WET CHEMISTRY
Bromate
Chlorate
METALS
Sodium, Total
Results Flag

ND
ND
ND
ND
ND
Results Flag
73.6
78.2

ND
Results Flag
106

ND
34.2

4.4
Units

ug/L
ug/L
ug/L
ug/L
ug/L
Units
%
A>

ug/L
Units
%

ug/L
ug/L

mg/L
Date Received: 5/14/201410:15
RDL

0.50
0.50
0.50
0.50
0.50
Limits
70-130
70-130

4.0
Limits
70-130

5.0
20.0

0.25
Method

EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
Method
EPA 524.2
EPA 524.2

EPA515.3
Method
EPA515.3

EPA 300.1
EPA 300.1

EPA 200.7
Prepared

5/20/14
5/20/14
5/20/14
5/20/14
5/20/14
Prepared
5/20/14
5/20/14

5/15/14
Prepared
5/15/14

5/20/14
5/20/14

5/21/14
By

TMP
TMP
TMP
TMP
TMP
By
TMP
TMP

JSH
By
JSH

SSL
SSL

AAM
Analyzed

5/20/1422:09
5/20/1422:09
5/20/1422:09
5/20/1422:09
5/20/1422:09
Analyzed
5/20/1422:09
5/20/1422:09

5/16/1418:48
Analyzed
5/16/1418:48

5/20/1413:48
5/20/1413:48

5/23/1405:20
By

TMP
TMP
TMP
TMP
TMP
By
TMP
TMP

EGO
By
EGO

SSL
SSL

ZMC
Cntr

B
B
B
B
B
Cntr
B
B

I
Cntr
I

H
H

G1
SUBCONTRACTED ANALYSIS
Subcontracted Analysis
See
Attached


Subcontract


7/31/1400:00
SUB
D
                                                                                 Ms. Debra J. Musser
                                                                                 Project Coordinator
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London • Mississauga • Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellowknife United Stales: Cincinnati • Everett • Fort Collins • Holland • Houston • Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2006708 - 8/26/2014
                                                                                                                  Page 4 of 26
                                                            C-58

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                               Appendix C
                     Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541  • Fax: 717-944-1430 • www.alsglobal.com

                                  NELAP Certifications:  NJ PA010 , NY 11759 , PA22-293   DoDELAP:  A2LA0818.01
                                       State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157  , WV 343


                                                    QUALITY CONTROL DATA
       Workorder: 2006708 2014-MD BRACKISH WATER STUDY
       QC Batch:         SVGC/34212

       QC Batch Method:  EPA 515.3

       Associated Lab Samples:  2006708001
                                                           Analysis Method:
                                                                                EPA515.3
METHOD BLANK: 2016997

Parameter
Dalapon
2,4-Dichlorophenylacetic
acid (S)
LABORATORY CONTROL SAMPLE
Parameter
Dalapon
2,4-Dichlorophenylacetic
acid (S)

Blank Reporting
Result Unjts Limit Qualifiers
ND ug/L 4.0
95 % 70 - 1 30

2016998
Spike LCS LCS % % Rec
Cone. units Result Rec Limit Qualifiers
5 ug/L 5.6 113 70-130
% 88 70-1 30

       MATRIX SPIKE SAMPLE: 2016999  ORIGINAL:
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.
                                   Original               Spike       MS     MS %     % Rec
Parameter
Dalapon
2,4-Dichlorophenylacetic
acid (S)
Result ynj(s Cone. Result
ug/L 5 5.5
%

Rec Limit
110 70-130
70- 130

Qualifiers



       MATRIX SPIKE SAMPLE: 2017000  ORIGINAL:
       ""NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                   Original
                                    Result
                                              Units
Spike
Cone.
  MS
Result
MS%
 Rec
% Rec
 Limit  Qualifiers
       Dalapon
       2,4-Dichlorophenylacetic
       acid (S)
                                              ug/L
                                                                  11.8
                                                                            237
                          70- 130
                          70- 130
                                   ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2006708 - 8/26/2014
                                                                                                                         Page 5 of 26
                                                               C-59

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                       Appendix C
                    Enuironmental
      34 Dogwood Lane  • Middletown, PA 17DS7 • Phone:717-944-5541  • Fax: 717-944-1430 •  www.alsglobal.com

                                 NELAP Certifications: Nj PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                     State Certifications:  DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343


                                                   QUALITY CONTROL DATA
      Workorder: 2006708 2014-MD BRACKISH WATER STUDY


      SAMPLE DUPLICATE: 2017001   ORIGINAL:

                                  Original                DUP               Max
      Parameter	Result     Units      Result      RPD      RPD  Qualifiers

      Dalapon                                ug/L        ND                30
      2,4-Dichlorophenylacetic                      %                100      130
      acid (S)
      2,4-Dichlorophenylacetic                      %                 2.6
      acid (S)
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland •  Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey

      Report ID: 2006708 - 8/26/2014                                                                                       Page 6 of 26
                                                             C-60

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                              Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7  •  Phone:717-944-5541  • Fax: 717-944-1430  •  www.alsglobal.com

                                  NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343


                                                    QUALITY CONTROL DATA
      Workorder: 2006708 2014-MD BRACKISH WATER STUDY
      QC Batch:         WETC/138176

      QC Batch Method:  EPA300.1

      Associated Lab Samples: 2006708001
                                                          Analysis Method:
                                                                               EPA 300.1
METHOD BLANK: 2018446

Parameter
Br ornate
Chlorate
LABORATORY CONTROL SAMPLE
Parameter
Br ornate
Chlorate

Blank
Result
ND
ND
2018447
Spike
Cone.
25
250


Units
ug/L
ug/L

Units
ug/L
ug/L

Reporting
Limit Qualifiers
5.0
20.0
LCS LCS % % Rec
Result Rec Limit Qualifiers
24.4 97.7 85-115
243 97.2 90-110
       MATRIX SPIKE: 2018449   DUPLICATE: 2018450   ORIGINAL: 2006965001
         CNOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spil
         :ent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                  Original
                                   Result
                                             Units
Spike
Cone.
  MS
Result
 MSD
Result
MS%
  Rec
MSD %
   Rec
% Rec
 Limit
                                                                                                           RPD
Max
RPD
                                                                                                                        Qualifiers
      Chlorate
                                              ug/L
                                                        250
                                                                 302
                                                                          277
                                                                                    110
                                                                                            99.9  75-125   8.69
                                                                                                                   25
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2006708 - 8/26/2014
                                                                                                                       Page 7 of 26
                                                              C-61

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                         Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com
                                 NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP:  A2LA0818.01
                                     State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157  , WV 343

                                                  QUALITY CONTROL DATA
      Workorder:  2006708 2014-MD BRACKISH WATER STUDY

      QC Batch:         VOMS/32695
      QC Batch Method:  EPA 524.2
      Associated Lab Samples:  2006708001
Analysis Method:
                    EPA 524.2
METHOD BLANK: 2018766

Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)

Blank
Result
ND
ND
ND
ND
ND
75.8
75.7
2018767
Spike
Cone.
1
1
1
1


2018768
Spike
Cone.
5
5
5
5
5




Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Reporting
Limit
0.50
0.50
0.50
0.50
0.50
70 - 1 30
70-130
LCS
Result
1.0
1.2
0.99
0.88


LCS
Result
4.8
5.1
5.4
5.0
5.7




Qualifiers







LCS %
Rec
102
120
98.6
88.2
87.6
88.7
LCS %
Rec
96.1
102
108
99.3
113
103
95.6










% Rec
Limit Qualifiers
50 - 1 50
50 - 1 50
50 - 1 50
50 - 1 50
70 - 1 30
70 - 1 30
% Rec
Limit Qualifiers
70 - 1 30
70-130
70 - 1 30
70 - 1 30
70 - 1 30
70 - 1 30
70-130
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland •  Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2006708 - 8/26/2014
                                                                                                                   Page 8 of 26
                                                            C-62

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                    Enuironmental
      34 Dogwood Lane  • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com
                                 NELAP Certifications: Nj PA010 , NY 11759 , PA22-293   DoDELAP: A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                   QUALITY CONTROL DATA
      Workorder: 2006708 2014-MD BRACKISH WATER STUDY

      MATRIX SPIKE: 2019023   DUPLICATE: 2019024  ORIGINAL: 2006905001
      ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
      percent recoveries. This result is not a final value and cannot be used as such.
Parameter
Chloroform
Bromodichloromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
4-Bromofluorobenzene (S)
1,2-Dichlorobenzene-d4 (S)
Original
Result Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%
Spike
Cone.




5


MS
Result
4.2
5.1
5.6
5.3
6.2


MSD
Result
4.0
5.3
5.3
5.1
5.5


MS%
Rec




124
106
110
MSD %
Rec




109
99
101
% Rec
Limit




70
70
70




- 130
- 130
- 130
RPD
5.26
2.53
5.52
3.86
12.5
6.79
8.94
Max
RPD
40
40
40
40
40


Qualifiers







                                  ALS Environmental  Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2006708 - 8/26/2014
                                                                                                                      Page 9 of 26
                                                             C-63

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                  Appendix C
                     Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541  • Fax: 717-944-1430 • www.alsglobal.com

                                  NELAP Certifications:  NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                       State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343


                                                    QUALITY CONTROL DATA
       Workorder: 2006708 2014-MD BRACKISH WATER STUDY
       QC Batch:         MDIG/45493

       QC Batch Method:  EPATRMD

       Associated Lab Samples:  2006708001
                                                           Analysis Method:
                                                                                EPA 200.7
       METHOD BLANK: 2018853
       Parameter
                                     Blank
                                    Result
                                              Units
Reporting
    Limit  Qualifiers
       Sodium, Total
                                      ND
                                              mg/L
                                                         0.25
       LABORATORY CONTROL SAMPLE: 2018854
       Parameter
                                    Spike
                                    Cone.
                                              Units
    LCS
   Result
LCS %
  Rec
% Rec
 Limit  Qualifiers
       Sodium, Total
                                       10
                                              mg/L
                                                         10.7
                                                                  107   85-115
       MATRIX SPIKE: 2018855   DUPLICATE: 2018856  ORIGINAL: 2007347003

       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix i

       percent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                   Original
                                    Result
                                              Units
   Spike
   Cone.
   MS
Result
 MSD
Result
MS%
  Rec
MSD %
   Rec
% Rec
 Limit
       Max
RPD   RPD
                                                                                                                          Qualifiers
       Sodium, Total
                                              mg/L
                                                                  41.2
                                                                           42.8
                                                                                                             3.87
                                                                                                                     20
       MATRIX SPIKE SAMPLE: 2018857  ORIGINAL:
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.

                                                                   MS
       Parameter
                                   Original
                                    Result
                                              Units
   Spike
   Cone.
                                                                Result
          MS%
            Rec
         % Rec
           Limit  Qualifiers
       Sodium, Total
                                              mg/L
                                                                  916
                                   ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2006708 - 8/26/2014
                                                                                                                        Page 10 of 26
                                                               C-64

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                       Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430  •  www.alsglobal.com

                                 NELAP Certifications: Nj PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                     State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                   QUALITY CONTROL DATA CROSS REFERENCE TABLE


      Workorder:  2006708 2014-MD BRACKISH WATER STUDY

                                                                                                            Analysis
      Lab ID                   Sample ID                Prep Method             Prep Batch     Analysis Method       Batch

      2006708001              PW1-DC-P                EPA515.3               SVGC/34212   EPA515.3            SVGC/34214


      2006708001              PW1-DC-P                                                   EPA300.1            WETC/138176


      2006708001              PW1-DC-P                                                   EPA 524.2            VOMS/32695


      2006708001              PW1-DC-P                EPATRMD              MDIG/45493    EPA200.7            META/44389
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown •  Salt Lake City • Spring City • York Mexico: Monterrey

      Report ID: 2006708-8/26/2014                                                                                    Page 11 of 26
                                                            C-65

-------
O
                      r
                      (/i
                                      CALS)
                               Environmental
34 Dogwood Lane       y^A
Middlctown, PA 1705? >s. 0
p. 717-944-5541         \^
F.717-944-1430
                                                                                              CHAIN OF CUSTODY/
                                                                                           REQUEST FOR ANALYSIS
                                                                                                       Page
                              Co. Name:
                              Contact
                              Address:
                                        Phone:
                              Om to (fd
                              Project Name/*: fCO 1.- DC
                                                                              ALS Quote *:
                               Email?

                                 fit!
V Nwrnil-SaiKfard TAT iซ 10-12 busiiMss days.

   Rush-Subject to ALS approval and surttetps.
                                                                              Date RecuirMl
                                        ,-y  no.,	
                                 Sample Description/Location
                                                                    COC Comments
                                                                   1^—-oT
                               *MPLED BY (Ptose Print):
                                                liiil.
                                     Relinquished By / Company Name
                                   JQซ. V
                                                                                         Sanijte
                                                                                                MMary
                                                                                   Cfr
                                                                                                                     Cl
                                                                                                                                                                   *2OO67O8
                                                                          IL
                                                                                                                                     Em
                                                                                                     H-
                                                                                                                           ANALYSESr^METHOD REOJESTED
                                                                         1
                                                                                                                                 8
                                                                                                                                 Ob
ci
300.
O
                                                                                                                                            Jo
                                                                                                                          Enter Number of Containers Per Analysis
                                  Date
                                           TTO
                                                                                             Received By/Company Name      Date  Time
                                                                                        10
                                                                               VStandard

                                                                              [~|gp-lite

                                                                              |  [
                                                                                                                                         n
                                                                                                 1


n
n
                                                                                                                                    HOD Cfittrta Rซ]ulซ(l?   A^
                                                                                                                                                        O
                                                                              "Container Typซ: AG-Amlwr Glass; CG-Clear Gla*
                                                          Hmr. GWmStaiaatmtv. Ol=OII; Qlซ0
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                  Appendix C
          VVulL
WECK LABORATORIES, INC.
                                                     CERTIFICATE OF ANALYSIS
                                                                                             Analytical laborat
Client: ALS Environmental - PA
34 Dogwood Lane
Middtetown PA, 17057

Attention: Debra Musser
Phone: (800) 794.7709
Fax: (717)944-1430
Work Orderts): 4E16027
Report Date:
Received Date:
Turn Around:
Client Project:



07/31/14 13:15
05/16/14 10:30
Normal
2006708



                                  NELAP (KH229CA ELAP#1132 NEVADA *CA211  HAWAII LACSD #10143

        The results in Otis report apply to the samptes analyzed In accordance with me Chain of Custody document. Week Laboratories, Inc.
        certifies that the test results meet a# NELAC requirements unless noted in the case narrative. This analytical report is confidential and is
        only intended for the use of Week Laboratories, Inc. and its client. Tnis report contains the Chain of Custody document, which is an integral
        part of it, and can only be repfoduceH In fun with the authorization o! Week Laboratories, Inc.

        Dear Debra Musser:

        Enclosed are the results of analyses for samples received 05/16/14 10:30 with the Chain of Custody document. The samples
        were received in good condition, at 8,4 "C and on tee. All analysis met the method criteria except as noted below or in the report
        with data qualifiers.

        Case Narrative:
        SUPP report generated to include mono compounds.  BG 7/31/14

        Reviewed by:
       Brandon Gee
       Project Manager
                     Vปck Laiwotortes, Inc  KSSa ฃau Gtark Avenue. City of Innusny. California 9!?i:,-l3g6  ,5Z6) 33-6-2'33  FAX (626)
            Tne results in this report apply lo the umplซs tmfyiea in aomrdanw with the chain oป cซsซdj d
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                     Appendix C
          WiiL
WECK LABORATORIES, INC.
                                                                                          An-siyUcal Ijborrmj.'y Servfw - Since }
        ALS Environmenial - PA                                                               Date Received:    05/16/14 10:30
        34 Dogwood Lane                                                                    Dale Reported;    07/31/1413:15
        Middtetown PA, 170S7
                                                 ANALYTICAL REPORT FOR SAMPLES

        Sample ID                         Sampled by:    Sample Comments                         lab ID     Mwrt<      Date Sampled

        2006708                          Own]                                            4E56027-01    Water      05/13f1ซ 00:0ซ
        DBPaOy 6PA 551.1
                                                                                                              Page 20(8
            Thซ results in 
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                         Appendix C
          WnL
                                       WECK LABORATORIES, INC.
        ALS Environmental - PA
        34 Dogwood Lane
        Midjfletown PA, 17057
        Sampled: 05/13/1400:00
4E1602701      2006708
      Sampled By:  Client
   DBPs by EPA 551.1
                                      Analytical labafrKiHySprvtTe - Sipi.*- l%d

                                      Date Received:   05/1S/14 10:30
                                      Date Reported:   07/31/1413:15
                                                                                                             Matrix: Water
Method: EPA 551.1
Analyte
1,1,1 -trichlof o*2-propafK*rie
l,l-O!ehlซa-2-propaf>one
Bramachloroacetonitrte
Chloral hydrate
Chloropicrin
Oi&romoaceumitrile
Dichloroscatonltrife
TricntoroacetonitriSe
Surr Decsflaomtiipbenyl
Batch: W4E1377
ResuK
ND
NO
NO
ND
ND
ND
ND
ND
S9%
Prepared: 05/27/14 14:18
MRL Unite
O.SO
0,60
0.50
0.60
0.50
0.50
0,50
0.50
ConcS.SS 80-120
ug'l
ugfl
ugrt
ugrt
ugA
ug/f
ug/1
ugfl
%
Analyst:
Oil Analyzed
1 05/3W14 05:39
1 05/30/14 05:39
1 05/3W14 05:39
1 05/30rt4 05:39
1 05/30/14 05:39
1 05/30/14 05:39
1 06/30/14 05:39
1 OS/30/14 05:39

JyNet ChDotipanya
Qualifier









                    Wees Ufcaralofres, I,TC HS69 East Clan-. Aปw,uc. Cily of mcuury. CaSIomio 31715-- 386  1025) 316-2139  FAX J626? 3:>.6-263ซ
            The result in this report apply B ihe sปmplซ* awlyied in accordance wilh (he chan ซ u/stoOy decumenl. This snaljtieal repoit must be repraducad in ils enliiely
                                                        www.wacklaftB.com
                                                                                                                Page 3 of 6
                                                                                                          ALS
                                                          C-69

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                         Appendix C
           Wi,IL
WECK LABORATORIES, INC,
                                                                                                   Acrylics! Lat)Offit;5fy SS?v^.e - Sines; 196*5

         ALS Environmental - PA                                                                      Date Received:    05/16/1410:30
         34 Dogwood Lane                                                                           Date Reported:    07/31/14 13:15
         Middletown PA, 17057

                                                       4E16027-01RE1      2006708
         Sampled: 05/13/1400:00                                    Sampled By: Client                                       Matrix: Water

                                                            DBFs by EPA 551.1
         Method; EPA 551.1                       Batch: W4G0414         Prepared: 07rtW1410:39                     Analyst: Juliet Choolipanya
         Anaiyte	Result	MRL	Units       mi      Analyzed	Qualifier
         BfomoacetcmMe                                  ND                   O50       iigfl1   07/09/14 22:01             oTT"
         CWoroaceionitrite                                  HO                   0.50       ug/t       1   07/09/1422:01             O-14
         Sutr Decafiuomtoiphenyl                            86%    Conc:8,60    80-120       %                                    O-14
                     VปOt UHxreteriai. Inc  HSS9 LSE1 Ctar* Aver-ue. Clly of inoustr,', CoKlointa 9 nt!j-;S'.!6   1628) JSe-i 138  FAX (ง2Si 336-;i>j5
            TNs resulti in Ihis report spply to the samples analyzed in accordance with the chain at o,5)o!!> aoeunlenl. This analytical report mus, De 1CT>rodl*ced in .11 eniirirty
                                                            www.weck3sM.corn
                                                                                                                  ALS
                                                               C-70

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                 Appendix C
         W  1,1  L
WECK LABORATORIES, INC.
       ALS Environmental - PA                                                        Date Received:   05/16/14 10:30
       34 Dogwood Lane                                                            Date Reported:   07/31/1413:16
       Middletown PA, 17067
                                    QUALITY   CONTROL
                                               SECTION
                  VMS** tsbcrstoriss, Ire  1
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
         WnlL
                                                                                   WECK LABORATORIES, INC.
IIIIIIIIIIIIIIM 1 —
ALS Environmental - PA
34 Dogwood Lane
Mtddletown PA, 17057
Batch W4E1377 - EPA 551.1
AruMyte
Blank (W4E1377-BLK1)
1,1.1 -tricWoro-2-pf opanone
1 , 1 -Dichtoro-2-pr opanone
Bromochloroacelonitrile
Chloral hydrate
Chtoraplcrtrt
Dibfomoacewnltrile
QicMoroacetonilrite
Trlchloroacetonilrlle
Sun-. Decaltvombiphenyl
LCS (W4E1 J77-BS1)
1,1.1 -trichloro-2-propanone
1 , 1 -DichlOf o-2-propanone
Bromochlofoacetonitrile
Chloral hydrate
Chforopierin
DBwomoaceloniMe
Dicttforoacetonil/ite
Trichtaroacetonilrile
Surr: Oecafluorubipttenyt
LCS Dgp (W4E1377-BSO1)
t , 1 , 1 -trichloro-2-propBnone
1 ,1-Oichloro-2-propanone
Bromochloroacetonitrile
Chloral hydrate
Chloropierin
Dibromoaeetonitrile
Dich&oroacetonitrife
Trichfofoacetonitrtle
Su/r. Decatiuorobiphetryl
Batch W4G0414 - EPA 551.1
Armlyle
Blank (W460414-BLK1)
Bromoacetofiitrile
Chloroacelonitrile
Surr: Decafluorvbipftenyi
LCS(W400414-BS1)
Bromoacetonilrile
Chloroacetortitrjle
Sun-: Decattuoto&ipheny/

•Aw* Lssoralc.-i8s. Me
DBPsbyEPASSL

Result

ND
ND
ND
ND
ND
ND
ND
ND
916

10.9
10.6
8,65
12.8
8.74
8.70
10.6
8.98
9.11

11.1
10.4
10.0
11.9
9.37
9.B6
10.8
9.52
10.4

Result

MRL

0-50
0.50
0.50
0.50
0.50
0.50
0.50
0.50


0.50
0.50
0.50
0.50
0.50
0.50
0.50
0.50


0.50
0.50
0,50
0.50
0.50
0.50
050
0.50


MRL
1 - Quality Control

Units

t/g/f
ug/l
ug/l
U3/1
ug/l
ug/l
ug/l
ug/l
ugf

ug!fl
ug/l
ug/l
us/I
ug/i
ugfl
ug/l
ug/l
ug/l

ug/l
ugfl
ug/l
ug/l
ug/l
ug/l
ug/l
ugfl
ug/l

Units

Spike
' Level
Analyzed:








10.0
Analyzed:
10.0
10.0
10.0
10.0
10.0
10,0
10,0
10.0
10.0
Analyzed:
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0

Spike
Level

IS ซE<:
: 05/30/14 04:24








92
05/30/14 04:49
109
106
90
128
87
87
106
90
91
05/30/14 05:14
111
104
100
119
94
99
108
95
104

Source
Result *ReC
Analyzed: 07/09/14 20:46
ND
ND
8 .68
o.so
0,50

ug/I
ug/l
ucrf


10.0


87
Analyzed: 07/09/14 21:11
9.06
8.92
9.47

I'Sesy Cast Ciar* Aver.t,
0.50
0.50


x City of TOL'ttry. C
ug/1
ug/l
ซ9*

.BlPtanla
10.0
10,0
10.0

9 INS-? 396
91
89
95

(M6133S-2139
Analytical Laburauxy VfviV.f- - "sif :<• !9<>s
Date Received: 05/16/1410:30
Date Reported: 07/31/14 13:15

% REC RPD
Hpn
Limits "Ku UrnK









80-120

75-125
75-125
75-125
75-125
75-125
75-125
75-125
75-125
80-120

75-125 1 25
75-125 2 25
75-125 11 25
75-125 7 25
75-125 7 25
75-125 12 25
75-125 1 25
75-125 6 25
80-120

% REC RPD
Limits RPD Limil



8O-120

80-120
80-120
SO- 120

TAX (S26) 336-2S34

Data














Q-oa
















Data








Page 6 or 8

          The resuls ,n this report acply ID she samples analyzed in accordance win the cRain or custody document This iwulyticol report mus! 66 raproduced .1 us, enti
                                                                                                ALS
                                                     C-72

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                                             Appendix C
                                                                                                      WECK LABORATORIES, INC.
         ALS Environmental • PA
         34 Dogwood Lane
         Middlefown PA, 170S7
                                                      DSP's by EPA 551.1 - Ouality Control
                                                                                         Data Received:
                                                                                         Date Reported:
                                                      05/16/14 10:30
                                                      07/31/1413:15
         Batch W4G0414 - EPA SS1.1
          Analyte
                                                                                 Spike
                                                                                                         RPO
                                                                                                         Limit
                                                                Data
                                                            QyatifJera
          LCS Dop (W4G0414-BSD1)
                                                                              Analyzed; 07/10/14 12:44
           Bromoacelonltrtle
           CMoroacetonitrile
           Surr Decafltiopo&iphenyt
                                       10.7
                                       10.5
                                       70.2
0.50
0.50
ug/l
ug/i
ug/i
10.0
10.0
10.0
107
105
102
8O-120
80-120
80-120
17
16
25
25
          VNtecft L8boreU''ies. Inc  KBbti GaatCtertt^
the resuiSs in this report apply to she ซampfซs analyzed in a
                                                                                                                            Page ? of 9
                                                        uc. City cf Incustry. CtifO
                                                        r^stiCB w^ih she cha.n o? c
           lKIMl-1395   (525)336-2133   FSX (626) 336-26M
           cdy docyrraenl. Th?s an^l^caf repeal my&t bซ reprtiduced tn us eftli!
                                                                                                                     ALS
                                                                C-73

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                            Appendix C
                                                                                                             WECK LABORATORIES, INC,
         ALS Environmental - PA                                                                            Date Received:    05/16/14 10:30
         34 Dogwood Lane                                                                                  Date Reported:    07/31/14 13:15
         Middletown PA, 17057
                                                            Notes and Definitions
         Q-QS      Hjgh bias in the QC sample does mtt affect sampte result since analyte was not detected or below tfta reporting limit.
         O-14      This analysis wis requested b> the clktnl aBer the holslnrj time was exceeded.
         ND       NOT DETECTED al or abam the Reporting Lljni!.  If J-valuo reported, then HOT DETECTED at or above the Meshos Detection unit (MDL)
         NR       Not ReponaUc
         Dii        DMueion
         dry       Sample results reported ot\ a dry weight feasta
         RPD       ffeSatw* Peroent D*fteremป
         % Rec     Pewsert! Recovery
         Sub       Subcontracted analysis, original report available upon request
         MOL       l.let-iod Dttoct.on Limit
         MDA       Minimum Deteoabte Aolvity
         MRL       Method Reporting Limit
        Any remaining samp(e(s> wil be disposed of one month from (tie final report dale unless other arrangements are made in advance,
        An Absence of Total Conform meets !he drinking watef standards as esiabBshed by Irte California Department or Heallh Services,
        The Reporting LimH (RL) is referenced as the Laboratory's Practical Quanfflation Limit (PQI.) or trie Detection Limit for Reporting Purposes
        (DLR).
        AM samples collected by Wreck Laboralories have been sampled In accordance (o laboratory SOP Number MISQ02.
                        WfeOc U: 3
                                                                                                                                    Page 8 of 8
             Tfca results in in is report aoply to the samples analyzed in accordance with the cJiain or eutiody documenl n>ป atsalj-tical report muss be reproduced n Us entirety
                                                                                                                             ALS
                                                                     C-74

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                     Appendix C
        v?eurofins
                              Eaton Analytical
                   110 South Hil!Smซ
                   South Bend, (N 
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                                      Appendix C
      Client Name:    ALS
                                                                                        Report*:  317971
      Sampling Point:   2006708 001
                                                                                        PWS ID:  Not Supplied
t EEA hปs demonstrated it can achieve these report limit
                                MCL
                                          n reagent water, byt can not document t&em in all sample rasaldces
                                                        Page 2 of 3
                                                                                                        ALS
                                                         C-76

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                             Appendix C
        Client Name:     ALS                                                                                Report*:  317971


                                                                     Lab Definitions

                     Continuing Calibration Check Standard (CCC) / Continuing Calibration Verification (CCV) I Initial Calibration
                     Verification Standard (ICV) / Initial Performance Check (IPC) - Is a standard containing one or more of (he large!
                     anatyles that is prepared from the same standards used to calibrate the instrument. This standard is used to verify
                     the calibrate curve at the beginning of each analytical sequence, and may also be analyzed ttiroughoul and at the
                     end of Ihe sequence. The concentration of continuing standards may be varied, when prescribed by the reference
                     meihod, so 1hal the range of the calibration curve Is verified on a regular basis.

                     Internal Standards (IS) • are pure compounds with properties similar to the analytes of Interest, which are added to
                     field samples Of extracts, calibration standards, and quality control standards al a known oortcenlration. They are
                     used to measure the relative responses of Ihe anafytes of interest and siwogates in Ihe sampte, calibration standard
                     or quality control standard,

                     Laboratory Duplicate (LD) - is a field sample aliquot taken from the same sample container in the laboratory and
                     analyzed separately using identical procedures. Analysis of laboratory duplicates provides a measure of the
                     precision of the laboratory procedures.

                     Laboratory Fortified Blank (LFB) I Laboratory Control Sample (LCS) - is an aliquot of reagent water to which
                    known concentrations of the analytes of interest are added. The LFB is analyzed exactly the same as the field
                    samples. LFBs are used to determine whether the method is in control.

                    Laboratory Method Blank (LMB) I Laboratory Reagent Blank (LRB) - is a sample of reagent water included in the
                    sample batch analyzed in the same way as the associated field samples. The LM8  is used to determine tf meihod
                    analytes or other background contamination have been introduced during Ihe preparation or analytical procedure.
                    The 1MB is analyzed exactly Ihe same as the field samples.

                    Laboratory Trip Blank (LTB) / Field Reagent Blank (FRB) • is a sampte of laboratory reagent water placed in a
                    sampie comainer in the laboratory and treated as a few sample, including swage,  preservation, and all analytical
                    procedures. The FRBA.TB container foBows Ihe cofledion bottles to and from the collection site, but Ihe FRRfLTB is
                    nol opened at any time during me trip. The FRB/LTB  is primarily a travel blank used to verify Ihat the samples were
                    not contaminated during shipment.

                    Matrix Spike Duplicate Sample (MSD) / Laboratory Fortified Sample Matrix Duplicate (LFSMD). is a sample
                    aliquol taken from the same Held sample source  as Ihe Matrix Spike Sampte to which known quanlities of Ihe
                    analytes of interest are added in the laboratory. The MSD is analyzed exactly the same as Ihe field samples.
                    Analysis of Ihe MSO provides a measure of the precision of Ihe laboratory procedures In a specific matrix.

                    Matrix Spike Sample (MS) / Laboratory Fortified Sample Matrix (LFSM) - is a sample aliquot taken from Itetd
                    sample source to which known quantities of (he analytes of Merest are added in the laboratory. The MS is analyzed
                    exactly the same as the field samples. The purpose is to demonstrate recovery of the analytes from a sample matrix
                    to determine if the Specific matrix contributes bias to the analytical results.

                    Quality Control Standard (QCS) / Second Source Calibration Verification (SSCV) - Is a solution conlaining
                    known concentrations of the analytes of interest prepared from a source different from the source of the calibration
                    standards. The solution is obtained from a second manufacturer or lol If Ihe tot can be demonstrated by the
                    manufacturer as prepared independently from other lots. The QCS sample is analyzed using the same procedures
                    as Held samples. The QCS is used as a check on the  calibration standards used in the meihod on a routine basis.

                    Reporting Llm It Check (RLC) / Initial Calibration Check Standard (ICCS) - is a procedural slandard that is
                    analyzed each day to evaluate instrument performance at or below the minimum reporting limil (MRL).

                    Surrogats Standard (SS) / Surrogate Analyte (SUR) - is a pure compound with properties similar to the analytes of
                    interest, which is highly unlikely to be found in any field sample, that is added lo Ihe field samples, calibration
                    standards, blanks and quality control standards before sample preparation. The SS is used to evaluate Ihe efficiency
                    of the sampie preparation process.
                                                                      Page 3 of 3
                                                                                                                                ALS
                                                                      C-77

-------
          4ฃeurofins
                               Eaton Analytical
                                         Eurofms Eaton Analytical
                                                 Run Log
                                      Run ID:  191203    Method;   $52,2
             Tvpg
             CCL
             LMB
              FS
             ccc
Sample Id
 3032520
 3032517
 3029940
 3D32518
Sample Site
2006708001
Matrix
 RW
 KIN
 OW
 RW
Instrument 10
    BP
    BP
    BP
    6P
 Analysis Date
OSQ3G014 16:34
05/23(2014 17:09
OM3Q014 17:45
OS24/2014 00:09
Calibration rile
SS2_2-Q52214BP
552_2.052214BP
552J-052214BP
552 2-052214BP
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          Page 1 of 3
                                                                                                                    EEA Run iO 191203 / EEA Report # 317971
                                                                                                                                        X
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-------
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                        r
                                                                                                           QC Summary Report
                                                                                                                    7730    |i   To   |f   uyi    |,   77  "I  SO. 150  |!~—

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                                                                          SM?	j[~ 20 1    300WBOQ1   J  '  ]'


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                                                                                                                            400

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                                                                       			 Oy2MC140;40 [ OM47014IXI09 I ป82iซ8]


                                                                       5   ^70 1JO IP---"]  — ^[lO  J D5??i7014D740 1 OS/2AI2S1400-09 j 3002516j



                                                                                      EEA Run ID 191203 / EEA Report # 317971
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-------
                                                                                          QC Sufnmafy Report (cont.)
                                                                                      Resuil
            _pCC_Jl
                                                                                                          Tmga
                                                                                                                                     Recovery

                                                                                                                                      Llnita
F1PO  RPD II  Oil

     Urnlt  Factor
EEA


ID*
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                                                                                                                                                                                                         I3
             Page 3 of 3
                                                                                                                                               EEA Run ID 191203 / EEA Report # 317971
                                                             X

                                                             o

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                     Appendix C
                   Enuironmental
     34 Dogwood Lane • .Middletown. PA 17057 • Phone: 717-944 5541  •  Fax: 717-9J1-1J30 • www.alsglobal.com

                               NELAP Certifications: NJ PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                   State Certifications: DE ID 11 , MAPA0102, MD 128 , VA 460157 , WV 343


         August 26, 2014
              Ms. Janet Barnes
              University of MD-UMCES - Solomons, MD
              P.O. Box 38
              146 Williams Street
              Solomons, MD 20688
                                         Certificate of Analysis
      Project Name:     2014-MD BRACKISH WATER STUDY  Workorder:     2009393
      Purchase Order:                                         Workorder ID:  PW2-DC
      Dear Ms. Barnes:

        Enclosed are the analytical results for samples received by the laboratory on Thursday, May 29, 2014.

        The ALS Environmental laboratory in Middletown, Pennsylvania is a National Environmental Laboratory
        Accreditation Program (NELAP) accredited laboratory and as such, certifies that all applicable test results meet the
        requirements of NELAP.

        If you have any questions regarding this certificate of analysis, please contact Ms. Debra J. Musser (Project
        Coordinator) at (717) 944-5541.

        Analyses were performed according to our laboratory's NELAP-approved quality assurance program and any
        applicable state requirements. The test results meet requirements of the current NELAP standards or state
        requirements, where applicable. Fora specific list of accredited analytes, refer to the certifications section of the
        ALS website at www.alsglobal.com/en/Our-Services/Life-Sciences/Environmental/Downloads.

        This laboratory report may not be reproduced, except in full, without the written approval of ALS Environmental.

        ALS Spring City: 10 Riverside Drive, Spring City, PA 19475 610-948-4903
      This page is included as part of the Analytical Report and                         Ms. Debra J. Musser

      must be retained as a permanent record thereof.                                Project Coordinator



                                ALS Environmental Laboratory Locations Across North America
       Canada: Burlington - Calgary • Centre of Fxcellence - Fdmonton • Fort McMurray - Fort St. John • Grande Prairie • 1 ondon - Mississauga - Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellow/knife United States: Cincinnati  • Everett  Fort Collins - Holland •  Houston • Middletown > Salt Lake City • Spring City - York Mexico: Monterrey

     Report ID: 2009393 - 8/26/2014                                                                                 Page 1 of 27
                                                         C-81

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                                                       Appendix C
               Enuironmental
34 Dogwood lane • Middletown, PA 170S7 ป Phone:717-9445541  • Fax: 717-944-1430 • www.3lsqlobal.cam
                              NELAP Certifications: NJ PA010, NY 11759, PA22-293  DoD ELAP: A2LA0818.01
                                  State Certifications:  DE ID 11 , MAPA0102 , MD 128 , VA460157 , WV 343

                                                    SAMPLE SUMMARY
 Workorder: 2009393 PW2-DC
Lab ID
2009393001
2009393002
Sample ID
PW2-DC-P/Merc Barge
Trip Blank
Matrix
Water
Water
Date Collected
5/28/201410:50
5/29/201410:00
Date Received
5/29/201410:00
5/29/201410:00
Collected By
Ms. Janet Barnes
Ms. Janet Barnes
  Notes
   —  Samples collected by ALS personnel are done so in accordance with the procedures set forth in the ALS Field Sampling Plan (20 -
       Field Services Sampling Plan).
   ~  All Waste Water analyses comply with methodology requirements of 40 CFR Part 136.
   —  All Drinking Water analyses comply with methodology requirements of 40 CFR Part 141.
   —  Unless otherwise noted, all quantitative results for soils are reported on a dry weight basis.
   —  The Chain of Custody document is included as part of this report.
   --  All Library Search analytes should be regarded as tentative identifications based on the presumptive evidence of the mass spectra.
      Concentrations reported are estimated values.
   -  Parameters identified as "analyze immediately" require analysis within 15 minutes of collection. Any "analyze immediately" parameters
      not listed under the header "Field Parameters" are preformed in the laboratory and are therefore analyzed out of hold time.
   —  Method references listed on this report beginning with the prefix "S" followed by a method number (such as S2310B-97)
      refer to methods from "Standard Methods for the Examination of Water and Wastewater".

  Standard Acronyms/Flags
     J     Indicates an estimated value between the Method Detection Limit (MDL) and the Practical Quantitation Limit (PQL) for the analyte
     U     Indicates that the analyte was Not Detected (ND)
     N     Indicates presumptive evidence of the presence of a compound
   MDL    Method Detection  Limit
   PQL    Practical Quantitation Limit
   RDL    Reporting Detection Limit
    ND    Not Detected - indicates that the analyte was Not Detected at the RDL
   Cntr    Analysis was performed using this container
  RegLmt   Regulatory Limit
   LCS    Laboratory Control Sample
    MS    Matrix Spike
   MSD    Matrix Spike Duplicate
   DUP    Sample Duplicate
   %Rec   Percent Recovery
   RPD    Relative Percent Difference
   LOD    DoD Limit of Detection
   LOQ    DoD Limit of Quantitation
    DL    DoD Detection Limit
                              ALS Environmental Laboratory Locations Across North America
  Canada: Burlington • Calgary - Centre of Excellence - Edmonton • Fort McMurray - Fort St. John • Grande Prairie • London • Mississauga •  Richmond Hill - Saskatoon - Thunder Bay
 Vancouver Waterloo • Winnipeg • Yellowknife  United States: Cincinnati • Eyerett • Fort Collins • Holland •  Houston • Middletown • Salt take City • Spring City • York  Mexico: Monterrey
ReportID: 2009393-8/26/2014
                                                                                                                        Page2of27
                                                            C-82

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                       Appendix C
                                                                                                             ^ W;j-
                    Enuironmental                                                        '"

      34 Dogwood lane  • Middletown, PA 17057  •  Phone:717-9445541  • Fax: 717-914-1430 • www.alsglobal.com
                                  NELAP Certifications: KJ PA010, NY 11759, PA22-293   DoD ELAP: A2LA0818.01
                                      State Certifications:  DE ID 11 , MAPA0102 , MD 128 , VA460157 , WV 343

                                                      PROJECT SUMMARY


      Workorder: 2009393 PW2-DC

       Workorder Comments

            Please see the attached EPA551 results analyzed by Week Laboratories, Inc. DJM
            Please see the attached EPA552 results analyzed by Eurofins DJM

       Sample Comments

       Lab ID: 2009393001            Sample ID: PW2-DC-P/Merc Barge    Sample Type: SAMPLE
            Assuming that all bromate present in the sample is in the form of sodium bromate, the sodium bromate concentration is <5.9 ug/L.
            Assuming that all chlorate present in the sample is in the form of sodium chlorate, the sodium chlorate concentration is 52.2 ug/L.
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary - Centre of Excellence - Edmonton • Fort McMurray - Fort St. John • Grande Prairie • London • Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellowknife  United States: Cincinnati • Everett • Fort Collins • Holland • Houston • Middletown • Salt take City • Spring City • York Mexico: Monterrey

      ReportID: 2009393-8/26/2014                                                                                         Page3of27
                                                              C-83

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                    Environmental
      34 Dogwood Lane • Middletowri, PA 17057 • Phono: 717-944-5541  •  Fax: 717-9J4-1430  •  www.al5global.com

                                 NELAP Certifications: NJ  PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                     State Certifications:  DE ID 11 , MAPA0102, MD 128 , VA 460157 , WV 343

                                                   ANALYTICAL RESULTS
      Workorder: 2009393 PW2-DC
Lab ID: 2009393001
Date Collected: 5/28/201410:50 Matrix: Water
Sample ID: PW2-DC-P/Merc Barge
Parameters
VOLATILE ORGANICS
Bromodichloromethane
Bromoform
Chlorodibro mo methane
Chloroform
1 ,2,3-Trichloropropane
Surrogate Recoveries
1 ,2-Dichlorobenzene-d4 (S)
4-Bromotluorobenzene (S)
HERBICIDES
Dalapon
Surrogate Recoveries
2,4-Dichlorophenylacetic
acid (S)
WET CHEMISTRY
Bromate
Chlorate
METALS
Sodium, Total
Results Flag

ND
1.2
ND
ND
ND
Results Flag
92 .4
75.2

ND
Results Flag
99

ND
40.9

7.4
Units

ug/L
ug/L
ug/L
ug/L
ug/L
Units
%
A>

ug/L
Units
%

ug/L
ug/L

mg/L
Date Received: 5/29/201410:00
RDL

0.50
0.50
0.50
0.50
0.50
Limits
70-130
70-130

4.0
Limits
70-130

5.0
20.0

0.25
Method

EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
Method
EPA 524.2
EPA 524.2

EPA 51 5.3
Method
EPA 51 5.3

EPA 300.1
EPA 300.1

EPA 200.7
Prepared

6/7/14
6/7/14
6/7/14
6/7/1 4
6/7/1 4
Prepared
6/7/14
6/7/14

6/2/1 4
Prepared
6/2/14

6/4/14
6/4/1 4

6/4/14
By

TMP
TMP
TMP
TMP
TMP
By
TMP
TMP

KMR
By
KMR

SSL
SSL

AAM
Analyzed

6/7/1408:40
6/7/1408:40
6/7/1408:40
6/7/1408:40
6/7/1408:40
Analyzed
6/7/1408:40
6/7/1408:40

6/2/1421:59
Analyzed
6/2/1421:59

6/4/1413:14
6/4/1413:14

6/5/1413:49
By

TMP
TMP
TMP
TMP
TMP
By
TMP
TMP

EGO
By
EGO

SSL
SSL

ZMC
Cntr

B
B
B
B
B
Cntr
B
B

J1
Cntr
J1

I
I

H1
SUBCONTRACTED ANALYSIS
Subcontracted Analysis
See
Attached


Subcontract


7/31/1400:00
SUB
D
                                                                                 Ms. Debra J. Musser
                                                                                 Project Coordinator
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London • Mississauga • Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellowknife United Stales: Cincinnati • Everett • Fort Collins • Holland • Houston • Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2009393 - 8/26/2014
                                                                                                                  Page 4 of 27
                                                            C-84

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                   Enuironmental
      34 Dogwood Lane . Middle-town, PA 17057 . Phono: 717-944-5511 . Fax: 717-941-1430 •  www.alsglobal.com

                                NELAP Certifications: HI PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                    State Certifications: DE ID 11 ,MAPA0102,MD 128 , VA 460157 , WV 343

                                                   ANALYTICAL RESULTS
      Workorder: 2009393 PW2-DC
Lab ID: 2009393002
Sample ID: Trip Blank
Parameters
VOLATILE ORGANICS
Bromodichloromethane
Bromoform
Chlorodibro mo methane
Chloroform
1 ,2,3-Trichloropropane
Surrogate Recoveries
1 ,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
Date Collected: 5/29/201410:00 Matrix: Water
Date Received: 5/29/201410:00
Results Flag

ND
ND
ND
ND
ND
Results Flag
90.7
96.7
Units

ug/L
ug/L
ug/L
ug/L
ug/L
Units
A>
K>
RDL

0.50
0.50
0.50
0.50
0.50
Limits
70-130
70-130
Method

EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
Method
EPA 524.2
EPA 524.2
Prepared

6/7/14
6/7/14
6/7/14
6/7/14
6/7/14
Prepared
6/7/1 4
6/7/1 4
By

IMP
IMP
IMP
IMP
IMP
By
IMP
IMP
Analyzed

6/7/1402:15
6/7/1402:15
6/7/1402:15
6/7/1402:15
6/7/1402:15
Analyzed
6/7/1402:15
6/7/1402:15
By

IMP
IMP
IMP
IMP
IMP
By
IMP
IMP
Cntr

B
B
B
B
B
Cntr
B
B
                                                                                 Ms. Debra J. Musser
                                                                                 Project Coordinator
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo Winnipeg  Yellowkmfc United States: Cincinnati Everett Fort Collins  Holland  Houston - Middlctown •  Salt Lake City Spring City • York Mexico: Monterrey
      Report ID: 2009393 - 8/26/2014
                                                                                                                  Page 5 of 27
                                                            C-85

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                               Appendix C
                     Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541  •  Fax: 717-944-1430  •  www.alsglobal.com
                                  NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                    QUALITY CONTROL DATA
      Workorder: 2009393 PW2-DC

      QC Batch:         SVGC/34405
      QC Batch Method:  EPA 515.3
      Associated Lab Samples:  2009393001
   Analysis Method:
                        EPA515.3
       MATRIX SPIKE SAMPLE: 2024379   ORIGINAL:
         CNOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix!
         :ent recoveries. This result is not a final value and cannot be used as such.
Original
Parameter Result Units
Dalapon ug/L
2,4-Dichlorophenylacetic %
add (S)
SAMPLE DUPLICATE: 2024380 ORIGINAL:
Original
Parameter Result Units
Dalapon ug/L
2,4-Dichlorophenylacetic %
acid (S)
2,4-Dichlorophenylacetic %
acid (S)
Spike MS MS% % Rec
Cone. Result Rec Limit Qualifiers
5 6.5 129 70-130
70- 130
DUP Max
Result RPD RPD Qualifiers
ND 30
107 130
6.6
       MATRIX SPIKE SAMPLE: 2024381   ORIGINAL: 2009393001
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.
                                  Original               Spike      MS     MS%    %Rec
       Parameter                    Result     Units
Cone.     Result
                    Rec
                             Limit  Qualifiers
Dalapon
2,4-Dichlorophenylacetic
acid (S)
METHOD BLANK: 2024382
Parameter
Dalapon
2,4-Dichlorophenylacetic
acid(S)
ND
99

Blank
Result
ND
94
ug/L 5 6.0
%

Reporting
ynjts Limit Qualifiers
ug/L 4.0
% 70 - 1 30
120 70-130
70-130



                                   ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland •  Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2009393-8/26/2014
                                                                                                                        Page 6 of 27
                                                               C-86

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                       Appendix C
                    Enuironmental
      34 Dogwood Lane  • Middletown, PA 17DS7  • Phone:717-944-5541  •  Fax: 717-944-1430 • www.alsglobal.com
                                 NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                     State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                   QUALITY CONTROL DATA
      Workorder: 2009393 PW2-DC

      LABORATORY CONTROL SAMPLE: 2024383

                                   Spike                LCS   LCS %    % Rec
      Parameter	Conc-     Units     Result      Rec     Limit  Qualifiers
      Dalapon                          5      ug/L        5.2      105   70-130
      2,4-Dichlorophenylacetic                     %                 95   70-130
      acid (S)
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey

      Report ID: 2009393 - 8/26/2014                                                                                      Page 7 of 27
                                                             C-87

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                              Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7  •  Phone:717-944-5541  • Fax: 717-944-1430 • www.alsglobal.com

                                  NELAP Certifications: NJ  PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343


                                                    QUALITY CONTROL DATA
      Workorder: 2009393 PW2-DC
      QC Batch:         WETC/138842

      QC Batch Method:  EPA300.1

      Associated Lab Samples: 2009393001
                                                          Analysis Method:
                                                                               EPA 300.1
METHOD BLANK: 2025381

Parameter
Br ornate
Chlorate
LABORATORY CONTROL SAMPLE
Parameter
Br ornate
Chlorate

Blank
Result
NO
ND
2025382
Spike
Cone.
25
250


Units
ug/L
ug/L

Units
ug/L
ug/L

Reporting
Limit Qualifiers
5.0
20.0
LCS LCS % % Rec
Result Rec Limit Qualifiers
23.0 92 85-115
248 99.1 90-110
       MATRIX SPIKE: 2025386   DUPLICATE: 2025387   ORIGINAL:  2009703001
         CNOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spil
         :ent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                  Original
                                   Result
                                             Units
Spike
Cone.
  MS
Result
 MSD
Result
MS%
  Rec
MSD %
   Rec
% Rec
 Limit
                                                                                                           RPD
Max
RPD
                                                                                                                        Qualifiers
      Chlorate
                                              ug/L
                                                        250
                                                                 336
                                                                           351
                                                                                    101
                                                                                             108  75-125    4.51
                                                                                                                    25
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon -  Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2009393-8/26/2014
                                                                                                                       Page 8 of 27

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                  Appendix C
                     Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com

                                  NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                       State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343


                                                    QUALITY CONTROL DATA
       Workorder: 2009393 PW2-DC
       QC Batch:         MDIG/45719

       QC Batch Method:  EPATRMD

       Associated Lab Samples:  2009393001
                                                           Analysis Method:
                                                                                EPA 200.7
       METHOD BLANK: 2025583
       Parameter
                                     Blank
                                    Result
                                              Units
Reporting
    Limit  Qualifiers
       Sodium, Total
                                       NO
                                              mg/L
                                                         0.25
       LABORATORY CONTROL SAMPLE: 2025584
       Parameter
                                     Spike
                                     Cone.
                                              Units
    LCS
   Result
LCS %
  Rec
% Rec
 Limit  Qualifiers
       Sodium, Total
                                       10
                                              mg/L
                                                          9.6
                                                                  96.4   85-115
       MATRIX SPIKE: 2025585   DUPLICATE: 2025586  ORIGINAL:  2009247002

       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix i

       percent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                   Original
                                    Result
                                              Units
   Spike
   Cone.
   MS
Result
 MSD
Result
 MS%
  Rec
MSD %
   Rec
% Rec
 Limit
                                                                                                             RPD
Max
RPD
                                                                                                                          Qualifiers
       Sodium, Total
                                              mg/L
                                                          10
                                                                  29.8
                                                                           30.4
                                                                                     96.5
                                                                                               102   70-130   1.98
                                                                                                                      20
       MATRIX SPIKE SAMPLE: 2025587  ORIGINAL:
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                   Original
                                    Result
                                              Units
   Spike
   Cone.
   MS
Result
 MS%
  Rec
% Rec
 Limit  Qualifiers
       Sodium, Total
                                              mg/L
                                                                  617
                                   ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon -  Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2009393-8/26/2014
                                                                                                                         Page 9 of 27
                                                               C-89

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                         Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com
                                 NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                     State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                  QUALITY CONTROL DATA
      Workorder: 2009393 PW2-DC

      QC Batch:        VOMS/32864
      QC Batch Method:  EPA 524.2
      Associated Lab Samples:  2009393001, 2009393002
Analysis Method:
                    EPA 524.2
METHOD BLANK: 2027213

Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)

Blank
Result
NO
ND
ND
ND
ND
94.3
81
2027214
Spike
Cone.
1
1
1
1


2027215
Spike
Cone.
5
5
5
5
5




Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Reporting
Limit
0.50
0.50
0.50
0.50
0.50
70 - 1 30
70-130
LCS
Result
0.98
1.0
0.93
0.98


LCS
Result
5.7
5.1
5.0
4.9
5.1




Qualifiers







LCS %
Rec
98.4
103
92.6
97.7
109
84.6
LCS %
Rec
115
103
100
98.9
101
122
98.1










% Rec
Limit Qualifiers
50 - 1 50
50 - 1 50
50 - 1 50
50 - 1 50
70 - 1 30
70 - 1 30
% Rec
Limit Qualifiers
70 - 1 30
70-130
70 - 1 30
70 - 1 30
70 - 1 30
70 - 1 30
70-130
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland •  Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2009393-8/26/2014
                                                                                                                   Page 10 of 27
                                                            C-90

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                    Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com
                                 NELAP Certifications: Nj PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                     State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                   QUALITY CONTROL DATA CROSS REFERENCE TABLE
      Workorder:  2009393 PW2-DC
      Lab ID
                              Sample ID
                                                      Prep Method
                                                                            Prep Batch    Analysis Method
                                                                                                             Analysis
                                                                                                             Batch
      2009393001
                              PW2-DC-P/Merc Barge      EPA515.3
                                                                            SVGC/34405    EPA 515.3
                                                                                                             SVGC/34413
      2009393001
                              PW2-DC-P/Merc Barge
                                                                                          EPA 300.1
                                                                                                             WETC/138842
      2009393001
                              PW2-DC-P/Merc Barge      EPATRMD
                                                                            MDIG/45719    EPA200.7
                                                                                                             M ETA/44526
      2009393001
      2009393002
PW2-DC-P/Merc Barge
Trip Blank
EPA 524.2
EPA 524.2
VOMS/32864

VOMS/32864
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland •  Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2009393-8/26/2014
                                                                                                                  Page 11 of 27
                                                            C-91

-------
O
OD
to
                   r
                   (/i
                         Enuiranmental
                                                  34 Dogwood lane
                                                  Middletown, PA17057
                                                  P, 717-944-5541
                                                    7-944-1430
^
  CHAIN OF CUSTODY/
REQUEST FOR ANALYSIS
                                                                                                                      Pafio
                                                                                                                            of   1
                                                                                                    I
                                                                                                                                                                        GrQ
                                                                                                                                                                        1 o-
                                                                                                                                                                        ; S"
                                                                                                                                                                         ^
                                                                                                                                                                         a
                                                                                                                                                                      ^?
                                                                                                                                                                         Q
                                                                                                    TO



                                                                                                I3
                          Ceptej; WHITE - ORIGIIWL C*NWW - CUSTOMER COPY
                                                                   ConHliiir TyปK AG-ABtaf OO.K C0
-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                     Appendix C
           WnlL
                                WECK. LABORATORIES, INC.
                                                        CERTIFICATE OF ANALYSIS
                                                                                                         rtl Laboratory Service •
           Client:    ALS Environmental - PA
                     34 Dogwood Lane
                     Middletown PA, 17057


           Attention: Debra Musser

           Phone:    (300) 794-7709

           Fax:      (717> 944-1430

           Wor* Orders):   4F03015
Report Data:       07/31/1411:45

Receivad Date:     06/03/1409:10

Turn Around:      Normal

Client Project     2009393
                                    NELAP #Q4Z29CA  ELAP#1132  NEVADA #CA211  HAWAII LACSD #10143
        The results in this report apply to the samples analyzed in accordance with trie Chain o! Custody document.  Wsctt Laboratories, Inc.
        certifies that the test results meet all NELAC requirements unless noted in the case mtrative. This analytical report is confidential and is
        only intended for the use of Week Laboratories. Inc. and its client. This report contains the Chain of Custody document, which is an integral
        part of it, and can only be reproduced in full with the authorization of Week Laboratories, Inc.

        Dear Debra Musser:

        Enclosed are the results of analyses for samples received 06/03/14 09:10 wHh the Chain of Custody document. The samples
        were received in good condition, at 6,3 *C and on tee. All analysis met the method criteria except as noted below or in (he report
        with data qualifiers.

        Case Narrative:
        SUPP report generated to reprot Mono compounds. BG 7/31/14

        Reviewed by:
        Brandon Gee
        Project Manager
                                                                                                                          Page 1 of 8
                       
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                                              Appendix C
           Wi,IL
                                                                                          WECK LABORATORIES, INC,
        ALS Environmental - PA
        34 Dogwood Lane
        Middletowm PA, 17057
                                                                                         Ana'yEicai IsfconHory 5€fvi(tr - Sii'j.e 19fi?sS HrMSIylcai ซpert musi be fepro<5MCftd in ite enlirety
                                                                                                          ALS
                                                       C-94

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                         Appendix C
                                                                                                     WECK LABORATORIES, INC.
        ALS Environmental - PA                                                                        Date Received:    06/03/1409:10
        34 Dogwood Lane                                                                             Date Reported:    07/31/14 11:45
        MWdletown PA. 17057

                                                        4F03Q15-01      2009393001
        Sampled: 05/28/1400:00                                    Sampled 8ป: Cten!                                        Matrix: WWer

                                                             OBPs by EPA 551.1
        Method: EPA 551.1                       Batch: W4F0473         Prepared: 06/09/1414:28                      Analyst: Juliet Chootipanya
        Analyte                                         Result                 MRL       ynils      Oil      Analyzed            Qualifier
        Chtoropicrin  	           NO                   535        uงfl        i   06/12/1423:02
        Dibromoacelonitrile                                  ND                   0.50        ug/I        1   Cป12/14 23:02
        DicWoroacetonitrite                                  ND                   0.50        ug/I        1   W/12/14 23:02
        Su/r; Decafuemblphenyl                            108%     Cone 10.8     80-(20       %
                                                                                                                             Page 9 of 8
                       Week LsEorstoTOS. ItK  KU50 ฃastCl^t.Av^Hie. City oit^usEry, Callfotn!a1?i/4ij.-!syB   fe^jaio^^s   FAX iK6>336-2ijM
                   uh& in this ref*art apply to !he samples snslyxed in acco^ance wi^h the chain Qf custody document !>ป!& analytical report mus^ be reproduced HI iia entirely
                                                               www.wochlabiS.com
                                                                                                                      ALS
                                                                 C-95

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                                          Appendix C
  WnlL
                                                                                              WECK LABORATORIES, INC.
ALS Environmental - PA
34 Dogwood Lane
Middleiown PA, 17057
Sampled: 0508/1400:00


Method: EPA 551.1
Analyte
                                                   4F03015-01RE1      2009393 001
                                                             Sampled By:  Client
                                                         DBFs by EPA 551,1
                                           Batch: \AMG0414       Prepared: 07/0*14 10:39
                                                    Result                 MRL      Unite
                                                                                              Date Received:    06/03/14 09:10
                                                                                              Date Reported:    07/31/14 11:45
                                                                                                        Matrix: Water
                                                                                              Analyst: Juliet Chootipanya
                                                                                           Analyzed
                                                                                                            Qualifier
Bramoacetonitrile
Chloroaeetortltrtfe
Burr Decattuorobiplienyl
 NO
 ND
84%
                                                    Conc:8,*3
 050
 O.SO
80-120
                                                                           ug/
                                                                           ugfl
                                                                            %
                                                                                                07/OW14 22:26
                                                                                            1   07/09/1422:26
                                                                                                               CM4
                                                                                                               0-14
                                                                                                               O-M
    The resuMs s^ this tejMrl apply to 1he a
                                         in acco^Gsnqe wilfs the chaซ ol cuaiodj flocumem  f li^a anslylicai report mซsi be feproducซ<3
                                                                                                            Page 4 of 8
                                                                                                      ALS
                                                    C-96

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                               Appendix C
        WnlL
WECK LABORATORIES, INC.
                                                                             Analytical Laboratory Service > S'r,i:e 1964

       ALS Environmental - PA                                                      Date Received:   06/03/14 09:10
       34 Dogwood Lane                                                          Date Reported:   07/31/14 11:45
       Middletown PA, 17057
                                   QUALITY    CONTROL
                                              SECTION
                  VV^;k LsbersSonQiS, Inc 'K&SS East DBF*: Averue. Cily of infiyy-li'v, C*?-ifOtfป^ 9-S?4?-'13$Cv  [&2&J.23B-i"l3a  TAX jB2&) 3SB"*ง3A
            ซ Jesuits, ir^ 6his report apply to the samples anatxsed in Bccordance with she chsซ* d cuslody cfocymen; This ana^ticaf recort my at be reproduced in i& ensire
                                                                                          ALS
                                                  C-97

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                   Appendix C
          WnlL
WECK LABORATORIES, INC.
        ALS Environmental - PA
        34 Dogwood Lane
        Middletown PA, 17057
                                                DBPs by EPA 551.1 - Quality Control
Ar.^ytisaKatwaoj'ySt'rvK-e - Since 1944

Dale Received:    06/03/14 09:10
Dale Reported:    07/31/14 11:45
        Batch W4F0473 - EPA 551.1
Analyse
Blank (W4F0473-8LK1)
1 , 1,1 -trichlQro-2-propanorse
1 ,1-Dichfoco-2-propanone
Sromochloroacetonitnle
Chloral hydrate
CWofopicrin
Oibromoacetortilrile
DichloroaceSonitrile
TricWoroacelonrtrite
Surr Decafluarobiphenyt
LCS(W4F0473-BS1)
1 .1 . 1 -trtcWoro-2-propanone
1 , 1 -DichIoro-2-propanone
BramoehltBoacelonitrile
Chloral hydrate
Chtofop&crin
Dibromoacetonitrile
Diehloroaceionitrte
Trlchloroacelonttrile
Surr: Decaffuorobipheny!
LCS Dup (W4F0473-BSD1)
1,1,1 -lrichloro-2-proparx>rse
1 ,1-Dichloro-2-propanone
Bromochloroacetonitriie
CWoral hydrate
Chtoroptain
Dibromoacetonitrile
Diehloroacetonrtrile
TrlcWofoacelonitrile
Surr: Decafiuombtphenyt
Batch W4G0414 - iPA 551.1
Analyte
Blank (W4GD414-BLK1)
Bromoacetonilrile
Chloroacetortltrile
Surr' Decafluorobiphenyt
LCS (W4G0414-BS1)
Bromoacetonrtrile
Chloroaeelonftrite
Surr Decafluorobiphenyl

Week iaccซf-to:ie
Resyrt

NO
ND
ND
ND
ND
ND
NO
NO
10.9

104
10.1
10,5
10,1
9.70
9.84
10.7
8,99
10.9

11.4
10.6
11,1
10.8
11.2
10.0
11,3
104
10.9

Rejdt

ND
ND
S.68

9.08
8.92
9,47

s, Inc 14969 EassClarK.AvOR
MRL

0,50
0,50
0.50
O.SO
0.50
0.50
0,50
0,50


0.60
0.50
O.SO
0,50
0,50
0,50
0.50
0.50


0.50
0,50
0,50
0.50
0.50
0.50
0.50
0.50


MRL

0.50
0.50


0.50
0.50


.MI. Cny of Inbusst
Units

ug/l
ug/l
ug/l
ug/l
ug/l
ug/l
U0/I
ug/l
ugfl

ug/1
ug/l
ug/l
ug/l
ug/l
ufl/l
ug/l
ug/l
ogd

ug/l
ug/l
ugfl
ug/l
ug/1
ug/l
ug/l
ug/l
ug/l

Untts

ug/l
ug/l
"S*

ug/I
ugrt
1^1

y, Cali-wsia
Spike
Levtti
Analyzed








10.0
Analyzed:
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
Analyzed:
10.0
10.0
10.0
10,0
10.0
10.0
10.0
' 10.0
10.0

?ฑel
Analyzed:


fO.O
Analyzed:
10.0
10.0
JO.O

9l.' {S26? 336-2* 39
% REC SPD
Lluiia Rpo Una









fl
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                           Appendix C
                                                                                                      WECK LABORATORIES, INC.
         ALS Environmental - PA
         34 Dogwood Lane
         MidcJIetown PA, 17057
                                                      DBFs by EPA 551.1 - Quality Control
                                     Analytical &j3bo*atory Servsce - Sine*- ] 964

                                     Date Received:    06/03/14 09:10
                                     Date Reported:    07/31/1411:45
         Batch W4O0414 - EPA 551.1
          ArtMyie
          LCS Dup (W4G0414-QSD1)
                 Spike
                 Level
                                                                                         Resuil
                                                                                               %REC
                             %REC
                              Limns
                                    RPO
                                    Ulmtt
                                 Data
                             Quoiltefs
                                                                              AnaSyzed; 07/10/14 12:44
           Chteoacetonitrile
           SUIT DKafvorobiphenyl
                                                   10.7
                                                   10.5
0.50
0.50
ug'l
ugll
10.0
10.0
10.0
107
105
102
80-120
60-120
80-120
17
16
25
25
                                                                                                                             Page 7 of 8
                       tAteck Letorefo^s, lnซ  1^S1ซ9 Gast Clartc Avenue-. Cily of industry California  21*6-^1^   TAX J628) 33&-SS34
                      r. Shis report apply to tha samples analyzed in accordance wilN the chain of &UEi
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                       Appendix C
                                                                                                           WECK LABORATORIES, INC.
         ALS Environmental - PA
         34 Dogwood Lane
         Mkidietown PA, 17057
Date Received:
Date Reported:
06/03/1409:10
07/31/1411:45
                                                          Notes and Definitions

        Q-14      This analysis was requested by the died! after She heading time was exceeded.

        ND       NOT DETECTED a! or above (he Reporting limit. I* J-vaiue reported, then NOT DETECTED at or above the Method Defection Limit (MDt)

        NR       No] Reported

        Dfl        Dilution

        dry       Sample results reported on a dry weight basis

        RPD      Relative Percent Deference
        % Rec    Percent Recovery

        Sub      ฉyfacojutracteid analysis, anginal report available upon request

        MOL      Method Detection Limit

        MDA      Minimum DetectaWe Activity

        MRL      Method Reporting Urni*
        Any remaWng samplers) win be cflsposed of one monlh from the final report date unless other arrangements are made in advance,

        An Absence of Total Colrfomi meets Ifte dJirtKing water standards as established by the California Department of Health Services.

        The Reporting Limit (RL> is referenced as the Laboratory's Practical Quantttatlon Limit fPQL) or the Detection Lwrrft for Reporting Purposes
        (DLR).

        AH samples collected by Week Laboratories have been sampled in accordance to laboratory SOP Number MISOQ2.
                                                                                                                                    Page 8 ol 8
              The results in this report a??ply !B the s
                                                 Ea-5i ClaiK Avermt, Csly of mdusiry, CaiMomia Sl',Mฃ-i3yii   (62S) U3&-21M   FAX (&26J ^3^-2634
                                                an&tyz&3 in accordance wilh the chain of custody documert. This a^s!ytcซl report must be reproduced in its entirety
                                                                                                                             ALS
                                                                    C-100

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                      Appendix C
            eurofins
                              Eaton Analytical
                   110 South Hill Street
                   Sooth Bend, IN 4661?
                   Tel:  (574)233-4777
                   Fit (574)233-8207
                   1 800332 4345
        Client:  ALS

         Attn:  Karen Etofsky
               34 Dogwood Lane
               Middletown, PA 17057
                                                      Laboratory Report
Report:
Priority:
Status:
PWS1D:
PA Lab ID:
318604
Standard Written
Final
Not Supplied
684S6
Copies
to: None
Sample Information
EEA
1D#
3036331
Client ID
2009393 00!
Method
ssa.2
Collected |
Date / Time ||
OK28/M 10:50 |
Collected
By:
Client
Received
Oat* / Time
06KJ3/14 09:00
                                                          Report Summary
       Note: Sample container was provided by the client.
       Detailed quantitative results are presented on ihe following pages. The results presented relate only to the samples provided for
       analysis.
       We appreciate the opportunity to provide you with Ihis analysis. If you have any questions concerning this report, please do not
       hesitate to call Nathan Trowbridge at (574) 233-4777.

       Note: This report may not be reproduced, except in full, without written approval from EEA.  EEA is accredited by the National
       Environmental Laboratory Accreditation Program (NELAP).
                                                 Digitally signed by Traci
                                                 Chlebowski
                                                 Dซe: 2014.06.17 16:19:14-04*00'
         Authorized Signature

       Client Name:     ALS
       Report*        318604
                                                              Title
                                                             Page 1 of 3
                                                                                                        Date
                                                                                                              ALS
                                                            C-101

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Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
      Clien! Name:
                    ALS
                                                                                        Report*  3186O4
      Sampling Point:   2009393 001
                                                                                         PWS ID:  Not Supplied
      t EEA has 
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                             Appendix C
       Client Name:     ALS                                                                               Report*  318604


                                                                     Lab Definitions

                    Continuing Calibration Check Standard (CCC) / Continuing Calibration Verification (CCV) / initial Calibration
                    Verification Standard (ICV) I Initial Performance Check (IPC) - Is a standard containing one or more of the target
                    analytes that is prepared from the same standards used to calibrate the Instrument. This standard is used to verify
                    the calibration curve at the beginning of each analytical sequence, and may also be analyzed  throughout and a! the
                    end of the sequence. The concentration of continuing standards may be vbried, when prescribed by the reference
                    method, so that the range of the calibration curve is verifled on a regular basis.

                    Internal Standards (IS) - are pure compounds with properties similar to the analytes of interest, which are added to
                    field samples or extracts, calibration standards, and quality control standards a! a known concentration. They are
                    used to measure the relative responses of the analytes of interest and surrogates in the sample, calibration standard
                    or quality control standard.

                    Laboratory Duplicate (LO) - is a field sample aliquot taken from the same sample container in the laboratory and
                    analyzed separately using identical procedures. Analysis of laboratory duplicates provides a measure of the
                    precision of the laboratory procedures.

                    Laboratory Fortified Blank (LFB) / Laboratory Control Sample  (LCS) • is an aliquot of reagent water to which
                    known concentrations of tie analytes of interest are added. The LFB is analyzed exactly Ihe same as the field
                    samples. LFBs are used to determine whether [he method is in control.

                    Laboratory Method Blank (1MB) (Laboratory Reagent Blank (LRB) - is a sample of reagent  water included in Ihe
                    sample batch analyzed in the same way as the associated field samples. The LMB is used lo  determine if method
                    analytes or other background contamination have been Introduced during the preparation of analytical procedure.
                    The LMB is analyzed exactly the same as the field samples.

                    Laboratory Trip Blank (LTB) / Fteld Reagent Blank (FRB) - is a sample of laboratory reagent water placed in a
                    sample container in Ihe  laboralory and treated as a field sample, including storage, preservation, and all analytical
                    procedures. The FRB/LTB container follows the collection bottles to and from Ihe collection site, bul the FRB/LTB is
                    not opened at any time during the trip, The FRB/LTB is primarily a travel blank used to verify that the samples were
                    not contaminated during shipment.

                    Matrix Spike Duplicate Sample (MSD) / Laboratory  Fortified Sample Matrix Duplicate (LFSMD) - is a sample
                    aliquot taken from the same field sample source  as the Matrix Spike Sample lo which known quantities of Ihe
                    analytes of interest are added in the laboratory. The MSD is analyzed exactly thซ same as Ihe field samples.
                    Analysis of the MSD pf ovides a measure  of the precision of Ihe  laboratory procedures in a specific matrix.

                    Matrix Spike Sample (MS) / Laboratory Fortified Sample Matrix (LFSM) - is a sample aliquot taken from field
                    sample source to which known quanlities of the analytes of interest are added in the laboratory. The MS is analyzed
                    exactly trie same as trie field samples. The purpose  Is to demons&ate recovery of the analytes from a sample matrix
                    lo determine if the specific matrix contributes bias to the analytical results.

                    Quality Control standard (QCS) / Second Source Calibration Verification 4SSCV) - is a solution containing
                    known concentrations of Ihe analytes of interest  prepared from a source different from the source of the calibration
                    standards. The solution is obtained from a second manufacturer or lot if Ihe lot can be demonstrated by Ihe
                    manufacturer as prepared independently  from other lots- The QCS sample is analyzed using  the same procedures
                    as field samples. The QCS is used as a check on the calibration standards used in the method on a routine basis.

                     Reporting Limit Check  (RLC) / Initial Calibration Check Standard (ICCS) - Is a procedural standard that is
                    analyzed each day to evaluate instrument performance at or below Ihe minimum reporting limit (MRL).

                     Surrogate Standard (SS) / Surrogate Analyte (SUR) - is a pure compound with properties similar to the analytes of
                     interest, which is highly  unlikely to be found in any Held sample, thai is a*ted to the field samples, calibration
                    standards, blanks and quality control standards before sample preparation. The SS is used to evaluate the efficiency
                    of the sample preparation process.
                                                                       Page 3 of 3
                                                                                                                                 ALS
                                                                      C-103

-------
Feasibility and Efficacy of Using Potable Water Generators

as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
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                                                                         Sample Type Key
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           TvwHAtibr.l
               ccc
               CCL
                fS
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                MS
Sample Type
Continuing Calibration Check
Continuing Calibration Low
Field Sample
Laboratory Method Blank
Matrix Spike
TyptlAbbr.)
Sample Type
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                                                                                                                                          I
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                                                                                                                                          o

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                    Appendix C
                   Environmental
     34 Dogwood Lane • Middlctowi, PA 17057 • Phono: 717-944-5541  •  Fax: 717-9J4-1430 •  www.al5global.com

                               NELAP Certifications:  NJ PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                   State Certifications: DE ID 11 , MAPA0102, MD 128 , VA 460157 , WV 343


         August 26, 2014
              Ms. Janet Barnes
              University of MD-UMCES - Solomons, MD
              P.O. Box 38
              146 Williams Street
              Solomons, MD 20688
                                         Certificate  of Analysis
      Project Name:      2014-MD BRACKISH WATER STUDY  Workorder:     2010351
      Purchase Order:                                         Workorder ID:   PW3-DC
      Dear Ms. Barnes:

        Enclosed are the analytical results for samples received by the laboratory on Wednesday, June 4, 2014.

        The ALS Environmental laboratory in Middletown, Pennsylvania is a National Environmental Laboratory
        Accreditation Program (NELAP) accredited laboratory and as such, certifies that all applicable test results meet the
        requirements of NELAP.

        If you have any questions regarding this certificate of analysis,  please contact Ms. Debra J. Musser (Project
        Coordinator) at (717) 944-5541.

        Analyses were performed according to our laboratory's NELAP-approved quality assurance program and any
        applicable state requirements. The test results meet requirements of the current NELAP standards or state
        requirements, where applicable. Fora specific list of accredited analytes, refer to the certifications section of the
        ALS website at www.alsglobal.com/en/Our-Services/Life-Sciences/Environmental/Downloads.

        This laboratory report may not be reproduced, except in full, without the written approval of ALS Environmental.

        ALS Spring City:  10 Riverside Drive, Spring City, PA 19475 610-948-4903
      This page is included as part of the Analytical Report and                         Ms. Debra J. Musser

      must be retained as a permanent record thereof.                                Project Coordinator



                                ALS Environmental Laboratory Locations Across North America
       Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London •  Mississauga • Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellowknife United Stales: Cincinnati • Everett • Fort Collins • Holland •  Houston • Middletown • Salt Lake City • Spring City • York Mexico: Monterrey

     Report ID: 2010351 -8/26/2014                                                                                 Page 1 of 30
                                                        C-108

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                      Enuironmental
      34 Dogwood lane • Middletown, PA 170S7 ป  Phone:717-9445541  • Fax: 717-944-1430 • www.3lsqlobal.cam
                                    NELAP Certifications: NJ PA010, NY 11759, PA22-293   DoD ELAP: A2LA0818.01
                                        State Certifications:  DE ID 11 , MAPA0102 , MD 128 , VA460157 , WV 343

                                                          SAMPLE SUMMARY
       Workorder: 2010351 PW3-DC
Lab ID
2010351001
2010351002
Sample ID
PW3-DC-P/MERC BARGE
TRIP BLANK
Matrix
Water
Water
Date Collected
6/3/201410:30
6/4/201410:30
Date Received
6/4/201410:30
6/4/201410:30
Collected By
Collected by Client
Collected by Client
        Notes
         — Samples collected by ALS personnel are done so in accordance with the procedures set forth in the ALS Field Sampling Plan (20 -
             Field Services Sampling Plan).
         ~ All Waste Water analyses comply with methodology requirements of 40 CFR Part 136.
         — All Drinking Water analyses comply with methodology requirements of 40 CFR Part 141.
         — Unless otherwise noted, all quantitative results for soils are reported on a dry weight basis.
         — The Chain of Custody document is included as part of this report.
         -- All Library Search analytes should be regarded as tentative identifications based on the presumptive evidence of the mass spectra.
            Concentrations reported are estimated values.
         - Parameters identified as "analyze immediately" require analysis within 15 minutes of collection. Any "analyze immediately" parameters
            not listed under the header "Field Parameters" are preformed in the laboratory and are therefore analyzed out of hold time.
         — Method references listed on this report beginning with the prefix "S" followed by a method number (such as S2310B-97)
            refer to methods from "Standard Methods for the  Examination of Water and Wastewater".

        Standard Acronyms/Flags
           J     Indicates an estimated value between the Method Detection Limit (MDL) and the Practical  Quantitation Limit (PQL) for the analyte
           U     Indicates that the analyte was Not Detected (ND)
           N     Indicates presumptive evidence of the presence of a compound
         MDL    Method Detection Limit
         PQL    Practical Quantitation Limit
         RDL    Reporting Detection Limit
          ND    Not Detected - indicates that the analyte was Not Detected at the RDL
         Cntr    Analysis was performed using this container
        RegLmt  Regulatory Limit
         LCS    Laboratory Control Sample
          MS    Matrix Spike
         MSD    Matrix Spike Duplicate
         DUP    Sample Duplicate
         %Rec   Percent Recovery
         RPD    Relative Percent Difference
         LOD    DoD Limit of Detection
         LOQ    DoD Limit of Quantitation
          DL    DoD Detection Limit
                                    ALS Environmental  Laboratory Locations Across North America
         Canada: Burlington • Calgary - Centre of Excellence - Edmonton • Fort McMurray - Fort St. John • Grande Prairie •  London •  Mississauga • Richmond Hill - Saskatoon - Thunder Bay
       Vancouver Waterloo • Winnipeg • Yellowknife  United States: Cincinnati • Eyerett • Fort Collins •  Holland • Houston • Middletown • Salt take City • Spring City • York Mexico: Monterrey
      Report ID: 2010351-8/26/2014
                                                                                                                              Page 2 of 30
                                                                 C-109

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                        Appendix C
                                                                                                              ^ W;j-
                    Enuironmental                                                         '"

      34 Dogwood lane • Middletown, PA 17057 ป Phone:717-9445541 • Fax: 717-914-1430 • www.alsglobal.com
                                  NELAP Certifications: NJ PA010, NY 11759, PA22-293  DoD ELAP: A2LA0818.01
                                      State Certifications:  DE ID 11 , MAPA0102 , MD 128 , VA460157 , WV 343

                                                      PROJECT SUMMARY


      Workorder: 2010351 PW3-DC

       Workorder Comments

            Please see the attached EPA551 results analyzed by Week Laboratories, Inc. DJM
            Please see the attached EPA552 results analyzed by Eurofms. DJM

       Sample Comments

       Lab ID: 2010351001            Sample ID: PW3-DC-P/MERC        Sample Type: SAMPLE
                                   BARGE
            The method 524.2 internal standard was recovered outside of the control limits.
            Assuming that all bromate present in the sample is in the form of sodium bromate, the sodium bromate concentration is <5.9 ug/L.
            Assuming that all chlorate present in the sample is in the form of sodium chlorate, the sodium chlorate concentration is 63.3 ug/L.
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary - Centre of Excellence - Edmonton • Fort McMurray - Fort St. John • Grande Prairie • London • Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellowknife  United States: Cincinnati • Everett • Fort Collins • Holland • Houston • Middletown • Salt take City • Spring City • York Mexico: Monterrey

      Report ID: 2010351 - 8/26/2014                                                                                        Page 3 of 30
                                                              C-110

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                   Environmental
      34 Dogwood Lane • Middletown, PA 17057 • Phono: 717-944-5541 • Fax: 717-9J4-1430 •  www.al5global.com

                                 NELAP Certifications: NJ PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                    State Certifications: DE ID 11 , MAPA0102, MD 128 , VA 460157 , WV 343

                                                   ANALYTICAL RESULTS
      Workorder: 2010351 PW3-DC
Lab ID: 2010351001
Date Collected: 6/3/201410:30 Matrix: Water
Sample ID: PW3-DC-P/MERC BARGE
Parameters
VOLATILE ORGANICS
Bromodichloromethane
Bromoform
Chlorodibro mo methane
Chloroform
1 ,2,3-Trichloropropane
Surrogate Recoveries
1 ,2-Dichlorobenzene-d4 (S)
4-Bromotluorobenzene (S)
HERBICIDES
Dalapon
Surrogate Recoveries
2,4-Dichlorophenylacetic
acid (S)
WET CHEMISTRY
Bromate
Chlorate
METALS
Sodium, Total
Results Flag

ND
0.57
ND
ND
ND
Results Flag
87.4
78.4

ND
Results Flag
103

ND
49.6

5.6
Units

ug/L
ug/L
ug/L
ug/L
ug/L
Units
%
A>

ug/L
Units
%

ug/L
ug/L

mg/L
Date Received: 6/4/201410:30
RDL

0.50
0.50
0.50
0.50
0.50
Limits
70-130
70-130

4.0
Limits
70-130

5.0
20.0

0.25
Method

EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
Method
EPA 524.2
EPA 524.2

EPA515.3
Method
EPA515.3

EPA 300.1
EPA 300.1

EPA 200.7
Prepared

6/10/14
6/10/14
6/10/14
6/10/14
6/10/14
Prepared
6/10/14
6/10/14

6/11/14
Prepared
6/11/14

6/10/14
6/10/14

6/9/14
By

TMP
TMP
TMP
TMP
TMP
By
TMP
TMP

KMR
By
KMR

SSL
SSL

AAM
Analyzed

6/10/1420:04
6/10/1420:04
6/10/1420:04
6/10/1420:04
6/10/1420:04
Analyzed
6/10/1420:04
6/10/1420:04

6/11/1423:30
Analyzed
6/11/1423:30

6/10/1407:09
6/10/1407:09

6/13/1402:53
By

TMP
TMP
TMP
TMP
TMP
By
TMP
TMP

EGO
By
EGO

SSL
SSL

ZMC
Cntr

I
I
I
I
I
Cntr
I
I

G1
Cntr
G1

F
F

E1
SUBCONTRACTED ANALYSIS
Subcontracted Analysis
See
attached


Subcontract


6/19/1422:25
SUB
C
                                                                                 Ms. Debra J. Musser
                                                                                 Project Coordinator
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London • Mississauga • Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellowknife United Stales: Cincinnati • Everett • Fort Collins • Holland • Houston • Middletown •  Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2010351 - 8/26/2014
                                                                                                                  Page 4 of 30
                                                           C-lll

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                    Enuironmental
      34 Dogwood Lane . Middle-town, PA 17057 . Phono: 717-944-5511  .  Fax: 717-941-1430 •  www.alsglobal.com

                                 NELAP Certifications: HI PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                     State Certifications:  DE ID 11 ,MAPA0102,MD 128 , VA 460157 , WV 343

                                                   ANALYTICAL RESULTS
      Workorder: 2010351 PW3-DC
Lab ID: 2010351002
Sample ID: TRIP BLANK
Parameters
VOLATILE ORGANICS
Bromodichloromethane
Bromoform
Chlorodibro mo methane
Chloroform
1 ,2,3-Trichloropropane
Surrogate Recoveries
1 ,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
Date Collected: 6/4/201410:30 Matrix: Water
Date Received: 6/4/201410:30
Results Flag

ND
ND
ND
ND
ND
Results Flag
92.5
120
Units

ug/L
ug/L
ug/L
ug/L
ug/L
Units
A>
K>
RDL

0.50
0.50
0.50
0.50
0.50
Limits
70-130
70-130
Method

EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
Method
EPA 524.2
EPA 524.2
Prepared

6/10/14
6/10/14
6/10/14
6/10/14
6/10/14
Prepared
6/10/14
6/10/14
By

IMP
IMP
IMP
IMP
IMP
By
IMP
IMP
Analyzed

6/10/1401:59
6/10/1401:59
6/10/1401:59
6/10/1401:59
6/10/1401:59
Analyzed
6/10/1401:59
6/10/1401:59
By

IMP
IMP
IMP
IMP
IMP
By
IMP
IMP
Cntr

B
B
B
B
B
Cntr
B
B
                                                                                 Ms. Debra J. Musser
                                                                                 Project Coordinator
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo Winnipeg  Yellowkmfc United States: Cincinnati Everett  Fort Collins  Holland  Houston - Middlctown • Salt Lake City  Spring City • York Mexico: Monterrey
      Report ID: 2010351 - 8/26/2014
                                                                                                                   Page 5 of 30
                                                           C-112

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                  Appendix C
                     Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com

                                  NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                       State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343


                                                    QUALITY CONTROL DATA
       Workorder: 2010351 PW3-DC
       QC Batch:         MDIG/45783

       QC Batch Method:  EPATRMD

       Associated Lab Samples:  2010351001
                                                           Analysis Method:
                                                                                EPA 200.7
       METHOD BLANK: 2027722
       Parameter
                                     Blank
                                    Result
                                              Units
Reporting
    Limit  Qualifiers
       Sodium, Total
                                      NO
                                              mg/L
                                                         0.25
       LABORATORY CONTROL SAMPLE: 2027723
       Parameter
                                     Spike
                                     Cone.
                                              Units
    LCS
   Result
LCS %
  Rec
% Rec
 Limit  Qualifiers
       Sodium, Total
                                       10
                                              mg/L
                                                          9.9
                                                                  99.2   85-115
       MATRIX SPIKE: 2027724   DUPLICATE: 2027725  ORIGINAL: 2010181001

       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix i

       percent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                   Original
                                    Result
                                              Units
   Spike
   Cone.
   MS
Result
 MSD
Result
MS%
  Rec
MSD %
   Rec
% Rec
 Limit
       Max
RPD   RPD
                                                                                                                          Qualifiers
       Sodium, Total
                                              mg/L
                                                                  15.2
                                                                           15.4
                                                                                                             1.01
                                                                                                                      20
       MATRIX SPIKE SAMPLE: 2027726  ORIGINAL:
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.

                                                                   MS
       Parameter
                                   Original
                                    Result
                                              Units
   Spike
   Cone.
                                                                Result
          MS%
            Rec
         % Rec
           Limit  Qualifiers
       Sodium, Total
                                              mg/L
                                                                  13.5
                                   ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2010351 - 8/26/2014
                                                                                                                         Page 6 of 30
                                                              C-113

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                         Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com
                                 NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                     State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                  QUALITY CONTROL DATA
      Workorder:  2010351 PW3-DC

      QC Batch:         VOMS/32878
      QC Batch Method:  EPA 524.2
      Associated Lab Samples:  2010351001, 2010351002
Analysis Method:
                    EPA 524.2
METHOD BLANK: 2028011

Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
4-Bromofluorobenzene (S)
1,2-Dichlorobenzene-d4 (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)

Blank
Result
NO
ND
ND
ND
ND
97.7
85.9
2028012
Spike
Cone.
1
1
1
1


2028013
Spike
Cone.
5
5
5
5
5




Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Reporting
Limit
0.50
0.50
0.50
0.50
0.50
70 - 1 30
70-130
LCS
Result
0.60
1.0
1.1
0.99


LCS
Result
5.5
5.0
5.4
4.9
5.0




Qualifiers







LCS %
Rec
60.2
100
113
99
80.2
98.8
LCS %
Rec
111
99.6
109
98.7
99.7
110
95.1










% Rec
Limit Qualifiers
50 - 1 50
50 - 1 50
50 - 1 50
50 - 1 50
70 - 1 30
70 - 1 30
% Rec
Limit Qualifiers
70 - 1 30
70-130
70 - 1 30
70 - 1 30
70 - 1 30
70 - 1 30
70-130
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland •  Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2010351 - 8/26/2014
                                                                                                                   Page 7 of 30
                                                            C-114

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 •  Fax: 717-944-1430 • www.alsglobal.com
                                  NELAP Certifications:  Nj PA010 , NY 11759 , PA22-293  DoDELAP:  A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157  , WV 343

                                                   QUALITY CONTROL DATA
      Workorder: 2010351 PW3-DC

      MATRIX SPIKE: 2028317   DUPLICATE: 2028318  ORIGINAL: 2010692014
      ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
      percent recoveries. This result is not a final value and cannot be used as such.
Original
Parameter Result Units
Chloroform
Bromodichloromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
ug/L
ug/L
ug/L
ug/L
ug/L
%
%
Spike
Cone.
5
5
5
5
5


MS
Result
4.6
5.2
5.4
4.5
4.9


MSD
Result
5.0
5.1
5.0
4.9
4.9


MS%
Rec
92.6
104
107
90.4
98.2
114
96.7
MSD %
Rec
100
102
100
97.2
98.1
109
90.3
% Rec
Limit
70-
70-
70-
70-
70-
70-
70-
130
130
130
130
130
130
130
RPD
8.01
2.03
6.55
7.25
.08
4.85
6.9
Max
RPD Qualifiers
40
40
40
40
40


                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2010351 - 8/26/2014
                                                                                                                      Page 8 of 30
                                                             C-115

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                 Appendix C
                     Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541  • Fax: 717-944-1430 • www.alsglobal.com

                                  NELAP Certifications:  NJ PA010 , NY 11759 , PA22-293   DoDELAP: A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343


                                                    QUALITY CONTROL DATA
       Workorder: 2010351 PW3-DC
       QC Batch:         WETC/139120

       QC Batch Method:  EPA300.1

       Associated Lab Samples:  2010351001
                                                           Analysis Method:
                                                                                EPA 300.1
       METHOD BLANK: 2028028

Parameter
Br ornate
Chlorate
Blank
Result
ND
ND
Reporting
Units
ug/L
ug/L
Limit
5.0
20.0
Qualifiers


       LABORATORY CONTROL SAMPLE: 2028029
       Parameter
                                    Spike
                                    Cone.
                   LCS
                 Result
                 LCS %
                    Rec
                % Rec
                  Limit  Qualifiers
       Br ornate
       Chlorate
 25
250
ug/L
ug/L
23.8
 246
95.3
98.3
85- 115
90-110
       MATRIX SPIKE: 2028031  DUPLICATE:  2028032  ORIGINAL: 2010344001
         CNOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spil
         :ent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                   Original
                                    Result
                                              Units
                  Spike
                  Cone.
                    MS
                  Result
                  MSD
                 Result
                  MS%
                   Rec
                   MSD %
                      Rec
% Rec
 Limit
                                                                                                             RPD
Max
RPD
                                                                                                                          Qualifiers
       Br ornate
                                              ug/L
                                                          25
                                                                  20.6
                                                                           22.3
                                                                                    82.4
                                                                                              89.3  75-125
                                                                                                             8.01
                                                                                                                     20
       MATRIX SPIKE: 2028033  DUPLICATE:  2028034  ORIGINAL: 2010353003

       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike

       percent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                   Original
                                    Result
                                              Units
                  Spike
                  Cone.
                    MS
                  Result
                  MSD
                 Result
                  MS%
                   Rec
                   MSD %
                      Rec
% Rec
 Limit
                                                                                                             RPD
Max
RPD
                                                                                                                          Qualifiers
       Chlorate
                                              ug/L
                                                         250
                                                                  225
                                                                           226
                                                                                    89.8
                                                                                              90.3  75-125
                                                                                                              .53
                                                                                                                     25
                                   ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2010351 - 8/26/2014
                                                                                                                        Page 9 of 30
                                                              C-116

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                         Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com
                                 NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                     State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                  QUALITY CONTROL DATA
      Workorder:  2010351 PW3-DC

      QC Batch:         VOMS/32885
      QC Batch Method:  EPA 524.2
      Associated Lab Samples:  2010351001
Analysis Method:
                    EPA 524.2
METHOD BLANK: 2028366

Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)

Blank
Result
NO
ND
ND
ND
ND
93
77.8
2028367
Spike
Cone.
1
1
1
1


2028368
Spike
Cone.
5
5
5
5
5




Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Reporting
Limit
0.50
0.50
0.50
0.50
0.50
70 - 1 30
70-130
LCS
Result
1.2
0.99
0.91
1.0


LCS
Result
5.5
4.9
5.4
4.9
4.9




Qualifiers







LCS %
Rec
116
99.4
90.9
100
106
83.4
LCS %
Rec
110
97.3
108
97.9
97
113
94










% Rec
Limit Qualifiers
50 - 1 50
50 - 1 50
50 - 1 50
50 - 1 50
70 - 1 30
70 - 1 30
% Rec
Limit Qualifiers
70 - 1 30
70-130
70 - 1 30
70 - 1 30
70 - 1 30
70 - 1 30
70-130
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland •  Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2010351 - 8/26/2014
                                                                                                                  Page 10 of 30
                                                           C-117

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                               Appendix C
                     Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541  •  Fax: 717-944-1430  •  www.alsglobal.com
                                  NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                    QUALITY CONTROL DATA
      Workorder: 2010351 PW3-DC

      QC Batch:         SVGC/34522
      QC Batch Method:  EPA 515.3
      Associated Lab Samples:  2010351001
   Analysis Method:
                        EPA515.3
       MATRIX SPIKE SAMPLE: 2028726   ORIGINAL:
         CNOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix!
         :ent recoveries. This result is not a final value and cannot be used as such.
Original
Parameter Result Units
Dalapon ug/L
2,4-Dichlorophenylacetic %
add (S)
SAMPLE DUPLICATE: 2028727 ORIGINAL:
Original
Parameter Result Units
Dalapon ug/L
2,4-Dichlorophenylacetic %
acid (S)
2,4-Dichlorophenylacetic %
acid (S)
Spike MS MS% % Rec
Cone. Result Rec Limit Qualifiers
5 6.2 125 70-130
70- 130
DUP Max
Result RPD RPD Qualifiers
ND 30
2.7
97 130
       MATRIX SPIKE SAMPLE: 2028728   ORIGINAL:
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.
                                  Original              Spike      MS     MS %    % Rec
       Parameter                    Result     Units
Cone.     Result
                    Rec
                             Limit  Qualifiers
Dalapon
2,4-Dichlorophenylacetic
acid (S)
METHOD BLANK: 2028729
Parameter
Dalapon
2,4-Dichlorophenylacetic
acid(S)
ug/L 5 8.6
%

Blank Reporting
Result ynjts Limit Qualifiers
ND ug/L 4.0
98 % 70 - 1 30
172 70-130
70-130



                                   ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland •  Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2010351 - 8/26/2014
                                                                                                                       Page 11 of 30
                                                              C-118

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                       Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7  •  Phone:717-944-5541 •  Fax: 717-944-1430 • www.alsglobal.com
                                 NELAP Certifications:  NJ PA010 , NY 11759 , PA22-293   DoDELAP: A2LA0818.01
                                     State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                  QUALITY CONTROL DATA
      Workorder: 2010351 PW3-DC

      LABORATORY CONTROL SAMPLE: 2028730

                                   Spike                LCS   LCS %    % Rec
      Parameter	Conc-     Units     Result      Rec     Limit  Qualifiers
      Dalapon                         5      ug/L        6.4      128  70-130
      2,4-Dichlorophenylacetic                     %                99  70-130
      acid (S)
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey

      Report ID: 2010351-8/26/2014                                                                                     Page 12 of 30
                                                            C-119

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                   Enuironmental

      34 Dogwood lane • Middletown, PA 17057 ป Phone:717-9445541 • Fax: 717-914-1430  •  www.alsglobal.com
                                 NELAP Certifications: NJ PA010, NY 11759, PA22-293  DoD ELAP: A2LA0818.01
                                    State Certifications: DE ID 11 , MAPA0102 , MD 128 , VA460157 , WV 343

                                   QUALITY CONTROL DATA CROSS REFERENCE TABLE
      Workorder: 2010351 PW3-DC
      Lab ID
                              Sample ID
                                                      Prep Method
                                                                            Prep Batch
                                                                                         Analysis Method
                                                                                                            Analysis
                                                                                                            Batch
      2010351001
                              PW3-DC-P/MERC BARGE    EPATRMD
                                                                            MDIG/45783    EPA 200.7
                                                                                                            M ETA/44624
      2010351002
                              TRIP BLANK
                                                                                         EPA 524.2
                                                                                                            VOMS/32878
      2010351001
                              PW3-DC-P/MERC BARGE
                                                                                         EPA 300.1
                                                                                                            WETC/139120
      2010351001
                              PW3-DC-P/MERC BARGE
                                                                                         EPA 524.2
                                                                                                            VOMS/32885
      2010351001
                              PW3-DC-P/MERC BARGE    EPA515.3
                                                                            SVGC/34522    EPA 515.3
                                                                                                            SVGC/34542
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary - Centre of Excellence - Edmonton • Fort McMurray - Fort St. John • Grande Prairie • London • Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellowknife United States: Cincinnati • Everett • Fort Collins • Holland • Houston • Middletown • Salt take City • Spring City • York Mexico: Monterrey
      Report ID: 2010351-8/26/2014
                                                                                                                 Page 13 of 30
                                                           C-120

-------
p
to
                     r
                     w
                            enulronmental
34 Dogwood Lane
Middletown, PA17057
f. 717-944-5541
F.7i7~944-143Q
                                                                                       CHAIN OF CUSTODY/
                                                                                    REQUEST FOR ANALYSIS
                                                                                                                                     I
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                            Cotms: WHITE. ORIGINAt CANARY • CAJS1OMER COPY
                                                                        •"ConMiBM Type ซS-AmWr DIMS; C6-Cleป Ol>ซs, PL-Ptosfc ConHlrair SIM! JSOml, $00mt, 1 L, Sol, Me, Preswvsllvs: HCI. UNO J, NaOH, Me.
                                                                                                                                  I
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-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                  Appendix C
          WI.IL
                              WECK LABORATORIES, INC,
                                                     CERTIFICATE OF ANALYSIS
                                                                                                   M! Laboratory S
          Client:    ALS Environmental - PA
                    34 Dogwood Lane
                    Middletown PA, 17057


          Attention:  Oebra Musser

          Phone:    (SCO) 794-7709

          Fax:      (717)944-1430

          Work Order(s):  4F10QB1
Report Date:       07/03/14 13:34

Received Date:    06/10/14 09:05

Turn Around:      Normal

Client Project:     2010351
                                  NELAP S04229CA ELAPS1132 NEVADA #CA211 HAWAII LACSD #10143

        The results in this report apply to the samples analyzed in accordance with the Chain ml Custody document. Week Laboratories, Inc.
        certifies that lite test results meet ปll NELAC requirements unless noted in trie case narrative. This analytical report is confidential and is
        only internists for the use of W*rt Laboratories, tne, ami its client.  This report contains the Chain of Custody document, which is an integral
        part of it, and can only tie reproduced *> M *** "*• authorization of Week Laboratories, Inc.

        Dear Oebra Musser:

        Enclosed are the results of analyses for samples received 06/10/14 09:05 with she Chain of Custody document- The samples
        were received in good condition, at 5.0 ฐC and on ECS. All analysts met the method criteria except as noted below or in the report
        with  data  qualifiers.

        Case Narrative:
        Reviewed by:
        Brandon Gee
        Project Manager
                                                                                                                    aงa io<6
                     V*?ck Ls;berr:iG.-e:*, Ire  14SSS East Clart; Avenue City of indi^t-y Cs^toTn:a 91 ?45--53?ซ$  ,'626) 3?S-^13^  FAX {^6} 33S-^3^
            t he results ^ Ihas re^KJft apply to (tie sarnies analyzed in accon^ance wrth the cham c* cu&lody dccarmenE Tins anaiytieal report mus! be reproduced in *Js e
                                                                                                             ALS
                                                           C-122

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                         Appendix C
                                                                                                     WECK LABORATORIES, INC.
         ALS Environmental - PA                                                                       Date Received:    06/10/1409:05
         34 Dogwood Lane                                                                             Date Reported;    07/03/1413:34
         MitJcJIetown PA, 17057
                                                       ANALYTICAL REPORT FOR SAMPLES

        Sample ID                            Sampled by;    Sample Comments                             Lab ID      Matrix       Date Sampled

        2010351001                           ClBrt                                                 4FI0081-OI     MWIM      06rtป14 00-00
        DBPsby EPASS1-1
                                                                                                                             Page 2 0(6
                       Wteoe Lat^fSiSores. Jiic  14359 Eo&l Cltlf*. Avenue, City of industry California 9 i 745-131)6   |S52&) 336-2139  FAX C$26) 336-2634
              The results an ihis report apply lo she sampN;s analysed in aecoftjsnce wilh the cliatn ol custody document This an^yltcaF ce^ott T?usai be ceproEJyeed in its e^l^ety
                                                               www.wccklahs.ccMn
                                                                                                                      ALS
                                                                C-123

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                            Appendix C
          WiilL
                                                                         WECK LABORATORIES, INC.
        ALS Environmental - PA
        34 Dogwood Lane
        Middletown PA, 17057


        Sampled: 06(03/1400:00
                                4F10081-01     2010351 001
                                        Sampled By: Client

                                    DBPs by EPA 551.1
                                                                        ArisiyTica* iabofstory Service • Sire* 196-i

                                                                        Date Received:   06/10/14 09:05
                                                                        Date Reported:   07/03/14 13:34
Matrix: Water
Melhod: EPA 551.1
Analyte
1.1.1 -trichtOfO-2-propanone
1 , 1 -CHcWoro-2-propanone
Brornoacetonitrite
BramocWoroacetonilrite
Chloral hydrate
Chloroacetonilrile
Chloroplcrtn
DBjrornoacetonitrile
Dichtofoacslonitrile
TrtchtofoacetonitrHe
Sufr. DeeaffusmHlpnenyl
Balcft W4F0944
Result
ND
NO
NO
ND
ND
ND
ND
ND
ND
ND
98%
Prepared: 06/1 7/14
MRL
0.50
0.50
0.50
0.50
0.50
0.50
0.50
0.50
0.50
0.50
Cone: 9. 77 80-120
14:19
Units
ug.'l
ugfl
ug/l
ug/1
ug/l
ug/l
ug'l
ug/l
ug/l
ug/l
%
Analyst:
Oil Analyzed
t 06/19/1422:25
1 06/19/1422:25
1 06/19/1422:25
1 06/19/1422:25
1 06/19/14 22:25
1 06/1W14 22:25
1 06/19/14 22:25
1 06/19/1422:25
1 06/19/14 22:25
1 06/19/1422:25

Juliet Chootipanya
Qualifier











                                                                                                                  Paga3ol6
             , lปc  M8&S ฃaฃt ClwH Avenue Cปy et Indufity. Coitfomifl 91745-1396
in this capoft app*y So the samples analyzed *?s accordance with the chain of custody documenl. "
                                     ww w . wee k f ,n tฎ -C o rH
                                                                                   3^) 338-7139   TAX f!>26; 33&-
                                                                                  s anaSytcai repoct mcs! be te
                                                                                                            ALS
                                                           C-124

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                 Appendix C
         WnlL
WECK LABORATORIES, INC.
                                                                                Ana'yUcal Laboratory Ser/ice • Ssnce 1964

       ALS Environmental - PA                                                         Date Received:   05/10/1409:05
       34 Dogwood Lane                                                             Date Reported:   07/03/1413:34
       Middletown PA, 17057
                                    QUALITY    CONTROL
                                                SECTION
                                                                                                   Page: J
                  V&ck Uibcsrstoncs, trie  14ปM> Eas! Oarfc. Avenue CHy crnntfustry, C:*:*fotf!ii 1M74&ซl39n  iSi'S.i X!&>*i:t9  TAX {&#$? i3fo-5$3-1
             r**uHis in Ehts repeat appty 5o Ihe samples anaiyzed in ^xorda^t-se with ihecti^in of custody oocumesn. Th^a aoaty&cal repeal rmjst be repioduoed in its e
                                                  www.weck labs.com
                                                                                              ALS
                                                   C-125

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                            Appendix C
          WiilL
                                                                        WECK LABORATORIES, INC.
        ALS Environmental - PA
        34 Dogwood Lane
        Middletown PA, 17057
                                                 DBFs by EPA 551.1 - Quality Control
                                                                        Analytical Laborsmry Service - SHce I^A

                                                                        Date Received:   06/10/14 09:05
                                                                        Date Reported:   07/03/14 13:34
        Batch W4F0944 - EPA 551.1

Anaiyte
Blank (W4F0944-BLK1)
1,1,1-lricWoro-2-propanone
1 ,1-Dichtofo-2-propanone
Bromoacetonilrile
BromocMoroacetonilrite
Chloral hydrate
Chloroacetonilrtle
CWoropccrtn
DibroitioaoetofliMle
Dichteoaceloretrile
Trtchlofoacelorttrtle
Surr Decafluorobiphenyi
LCS (W4F0944-BS1)
1,1.1 -lfteMoro-2-propanone
1 , 1 -DicMoro-2-propancme
Bromoaoetortitriie
Bromocritoroacetonitriie
Chloral hydrate
Chioroacetonilrile
Ghloropicrin
Dibromoacetonitrile
Dicn(oroacetofปtrile
Tffchtoroaeetcmttrile
Surr. Decafiuorot>ifttปnyl
LCS Dup (W4F0944-BS01)
1,1,1 -Mctiioro-2-propanone
1 , 1 -Dichloro-2-propanone
Bromoacetoniwe
BromocrtloroscetoniMe
Chloral hydrate
CnteroaoetoniMle
Chloropicrin
DiWomoacetonitrile
Drchloroaceloratrile
Trichloroacelonitrile
Surr: Oecafluomblpfienyl


ftesuK

NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
10.4

10.2
9.65
10.1
9,12
9.79
11.6
8.57
8.93
8.90
8.92
fO.3

10.9
9.78
9,70
9.74
8.50
11.5
9.33
9.41
9.27
10.0
1O.3


MRL

0.50
0,50
O.SO
0.50
0.50
0,50
0.50
0.50
0.50
0-50


0.50
0.50
0.50
0.50
0,50
0.50
0.50
0.50
0,50
0.50


0.50
0.50
0.50
0.50
0.50
o'so
O.SO
050
0.50
0,50



Units

U9fl
ug/l
ug/l
ugfl
yrtfl
ug/l
ug/l
ugjl
ugfl
ugJ5
ug/l

ug/i
ug/i
ug/l
ug/l
ug/l
ug/i
ug/l
ug/l
ug/l
ug/l
ug/l

ug/l
ug/l
ugl
ug/l
ug/l
ug/i
ug/I
ug/l
ug/I
ug/l
ug/l

Spike
Level
Analyzed:










10.0
Analyzed:
10.0
10.0
10.0
10,0
10.0
10.0
10.0
10.0
10.0
10.0
fO.O
Analyzed:
100
10.0
10.0
10.0
10.0
10,0
10.0
10.0
10.0
10.0
100

Source
Re&ult ^*"*'^v
06/19/1421:10










104
06/19/1421:35
102
96
101
91
98
116
86
89
89
89
103
06/20/14 10:45
109
98
97
97
35
115
93
94
93
100
103

% REC RPD Oats
Limits RPD Limit ChMflifiors











80-f20

75-125
75-125
75-125
75-125
75-125
75-125
75-125
75-125
75-125
75-126
80-120

75-125 6 25
75-125 1 25
75-125 5 25
75-125 7 25
75-125 14 25
75-125 0,9 25
75-125 8 25
75-125 5 25
7S-125 4 25
75-125 12 25
80-120
Page 5 of 6
 Wee* LatcrsEorleS, tnc 14S&9 Eff-sl Cf-nrK Avcrac. CHy uf ^nduslry, CaiWc
n thts report apply to the samples analyzed in accordance wrth the chain oฃ c
                                                                      a 9 1 ?4S-i 39ft  (S26s 33ซ-2 S 39  FAX (&^6) 33&-^S j-1?
                                                                      iody document , 1 his. analytical report must be reproduced m sis e
                                                                                                            ALS
                                                           C-126

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                          Appendix C
           WiJL
WECK LABORATORIES, INC,
                                                                                                        Ana ;yt seal Laboratory ^rvite- Sm;e 1964


         ALS Environmental - PA                                                                         Date Received:    06/10/14 09:05
         34 Dogwood Lane                                                                               Date Reported:    07/03/14 13:34
         Middletown PA, 17057

                                                         Motes and Definitions

         ND       WT DETECTED ซt Of atwve the Reportmg Limit, ฃf J-value reported, then NOT DETECTED at <& above tha Method Detection Limit (MDL)

         MR       Not Repoitable

         Dit       DAuUOfl

         dry       Sampf* fflsults rejwrtea ort a tfiy weigh! basis

         RPO      Relative Percent Difference

         % Rec     Percent Recovery

         Syb      Subcontracted analysis, &r!*ginal report available u|>or> request

         MDL      Metftod Detection Limit

         MOA      Minimum DetecSaWe Activity

         MRL      Method Reporting Limit
        Any remaining sampfe(&) wfll be disposed of one month from the final report date unless other arrangements are made in advance.

        An Absence of Total Colifoun meets the drinking water standards as established by the California Department of Health Services,

        Tne Reporting Umit (RL) Is referenced as Ihe Laboratory's Pradicaf Qyantttation Limit (POL) or the Detection Limit for Reporting Purposes
        (DLR).

        A!( samples colfe:ted by WecK Laboratorfes have been sampled in accordance to laboratory SOP Number M1S002
                                                                                                                                 Page 6 of 6
                        Wfeck Labcretoncs, Ifw  1-'.eS^ Enst Clark Avenue. City G' Inctoirt-y. Ca'rforTTซ^5?'tS-l3<^   {&2iU> 338-213*J  TAX fB^6} 33B-2S^rt
                e resets in this reporl ซppiy KJ ih* samples &na!yzed ^s sccoidanee with ih# ch.-j!?s of cus.-!c
-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                Appendix C
       4ฃeurofins
                         Eaton Analytical
                                        LABORATORY REPORT
                                      This report contains    10    pages.
                                            (including the cover page)
                 If you have any questions concerning this report, please do not hesitate to call us at
                 (800) 332-4345 Of (574) 233-4777.
                 This report may not be reproduced, except in full, without written approval from Eurofins
                 Eaton Analytical, Inc.
                                                                                      Page 1 of 10
                                                                                           ALS
                                                  C-128

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                   Appendix C
       4ฃeurofins
                           Eaton Analytical
                                                NELAC NARRATIVE PAGE



                   Client:  ALS                                                    Report #:  319048NP


                   Eurofins Eaton Analytical, Inc. is a NELAP accredited laboratory. All reported results
                   meet the requirements of the NELAC standards, unless otherwise noted.
                   EEA contact person:  Nathan Trowbridge

                   NELAP requires complete reporting of deviations from method requirements, regardless
                   of the suspected impact on the data.  Quality control failures not reported within the
                   report summary are noted here.
                   There were rvo quality control failures.
                   Note: This report may not be reproduced, except in full, without written approval from
                   EEA. EEA is accredited by the National Environmental Laboratory Accreditation
                   Program (NELAP),          $ฐIJ .^^  /-?/77        Digitally signed by James Vernon
                                                           r, f  .       Date:2014.06.1809:13:32-04W

                   Authorized Signature                   Title                           Date
                                                                                            Page 1 of 1
                                                                                               Page 2 of 10
                                                                                                    ALS
                                                       C-129

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                 Appendix C
       4>*eurofins
                            Eaton Analytical
                  110 South Hill Street
                  Somh BentfJN 46617
                  Tel: (574)233-4777
                  Fax- (574)233-8207
                  I 800 332 4345
       Client:  ALS

        Attn:  Karen Elofsky
              34 Dogwood Lane
              Middtetown, PA 17057
                                                 Laboratory Report
              Report:
              Priority:
              Status:
              PWSID:
              PA Lab ID:
319046
Standard Written
Final
Not Supplied
68466
Copies
to: None
Sample Information
EEA
ID*
sworn
Client ID | Method
2010351 001 1 552,2-

1 Collected
Date / Time
|| (W03M4 10:30
Collected
By:
Oiiem
Received
Date / Time
06(10/1409:00

                                                     Report Summary
      Note: See attached page for additional comments.
      Note: Sample container was provided by the client.
      Detailed quantitative results are presented on the following pages. The results presented relate only to the samples provided for
      analysis.
      We appreciate the opportunity to provide you with this analysis.  If you have any questions concerning this report, please do not
      hesitate to call Nathan Trowbfidge at (574) 233-4777.

      (Vote: This report may not be reproduced, except in full, without written approval from EEA. EEA is accredited by the National
      Environmental Laboratory Accreditation Program (NELAP).
                    //           s'
                     ^{4/WV*^*^
   Digitally signed by James Vernon
'   Date: 2014.06.18 09:13:47-04*00'
        Authorized Signature
      Client Name:     ALS
      Report*:        31M46
                                                        Title
                                                       Page 1 of 3
                                                                                               Page 3 of 10
                                                                                                     ALS
                                                       C-130

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                  Appendix C
      Client Name:
                  ALS
                                                                                Report*:  319046
      Sampling Point:   2010351 001
PWSID: Not Supplied

Anaryte
ID S
5589-8^8
5278-85-5
631-64-1
79-43-6
79-08-3
79-11-8
75-W-l
76-03-9
—
Analyte
Bromochioroace&c aeirf
CMorotttramMGilic xxS
Dibrbmoaoesie add
Qlchloroacatic add
ItfonoSHmnoacstsc ackl
MwKschtoKsacabs acid
Tfl&fomoecelic pcld
Trtchioresrassacld
Total HAA5
Method I Reg I MRLf
1 Umlt 1
552.2
552.2
5522
552.2
552.2
55Z.2
552, Z
552.2
S52.2
(I 1.0
t--
1 ~
-
-
_
— ^-ป
60-
! 2.0
10
i 10
1.0
' 4,0
t 1.0
i 2-0
Re'sutt | Unfts


< 1 0 fl uซ.'L
< 2 0 J uf-n.
< 1 0 * ug/L
< 1 0 ^ u^L
~
< 1 0 ? u$L

Preparation I
Data 1
OW1 3/14 08:40
06ป'1 3(14 08:40
06

06*13/1406:40 ;
OKT13/140640
* 2 0 " uga. p O&f 1 3/14 OB:40 |
* * 0 " ซgป>L
< 1 0 s ug^L
< 2 0 yg^L
1
06
. ™
/1 3/14 06:40 |
/13/M 08:40 j
06/13/1406:40 I


Anaryzed
Date
06/13/14 18:45
06/13(14 18:45
06/13/14 18:45
06/13/14 18:46
06/13/14 18:45
06/13/14 t8:45
Oe/13,'14 t8:45
OS/13/14 18:45
OS/13/14 18:45
EEA
ID*
3040772
3040772
3040772
3040772
3040772
S04077Z
3040771
3040772
3040772
t EฃA has demonstrated Et can achieve these report limits in reagent water, but can not document them In all sample matrices
Rflg UmK Type: [ MCI I
. .SMC*- . . ..] 	 AL ... i
Sym&ol: i " 1 * i '
|


                                                    Page 2 of 3
                                                                                              ALS
                                                   C-131

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                              Appendix C
        Client Name:     ALS                                                                                Report*  319046


                                                                      Lab Definitions

                     Continuing Calibration Check Standard (CCC) I Continuing Calibration Verification (CCV) / Initial Calibration
                     Verification Standard (ICV) t initial Performance Check (IPC) - is a standard containing one or more of the targe!
                     analytes that is prepared from the same standards used to calibrate Ine instrument, This standard is used to verify
                     the calibration curve at the beginning of each analytical sequence, and may also be analyzed throughout arxf at the
                     end of tne sequence. The concentration of continuing standards may be varied, when prescribed by (he reference
                     method, so that the range of the calibration curve is verified on a regular basis.

                     Internal Standards (IS)  - are pure compounds wilh properties similar to the analytes of interest, which are added to
                     (lew samples or extracts, calibration standards, arid quality control standards at a known concentration. They are
                     used to measure the relative responses of the analytes of interest and surrogates in the sample, calibration standard
                     or quality control standard.

                     Laboratory Duplicate (LD) • is a field sample aliquot taken from the same sample container in the laboratory and
                     analyzed separately using identical procedures. Analysis of laboratory duplicates provides a measure of itie
                     precision of the laboratory procedures.

                     Laboratory Fortified Blank (LFB) / Laboratory Control Sample (LCS) - is an aliquot of reagent water to which
                     known concentrations of the analytes of interest are added. The LFB is analyzed exactly the same as the field
                     samples. LFBs are used lo determine whether the method Is in control

                     Laboratory Method Blank (LMB) / Laboratory Reagent Blank (LRB) • is a sample of reagent water included in the
                     sample batch analyzed in the same way as the associated field samples. The LM8 is used to determine  if method
                     analytes or ottier background contamination have been introduced during (tie preparation or analytical procedure.
                     The LMB is analyzed exactly the  same as the field samples.

                     Laboratory Trip Blank (LTB) / Field Reagent Blank (FRB) - is a sample of laboratory reagent water  placed in a
                     sample container in the  laboratory and treated as a field sample, including storage, preservation, and all  analytical
                     procedures. The FRRfLTB container follows the collection bottles to and from the collection site, but the FR8/LTB ซs
                     not opened at any time during the Irip. The FRB/LTB is primarily a travel blank used to verify that the samples were
                     not contaminated during shipment.

                     Matrix Spike Duplicate Sample (MSO) / Laboratory Fortified Sample Matrix Duplicate (LFSMD) - is a sample
                     aliquot taken from Ihe same field  sample source as the Matrix Spike Sample to which known quantities of the
                     analytes of interest are added in the laboratory. The MSD is analyzed exactly the same as the field samples
                     Analysis of tne MSD provides a measure of Ihe precision of the laboratory procedures in a specific matrix.

                     Matrix Spike Sample (MS) / Laboratory Fortified Sample Matrix (LFSM) - is a sample aliquot taken  from field
                     sample source to which known quantities of tne analytes of Merest are soded in the laboratory. The MS is analyzed
                     exactly the same as the field samples. The purpose Is to demonstrate recovery of the analytes from a sample matrix
                     to determine if the specific matrix contributes bias lo the analytical results.

                     Quality Control Standard (QCS) f Second Source Calibration Verification (SSCV) - is a solution containing
                     known concentrations of the analytes of inleresl prepared from a source different from the source of the calibration
                     standards. The solution  is obtained from a second manufacturer or lot if the lot can be demonstrated by the
                     manufacturer as prepared independently from other lots. The QCS sample is analyzed using the same procedures
                     as field samples. The QCS is used as a cheek on the callbralton standards used in tne method on a routine basis.

                     Reporting Limit Check (RtC) / Initial Calibration Check Standard (ICCS) - is a procedural standard that is
                     analyzed each day to evaluate instrument performance at or below the itHnimum reporting limit (MRLJ.

                     Surrogate Standard (SS) / Surrogate Analyte (SUR) - is a pure compound with properties similar to the analytes of
                     Interest, which Is highly unlikely to be found in any field sample, that is added to the field samples, calibration
                     standards, blanks and quality control standards before sample preparation. The SS is used 10 evaluate the efficiency
                     of the sample preparation process.
                                                                       Page 3 of 3


                                                                                                                          Page 5 of 10
                                                                                                                                  ALS
                                                                      C-132

-------
o
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                                                                3i
                                                                         ^5ฃ3^3
A 34 Doswod Lane CHAIN OF CUSTODY/
/T.%. Mi.i>Ai7BS7 REQUEST FOR ANALYSIS
QQ^S^^HEฃฃBgg^^^| TAMP^IM^ GLIEfiT' •
Client Nam: AtS Btidrantrartal
Address 34 Dapma! Lซe
tAMetaw. PA 17057
Contact Customer Settee
Raw*: (717)944-5541
ProjectKarroW:
Bill To: AiSErtwofirneflM
TAT [xjNoimaKBmlanlTAT is 10
3ate Required: Ai
Email? [YJ-Y AUvtDT.Subcontraet
-12businปs
Jvalandsm
)pnปซIBy:
SALSGtob
soays-
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Fw? Cr'*-
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-------
          4ฃeurofins
                              Eaton Analytical
                                       Eurofins Eaton Analytical
                                                Run Log
                                     Run ID:   191830    Method;  552.2
                               I
             Type
             CCL
             1MB
              FS
             ccc
Sample Id
 3044248
 304424?
 3040772
 3044249
                                                    Sample Site
2010351 001
Matrix
 RW
 RW
 DW
 RW
Instrument ID
   PW3
   PW3
   PW3
   PW3
 Analysis Date
OS13tt014 16:56
06/13/2014 17:32
06/13/2014 18:45
06/14/201400:50
 Calibration File
552J-061014PW3
S52_2-061014PW3
SS2_2-Q61
r
                                                                                                                                                              M ^
                                                                                                                                                              ^J 01
                                                                                                                                                              P
                                                                                                                                                             I3
          Page 1 of 3
                                                                                                                EEA Run ID 191830 / E
                                                                                                                                           319046
                                                                                                                                    I
                                                                                                                                    X
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-------
o
                                                                                                         QC Summary Report
                                                                                                                                    ugt   n   %&  ง so


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v. ,. ^ JL^-™_^w.",^.ซ..,^i^—.—
                                                                                                                                                            rJQJ

                                                                                                                                                              EEA Run ID
                                                                                                                                                                                                                        I
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                                                                                                                                                                                                                       GrQ
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-------
QC Summary Report (coni)
Sample ji Analyte
|Mซthod H MRL 11 CUcfillD llRa^ulI
\l 1 I "*
OCC ง IS.I.Z.S.'tacNcmpnpn \\ ง&2 || NW || -- ||_
amounl t Targn
5B&5S g 59ESS
Units II % II Rtco.fry
j| Recovery | limits
WO. J[ 95 1 TO- 130
WO
..
RPD | Oil
Limit | Fictor
- i! vo
Extracted i
W1#2G14GS--40
! Analyzed
0ฉf14(2$1
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                                                                                                                                                                               P

                                                                                                                                                                              I3
            Page 3 of 3
EEA Run 10 191830 / E!j$6!pฐor!& 319046
I
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-------
                                                                                            Sample Type Key
                                                                                                                                                                                           I
                                                                                o
                                                                                a
                               Type (Abbr.l
                                   ccc
                                   CCL
                                    FS
                                   1MB
Sample Type
Continuing Calibration Check
Continuing Calibration Low
Field Sample
Laboratory Method Blank
Type fAbbr.l
                Sample Type
                                                                                                                                                                                          GrQ
O
                                                                                                                                        t-i a
                                                                                                                                        VJ TO

                                                                                                                                        P
                                                                                                                                       I3
                               Page 1 of 1
                                                                                                                                        EEA Run \D 191830 /
                                                                                                                                                                    319W6
                                                                                                                                        I
                                                                                                                                        X
                                                                                                                                        o

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                    Appendix C
                   Environmental
     34 Dogwood Lane • Middlctowi, PA 17057 •  Phono: 717-944-5541 • Fax: 717-9J4-1430 • www.al5global.com

                               NELAP Certifications: NJ PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                   State Certifications: DE ID 11 , MAPA0102, MD 128 , VA 460157 , WV 343


         August 26, 2014
              Ms. Janet Barnes
              University of MD-UMCES - Solomons, MD
              P.O. Box 38
              146 Williams Street
              Solomons, MD 20688
                                         Certificate  of Analysis
      Project Name:      2014-MD BRACKISH WATER STUDY   Workorder:    2011706
      Purchase Order:                                         Workorder ID:  2014-MD BRACKISH WATER STUDY
      Dear Ms. Barnes:

        Enclosed are the analytical results for samples received by the laboratory on Wednesday, June 11, 2014.

        The ALS Environmental laboratory in Middletown, Pennsylvania is a National Environmental Laboratory
        Accreditation Program (NELAP) accredited laboratory and as such, certifies that all applicable test results meet the
        requirements of NELAP.

        If you have any questions regarding this certificate of analysis, please contact Ms. Debra J. Musser (Project
        Coordinator) at (717) 944-5541.

        Analyses were performed according to our laboratory's NELAP-approved quality assurance program and any
        applicable state requirements. The test results meet requirements of the current NELAP standards or state
        requirements, where applicable. Fora specific list of accredited analytes, refer to the certifications section of the
        ALS website at www.alsglobal.com/en/Our-Services/Life-Sciences/Environmental/Downloads.

        This laboratory report may not be  reproduced, except in full, without the written approval of ALS Environmental.

        ALS Spring City:  10 Riverside Drive, Spring City, PA 19475 610-948-4903
      This page is included as part of the Analytical Report and                        Ms. Debra J. Musser

      must be retained as a permanent record thereof.                               Project Coordinator



                               ALS Environmental Laboratory Locations Across North America
       Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London • Mississauga • Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellowknife United Stales: Cincinnati • Everett • Fort Collins • Holland • Houston • Middletown • Salt Lake City • Spring City • York Mexico: Monterrey

     Report ID: 2011706-8/26/2014                                                                                Page 1 of 21
                                                        C-138

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                                                       Appendix C
               Enuironmental
34 Dogwood Lane • Middletown, PA 17DS7 •  Phone:717-944-5541  • Fax: 717-944-1430 • www.alsglobal.com
                              NELAP Certifications: NJ PA010 , NY 11759 , PA22-293   DoDELAP: A2LA0818.01
                                  State Certifications:  DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                    SAMPLE SUMMARY
 Workorder: 2011706 2014-MD BRACKISH WATER STUDY
Lab ID
2011706001
2011706002
Sample ID
PW4-DC-P/MERC Barge
Trip Blank
Matrix
Water
Water
Date Collected
6/10/201410:45
6/11/2014 10:20
Date Received
6/11/2014 10:20
6/11/2014 10:20
Collected By
Ms. Janet Barnes
Ms. Janet Barnes
  Notes
   --  Samples collected by ALS personnel are done so in accordance with the procedures set forth in the ALS Field Sampling Plan (20 -
       Field Services Sampling Plan).
   --  All Waste Water analyses comply with methodology requirements of 40 CFR Part 136.
   -  All Drinking Water analyses comply with methodology requirements of 40 CFR Part 141.
   —  Unless otherwise noted, all quantitative results for soils are reported on a dry weight basis.
   -  The Chain of Custody document is included as part of this report.
   --  All Library Search analytes should be regarded as tentative identifications based on the presumptive evidence of the mass spectra.
      Concentrations reported are estimated values.
   -  Parameters identified as "analyze immediately" require analysis within 15 minutes of collection. Any "analyze immediately" parameters
      not listed under the header "Field Parameters" are preformed in the laboratory and are therefore analyzed out of hold time.
   —  Method references listed on this report beginning with the prefix "S" followed by a method number (such as S2310B-97)
      refer to methods from "Standard Methods for the Examination of Water and Wastewater".

  Standard Acronyms/Flags
     J     Indicates an estimated value between the Method Detection Limit (MDL) and the Practical Quantitation Limit (PQL) for the analyte
     U     Indicates that the analyte was Not Detected (ND)
     N     Indicates presumptive evidence of the presence of a compound
   MDL    Method Detection  Limit
   PQL    Practical Quantitation Limit
   RDL    Reporting Detection Limit
    ND    Not Detected - indicates that the analyte was Not Detected at the RDL
   Cntr    Analysis was performed using this container
  RegLmt   Regulatory Limit
   LCS    Laboratory Control Sample
    MS    Matrix Spike
   MSD    Matrix Spike Duplicate
   DUP    Sample Duplicate
   %Rec   Percent Recovery
   RPD    Relative Percent Difference
   LOD    DoD Limit of Detection
   LOQ    DoD Limit of Quantitation
    DL    DoD Detection Limit
                              ALS Environmental  Laboratory Locations Across North America
  Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie •  London -  Mississauga • Richmond Hill - Saskatoon - Thunder Bay
Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
Report ID: 2011706-8/26/2014
                                                                                                                         Page 2 of 21
                                                           C-139

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                        Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7  • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com

                                  NELAP Certifications: Nj PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                      State Certifications:  DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                       PROJECT SUMMARY


      Workorder: 2011706 2014-MD BRACKISH WATER STUDY


       Workorder Comments

            Eurofins was unable to report the HAAdata due to OC failure. DJM
            See attached subcontracted acetonitriles results from Week Labs. LDN

       Sample Comments

       Lab ID: 2011706001            Sample ID: PW4-DC-P/MERC        Sample Type: SAMPLE
                                   Barge
            Assuming that all bromate present in the sample is in the form of sodium bromate, the sodium bromate concentration is <5.9ug/L.
            Assuming that all chlorate present in the sample is in the form of sodium chlorate, the sodium chlorate concentration is 60.8 ug/L.
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga - Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States; Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey

      Report ID: 2011706-8/26/2014                                                                                         Page 3 of 21
                                                              C-140

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                   Environmental
      34 Dogwood Lane • Middletown, PA 17057 • Phono: 717-944-5541 • Fax: 717-9J4-1430 •  www.al5global.com

                                NELAP Certifications: NJ PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                    State Certifications: DE ID 11 , MAPA0102, MD 128 , VA 460157 , WV 343

                                                   ANALYTICAL RESULTS
      Workorder: 2011706 2014-MD BRACKISH WATER STUDY
Lab ID: 2011706001
Date Collected: 6/10/201410:45 Matrix: Water
Sample ID: PW4-DC-P/MERC Barge
Parameters
VOLATILE ORGANICS
Bromodichloromethane
Bromoform
Chlorodibro mo methane
Chloroform
1 ,2,3-Trichloropropane
Surrogate Recoveries
1 ,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
HERBICIDES
Dalapon
Surrogate Recoveries
2,4-Dichlorophenylacetic
acid (S)
WET CHEMISTRY
Bromate
Chlorate
METALS
Sodium, Total
Results Flag

ND
1.4
ND
ND
ND
Results Flag
102
85.5

ND
Results Flag
100

ND
47.7

7.4
Units

ug/L
ug/L
ug/L
ug/L
ug/L
Units
%
A>

ug/L
Units
%

ug/L
ug/L

mg/L
Date Received: 6/11/201410:20
RDL

0.50
0.50
0.50
0.50
0.50
Limits
70-130
70-130

4.0
Limits
70-130

5.0
20.0

0.25
Method

EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
Method
EPA 524.2
EPA 524.2

EPA515.3
Method
EPA515.3

EPA 300.1
EPA 300.1

EPA 200.7
Prepared

6/12/14
6/12/14
6/12/14
6/12/14
6/12/14
Prepared
6/12/14
6/12/14

6/19/14
Prepared
6/19/14

6/17/14
6/17/14

6/12/14
By

IMP
IMP
IMP
IMP
IMP
By
IMP
IMP

JEK
By
JEK

SSL
SSL

AAM
Analyzed

6/12/1420:44
6/12/1420:44
6/12/1420:44
6/12/1420:44
6/12/1420:44
Analyzed
6/12/1420:44
6/12/1420:44

6/20/1401:06
Analyzed
6/20/1401:06

6/17/1408:39
6/17/1408:39

6/17/1405:07
By

IMP
IMP
IMP
IMP
IMP
By
IMP
IMP

EGO
By
EGO

SSL
SSL

ZMC
Cntr

B
B
B
B
B
Cntr
B
B

E
Cntr
E

H
H

G1
SUBCONTRACTED ANALYSIS
Subcontracted Analysis
See
attached


Subcontract


6/19/1422:50
SUB
D
                                                                                 Ms. Debra J. Musser
                                                                                 Project Coordinator
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London • Mississauga • Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo • Winnipeg • Yellowknife United Stales: Cincinnati • Everett • Fort Collins • Holland • Houston • Middletown •  Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2011706 - 8/26/2014
                                                                                                                  Page 4 of 21
                                                           C-141

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                   Enuironmental
      34 Dogwood Lane . Middle-town, PA 17057  . Phono: 717-944-5511 . Fax: 717-941-1430 • www.alsglobal.com

                                NELAP Certifications: HI PA010, NY 11759 , PA22-293  DoD ELAP: A2LA0818.01
                                    State Certifications: DE ID 11 ,MAPA0102,MD 128 , VA 460157 , WV 343

                                                   ANALYTICAL RESULTS
      Workorder: 2011706 2014-MD BRACKISH WATER STUDY
Lab ID: 2011706002
Sample ID: Trip Blank
Parameters
VOLATILE ORGANICS
Bromodichloromethane
Bromoform
Chlorodibro mo methane
Chloroform
1 ,2,3-Trichloropropane
Surrogate Recoveries
1 ,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
Date Collected: 6/11/201410:20 Matrix: Water
Date Received: 6/11/201410:20
Results Flag

ND
ND
ND
ND
ND
Results Flag
107
115
Units

ug/L
ug/L
ug/L
ug/L
ug/L
Units
A>
K>
RDL

0.50
0.50
0.50
0.50
0.50
Limits
70-130
70-130
Method

EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
EPA 524.2
Method
EPA 524.2
EPA 524.2
Prepared

6/12/14
6/12/14
6/12/14
6/12/14
6/12/14
Prepared
6/12/14
6/12/14
By

IMP
IMP
IMP
IMP
IMP
By
TMP
IMP
Analyzed

6/12/1415:11
6/12/14 15:11
6/12/14 15:11
6/12/14 15:11
6/12/14 15:11
Analyzed
6/12/14 15:11
6/12/14 15:11
By

TMP
TMP
TMP
TMP
TMP
By
TMP
TMP
Cntr

B
B
B
B
B
Cntr
B
B
                                                                                 Ms. Debra J. Musser
                                                                                 Project Coordinator
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill • Saskatoon • Thunder Bay
      Vancouver Waterloo Winnipeg  Yellowkmfc United States: Cincinnati Everett Fort Collins  Holland  Houston - Middlctown • Salt Lake City Spring City • York Mexico: Monterrey
      Report ID: 2011706 - 8/26/2014
                                                                                                                  Page 5 of 21
                                                           C-142

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                  Appendix C
                     Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com

                                  NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                       State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343


                                                    QUALITY CONTROL DATA
       Workorder: 2011706 2014-MD BRACKISH WATER STUDY
       QC Batch:         MDIG/45866

       QC Batch Method:  EPATRMD

       Associated Lab Samples:  2011706001
                                                           Analysis Method:
                                                                                EPA 200.7
       METHOD BLANK: 2029517
       Parameter
                                     Blank
                                    Result
                                              Units
Reporting
    Limit  Qualifiers
       Sodium, Total
                                       ND
                                              mg/L
                                                         0.25
       LABORATORY CONTROL SAMPLE: 2029518
       Parameter
                                     Spike
                                     Cone.
                                              Units
    LCS
   Result
LCS %
  Rec
% Rec
 Limit  Qualifiers
       Sodium, Total
                                       10
                                              mg/L
                                                          9.6
                                                                  95.9   85-115
       MATRIX SPIKE: 2029519   DUPLICATE: 2029520   ORIGINAL:  2011632001

       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix i

       percent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                   Original
                                    Result
                                              Units
   Spike
   Cone.
   MS
Result
 MSD
Result
MS%
  Rec
MSD %
   Rec
% Rec
 Limit
       Max
RPD   RPD
                                                                                                                          Qualifiers
       Sodium, Total
                                              mg/L
                                                                  341
                                                                            316
                                                                                                             7.68
                                                                                                                      20
       MATRIX SPIKE SAMPLE: 2029521   ORIGINAL:
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.

                                                                   MS
       Parameter
                                   Original
                                    Result
                                              Units
   Spike
   Cone.
                                                                Result
          MS%
            Rec
         % Rec
           Limit  Qualifiers
       Sodium, Total
                                              mg/L
                                                                  14.9
                                   ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2011706-8/26/2014
                                                                                                                         Page 6 of 21
                                                              C-143

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                         Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 • Fax: 717-944-1430 •  www.alsglobal.com
                                 NELAP Certifications:  NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                     State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                  QUALITY CONTROL DATA
      Workorder: 2011706 2014-MD BRACKISH WATER STUDY

      QC Batch:        VOMS/32913
      QC Batch Method:  EPA 524.2
      Associated Lab Samples:  2011706001, 2011706002
Analysis Method:
                    EPA 524.2
METHOD BLANK: 2029737

Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)
LABORATORY CONTROL SAMPLE
Parameter
Chloroform
Bromodichioromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
1,2-Dichlorobenzene-d4 (S)
4-Bromofluorobenzene (S)

Blank
Result
ND
ND
ND
ND
ND
92.4
81.3
2029738
Spike
Cone.
1
1
1
1


2029739
Spike
Cone.
5
5
5
5
5




Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
%
%

Units
ug/L
ug/L
ug/L
ug/L
ug/L
%
%

Reporting
Limit
0.50
0.50
0.50
0.50
0.50
70 - 1 30
70-130
LCS
Result
1.2
1.0
1.1
1.0


LCS
Result
5.2
4.9
4.9
4.2
4.2




Qualifiers







LCS %
Rec
123
104
109
102
110
89.7
LCS %
Rec
105
98.5
97.4
84.1
84.6
107
90.2










% Rec
Limit Qualifiers
50 - 1 50
50 - 1 50
50 - 1 50
50 - 1 50
70 - 1 30
70 - 1 30
% Rec
Limit Qualifiers
70 - 1 30
70-130
70 - 1 30
70 - 1 30
70 - 1 30
70 - 1 30
70-130
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2011706-8/26/2014
                                                                                                                    Page 7 of 21
                                                            C-144

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 •  Fax: 717-944-1430 • www.alsglobal.com
                                  NELAP Certifications:  Nj PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                   QUALITY CONTROL DATA
      Workorder: 2011706 2014-MD BRACKISH WATER STUDY

      MATRIX SPIKE: 2029858   DUPLICATE: 2029859  ORIGINAL: 2011704001
      ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
      percent recoveries. This result is not a final value and cannot be used as such.
Original
Parameter Result Units
Chloroform
Bromodichloromethane
Chlorodibromomethane
Bromoform
1 ,2,3-Trichloropropane
4-Bromofluorobenzene (S)
1,2-Dichlorobenzene-d4 (S)
ug/L
ug/L
ug/L
ug/L
ug/L
%
%
Spike
Cone.
5
5
5
5
5


MS
Result
5.8
5.4
5.8
6.2
5.4


MSD
Result
5.7
5.2
5.6
5.7
5.5


MS%
Rec
117
108
116
123
107
100
125
MSD %
Rec
114
104
112
114
110
94
118
% Rec
Limit
70-
70-
70-
70-
70-
70-
70-
130
130
130
130
130
130
130
RPD
2.65
2.97
3.21
7.73
2.42
6.32
5.42
Max
RPD Qualifiers
40
40
40
40
40


                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2011706-8/26/2014
                                                                                                                      Page 8 of 21
                                                             C-145

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                              Appendix C
                    Enuironmentai
                                                                                                             m-
      34 Dogwood Lane • Middlctown, PA 17057 >  Phone: 717-944-5541  • Fax: 717-944-1430  •  www.alsglobal.com

                                  NELAP Certifications: NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                      State Certifications: DE ID11 , MAPA0102, MD 128 , VA460157 , WV 343


                                                   QUALITY CONTROL DATA
      Workorder: 2011706 2014-MD BRACKISH WATER STUDY
      QC Batch:         WETC/139431

      QC Batch Method:  EPA300.1

      Associated Lab Samples: 2011706001
                                                          Analysis Method:
                                                                               EPA 300.1
METHOD BLANK: 2031 421
Parameter
Br ornate
Chlorate
LABORATORY CONTROL SAMPLE
Parameter
Br ornate
Chlorate

Blank
Result
ND
ND
: 2031422
Spike
Cone.
25
250

Units
ug/L
ug/L

Units
ug/L
ug/L

Reporting
Limit Qualifiers
5.0
20.0

LCS LCS % % Rec
Result Rec Limit Qualifiers
24.0 96.1 85-115
243 97.2 90-110
       MATRIX SPIKE: 2031424   DUPLICATE: 2031425  ORIGINAL: 2011689006
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.
       Parameter
                                  Original
                                   Result
                                             Units
Spike
Cone.
  MS
Result
 MSD
Result
MS%
  Rec
MSD %
   Rec
% Rec
 Limit
                                                                                                           RPD
Max
RPD
                                                                                                                        Qualifiers
      Chlorate
                                             ug/L
                                                        250
                                                                 226
                                                                          230
                                                                                   90.4
                                                                                            92.2  75-125
                                                                                                           1.95
                                                                                                                   25
       MATRIX SPIKE: 2031426   DUPLICATE: 2031427   ORIGINAL: 2012000001
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.

                                  Original               Spike       MS     MSD     MS %    MSD %   % Rec
       Parameter                    Result     Unjts
Cone.    Result
                  Result
                             Rec
                                      Rec
                                              Limit
                                                   Max
                                            RPD    RPD   Qua|ifiers
      Chlorate
                                             ug/L
                                                        250
                                                                 233
                                                                          233
                                                                                   92.6
                                                                                            92.4  75-125
                                                                                                            .16
                                                                                                                   25
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington • Calgary • Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London •  Mississauga • Richmond Hill - Saskatoon • Thunder Bay
      Vancouver Waterloo • Winnipeg • Yeliowknife  United States: Cincinnati - Everett - Fort Collins • Holland •  Houston  Middletown  Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2011706-8/26/2014
                                                                                                                       Page 9 of 21
                                                             C-146

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                           Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 • Phone:717-944-5541 •  Fax: 717-944-1430 • www.alsglobal.com
                                  NELAP Certifications:  NJ PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                      State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                                   QUALITY CONTROL DATA
      Workorder: 2011706 2014-MD BRACKISH WATER STUDY

      QC Batch:         SVGC/34633
      QC Batch Method:   EPA 515.3
      Associated Lab Samples:  2011706001
Analysis Method:
                     EPA515.3
METHOD BLANK: 2033186
Parameter
Dalapon
2,4-Dichlorophenylacetic
acid (S)

Blank Reporting
Result ynjts Limit Qualifiers
ND ug/L 4.0
87 % 70 - 1 30
LABORATORY CONTROL SAMPLE: 2033187
Parameter
Dalapon
2,4-Dichlorophenylacetic
acid (S)
SAMPLE DUPLICATE: 2033188
Parameter
Dalapon
2,4-Dichlorophenylacetic
acid (S)
2,4-Dichlorophenylacetic
acid (S)
Spike LCS LCS % % Rec
Cone. unjts Result Rec Limit Qualifiers
5 ug/L 6.3 126 70-130
% 97 70-1 30
ORIGINAL:
Original DUP Max
Result Unijs Result RPD RPD Qualifiers
ug/L ND 30
% 1 .9
% 93 130
       MATRIX SPIKE SAMPLE: 2033189  ORIGINAL:
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries. This result is not a final value and cannot be used as such.
Original Spike MS MS % % Rec
Parameter Result Units Cone. Result Rec Limit Qualifiers
Dalapon
2,4-Dichlorophenylacetic
acid (S)
ug/L 5 5.9 119 70-
% 70 -
130
130
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown •  Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2011706-8/26/2014
                                                                                                                     Page 10 of 21
                                                             C-147

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                        Appendix C
                    Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7  • Phone:717-944-5541 • Fax: 717-944-1430 • www.alsglobal.com

                                  NELAP Certifications: Nj PA010 , NY 11759 , PA22-293   DoDELAP:  A2LA0818.01
                                      State Certifications:  DE ID 11 , MAPA0102.MD 128 , VA 460157  , WV 343


                                                    QUALITY CONTROL DATA
      Workorder: 2011706 2014-MD BRACKISH WATER STUDY
       MATRIX SPIKE SAMPLE: 2033190   ORIGINAL:
       ****NOTE - The Original Result shown below is a raw result and is only used for the purpose of calculating Matrix Spike
       percent recoveries.  This result is not a final value and cannot be used as such.
       Parameter
                                  Original
                                   Result
         Spike
         Cone.
  MS
Result
MS%
 Rec
% Rec
 Limit  Qualifiers
       Dalapon
       2,4-Dichlorophenylacetic
       acid(S)
ug/L
  %
                                                                  6.5
                                                                           130
                 70- 130
                 70- 130
                                  ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London - Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2011706-8/26/2014
                                                                                                                      Page 11 of 21
                                                              C-148

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                   Enuironmental
      34 Dogwood Lane • Middletown, PA 17DS7 •  Phone:717-944-5541  • Fax: 717-944-1430 • www.alsglobal.com
                                NELAP Certifications: Nj PA010 , NY 11759 , PA22-293  DoDELAP: A2LA0818.01
                                    State Certifications: DE ID 11 , MAPA0102.MD 128 , VA 460157 , WV 343

                                   QUALITY CONTROL DATA CROSS REFERENCE TABLE
      Workorder: 2011706 2014-MD BRACKISH WATER STUDY
Lab ID
2011706001
2011706001
2011706002
Sample ID Prep Method
PW4-DC-P/MERC Barge EPATRMD
PW4-DC-P/MERC Barge
Trip Blank
Prep Batch Analysis Method
MDIG/45866 EPA200.7
EPA 524. 2
EPA 524.2
Analysis
Batch
M ETA/44660
VOMS/32913
VOMS/32913
      2011706001
                              PW4-DC-P/MERC Barge
                                                                                        EPA 300.1
                                                                                                           WETC/139431
      2011706001
                              PW4-DC-P/MERC Barge     EPA515.3
                                                                           SVGC/34633   EPA 515.3
                                                                                                           SVGC/34642
                                 ALS Environmental Laboratory Locations Across North America
        Canada: Burlington - Calgary - Centre of Excellence • Edmonton • Fort McMurray • Fort St. John • Grande Prairie • London -  Mississauga • Richmond Hill - Saskatoon - Thunder Bay
      Vancouver Waterloo - Winnipeg • Yellowknife  United States: Cincinnati • Everett - Fort Collins • Holland • Houston - Middletown • Salt Lake City • Spring City • York Mexico: Monterrey
      Report ID: 2011706-8/26/2014
                                                                                                                Page 12 of 21
                                                          C-149

-------
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34 Dogwood Lane
Middletown, PA 17057
P. 717-944-5541
F.717-944-1430
                                                                     CHAIN OF CUSTODY/
                                                                  REQUEST FOR ANALYSIS
                                                                    HOED AREAS WUST BE COMPLETED BY THE Clil
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                                   34 Dogwood Lane
                                   Mlddtetown. PA \ 7057
                                 '  P. ?I7-944_SS41
              Environmental   fm-9ซ4-M30
  CHAIN OF CUSTODY/
REQUEST FOR ANALYSIS
                                                                                                                        Htcปlpt hformnten (tcmplelrt i>y RซtMna Ub
                                               At e CปtHll^ntJ^>i^^. ""J*   	   -  	^..•.,^,>... vx.-m,, m,ปซJiuiBr uqufg al.=2IซUaae DU*
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-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
Appendix C
                                                                                                     WECK LABORATORIES, INC,
                                                        CERTIFICATE OF ANALYSIS
Client: ALS Environmental - PA
34 Dogwood Lane
Middletown PA, 17057

Attention: Debra Musser
Phone: (800) 794-7709
Fax: (717)944-1430
Work Orders): 4F13012
Report Date:
Received Date:
Turn Around:
Client Project



07/06/14 12:50
06/13/14 10:00
Normal
2011706



                                    NELAP TO42Z9CA  ELAP#1132 NEVADA #CAZ11 HAWAII LACSD #10143

        The results in this report apply to the samples ana/yzed in eecorcfance with the Chain of Custody document Week Laboratories, Inc.
        certifies that the test results meet at NELAC requirements unless noted in tlte case narrative.  This analytical report te conffOential and is
        only intended for (he use of Week iaoofsforfes, Inc. ami Its client.  This report contains the Chain of Custody document, wnichisan integral
        part of it, and can only be reproduced in full wrfft We authorization of Week Laboratories, Inc.

        Dear Debra Musser:

        Enclosed are the results of analyses for samples received 06/13/14 10:00 with the Chain of Custody document. The samples
        were received in good condition, at 5.7 ฐC and on ice. All analysis met the method criteria except as noted below or in the report
        with data qualifiers.

        Case Narrative:
        Reviewed by:
        Brandon Gee
        Project Manager
                                                                                                                           Page 1 ore
                       We-cH Laboratories, hie  14Bi<$ Cast Clark Aeenuc. City c
             The results ^ &MS report appiy to the sarnies analyzed w aceos^siicซ w
                                                                                                t repWft must be reproduced in its entirety
                                                                                                                     ALS
                                                                C-153

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                     Appendix C
          WnL
WECK LABORATORIES, INC.
        ALS Environmental - PA                                                                Date Received:   06/13/14 10.00
        34 Dogwood Lane                                                                    Date Reported:   07/06/14 12:50
        Middletown PA, 17057
ANALYTICAL REPORT FOR SAMPLES
SamslelD
2911706 OO1
Sampled by: Sample Comments
Client
Lab ID Matrix
4F13012-01 WSHer
Date Sampled
W/1W14 00:00
                                                          ANALYSES

       DBFs by EPA 551.1
                                                                                                              Page 2 of 6
                    Week Lsborstof^js, Snc  1^369 Cs*tOsrX Avenue. CityoHnrfMSfry, Califaoia 817-05-I 3HB  (S2Si 336-2139  FWc i'S26j 33fc-2S;M
           The results in this ?cpQrf apply to ฃhe samples analyzed in acosrclanca wflh the ซฃy)in Of fiyseody fiocume^l. Bits arsalytecat reppft mu&t be rcprocfcosd in its Entirely
                                                       www.w@cltlabs.com
                                                                                                        ALS
                                                         C-154

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                  Appendix C
          Wn   L
                                              WECK LABORATORIES, INC.
        ALS Environmental - PA
        34 Dogwood Lane
        Middletown PA, 170S7
        Sampled: 08/10/1400:00
   4F13012-01      2011708001
            Sampled By:  Client
        DBFs by EPA 551.1
                                             Asiaiytka! labordtory Service • Sirlte 1Q64

                                              Date Received:   06/13/14 10:00
                                              Date Reported:   07/06/14 12:50
                                                                                                                   Matrix: Water
Method: EPA 551,1
Anatyte
1,1,1 .trtchtoro-2.propar>one
1 . 1 -D*cWoro-2-i>rQpanQne
Bromoacetonitrile
Bromoctitoroacetontlrile
Chloral hy*a(e
ChlofoacetoniUite
Chloropicrin
Dibrorr.oaceloniltile
Dichloroacetonilrite
Tricfiforoaeetonilrite
Star Decaffuorvbiphenyl
Batch. W4F0944
Result
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
126%
Prepared: OS/17/14 14:
MRL
0.50
O.SO
0,50
0.50
0.50
0,50
0.50
O.SO
0.50
0.50
Conc:12.6 80-120
19
Unils
ug/l
i^/1
ugji
ug/l
ugrt
ugff
ug/l
ugfl
ug/l
ug/l
%
Anatyst:
Oil Analyzed
1 06MW14 22:50
1 06/1W14 22:50
1 06rt9H4 22:50
1 06/19/14 22:50
1 06/19/14 22:50
1 06/19/14 22:60
1 08/19/14 22:50
1 06/19/14 22:50
1 06/19/14 22:50
1 06/19/14 22:50

Jultet Chootipanya
Qualife










S-03
                                                                                                                      Page 3 of €
                results m thts report apply to UK s
Av(fiiue, Cttj-- c* indust-v, Ca'itainia U17
accordance wdh ihe cli35A erf custc>i3y fl
                                                                                    f 526} 338-213^  FAX f
                                                                                   This sfttaylical report m^si
                                                                                                              l m its entirety
                                                                                                                ALS
                                                             C-155

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                                                                                  Appendix C
WnlL
                                                                           WECK LABORATORIES, INC.
      ALS Environmental - PA
      34 Dogwood Lane
      MWdletown PA, 17057
                                                                  Ainaiytka* lafcurdtory Service - Since 1 964

                                                                  Date Received:  06/13/1410:00
                                                                  Date Reported:  07/06/1412:50
                          QUALITY    CONTROL
                                    SECTION
    re$.u!i& SA thi-s rซj>or! a^piy be ihe samples analyzed fซ- scccmxSsnce wiih ihe cha^n of e
                                                                                    Pa$o 4 of 6
                                                                 {fc^ซ.) 236-^13?  FAX (&26) 338-263-'-
                                                                . This anslylical report ^uisi be re^roducsd ii ds entiie^y
                                                                               ALS
                                       C-156

-------
Feasibility and Efficacy of Using Potable Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits
                    Appendix C
                                                                                              WECK LABORATORIES, INC.
        ALS Environmental - PA
        34 Dogwood Lane
        Middletown PA, 17057
                                                  DBPs by EPA 551.1 - Quality Control
Ana.'ytKa' Laboratory Service - Sin;:*? iyw

Date Received:    06/13/14 10:00
Date Reported:    07/06/14 12:50
        Batch W4FQ944 - EPA 551.1
Analyte
Blank (W4F0944-BLK1)
1 ,1 ,1-triehloซ>-2-prof>anone
1,1-Oichloco-2-propanone
Bromoacetonltrile
Sromochlofoacetonrtrile
CNoral hydrate
ChloroaoetonUrile
Chtoropicrin
Dibromoacetonitrile
Dichloroaeelonitfile
Trlchloroacetonitrile
Surr: DecallvQmtiiphenyl
LCS (W4F0944-BS1)
1,1,1 -trfchlor o-2-propanone
1 , 1 -Dlcht_ro-2-prop8rH>ne
BromoacetonitriSe
Sromxhloroacelonitrfe
CWoral hydrate
ChloroacetortUrile
Chioropscrin
Dibromoacetonilrile
DtchNxoacelooitrile
Trichlofoacelonitrtle
Surr: Decafluombiptienyt
LCS Dup (W4F0944-BSD1)
1.1,1 -tricriloro-2-pf opanone
1 , 1 -Dichloro-2-propanone
BromoacelonlWe
Brornocnloroacetonitrile
Chloral hydrate
ChloroaceEonilrlle
ChlorTr.M6-ucซ
S %REC
08/19/1421:10










104
06/19/1421:35
102
9S
101
91
98
116
86
89
89
89
103
06/20/14 10:45
109
9B
97
97
85
115
93
94
93
100
103

3 (626)^36-2110
% REC RPO Date
Limio RPD nmt OuallfieB











80-f20

75-125
75-125
75-125
75-125
75-125
75-125
75-125
75-125
75-126
75-125
S0-f20

75-125 6 25
75-125 1 25
75-125 5 25
75-125 7 25
75-126 14 25
75-126 0.9 26
75-125 8 25
75-125 5 25
75-125 4 25
75-125 12 25
80- 120
Page 5 off
FAX (5J6.I 33S.38M
                    n this report apoly to Ihs samples analyzed in accordance w^ih the chain ol gussocfy Coewriiftiil,

                                                          w w w. WEC k I a t>5 .com
                                                                                          s report must be (fซprcduced in i'S e-ftt^cS
                                                                                                              ALS
                                                            C-157

-------
Feasibility and Efficacy of Using Potable  Water Generators
as an Alternative Option for Meeting Ballast Water Discharge Limits                                             Appendix C
                                                                                                            WECK LABORATORIES, INC.
         ALS Environmental - PA                                                                            Date Recaiv8d:     06/13/14 10:00
         34 Dogwood Lane                                                                                  Date Reported:     07/06/1412:50
         Middletown PA, 17057


                                                            Notes and Definitions

         S-03       H>9h surrogate recovery for (his sample Is possibly due So a sample matrix elfect. The data was accepted since a^ target analyies were not
                   detected

         ND       NOT DETECTED at or above the Reporting Una, ซ J-valya reported. tlปn NOT DETECTED al or above tho Method Detection Limit (MOL)

         NR       Not Reoortable

         Dii        Dilution

         dry       Sample results reported on a Cry weight basis

         RPD       Relative Percem Difference
         % Rec     Percent Recovery

         Sub       SubcontmctBd analysis, originsฎ repot available u^off request

         MDL       Method Oetedten Limit

         MDA       Mirtmum DetecttKซAcซvitj

         MRL       MeHlod Reporting Limit
        Any remaining samples) will be disposed of one rnonlh from the final report date unless other arrangements are made in advance.

        An Absence of Tolal Collfomi meets the drinking water standards as established By the California Departmert of Health Sซrvkปs.

        The Reporting Limit (RL) is referenced as the Laboratory's Practical Quantilalton Limit (PQL) or the DetecSion Limit for Reporting Purposes
        ~> T-'te .^^3-
                     a in mis report apc% to Ir:* sairples ana!/zsd n accordance with the ch3:A erf cu&IMy docwmam This siafric-al report muRT he re^rodycea in its en1iret>'

                                                                   *vww.v/ซc Ktilhs .coni
                                                                                                                              ALS
                                                                    C-158

-------