Crystal Geyser Reportedly Plans to Use a Dolphin-Type Water

Treatment System for its Cooling Tower Blowdown

Wastewater but Reports Reveal This Equipment Can be
Ineffective and be Replaced with Chemical Systems That Pose
Even Greater Risks to Municipal Sewer Systems
A “Dolphin-type” system was briefly mentioned with association to the cooling towers.
That equipment was not required by the County nor mitigated in the EIR’s approval, thus
the EIR provided no regulation on cooling tower blowdown discharge purity. The EIR
never discusses the risks of necessary corrosion inhibitors or from toxins in that water to
prevent Legionaire's Disease when aerosol particles containing potentially deadly
Legionella bacteria waft into the neighborhood for a long distance from the cooling
towers. Nothing in EIR requires continuous use of such equipment, and that system
doesn’t eliminate all hazardous or toxic discharges anyway. A Dolphin system is not a
Zero Liquid Discharge (ZLD) system.

Professional in the online HVAC-TALK discussion group, with over 150,000 HVAC
Professionals & enthusiasts from around the world, have discussed their bad experiences
with Dolphin water treatment systems.
http://hvac-talk.com/vbb/showthread.php?70918-Dolphin-chemical-free-
water-treatment/page3
Here are some excerpts:

Dont Do It!!!!!!
i take care of a building with approx 225 water source heat pumps....basic system consisting
of two water loops, two towers, two booilers to keep loop temp up in winter, etc....the big
problem is both towers have THE DOLPHIN!!!! both towers are three years old and are
basically trash, the tubes are completely covered with scale and cannot by any means get it
off..i have to drain and shovel, and yes i said shovel out the scale from the sump bottom and
refill with new water...this is in canton oh who hsa terrible water for make up to respond to
the previos reply...i cannot say enough about not going with the dolphin....blowdowns are a
joke they dont work at all...believe it or not, these towers have sump pumps that run 24 hours
a day in the summer ot keep the loop temps hovering at 95 degrees....just lsat year i had one
of these pumps seize up from scale in the impeller twice and remind you that the thing runs
24 hours a day!!! i could go on but i will keep tabs on this thread to respond to any questions
that you guys may have about this system....i am currently begging the customer to throw it
out, get me a chemical guy in there and straighten this thing out

2010 Randy S.
Nope. Not for towers. We have one Dolphin that kinda halfway works, but our water in
this area is very good. It doesn't pencil out, when compared to our normal
phosphonate tower treatment with also a bromine biocide.

There is a closed loop gizmo called an "Elysator" which is a centrifugal solids separator
and a magnesium anode that does seem to work.

http://www.prochemtech.com/Literature/Case_Histories/dolphin1.html

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DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
08-26-2013, 02:32 PM#9

CraziFuzzy
Professional Member*
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Location
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The Dolphin and Sand Filter are for completely different things. The dolphin may help keep
some very small particles suspended, and keep them from laying down in the chiller, but it
does not REMOVE anything from the tower/water. The tower acts as a large air filter, grabbing
the dirt/dust out of every cubic feet of air that passes through it. If you do not remove the
debris, you will get mud building up in the tower basin, which will eventually get the solid
count high enough to make the dolphin unit moot. The mud also provides a great safe place
for legionella and other bacteria to flourish, protected from any biocide treatment. There are a
few ways to remove the solids - a side-stream off the pumps through a filter, a separate pump
for the filter, etc. I prefer a separate pump for the filter, and the return from the filter be
discharged through nozzles in the pool, to keep it turbulent, and prevent solids from laying
down. This keeps them suspended and allows the filter to pull them out.

The type of filter varies as well. Sand filters are very effective, but do use a lot of water for the
backwash, and at a high rate, requiring a decent enough drain location. Another option is a
cyclonic separator, which is much more compact, and it's blowdown is much less water volume
than a backwash

Continued
http://hvac-talk.com/vbb/showthread.php?683791-Putting-the-Dolphin-to-Sleep-Once-
and-For-All!&highlight=dolphin

11-17-2010, 09:57 PM#1

waterworld
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Putting the Dolphin to Sleep... Once and For All!
One thing I have noticed while browsing this board is a few threads on the Dolphin Chemical
Free Water Treatment System be Clearwater. There seemed to be some people advocating it,
and others... well not so much. Those who advocate the Dolphin really seem to think it's
great. They argue against the criticism saying that 'they don't understand the science'.

Well I agree, they dont understand the science; because there is no science behind
the Dolphin... period. The Dolphin, according to Clearwater, say that it changes the molecular
structure of the Calcium ion by hitting it with an electro-magnetic pulse.

Huh?

I also read on this board, (written by a Dolphin advocate) that the Dolphin can even desalinate
sea water?

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DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
Bigger huh?

First off, let me explain how scale is formed. Hardness, in the form of Calcium (Ca) and
Magnesium (Mg) are both unique ions in chemistry. They belong to a group of elements that
have 'inverse solubility' meaning they become less soluble the higher the temperature in a
body of water. Now, calcium also adds to the alkalinity of water when it is dissolved; the more
calcium, the more alkalinity, the higher the pH (usually). Now, city water is usually between
7.5 and 8.0 or so, it doesnt really matter. When you begin to cycle the bulk water up in a
tower, the pH begins to rise; when the pH reaches 8.3, the alkalinity begins to break down
into bicarbonate alkalinity or 'P' alkalinity. This is the monster that is the precursor to scale.
When the bicarbonate alkalinity becomes over saturated, Calcium, as Calcium Carbonate
begins to fall out of solution and onto heat transfer surfaces. This process is accelerated
greatly when heat is introduced into the equation.

Now, the Dolphin lovers are going to say, "Whatever Waterboy, I don't have any scale so it
must work."

Okay, I challenge you to do this: Go the Dolphin unit in the middle of the summer, keep the
controller plugged in (the one monitoring the conductivity and controlling the bleed) but
unplug the actual Dolphin unit. Leave it unplugged for the rest of the summer. Your results will
be identical to what you are getting now. I guarantee it!

It's a trick people, like mind reading or dowsing or whatever. Here's how they do it, (so I have
heard. I have no first-hand knowledge): There is a calculation to figure how many cycles
(conductivity setpoint for bleed) you can run without treatment of any kind at 100 degree
condenser water. If you look up my other posts you will find it. Now in addition to that
calculation, many municipal water sources have a nuturally occuring amount of Phosphate in
the water, usually around 1.4 to 2.1 ppm as PO4, so the Dolphin people (agian, this is my
assumption if what they are doing) use this in their equation as well to calculate thier max
cycles. Then they calculate the amount of Chlorine in the city supplied water, which can be as
high as 0.5 ppm. With these factors, they can easily calculate how many cycles they can run
without completely destroying your condenser and keep bio in check. BTW, the Dolphin claims
to 'encapsulate' bacteria. I laughed so hard I peed when I read that.

Now, for those that say, "But it works because I can see all the calcium in my sump" Again,
another trick. Remember what I said about heat? Well, in many cases, the calcium becomes
oversaturated. When that happens, it begins to fall out of solution as well, right? Right, but
because the Dolphin runs the Cycles so low, the constantly incoming makeup water is what is
doing the majority of the cooling, not the tower. So, the calcium does not scale, it can't.
There's nothing hot enough for it to adhere to because you are running so much 60 degree
make up into the tower system. Instead, it just falls out in the sump.

Okay, so to the Green freaks who say, "But there's no chemicals so it environmentally
friendly"

(Originally posted by me in another thread)

Okay, let's talk Green Technology. If on a chemical program, I can run a tower at say 5 cycles,
and on the Dolphin I can run 1.5, then which is truly "Green"? Here's food for thought-

If you have a 1000 tons of cooling that averages 80% load, 12 hours per day, at a 10 degree
Delta T, then the evaporation rate would be 30 gpm or 21,600 gallons per day. That is fixed.
However the bleed rate at 1.5 cycles is 60 gpm or 43,200 gallons per day. At FIVE cycles the
bleed rate falls to 8 gpm, (yes that much) or 5,760 gallons per day. So by using chemicals,
which are organic and non hazardous or harmful to the watersupply, you are saving almost
14,000,000 gallons of water per year. In California, that's HUGE! Now, at roughly $2.00 per
thousand gallons of makeup, and $2.50 per thousand gallons of bleed, (sewer) that's $63,000
in real money that a facility would save by using good water chemistry. Now stop and think
how much you would pay for that chemical program. A good rule of thumb is $1.00 per ton

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DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
per month. So, that would be $12,000 worth of chemical and service for a year. That's a
pretty big payback, verses the Dophin.

That is the problem with the Dolphin, they sell a piece of equipment that does absolutely
nothing except suck electricity and wastes water. Here are some links of studies done where
the Dolphin has been used:

http://www.prochemtech.com/Literatur.../dolphin1.html

http://www.prochemtech.com/Literatur.../dolphin2.html

http://www.prochemtech.com/Literatur.../dolphin3.html

I hope I have been helpful. There are some chemical free devices that do work to remove
calcium, but beware... calcium, in addtion to being a scale forming nuicance, also acts as a pH
buffer against corrosion on steel. If your water treater uses a good program, then there is
nothing 'Greener' and more effective that a quality chemical treatment!
---------------
Waterworld:

Seriously, I know I sound a little like a jerk here, and it really has been a long day, and I
apologize for my tone. But this gadget has caused more towers in California to collapse than
you could ever beleive. If you are indeed saying that your cycled bulk water is at 140 ppm,
then you need to fire your chemical guy and save some electricity by throwing the Dolphin in
the trash. You dont need any treatment at all. I suspect the problems you are having with the
other towers is being caused by your chemical guy. The only thing it sounds like you need is a
pool float with some Bromine tablets in it.
----

11-19-2010, 02:39 PM#13

jemawalton
Professional Member
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Oct 2004
Location
Metro ATL
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I can't confirm the 90 day money back trial but I can confirm the Dolphin being removed from
several sites around here after about a year due to poor performance.
-------------

The following detailed expert report found a Dolphin water treatment system for a
cooling tower to be so ineffective that it was replaced with a chemical water treatment
system in less than two years.

Comments on CGWC Industrial Sewer Permit Application, March 2018 p. 4 Attachment #4-D
DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
 Case History Report
The “Dolphin” Nonchemical Device
Cooling Towers

Device Evaluated
This is our second case history report on "The Dolphin HYTRONIC Series 1000" pulsed
power water treatment device (Dolphin) manufactured by Clearwater Systems LLC, 145
Dennison Rd., P.O. Box 463, Essex, CT 06426, ph: 860-767-0850 FAX 860-767-8972
WEB www.clearwater-dolphin.com

System Data
Clearwater representatives designed a water treatment program, based on Dolphin
non-chemical devices (NCD), for treatment of a new, large cooling tower/chiller system at
a Pennsylvania convention center. At the time of our site review, the system had been in
operation approximately 1 1/2 years and the operators were planning to convert to a
standard chemical water management program within a month.

Cooling Towers
Four (4) galvanized steel construction, 1500 ton capacity, BAC 3000 series cross flow
cooling towers, installed in banks of two (East and West), are used to provide cooling for
the condensers of four freon cycle chillers. Typical load is two units base, two units in
reserve. System metallurgy is black iron piping, copper tubes, and some brass valves.
Dolphin units are installed on each chiller condenser return line (4 units) and the makeup
water line (1 unit) to the cooling towers at a reported equipment cost of $120,000.

A conductivity based blowdown control was installed for control of concentration cycles
while a Lakos hydrocyclone was installed on the cooling tower hot water return line for
control of suspended solids. Makeup is normally obtained from an on-site well with City
of Pittsburgh water as a backup source.

Claims Made
Dolphin sales literature and WEB site information claim that the NCD "improves system
efficiency - eliminates bio-film - reduces encrustation & fouling - controls bacteria to very
low levels - inhibits corrosion" in cooling towers.

Dolphin WEB site data, 01/03, claims that Dolphin devices "impart pulsed, high frequency
electromagnetic energy into flowing water".

No USEPA registration pesticide number has been seen in the Dolphin literature reviewed.
Given the claim for control of bacteria and elimination of bio-film, we believe such a
registration is required under FIFRA.
Comment: Crystal Geyser proposes to use a
"Dolphin-type" water treatment system for its
cooling towers. This report found one Dolphin
system ineffective where it was replaced with
1 a chemical water treatment system. CGWC
may do the same someday.

Comments on CGWC Industrial Sewer Permit Application, March 2018 Attachment #4-D
DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
 History
The Dolphin units were installed concurrent with construction of the convention center
with start-up in April, 2002. Operation was continued through September 15, 2003, date
of our review, using only the installed NCD systems as treatment with no pretreatment of
the makeup well water. We have since confirmed that the convention center converted to a
chemical water management program about one month after our review.

Review
PCT personnel visited the site on September 15, 2003, to walk the system and examine the
cooling towers. The site visit was at the request of operating personnel as they had
determined, based on their experience with the NCD systems, to return to a chemical
treatment program in the near future. During the visit, plant personnel reported substantial
corrosion, scaling, deposition, and algae growth problems. The cooling towers were
reported to require frequent manual cleanup to remove algae and slime growth from the
decks and fill, while the tube sheets and water boxes of the chiller condensers had been
wire brushed to remove rust and deposition. The tubes had been brushed once to remove
fouling.

Color pictures were supplied of cooling tower algae growth; chiller tube and water box
corrosion and deposition; and cooling tower corrosion and deposition. Please note the
attached pictures numbered 1 through 4.

A report by Cyrus Rice Water Consultants (CRC), an independent water consultant, on a

cooling water system water audit they had undertaken in July, 2003, was also provided to
us by the operating personnel. Analytical data from this report is summarized as follows:

Parameter Well water makeup East cooling tower West cooling tower
pH 8.0 8.1 8.2
conductivity, mmhos 544 1418 1525
total alkalinity, mg/l 140 150 162
calcium, mg/l 84 102 110
chloride, mg/l 96 273 297
silicon, mg/l 7.4 18.1 15.1
copper, mg/l <0.1 0.54 0.51
iron, mg/l 0.70 0.82 0.85
saturation index +0.84 +0.95 +1.2

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DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
 Microbiological samples were also taken by CRC with the following results reported:

Parameter East cooling tower West cooling tower

Planktonic plate count cfu/100 ml 1,100 1,380
Sessile swab sample cfu/ml TNTC TNTC
TNTC = to numerous to count

Our own inspection of the cooling towers showed algae growth in the basins and scale on
the cooling tower fill. A sample of the scale removed from the cooling tower was analyzed
at Analytical Services, Inc., a sate certified laboratory, with the following results reported.

Parameter Results as % dry Parameter Results as % dry

weight weight
Loss on ignition 18.8 Acid insoluble 0.5
Aluminum as Al2O3 0.03 Calcium as CaO 47.2
Copper as CuO 0.36 Iron as Fe2O3 1.93
Magnesium as MgO 0.72 Manganese as MnO2 1.80
Silicon as SiO2 0.63 Sulfate as SO4 0.29
Phosphate as PO4 0.03 Zinc as ZnO 0.57

A Dolphin unit control box was opened and found to contain a small transformer. The
transformer output, passing through an inductor coil, fed into the actual Dolphin unit. The
Dolphin unit was also inspected and appeared to be nothing more than an insulated coil of
wire wound around a pipe spool. Typical power input was listed on the literature as 110 to
390 va.

Discussion
The data in the CRC report clearly shows that the cooling tower system had a substantial
loss of calcium and alkalinity while operating with NCD treatment. True cycles of
concentration, based on chlorides, was 2.8 to 3.1 cycles, east and west cooling towers
respectively, while the alkalinity cycles were only 1.1 and 1.2, and calcium cycles were 1.2
and 1.3. Picture 1, which clearly shows calcium scale slough off and some scale still on the
cooling tower fill, shows where the calcium and alkalinity went. The analysis of the scale
obtained from the cooling tower fill agrees with the water analysis data in that the majority
of the scale was calcium carbonate. Picture 3 also shows what appears to be calcium scale
on the inside surface of the condenser tubes.

We also note that the iron present in the makeup water, 0.7 mg/l, has also failed to cycle in
the cooling water, levels of 0.82 and 0.85 being reported in the cooling waters. Given
aeration of the cooling waters and the alkaline pH, iron would be expected to precipitate.
Looking at pictures 1, 2, and 3; the red coloration of the scale and deposits is likely due to
iron. Further, the scale analysis confirms the presence of iron at 1.93 %

Comments on CGWC Industria Sewer Permit Application, March 2018 Attachment #4-D
DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
Again referencing picture 3, it appears that the tube sheet is suffering from rather extensive
corrosion as indicated by the presence of rusty areas. This was further confirmed by
operating personnel reporting pits in the tube sheet when it was cleaned of deposits.

Looking at the water analysis data, we also see that the level of copper in both cooling
towers is substantially elevated over what would be expected based upon cycling of the
makeup water. This is a good indication that corrosion of the copper tubes in the condenser
was a problem.

The low microorganism planktonic plate count found was not a surprise. Given the
obvious calcium precipitation within the system, removal of microorganisms from the
cooling water by simple flocculation could be expected. Flocculation is the chemical
process commonly used in many potable water treatment plants and has nothing to do with
"operation" of the NCD, being simply a precipitation of calcium carbonate when the
concentration present in the water exceeds its solubility limit.

The high sessile microorganism level reported is visually confirmed by picture 4, showing
substantial algae growth, and our own observations. The high level of sessile
microorganisms found is of great concern due to both under deposit corrosion and the
effects when these organisms slough off. Such organism masses are an ideal place for
legionella bacteria to multiply and they would become dispersed throughout the water
during sloughing events, and thus able to enter the cooling tower windage stream.

Conclusions
Based on the analytical data and observed corrosion, it is evident that the Dolphin NCD
does not control corrosion in a cooling water environment.

The analytical data and scale observed prove that the Dolphin NCD does not provide an
acceptable level of scale control when a moderate hardness water is used as makeup.
Substantial scale formation within the cooling tower fill was observed and picture 3 shows
scale formation within the condenser tubes.

While the CRC report noted that planktonic microorganisms were at low numbers, the very
high levels of sessile microorganisms found is completely unacceptable for operation of a
cooling water system. Based on the high levels of sessile microorganisms reported and
observed, it is clearly evident that the Dolphin NCD has no effect on biofilms. We are also
of the opinion that the low level of planktonic microorganisms is due solely to
flocculation, with subsequent removal in the hydrocyclone, resultant from calcium
precipitation within the cooling water.

Literature
Review of the supplied literature and Clearwater WEB site shows no theory of operation
for the Dolphin NCD which is consistent with accepted scientific principals.

Comments on CGWC Industria Sewer Permit Application, March 2018 Attachment #4-D
DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
 For instance, reference is made to Faraday's Law of Magnetic Induction (1) to "explain"
how the Dolphin unit "effects surface charge and precipitation". This law concerns
induction of an electrical voltage via movement of a magnetic field relative to a conductor.
At no place in the equation for this law, EMF = -lambda X (dif magnetic flux/dif time),
can one find an addition, or removal, of an electron to a particle, which would be required
to effect surface charge.

Dolphin literature further states operation is via "The electric field effects the surface
charge and precipitation behavior of charged particles--". It is a commonly accepted
chemical principal that the constituents responsible for scale formation exist in water as
separate, hydrated ions, not as "charged particles". Since there are no particles in the water
to be "effected" by an electric field, there will be no action by the NCD.

The claimed "activation of colloidal nucleation sites" resulting in bulk water precipitation
of calcium carbonate is easily explained by well known chemical processes, operating
with, or without, the presence of the Dolphin NCD.

A further claim is made that bacteria are controlled, by the Dolphin NCD, in cooling water
by application of "pulsed power" magnetic fields. Control of bacteria has been
demonstrated in fluids by application of very powerful magnetic fields, several orders of
magnitude greater than any possible field generated by a Dolphin NCD based simply upon
its low power input. It is thus highly unlikely that any measurable effect is produced by the
low intensity magnetic field generated in the Dolphin NCD. This claim could be easily
tested by running plate counts on the influent and effluent from a Dolphin NCD. To date,
we have not seen any such data in the literature.

We would also comment that even if the Dolphin NCD did demonstrate biocidal action,
the effect would be restricted to the water actually passing through the device and thus
provide no control of sessile microorganisms in the rest of the cooling system. As many
problems in cooling tower systems are caused by sessile microorganisms, either in place or
after they slough off, such an effect would not be of much utility.

Economics
A general claim is made that programs based on Dolphin NCD are less expensive to
operate than typical chemical water management programs. With the convention center
spending $120,000 for the Dolphin units and noting that they have operated for the last 1
1/2 years at approximately 25 percent (1500 ton) of design load, we have calculated the
following cost comparison with a typical chemical program.

Comments on CGWC Industria Sewer Permit Application, March 2018 Attachment #4-D
DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
 Item Dolphin NCD Chemical program
evaporation gpd 37,332 37,332
cycles 3 4.5
blowdown gpd 18,666 10,666
capital $120,000 $5,376.00
capital cost at 5% $6,000 269.00
annual chemical cost $0 $12,724.00
sewerage @ $2.00/1000 $13,651 $7,811.00
total operating cost $19,651.00 $20,804.00

Annual cost reduction for Dolphin NCD = $1,153

This analysis shows that the Dolphin NCD has a lower, about 5.5%, annual operating cost
than a chemical program. However, when the difference in capital costs are considered, the
Dolphin NCD has a very poor return on investment as shown in the following:

capital cost difference = $114,624

simple return on investment = 99.4 years

Since most industrial projects are required to yield a maximum return on investment time
of 5 years, even if the Dolphin NCD worked as claimed, it is a very poor investment based
on the cost savings obtained.

Please note that this evaluation did not consider the cost for makeup water, since the
convention center uses well water, which at a typical $2.00/1000 gallons would have given
the chemical program the lower operating cost by $4,687. In general, we observe that most
such studies use inflated chemical program costs to make the NCD the low cost option.

Legal
ProChemTech, and the reporter, have received two (2) letters, dated July 24, 2003 and
September 10, 2003, from an attorney representing Clearwater LLC, supplier of the
Dolphin NCD. Both letters referenced our first Case History Report on the Dolphin NCD
and demanded that the report be removed from our WEB site, and withdrawn from
distribution, on threat of litigation based on the "false and misleading statements"
contained in it.

It is our opinion that legal threats, as noted above, made with the express purpose of
preventing publication of findings is a good indication that the particular device, or
process, investigated is, in fact, not capable of the marketing claims made. If the product
functioned as advertised, there would be no adverse findings to report and thus no need of
legal threats.

The standing policy of ProChemTech International, Inc. is to investigate any "new"

technology in the water treatment field to ascertain its effectiveness and report the results.
6

Comments on CGWC Industria Sewer Permit Application, March 2018 Attachment #4-D
DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
 We believe that open presentation of such findings advances the entire field and science of
water management.

Reporter
Timothy Keister, FAIC, CWT
Chief Chemist

(1) Specific Faraday law noted in letter dated July 24, 2003,
from Robinson & Cole, attorneys for Clearwater Systems, LLC.

Report re-formatted 07/11

ProChemTech International, Inc.

“Innovation in Water Management”
Apache Junction, AZ, and Brockway, PA
814-265-0959 www.prochemtech.com

Comments on CGWC Industria Sewer Permit Application, March 2018 Attachment #4-D
DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
Picture 1, Convention Center, interior of BAC Model 3000 cooling tower showing rusty scale on deck
and scale on fill.

Picture 2, Convention Center chiller condenser with head removed.

Comments on CGWC Industria Sewer Permit Application, March 2018 Attachment #4-D
DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE
 Picture 3, Convention Center, close-up of chiller condenser tube sheet.

Picture 4, Convention Center, algae and slime growth in cooling tower basin and fill.

Comments on CGWC Industria Sewer Permit Application, March 2018 Attachment #4-D
DOLPHIN WATER TREATMENT SYSTEM REPORTED TO BE INEFFECTIVE