Revised DRAFT report

Technical Support for EPA Development of a Permitting Framework to
Address the Vacatur of the NPDES Vessel Exclusion

Prepared for:

Oceans and Coastal Protection Division

U.S. Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, D.C.  20460

Prepared by:

BATTELLE

397 Washington St.

Duxbury, MA 02332

			

EPA Contract No. 68-C-03-041

Work Assignment No. 4-50

Project No. G921350



This page intentionally left blank.CONTENTS

  TOC \o "1-3" \u  ACRONYMS AND ABBREVIATIONS	  PAGEREF _Toc177791317 \h
 vii 

1.0	INTRODUCTION	  PAGEREF _Toc177791318 \h  9 

1.1	The Clean Water Act	  PAGEREF _Toc177791319 \h  9 

1.2	Northwest Environmental Advocates, et al. v. EPA	  PAGEREF
_Toc177791320 \h  9 

1.3	Scope of the Vessel Vacatur	  PAGEREF _Toc177791321 \h  10 

1.3.1	Exemptions to the Vessel Vacatur	  PAGEREF _Toc177791322 \h  10 

2.0	DATA GATHERING AND ANALYSIS	  PAGEREF _Toc177791323 \h  11 

2.1	Recreational Vessel Data	  PAGEREF _Toc177791324 \h  11 

2.1.1	National Marine Manufacturers Association (NMMA) 2006 Boating
Statistics Report	  PAGEREF _Toc177791325 \h  11 

2.2	Commercial Vessel Data	  PAGEREF _Toc177791326 \h  11 

2.2.1	Merchant Vessels of the United States (VESDOC)	  PAGEREF
_Toc177791327 \h  11 

2.2.2	Waterborne Transportation Lines of the United States (WTLUS)	 
PAGEREF _Toc177791328 \h  12 

2.3	Foreign Vessel Data	  PAGEREF _Toc177791329 \h  12 

2.3.1	U.S. Customs Entrances/Clearances Records	  PAGEREF _Toc177791330
\h  12 

2.4	Port Data	  PAGEREF _Toc177791331 \h  12 

2.4.1	MARAD Vessel Calls	  PAGEREF _Toc177791332 \h  12 

2.4.2	U.S. Customs Entrances/Clearances Records	  PAGEREF _Toc177791333
\h  12 

2.4.3	National Ballast Information Clearinghouse	  PAGEREF _Toc177791334
\h  12 

2.4.4	EPA National Total Maximum Daily Load (TMDL) Database	  PAGEREF
_Toc177791335 \h  13 

2.4.5	National Estuary Program 2007 Coastal Condition Report	  PAGEREF
_Toc177791336 \h  13 

2.5	Discharge Data	  PAGEREF _Toc177791337 \h  14 

2.5.1	Uniform National Discharge Standards Reports	  PAGEREF
_Toc177791338 \h  14 

2.6	Pollution Control Technologies/Best Management Practices Data	 
PAGEREF _Toc177791339 \h  15 

2.6.1	Uniform National Discharge Standards Reports	  PAGEREF
_Toc177791340 \h  15 

2.6.2	Lloyd’s Register Ballast Water Treatment Technology Report	 
PAGEREF _Toc177791341 \h  15 

2.6.3	Miscellaneous Literature, Reports, and Phone Conversations	 
PAGEREF _Toc177791342 \h  15 

3.0	VESSEL POPULATION STATISTICS	  PAGEREF _Toc177791343 \h  15 

3.1	Recreational Vessels	  PAGEREF _Toc177791344 \h  15 

3.1.1	Recreational Vessel Numbers	  PAGEREF _Toc177791345 \h  16 

3.1.2	Recreational Vessel Propulsion and Size Data	  PAGEREF
_Toc177791346 \h  17 

3.2	Commercial Vessels	  PAGEREF _Toc177791347 \h  19 

3.2.1	Domestic Commercial Vessel Numbers and Types	  PAGEREF
_Toc177791348 \h  19 

3.2.2	Domestic Commercial Fishing Vessel Numbers	  PAGEREF _Toc177791349
\h  24 

3.2.3	Foreign Commercial Vessel Numbers	  PAGEREF _Toc177791350 \h  26 

4.0	PORT FINDINGS	  PAGEREF _Toc177791351 \h  27 

4.1	Calls to U.S. Ports	  PAGEREF _Toc177791352 \h  27 

4.2	Receiving Water Characteristics	  PAGEREF _Toc177791353 \h  33 

4.2.1	Houston, Texas	  PAGEREF _Toc177791354 \h  33 

4.2.2	New York City, NY	  PAGEREF _Toc177791355 \h  34 

4.2.3	Port Everglades, Florida	  PAGEREF _Toc177791356 \h  34 

4.2.4	Miami, Florida	  PAGEREF _Toc177791357 \h  34 

4.2.5	Los Angeles/Long Beach, CA	  PAGEREF _Toc177791358 \h  34 

4.2.6	San Juan, Puerto Rico	  PAGEREF _Toc177791359 \h  35 

4.2.7	Savannah, GA	  PAGEREF _Toc177791360 \h  35 

4.2.8	St. Thomas, Virgin Islands	  PAGEREF _Toc177791361 \h  35 

4.2.9	Seattle, WA	  PAGEREF _Toc177791362 \h  35 

4.2.10	New Orleans, LA	  PAGEREF _Toc177791363 \h  36 

4.2.11	Charleston, SC	  PAGEREF _Toc177791364 \h  36 

4.2.12	Baltimore, MD	  PAGEREF _Toc177791365 \h  36 

4.2.13	Elizabeth River, VA	  PAGEREF _Toc177791366 \h  36 

4.2.14	Oakland, CA	  PAGEREF _Toc177791367 \h  36 

4.2.15	Bayou Lafourche, LA	  PAGEREF _Toc177791368 \h  37 

4.2.16	Galveston, TX	  PAGEREF _Toc177791369 \h  37 

4.2.17	Tacoma, WA	  PAGEREF _Toc177791370 \h  37 

4.2.18	Jacksonville, FL	  PAGEREF _Toc177791371 \h  38 

4.2.19	South Louisiana, LA	  PAGEREF _Toc177791372 \h  38 

5.0	DISCHARGE FINDINGS	  PAGEREF _Toc177791373 \h  38 

5.1	Discharges Incidental to the Normal Operation of a Vessel	  PAGEREF
_Toc177791374 \h  38 

5.1.1	Aqueous Film Forming Foam (AFFF)	  PAGEREF _Toc177791375 \h  41 

5.1.2	Boiler Blowdown	  PAGEREF _Toc177791376 \h  42 

5.1.3	Cathodic Protection	  PAGEREF _Toc177791377 \h  43 

5.1.4	Chain Locker Effluent	  PAGEREF _Toc177791378 \h  44 

5.1.5	Clean Ballast	  PAGEREF _Toc177791379 \h  45 

5.1.6	Compensated Fuel Ballast	  PAGEREF _Toc177791380 \h  46 

5.1.7	Controllable Pitch Propeller Hydraulic Fluid	  PAGEREF
_Toc177791381 \h  47 

5.1.8	Deck Runoff	  PAGEREF _Toc177791382 \h  48 

5.1.9	Dirty Ballast	  PAGEREF _Toc177791383 \h  49 

5.1.10	Distillation and Reverse Osmosis Brine	  PAGEREF _Toc177791384 \h
 49 

5.1.11	Elevator Pit Effluent	  PAGEREF _Toc177791385 \h  50 

5.1.12	Firemain Systems	  PAGEREF _Toc177791386 \h  51 

5.1.13	Freshwater Layup	  PAGEREF _Toc177791387 \h  52 

5.1.14	Gas Turbine Water Wash	  PAGEREF _Toc177791388 \h  53 

5.1.15	Grey Water	  PAGEREF _Toc177791389 \h  53 

5.1.16	Hull Coating Leachate	  PAGEREF _Toc177791390 \h  55 

5.1.17	Motor Gasoline Compensating Discharge	  PAGEREF _Toc177791391 \h 
56 

5.1.18	Non-Oily Machinery Wastewater	  PAGEREF _Toc177791392 \h  56 

5.1.19	Photographic Laboratory Drains	  PAGEREF _Toc177791393 \h  57 

5.1.20	Refrigeration/Air Conditioning Condensate Discharge	  PAGEREF
_Toc177791394 \h  58 

5.1.21	Rudder Bearing Lubrication Discharge	  PAGEREF _Toc177791395 \h 
58 

5.1.22	Seawater Cooling Overboard Discharge	  PAGEREF _Toc177791396 \h 
59 

5.1.23	Seawater Piping Biofouling Prevention	  PAGEREF _Toc177791397 \h 
60 

5.1.24	Small Boat Engine Wet Exhaust	  PAGEREF _Toc177791398 \h  60 

5.1.25	Sonar Dome Discharge	  PAGEREF _Toc177791399 \h  61 

5.1.26	Steam Condensate	  PAGEREF _Toc177791400 \h  62 

5.1.27	Stern Tube Seals and Underwater Bearing Lubrication	  PAGEREF
_Toc177791401 \h  62 

5.1.28	Submarine Bilge Water	  PAGEREF _Toc177791402 \h  63 

5.1.29	Surface Vessel Bilge Water/Oil-Water Separator (OWS) Discharge	 
PAGEREF _Toc177791403 \h  64 

5.1.30	Underwater Ship Husbandry	  PAGEREF _Toc177791404 \h  64 

5.1.31	Welldeck Discharges	  PAGEREF _Toc177791405 \h  66 

6.0	Pollution Control Technologies and Best Management Practices	 
PAGEREF _Toc177791406 \h  66 

6.1	Aqueous Film Forming Foam	  PAGEREF _Toc177791407 \h  66 

6.2	Chain Locker Effluent	  PAGEREF _Toc177791408 \h  66 

6.3	Clean Ballast	  PAGEREF _Toc177791409 \h  67 

6.4	Compensated Fuel Ballast	  PAGEREF _Toc177791410 \h  70 

6.5	Controllable Pitch Propeller Hydraulic Fluid	  PAGEREF _Toc177791411
\h  70 

6.6	Deck Runoff	  PAGEREF _Toc177791412 \h  71 

6.7	Dirty Ballast	  PAGEREF _Toc177791413 \h  71 

6.8	Distillation and Reverse Osmosis Brine	  PAGEREF _Toc177791414 \h 
71 

6.9	Elevator Pit Effluent	  PAGEREF _Toc177791415 \h  72 

6.10	Firemain Systems	  PAGEREF _Toc177791416 \h  72 

6.11	Freshwater Layup	  PAGEREF _Toc177791417 \h  72 

6.12	Gas Turbine Water Wash	  PAGEREF _Toc177791418 \h  72 

6.13	Grey Water	  PAGEREF _Toc177791419 \h  72 

6.14	Hull Coating Leachate	  PAGEREF _Toc177791420 \h  74 

6.15	Motor Gasoline Compensating Discharge	  PAGEREF _Toc177791421 \h 
75 

6.16	Photographic Laboratory Drains	  PAGEREF _Toc177791422 \h  76 

6.17	Small Boat Engine Wet Exhaust	  PAGEREF _Toc177791423 \h  76 

6.18	Sonar Dome Discharge	  PAGEREF _Toc177791424 \h  76 

6.19	Surface Vessel Bilge Water/Oil-Water Separator Discharge	  PAGEREF
_Toc177791425 \h  76 

6.20	Underwater Ship Husbandry	  PAGEREF _Toc177791426 \h  78 

7.0	Laws, Regulations, and Conventions	  PAGEREF _Toc177791427 \h  81 

7.1	International and National Laws and Regulations	  PAGEREF
_Toc177791428 \h  81 

7.1.1	International Standards	  PAGEREF _Toc177791429 \h  81 

7.1.2	National Law	  PAGEREF _Toc177791430 \h  81 

7.1.3	State Law	  PAGEREF _Toc177791431 \h  82 

8.0	CONCLUSIONS	  PAGEREF _Toc177791432 \h  83 

9.0	REFERENCES	  PAGEREF _Toc177791433 \h  84 

 

LIST OF TABLES

  TOC \c "Table"  Table 3-1.  Top 20 U.S. States for Total Registered
Recreational Vessels, with General Type of Vessel Indicated.	  PAGEREF
_Toc177806314 \h  17 

Table 3-2.  Type of Propulsion for All Registered Mechanically-Propelled
Recreational Vessels.	  PAGEREF _Toc177806315 \h  18 

Table 3-3.  Lengths of All Registered Mechanically-Propelled
Recreational Vessels.	  PAGEREF _Toc177806316 \h  18 

Table 3-4.  Summary of the U.S.-Flag Cargo or Passenger Vessels
Operating in U.S. Waters by Region.	  PAGEREF _Toc177806317 \h  20 

Table 3-5. Top Twenty U.S. TSO Companies Operating Cargo or Passenger
Vessels in U.S. Waters by Number of Vessels Operated.	  PAGEREF
_Toc177806318 \h  22 

Table 3-6. Total Number of U.S. Documented Vessels by Service Type.	 
PAGEREF _Toc177806319 \h  23 

Table 3-7. Top 20 Most Frequently Recorded Flags Entering U.S. Ports or
Waterways in 2005	  PAGEREF _Toc177806320 \h  26 

Table 4-1.  2005 Vessel Calls at All U.S. Coastal Ports Organized by
Geographic Region	  PAGEREF _Toc177806321 \h  28 

Table 4-2. Top 20 U.S. Ports by Number of Vessel Calls in 2005.	 
PAGEREF _Toc177806322 \h  31 

Table 4-3. 2005 Domestic and Foreign Vessel Calls at Top 20 U.S. Ports.	
 PAGEREF _Toc177806323 \h  32 

Table 5-1.  Phase I UNDS Armed Forces Vessel Discharges Requiring an
MPCD.	  PAGEREF _Toc177806324 \h  39 

Table 6-1. Characteristics of Example Ballast Water Treatment Systems	 
PAGEREF _Toc177806325 \h  68 

Table 6-2. Ballast Water Treatment System Standards.	  PAGEREF
_Toc177806326 \h  70 

Table 6-3. Grey Water Treatment Technology Costs	  PAGEREF _Toc177806327
\h  74 

Table 6-4. Bilge Water Treatment Technology Costs	  PAGEREF
_Toc177806328 \h  78 

Table 6-5.  Global BMPs for Preventing Vessel Hulls from being Invasive
Species Vectors.	  PAGEREF _Toc177806329 \h  79 

Table 7-1. Current or Pending State Permitting Systems Pertaining to
Vessel Discharges Covered in this Report.	  PAGEREF _Toc177806330 \h  82


Table 8-1.  Summary of Statistical Findings for Vessels and Ports.	 
PAGEREF _Toc177806331 \h  83 

 

LIST OF FIGURES

  TOC \c "Figure"  Figure 3-1. 2006 U.S. Regional Recreational Vessel
Registration.	  PAGEREF _Toc177806846 \h  16 

Figure 3-2. Summary of U.S. Flag Cargo and Passenger Vessels Operating
in U.S. Waters by Region.	  PAGEREF _Toc177806847 \h  21 

Figure 3-3.  Documented Commercial Fishing Vessels by Owner’s Contact
State.	  PAGEREF _Toc177806848 \h  25 

Figure 4-1. 2005 Vessel Calls to U.S. Coastal Ports by Geographic
Region.	  PAGEREF _Toc177806849 \h  27 

Figure 6-1. Types of Processes Utilized by Ballast Water Treatment
Technologies.	  PAGEREF _Toc177806850 \h  68 

Figure 6-2. Grey Water Treatment System	  PAGEREF _Toc177806851 \h  73 

 

LIST OF ATTACHMENTS

ATTACHMENT A:  Table 1–State-by-state Recreational Vessel Registration
Information

ACRONYMS AND ABBREVIATIONS

AFFF			aqueous film-forming foam

ANPRM		advanced notice of proposed rulemaking

APPS			Act to Prevent Pollution from Ships

AWO			American Waterways Operators

BMP			best management practice

CBP			U.S. Customs and Border Protection

CERCLA	Comprehensive Environmental Response and Community Right-to-Know
Act

CFR			Code of Federal Regulations

CLIA			Cruise Lines International Association

CMC			Crowley Maritime Corporation

CPO			chlorine-produced oxidant

CPP			controllable pitch propeller

CSLC			California State Lands Commission

CWA			Clean Water Act

DA			Discharge Assessment

DB			deck barge

DCB			dry cargo barge

DDT			dichloro-diphenyl-trichloroethane

DEC			Department of Environmental Conservation (Alaska)

DHTB			double-hull tanker barge

DIN			dissolved inorganic nitrogen

DIP			dissolved inorganic phosphorus

DO			dissolved oxygen

DOB			dry open barge

DoD			Department of Defense

EEZ			exclusive economic zone

EPA			United States Environmental Protection Agency

gph			gallons per hour

gpm			gallons per minute

HEM			hexane extractable material

HEP			Harbor Estuary Program (New York/New Jersey)

IMO			International Maritime Organization

LMC			Liberty Maritime Corporation

LSB			lash/seabee barge

MARAD		Maritime Administration

MARPOL 73/78	International Convention for the Prevention of Pollution
from Ships, 

			1973, as modified by the Protocol of 1978 relating thereto

MOGAS		motor gasoline

MPCD			marine pollution control device

NAISA			National Aquatic Invasive Species Act

NAS			National Academy of Sciences

NBIC			National Ballast Information Clearinghouse

NDC			Navigation Data Center

NEA			Northwest Environmental Advocates

NEP			National Estuary Program

NISA			National Invasive Species Act

nmi			nautical mile

NMMA			National Marine Manufacturers Association

NOD			Nature of Discharge

NPDES			National Pollutant Discharge Elimination System

NVDC			National Vessel Documentation Center

OPA			Oil Pollution Act

OTB			other tank barge

OWS			oil/water separator

PAHs			polycyclic aromatic hydrocarbons

PCBs			polychlorinated biphenyls

PCT			pollution control technology

PSPA			Pacific Seafood Processors Association

RO			reverse osmosis

SBT			segregated ballast tanks

SERC			Smithsonian Environmental Research Center

TBT			tributyltins

TMDL			total maximum daily load

TMP			topside management plan

TOC			total organic carbon

TPH			total petroleum hydrocarbons

TSO			Transportation Series Operator

UNDS			Uniform National Discharge Standards

USACE		United States Army Corps of Engineers

USCG			United States Coast Guard

USDA			United States Department of Agriculture

USHMP		underwater ship husbandry management plan

UV			ultraviolet

VESDOC		Merchant Vessels of the United States

WCSC			Waterborne Commerce Statistics Center

WSC			World Shipping Council

WTLUS		Waterborne Transportation Lines of the United States

INTRODUCTION

The Clean Water Act 

Originally enacted in 1972, the Clean Water Act (CWA) is the primary
federal law governing water pollution in the United States (U.S.). 
Among other authorities, it allows the U.S. Environmental Protection
Agency (EPA) to regulate discharges to the nation’s waterways through
the National Pollutant Discharge Elimination System (NPDES).  The NPDES
program “requires permits for the discharge of pollutants from any
point source into the waters of the United States” (40 CFR 122.1(b)),
with the definition of point source including, among other things,
“vessel or other floating craft” (40 CFR 122.2).  The term pollutant
includes the following list of potential contaminants:

dredged spoil, solid waste, incinerator residue, filter backwash,
sewage, garbage, sewage sludge, munitions, chemical wastes, biological
materials, radioactive materials…, heat, wrecked or discarded
equipment, rock, sand, cellar dirt and industrial, municipal, and
agricultural waste. (40 CFR 122.2)

However, section 122.3(a) of the CWA regulations (40 CFR 122.3(a))
exempts some vessel discharges from requiring a NPDES permit, stating:

 

The following discharges do not require NPDES permits:

(a) Any discharge of sewage from vessels, effluent from properly
functioning marine engines, laundry, shower, and galley sink wastes, or
any other discharge incidental to the normal operation of a vessel. (40
CFR 122.3(a))

Although the CWA regulations do not specifically define “discharges
incidental to the normal operation of a vessel”, this term is broadly
described in “Phase I: Uniform National Discharge Standards (UNDS) for
Vessels of the Armed Forces”, a 1999 technical document developed by
the EPA and the Department of Defense (DoD) under Section 312 of the
CWA.  This UNDS document further breaks down incidental discharges of
Armed Forces vessels to include “discharges from the operation,
maintenance, repair, or testing of vessel propulsion systems,
maneuvering systems, habitability systems, or installed major systems
such as elevators or catapults, and discharges from protective,
preservative, or adsorptive hull coatings” (EPA, 1999a).  During the
development of the UNDS document, the authors consulted with Armed
Forces technical experts and developed a list of 39 different discharges
considered to be incidental to the normal operation of an Armed Forces
vessel.  While some of these 39 incidental discharges would not apply to
civilian vessels (e.g., catapult wet accumulator discharge, which can be
found on aircraft carriers), and some of the standards set for others
would not apply to civilian vessels, some of the studies developed for
the UNDS rule may be instructive for this effort. Discharge reports were
also developed for each of the discharges, with some of the more
critical ones receiving a more in-depth examination (Section 2.5.1).  

Northwest Environmental Advocates, et al. v. EPA 

In January 1999, several environmental groups, including Northwest
Environmental Advocates (NEA) (hereafter referred to as NEA et al.),
collectively petitioned the EPA to repeal 40 CFR 122.3(a) (hereafter
referred to as the ‘vessel exclusion clause’).  As explained in
their petition, the primary concern of NEA et al. was for the discharge
of ballast water and any potentially invasive or harmful organisms
contained therein from vessels into United States waters.  Referring to
the CWA definition of pollutant (40 CFR 122.2) and the inclusion of
‘biological materials’ in that definition, NEA et al. stated that
the vessel exclusion clause was illegal because it ran counter to the
CWA and case law (e.g., Natural Resources Defense Council v. Costle
(1977)).  The petition asked that the EPA repeal this exclusion “to
help prevent the further degradation of aquatic resources from”
invasive species (Johnston, 1999).

EPA denied the petition in September 2003, stating that other federal
statutes (e.g., the Act to Prevent Pollution from Ships [APPS], the
National Invasive Species Act [NISA]) and federal-sponsored activities
(e.g., workshops, research and development funding, and participation in
the International Maritime Organization’s (IMO) invasive species
control efforts) are sufficient to address the invasive species issue in
U.S. waters.  

In response to the petition denial, NEA et al. filed a lawsuit (C
03-05760 SI) in the U.S. District Court for the Northern District of
California in December 2003 seeking to compel the EPA to repeal the
vessel exclusion clause.  While the court found for the plaintiffs (NEA
et al.) in March 2005 and ordered the EPA to repeal 40 CFR 122.3(a), the
EPA returned to the court to request that the repeal apply solely to
ballast water and not to all “discharges incidental to the normal
operation of a vessel”.  This request was denied in a September 2006
injunction in which the court directed the EPA to vacate “the blanket
exemption for discharges incidental to the normal operation of a vessel,
contained in 40 CFR 122.3(a)” by September 30, 2008 (NEA et al. v.
EPA, 2006).  Hereafter, the vacating of the vessel exclusion clause
shall be referred to as the ‘vessel vacatur’.

Scope of the Vessel Vacatur

As a result of the court-ordered vessel vacatur, the EPA must develop a
feasible permitting system that will cover millions of formerly-exempt
vessel discharges under the NPDES program.  This permitting system must
be conceived, developed, and implemented by September 30, 2008 or the
EPA risks legal challenges.  Prior to determining the type and manner of
permitting system to implement, EPA must fully understand the scope of
the issue, including the number and types of vessels that must be
covered and the nature and type of discharges incidental to their normal
operation.  In addition, the EPA will need information on U.S. ports and
waterways, current national and international regulations that apply to
vessel discharges, and the current state of shipboard and land-based
pollution control technologies (PCTs) and best management practices
(BMPs).

Exemptions to the Vessel Vacatur

Under the pending NPDES permitting framework for the vessel vacatur,
some discharges incidental to the normal operation of a vessel will not
be affected due to their coverage or exemption under other federal
regulations.  As stated in the court’s injunction (NEA et al. v. EPA,
2006), NEA et al. sought to only vacate the first sentence of 40 CFR
122.3(a).  The manner in which the following discharge types are
regulated will not be affected by the vessel vacatur.

In CWA §312(a)(12)(B)(i), the discharge of rubbish, trash, and garbage
is specifically excluded as being ‘incidental to the normal operation
of a vessel’.  Rubbish, trash, and garbage discharge is regulated
under APPS, which is the U.S. implementation of the International
Convention for the Prevention of Pollution from Ships, 1973, as modified
by the Protocol of 1978 relating thereto (MARPOL 73/78).

Discharges originating from a vessel when it is operating in a capacity
other than a means of transportation, as specifically exempted in the
second sentence of 40 CFR 122.3(a), which is not being vacated.  

Discharges from a vessel or other floating craft outside the U.S. three
mile territorial sea limit do not constitute “the discharge of a
pollutant” under CWA §502(12)(A) and thus are not subject to NPDES
permitting.

Sewage discharge from a vessel is specifically excluded from CWA’s
definition of pollutant (CWA §502(6)(A)) and thus is not subject to
NPDES permitting.

Discharges incidental to the normal operation of a vessel of the U.S.
Armed Forces are excluded from NPDES permitting requirements under the
CWA’s definition of pollutant (CWA §502(6)(A)) and thus are not
subject to NPDES permitting.

This report summarizes the findings of a search of available literature
and databases and aims to provide EPA with the scope of existing
conditions (as available) in four major categories: vessels, ports,
discharges, and PCTs/BMPs.  Because the field of information is
constantly developing, particularly with regards to treatment
technologies, and data on vessels and ports are updated at least
annually, this report will be a living document to be added to and
amended based on the state of the most current knowledge.

DATA GATHERING AND ANALYSIS

Recreational Vessel Data

National Marine Manufacturers Association (NMMA) 2006 Boating Statistics
Report

Data on recreational vessels operating in U.S. waters were obtained
primarily from the 2006 National Marine Manufacturers Association’s
(NMMA) Recreational Boat Registration Statistics report (NMMA, 2007)
which compiles data from the registration agencies in each state and
territory, among other sources.  At the time of publication of this
document, the 2006 version of the NMMA report was the latest available. 
However, the overall state-by-state vessel registration numbers had not
been re-compiled for the 2006 version of the report; therefore, while
the report contains some data that are updated for 2006, much of the
data with which this report is concerned were from 2005.

Commercial Vessel Data

Merchant Vessels of the United States (VESDOC)

Vessel data were obtained from the United States Coast Guard (USCG) in
the form of the Merchant Vessels of the United States (VESDOC) data
file, which contained updated data through May 5, 2007 (USCG, 2007a). 
These data were sent from the USCG’s National Vessel Documentation
Center (NVDC) on CD-ROM to Battelle on May 14, 2007.  The CD-ROM
contained data in both tab-delimited and fixed-length formats as well as
a metadata document.  There were a total of 328,234 records in the file.
 These data were loaded into a table within the Battelle database on May
23, 2007.

VESDOC contains information on domestic merchant and recreational
vessels with a valid Certificate of Documentation, which is a form of
registration used to track U.S.-owned vessels involved in certain trade
activities.  Any vessel involved in fishing activities,
passenger/merchandise transportation, towing, or dredging within U.S.
navigable waters or the Exclusive Economic Zone (EEZ) and that measures
five net tons or greater must be documented.  A Certificate of
Documentation can allow a vessel to be ‘endorsed’ for a specific
trade, such as fishing or recreation, although a vessel that is only
documented for recreation cannot be used for any other purpose.  Some
states do not require a documented recreational vessel to also register
with the relevant state agency, a fact that has implications for the
statistics gathered from the NMMA report (Section 2.1.1)

VESDOC data presented some difficulties when database queries were
developed.  For example, the VESDOC field ‘hailing port’ provides
the state and/or city displayed on the vessel stern and is a good
indicator of the vessel’s geographic area of operation.  However, the
data entered for this field varied from city only to state only to a
city/state combination and the syntax used was inconsistent (e.g.,
commas were not always used to separate city from state, some state
abbreviations had periods, etc.).  These variations in data entry style
made some of the VESDOC querying difficult because the field could not
efficiently be parsed out. 

Waterborne Transportation Lines of the United States (WTLUS)

The Waterborne Transportation Lines of the United States (WTLUS) is an
annual three-volume product provided by the U.S. Army Corps of
Engineers’ (USACE) Navigation Data Center’s (NDC) Waterborne
Commerce Statistics Center (WCSC) (USACE 2005a, 2005b, 2005c).  At the
time of publication, the 2005 version of WTLUS was the latest available.
 Battelle downloaded 2005 WTLUS data in Microsoft Excel format directly
from the NDC website on April 25, 2007.  These data were loaded into a
table in the Battelle database.  

WTLUS contains summary information on vessel companies and their
U.S.-flagged vessels available for operation as of December 31, 2005
(for vessels capable of carrying passengers or freight, the information
is updated through August 1, 2006).  The three volumes contain summary
statistics, characteristics of the vessels available (e.g., net tonnage,
length, type, year built, etc.), and information on the companies that
own the vessels (e.g., contact information, number of vessels owned by
the company, etc.).  

Foreign Vessel Data

U.S. Customs Entrances/Clearances Records

Data on the comings and goings (entrances and clearances) of vessels at
U.S. ports were collected by U.S. Customs and Border Protection (CBP). 
The CBP gathers these data during the normal processing of imports and
exports.  Available information included the vessel name, the U.S. port
that it was entering/clearing, the type of vessel, the vessel’s flag
of registry, and the last port (domestic or foreign) that the vessel had
visited.  The CBP entrances and clearances data were used as an
indicator of the numbers and types of non-U.S. flag vessels coming to
U.S. ports.  Therefore, only the data on entrances have been described
in this report.  Battelle downloaded the most recently available (2005)
entrances data from USACE’s NDC website on May 10, 2007.  

Port Data

MARAD Vessel Calls

The U.S. Maritime Administration (MARAD) collects annual data on calls
by oceangoing vessels of 10,000 deadweight tons or greater at U.S.
coastal ports.  These data are published in a report entitled Vessel
Calls at U.S. Ports (the most recently available report contained 2005
data [MARAD, 2006a]) as well as in Excel spreadsheets.  Battelle
downloaded the most recently available (2005) data from the MARAD
website as an Excel spreadsheet on April 18, 2007.  The MARAD data
downloaded by Battelle contained information on the number of vessel
calls at U.S. coastal ports, separated by vessel type.  

U.S. Customs Entrances/Clearances Records

See Section 2.3.1.

National Ballast Information Clearinghouse

The Smithsonian Environmental Research Center (SERC) and the USCG
maintain the National Ballast Information Clearinghouse (NBIC), which
maintains a database of the ballast water management practices and
activities of commercial ships operating in U.S. waters and seeks to
keep track of the amount and origins of discharged ballast water.  This
database (NBIC, 2004) stores information from ballast water reports,
which must be submitted to the USCG by all ballast tank-equipped vessels
entering U.S. waters, as required under the National Aquatic Invasive
Species Act (NAISA) (33 CFR 151.2045).  The information provided by the
NBIC database includes state, port, vessel name, arrival date, the last
port/country the vessel called at, vessel type, and data on the ballast
water management (e.g., volume discharged [if any] and treatment
method).  The NBIC currently has data available from 1999 through 2004,
although in this report, only the most recent year of data were
provided.  

Similar to the problems encountered with the VESDOC data, the NBIC
database proved to be difficult to work with.  The NBIC website allows
users to download data by text file, which can then be exported into
Excel.  However, when the data were imported into Excel, the fields were
not consistent and the rows did not necessarily line up with the correct
column headers.  For example, a column that was supposed to contain
locations may have contained some dates because the rows had been
shifted or were misaligned.  These errors were inherent in the text
files and were not caused by incorrect importing.  Additional problems
were encountered when the data were downloaded in XML format: the
arrival dates for the vessels were not included in the output and,
therefore, could not be imported into Excel (despite the fact that the
arrival dates were included in the text file and HTML output types,
which were unusable in their own right).  Some of the states with the
busiest ports (i.e., the most amount of available data) contained
unallowable characters somewhere embedded in their files, preventing the
files from being imported into Excel at all.  After several attempts
were made to correct the data output through NBIC, Battelle determined
that, given these errors in the data and the inability to correct them
in a timely manner, the data available through NBIC were unusable for
the stated purposes.

EPA National Total Maximum Daily Load (TMDL) Database 

To describe the current conditions of the major U.S. ports, information
on pollutants that exceed water quality standards was gathered from
EPA’s collection of water bodies listed under §303(d) of the CWA
(EPA, 2007a).  Based on sampling activities, water bodies that do not
meet state water quality standards for particular pollutants are placed
on a list mandated by CWA §303(d).  The water bodies placed on this
list must have an evaluative report created for them, in which the
pollutant sources are assessed and future loading rates for the listed
pollutant(s) are set.  Current CWA §303(d) lists were available from
the EPA National TMDL database, which contains information on what
pollutants were exceeding state water quality standards in each port, at
the time of the most recent assessment (typically 2002 or 2004).

National Estuary Program 2007 Coastal Condition Report

The National Estuary Program’s (NEP) Coastal Condition report (EPA,
2007b) evaluates the 28 NEPs based on water quality, sediment quality,
benthic condition, and fish tissue contamination.  Five parameters are
measured as indicators of overall water quality of an NEP: dissolved
inorganic nitrogen (DIN), dissolved inorganic phosphorus (DIP),
chlorophyll a, water clarity, and dissolved oxygen (DO).  For each water
quality indicator, EPA has assigned a range of values that, depending on
the sampling data, allows the water quality station in question to be
rated as ‘good’, fair’, or ‘poor’.  For example, if DO
concentrations are measured as >5 mg/L, then the station is rated as
having ‘good’ DO levels.  If the measured concentrations are 2-5
mg/L or <2 mg/L, the station DO level is  rated as ‘fair’ or
‘poor’, respectively.  Once a station’s condition has been
assessed for each of the five indicators, the station’s health as a
whole can be rated as ‘good’, ‘fair’, or ‘poor’, depending
on the combination of indicator ratings.  Finally, once several stations
in an estuary have been evaluated in this manner, the estuary itself can
be rated for overall water quality using the same scale.  Because the
NEP water bodies listed below are described based on their overall
estuarine rating, the following guide can help put the estuarine
conditions in context.   

Good: Less than 10% of the NEP estuarine area is in poor condition, and
more than 50% of the NEP estuarine area is in good condition.

Fair: 10% to 20% of the NEP estuarine area is in poor condition, or more
than 50% of the NEP estuarine area is in combined poor and fair
condition.

Poor: More than 20% of the NEP estuarine area is in poor condition.

The same fundamental rating methodologies apply to the sediment quality,
benthic condition, and fish tissue contamination indices. 

Discharge Data

Uniform National Discharge Standards Reports

The vast majority of information on discharges originating from vessels
came from the UNDS reports.  A few other sources were helpful, but the
UNDS reports are the greatest single source of information on vessel
discharges.  Although these reports focus on Armed Forces vessels, some
of the discharge studies may be instructive for the evaluation of
discharges from civilian vessels.  

The team of federal agencies that is tasked with setting UNDS includes
EPA and the DoD.  Their activities are grouped into phases, with Phase I
consisting of “determining for which Armed Forces vessel discharges it
is reasonable and practicable to require control with a marine pollution
control device (MPCD)” (EPA, 1999a).  Phase II includes setting
performance standards for any MPCD that would be required based on Phase
I determinations.  Finally, Phase III consists of setting requirements
for the designing, constructing, installing, and operating the MPCDs
identified in Phase II.  

One of the results of Phase I was a technical development document
entitled “Phase I Uniform National Discharge Standards for Vessels of
the Armed Forces” (EPA, 1999a) which included as appendices separate
“Nature of Discharge” (NOD) reports for each of the 39 discharges
incidental to the normal operation of an Armed Forces vessel identified
during Phase I.  Each NOD report included a description of the discharge
and discussion on the discharge characteristics (e.g., constituents,
rates, concentrations, etc.), as applicable to vessels of the Armed
Forces.  Some of the information presented in the NOD reports was
gathered from primary research, while some of it was taken from existing
literature, expert opinion, and expert workshop results.  During Phase
I, EPA and DoD determined that 14 of the 39 discharges would not require
a MPCD when discharged from an Armed Forces vessel and, therefore, would
not be examined in more detail beyond the NOD report.  Therefore, only
25 discharges were chosen to undergo more extensive assessment for UNDS
purposes.

For Phase II, EPA and DoD split up the 25 remaining discharges into
batches and developed “Discharge Assessment” (DA) reports for the
first batch of seven.  For four of the seven discharges, EPA and DoD
also developed reports on the environmental effects, feasibility impact
analysis, and a characterization analysis.  Therefore, each of the 39
discharges has a NOD report, seven of them have a DA report, and four of
them currently have more in-depth analytical studies.  Phase II is
currently ongoing and more reports from EPA and DoD are expected in the
future.

Pollution Control Technologies/Best Management Practices Data

Uniform National Discharge Standards Reports  

While the UNDS NOD reports primarily cover the discharge characteristics
and constituents, the DA reports focus partially on some of the PCTs or
BMPs that were investigated by EPA and DoD for their feasibility in
treating discharges from Armed Forces vessels.  Although the DA reports
are slightly dated (which matters more for technological advances than
it does for the discharge characteristics discussed in the NOD reports),
many of the fundamental technologies and management practices are still
applicable today.   The DA reports were primarily used for PCT and BMP
information on chain locker effluent, deck runoff, elevator pit
effluent, firemain systems, and small boat engine wet exhaust.  In
addition, the Phase I  report (EPA, 1999a) included short separate MPCD
reports for four of the discharges: distillation and reverse osmosis
brine, hull coating leachate, small boat engine wet exhaust, and
underwater ship husbandry.  These four MPCD reports contained more
detailed cost-benefit/feasibility analyses than the DA reports and the
results are described in the appropriate sections of this report.

Lloyd’s Register Ballast Water Treatment Technology Report

In June 2007, a report was published by Lloyd’s Register that
summarized the current status of ballast water treatment technology. 
This document was very useful for identifying the technologies that are
currently available or soon to be approved as well as the costs of the
technologies.  

Miscellaneous Literature, Reports, and Phone Conversations

Much of what was learned about current PCTs and BMPs for operational
vessel discharges was gained through contacting equipment manufacturers,
conducting literature searches, and searching the endless available
information found on the internet.  For example, California Sea Grant
and California State Lands Commission had a wealth of information on
vessel hulls as vectors for invasive species introductions that helped
to inform the sections on hull coating leachate and underwater ship
husbandry.  Contacts were made with numerous representatives of various
PCTs, especially bilge water and grey water, which helped to establish
the estimated costs for some technologies.  Finally, state government
websites provided information on BMPs for some of the more common
discharges that may be found in a marina.

VESSEL POPULATION STATISTICS

To help EPA fully comprehend the universe of vessels that may need to be
covered by the NPDES permitting program (Section 1.3), Battelle has
compiled the most recently available data on the vessel population that
operates in U.S. waters.  The following sections present current data on
recreational vessels (Section 3.1) and commercial vessels (Section 3.2),
and includes (to the extent that the information was available) data on
numbers and types of vessels.  Section 2.0 describes the data sources
consulted for this section. 

Recreational Vessels

Battelle assumed that the vast majority of recreational vessels using
U.S. waters are registered in one of the fifty United States or in one
of the U.S. territories.  Some recreational traffic may come to U.S.
waters from Mexico or Canada, but, of the total population, these
numbers are expected to be minimal.  

Each of the states has different registration requirements for
recreational vessels (see Table A-1 in the attachments), so the numbers
provided in the NMMA report may not accurately represent the entire
picture of recreational vessels in any given state.  NMMA’s report
(NMMA, 2007) provides total and state-by-state numbers, in addition to
information on vessel type and size.  However, as indicated in Section
2.2.1, in some states recreational vessels that are documented in VESDOC
are not required to register with the relevant state agency.  The NMMA
report (NMMA, 2007) identifies those states that do not require the
registration of documented vessels and provides the numbers of
documented vessels in those states at the time of publication. Those
states are noted with an asterisk in Tables 3-1 and A-1 and the state
totals in Table 3-1 include both registered and documented recreational
vessels.

Specific ownership information for recreational vessels as well as data
on the port or harbor in which a recreational vessel is primarily used
are not available through NMMA.  However, Table A-1 includes the most
current contact information for the registration agency in each state. 
These states can be contacted individually for answers to specific
questions.

Recreational Vessel Numbers

According to NMMA’s 2006 data (NMMA, 2007), the U.S. population of
registered recreational vessels numbers 12,942,414.  Figure 3-1
illustrates the NMMA’s 2006 data on recreational vessel registration
separated by U.S. region.  Although it only encompasses five states, the
Great Lakes region boasts the greatest number of registered recreational
vessels, almost 44% more vessels than the next highest region, Inland.  

Figure   STYLEREF 1 \s  3 -  SEQ Figure \* ARABIC \s 1  1 . 2006 U.S.
Regional Recreational Vessel Registration.

Source: NMMA, 2007.

	

On a state-by-state basis, California had the greatest number of
registered recreational vessels in 2005, with Florida and Michigan
rounding out the top three.  Table 3-1 lists the top twenty states for
numbers of registered recreational vessels and also indicates that the
vast majority of registered vessels in the top twenty states were
mechanically-propelled.  However, as shown in Table A-1, not all states
require non-mechanically propelled vessels to be registered, and in
those states that do require such registration, some vessel owners
either may not be aware of the requirement or may ignore it.  Because
the registration of mechanically-propelled vessels is likely

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  1 .  Top 20 U.S.
States for Total Registered Recreational Vessels, with General Type of
Vessel Indicated.

State	Total Registered Recreational Vessels	Mechanically-Propelleda
Non-Mechanically- Propelledb

California*	989,021	892,722	71,036

Florida	973,859	932,673	41,186

Michigan	944,138	891,937	52,201

Minnesota*	856,411	640,862	212,627

Wisconsin	639,198	635,862	3,336

Texas*	623,868	604,929	9,687

New York	508,536	499,136	9,400

South Carolina*	419,841	393,341	23,422

Ohio	412,375	325,632	86,743

Illinois	380,865	308,875	71,990

North Carolina	362,784	357,253	5,531

Pennsylvania*	355,300	308,851	40,308

Missouri	326,749	277,433	49,316

Georgia	318,212	317,315	897

Louisiana*	310,772	308,104	0

Washington	267,793	267,793	0

Tennessee	267,567	265,966	1,601

Alabama	265,172	262,295	2,877

Virginia*	255,948	240,097	4,976

Iowa	243,924	115,044	128,880

Total	9,722,333	8,846,120	816,014

           Source: NMMA, 2007.

         * Indicates those states that do not require a documented
recreational vessel to be registered with the state.  Totals 

            for these states include both registered and documented
recreational vessel numbers. Information on propulsion 

            type is for registered vessels only; no data on propulsion
type for recreational documented vessels were 

            available.

             a  Mechanically-propelled includes power inboard, power
outboard, power sterndrive (or inboard/ 

           outboard), personal watercraft (PWC), auxiliary sail inboard,
and auxiliary sail outboard.

         b Non-mechanically propelled includes rowboats, sailboats,
kayaks/canoes, and other.

to be more strictly enforced and monitored (by the state agencies and
entities charged with enforcing vessel registration) than the
registration of non-mechanically-propelled vessels, it is assumed that
the NMMA numbers fully or nearly fully capture the national population
of recreational mechanically-propelled vessels.

Recreational Vessel Propulsion and Size Data

The particular type of engine used on a mechanically-propelled vessel
may have implications for the types of discharges it emits (Section
5.0).  For example, some engine types take up ambient water to act as a
cooling mechanism before discharging it back into receiving waters.  As
shown in Table 3-2, NMMA’s data indicates that almost 66% of all
registered mechanically-propelled recreational vessels are powered by
outboard engines.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  2 . Type of
Propulsion for All Registered Mechanically-Propelled Recreational
Vessels.

Propulsion Type	Number of Boats

Outboard	7,911,509

Inboard/PWC	2,269,542

Sterndrive	1,680,045

Auxiliary Sail Inboard	67,742

Auxiliary Sail Outboard	69,890

TOTAL	11,998,728

		                 Source: NMMA, 2007.

Along with the propulsion type of a recreational vessel, the size is
also important when considering potential discharges.  Smaller vessels
are more likely than larger vessels to be removed from the water for
repairs and maintenance.  Larger vessels are more likely to have greater
deck surface area, may generate grey water from an onboard galley or
bathroom, and have bilge water tanks with greater capacities.  

The NMMA data indicate that over 95% of all registered
mechanically-propelled recreational vessels in the U.S. are less than 26
feet in length (NMMA, 2007).  No data are available for sizes of
non-mechanically-propelled vessels.  Table 3-3 presents the number of
vessels less than 26 feet in length and the number of vessels 26 feet
and over in length for each state, organized by the percent of the total
registered mechanically-propelled recreational vessels that are less
than 26 feet in length.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  3 .  Lengths of
All Registered Mechanically-Propelled Recreational Vessels.

State	Number of Recreational Mechanically-Propelled Vessels	Percent of
total less than 26 feet 

	Less than 26 feet in length	26 feet and over in length

	Nebraska*	78,499	483	99.39%

North Dakota*	43,431	297	99.32%

South Dakota*	48,013	514	98.94%

Kansas*	92,385	1019	98.91%

Arkansas*	185,139	2,162	98.85%

Montana*	69,020	911	98.70%

Minnesota*	631,838	9,024	98.59%

West Virginia*	43,674	630	98.58%

Wyoming*	25,110	400	98.43%

Georgia	312,222	5,093	98.39%

Louisiana*	302,857	5,247	98.30%

Wisconsin	623,542	12,320	98.06%

New Mexico	36,430	766	97.94%

Pennsylvania*	302,432	6,419	97.92%

Colorado*	92,248	1,958	97.92%

Iowa	112,651	2,393	97.92%

Mississippi*	198,807	4,413	97.83%

South Carolina*	383,366	9,975	97.46%

Maine*	108,402	2,911	97.38%

Oklahoma	211,034	5,879	97.29%

Idaho*	79,756	2,279	97.22%

Alabama	254,566	7,729	97.05%

Table 3–3.  Lengths of All Registered Mechanically-Propelled
Recreational Vessels, continued.

State	Number of Recreational Mechanically-Propelled Vessels	Percent of
total less than 26 feet 

	Less than 26 feet in length	26 feet and over in length

	Missouri	268,975	8,458	96.95%

North Carolina	345,986	11,267	96.85%

Texas*	585,715	19,214	96.82%

Indiana	197,760	6,765	96.69%

Kentucky*	157,855	5,579	96.59%

Oregon	178,295	6,348	96.56%

Virginia*	231,629	8,468	96.47%

Vermont	31,120	1,266	96.09%

Utah	71,423	3,001	95.97%

Tennessee	254,708	11,258	95.77%

Michigan	850,848	41,089	95.39%

Illinois	294,328	14,547	95.29%

New Hampshire	93,501	4,669	95.24%

Massachusetts*	134,498	6,892	95.13%

California*	848,098	44,624	95.00%

Nevada*	53,436	3,150	94.43%

Arizona*	133,708	8,019	94.34%

Ohio	305,363	20,269	93.78%

Alaska*	40,379	3,027	93.03%

Connecticut	98,378	9,625	91.09%

Florida	847,626	85,047	90.88%

Washington	242,777	25,016	90.66%

New York	451,654	47,482	90.49%

New Jersey	171,450	20,463	89.34%

Hawaii*	12,461	1,851	87.07%

Delaware*	44,218	7,111	86.15%

Maryland	165,018	31,677	83.90%

Rhode Island	35,930	7,726	82.30%

District of Columbia	1228	784	61.03%

TOTAL	11,383,787	547,514	95.41%

                    Source: NMMA, 2007.

	        * Documented recreational vessel numbers are not included in
this table for those states that do not require a 

	         documented vessel to also be registered with the state.

Commercial Vessels

As described in Section 2.0, data on commercial vessels operating in
U.S. waters were obtained primarily from the USCG (VESDOC) and USACE
(WTLUS).  

Domestic Commercial Vessel Numbers and Types

USACE’s most recent WTLUS volumes (USACE, 2005a, 2005b, 2005c) contain
substantial and well-organized data on U.S.-flagged passenger and cargo
vessels operating in U.S. waters.  Table 3-4 presents the summary
findings by propulsion type (self-propelled or non-self-propelled); the
subtypes contained within these general categories are provided in the
table footnote.  Figure 3-2 illustrates that the vast majority (78%) of
cargo and passenger vessels operating in U.S. waters can be found in the
Mississippi River System or the Gulf Intracoastal Waterway.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  4 .  Summary of
the U.S.-Flag Cargo or Passenger Vessels Operating in U.S. Waters by
Region.

Type of Vessel	Total Number of Vessels	Atlantic, Gulf, and Pacific
Coasts	Mississippi River System and the Gulf Intracoastal Waterway	Great
Lakes System

SELF-PROPELLED

Dry Cargo and/or Passenger, Offshore Support	2,967	1,638	1,162	167

Vehicular Ferries and Railroad Cars	619	472	82	65

Tankers	100	90	6	4

Towboats	5,290	1,864	3,303	123

TOTAL SELF-PROPELLED	8,976	4,064	4,553	359

TOTAL CARGO CAPACITYa (short tons)	12,342,485	9,175,249	894,749
2,272,487

TOTAL PASSENGER CAPACITYb (persons)	451,723	330,271	85,072	36,380

NON-SELF-PROPELLED

Barges, Dry Cargo	27,876	3,961	23,739	176

Barges, Tanker	4,151	618	3,525	8

Railroad Car Barge	25	24	1	0

TOTAL NON-SELF-PROPELLED	32,052	4,603	27,265	184

TOTAL CARGO CAPACITYc (short tons)	57,035,748	11,398,711	45,259,164
377,873

TOTAL PASSENGER CAPACITYd (persons)	553	167	386	0

GRAND TOTAL SELF- AND NON-SELF-PROPELLED	41,028	8,667	31,818	543

Source: USACE, 2005a.

a Includes cargo capacity of dry cargo vessels and tankers.

b Includes passenger capacity of passenger vessels and vehicular ferries

c Includes cargo capacity of dry cargo barges, tanker barges, and
railroad car floats

d Includes passenger capacity of dry cargo barges

Self-Propelled, Dry Cargo: Crewboat / Supply / Utility Vessel; Vehicle
Carrier; General Cargo Freighter; Passenger Carrier; Break Bulk / RO-RO
Carrier; Combination Passenger and Cargo; RO-RO Vessel; Ferry; Bulk
Carrier; Railroad Car Ferry; Containership; Lash Vessel; Partial
Containership; Excursion / Sightseeing Vessel; Container / Vehicle /
Trailer (RO-RO) Carrier

Self-Propelled, Tanker: Petroleum / Chemical Carrier; Liquid Gas
Carrier; Chemical Carrier; Other Tanker; Liquid Bulk Tanker

Towboat: Pushboat; Tugboat 

Non-Self-Propelled, Tanker: Liquid Cargo Barge (Single Hull); Liquid
Cargo Barge (Double Bottom Only); Liquid Cargo Barge (Double Hull);
Other Liquid Cargo Barge, Not; Liquid Cargo Barge (Double Sided Only)
Elsewhere Included

Non-Self-Propelled, Dry Cargo: Open Hopper Barge; Covered Dry Cargo
Barge; Covered Hopper Barge; RO-RO Barge; Carfloat (Railroad Car Barge);
Container Barge; Flat / Deck Barge; Lash / Seabee Barge; Pontoon Barge;
Convertible Barge; Open Dry Cargo Barge; Other

Figure   STYLEREF 1 \s  3 -  SEQ Figure \* ARABIC \s 1  2 . Summary of
U.S. Flag Cargo and Passenger Vessels Operating in U.S. Waters by
Region.

Source: USACE, 2005a

As described in Section 2.2.3, WTLUS also provides information on the
Transportation Series Operator (TSO) company that operates these 41,028
passenger or cargo vessels (Volume 2) as well as the relevant
characteristics of the vessels themselves (Volume 3).  There are 2,732
TSO companies that own the 41,028 vessels (USACE, 2005b).  Table 3-5
lists the top twenty U.S. TSO companies according to the number of
vessels operated and includes the principal types of vessels operated as
well as a list of the major commodities carried.  More detailed
information on all 2,732 TSO companies with specific contact information
can be found in USACE (2005b).  USACE (2005c) also provides more detail
on each vessel, including in which specific subtype (in list above) the
vessel is categorized, the vessel’s registered length/depth/breadth,
and horsepower.

As described in Section 2.2.1, VESDOC is another source for data on
commercial vessels operating in U.S. waters.  All U.S.-owned commercial
vessels involved in passenger or merchandise transportation as well as
towing or dredging must be documented with the USCG.  One of the ways
VESDOC data are organized is by “Vessel Service Type”, which
indicates the primary service for which the vessel was documented.  The
VESDOC metadata (USCG, 2007b), however, caution that the vessel service
type may not be the most reliable indicator of the specific use of a
vessel.  Rather, USCG (2007b) recommends using the vessel numbers
provided in the ‘trade indicator’ fields, as described in Section
2.2.1, for a more complete picture.  However, the vessel service type
field is broken into more categories than the trade indicator field; in
addition, the trade indicator field appeared to be focused more on where
the vessel could be operated and less on the general use of the vessel. 
Table 3-6 provides the VESDOC statistics for the various vessel service
types.  

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  5 . Top Twenty
U.S. TSO Companies Operating Cargo or Passenger Vessels in U.S. Waters
by Number of Vessels Operated.

TSO Name	City/State Location of the TSO	Total Number of Vessels Operated
by TSO	Principal Types of Vessels Operated by TSOa	List of Principal
Commodities Carried by TSO’s Vessels

Ingram Barge Co.	Nashville, TN	4,256	DCB, DOB, DHTB	Towing, petroleum
products, bulk freight, coal, coke, grain and aggregates

American Commercial Lines, LLC	Jeffersonville, IN	3,249	DCB, DOB, DHTB
Towing, steel, petroleum products, coal, coke, sulphur, sugar, creosote,
grain, scrap iron, chemicals, salt and general commodities

American River Transportation Co.	Ama, LA	2,221	DCB, DHTB, DB	Grain and
grain products, coal, fertilizer, salt and scrap

AEP Memco, LLC	Chesterfield, MO	1,620	DOB, DCB, PUSH	Towing, coal,
grain, grain products, cement, chemicals, salt, steel, lime, coke, slag,
and aggregates

Kirby Inland Marine, LP	Houston, TX	1,013	DHTB, PUSH, OTB	Chemical and
petroleum products

Crounse Corporation	Paducah, KY	939	DOB, PUSH	Towing, bulk freight and
coal

Cargill Marine and Terminal, Inc.	Minneapolis, MN	673	DCB	Coal, grain,
vegetable oil, salt and miscellaneous commodities

McDonough Marine Service (Div. of Marmac Corporation)	Metarie, LA	672
DB, DOB, DHTB	Miscellaneous freight

Teco Barge Line	Metropolis, IL	612	DOB, DCB	Coal, phosphate sulphur and
bulk commodities

Canal Barge Company, Inc.	New Orleans, LA	608	DOB, DHTB, DB	Towing, bulk
petroleum, molten sulphur, chemicals, coal, grain, fertilizer and
general cargo

SCF Marine, Inc.	St. Louis, MO	581	DCB, DOB, DB	Grain, industrial
commodities, rice, meals, salt, coal and dry bulk commodities

Campbell Transportation Co.	Charleroi, PA	404	DOB	Coal, sand & gravel

American Commercial Barge Line, LLC	Jeffersonville, IN	383	DCB	Towing,
liquid chemicals, petroleum, crude oil and refined oil products

Central Gulf Lines, Inc.	New Orleans, LA	378	LSB	Steel, paper products
and miscellaneous cargo - rubber, timber, flour and rice

Forest Lines, LLC	New Orleans, LA	332	LSB	Paper products

Table 3–5. Top Twenty U.S. TSO Companies Operating Cargo or Passenger
Vessels in U.S. Waters by Number of Vessels Operated, continued.

TSO Name	City/State Location of the TSO	Total Number of Vessels Operated
by TSO	Principal Types of Vessels Operated by TSOa	List of Principal
Commodities Carried by TSO’s Vessels

Alter Barge Line, Inc.	Bettendorf, IA	327	DCB, DB	Coal, steel, scrap,
grain, containers and general commodities; bulk products - regulated and
exempt

Consolidation Coal Company (River Division)	Elizabeth, PA	297	DOB	Coal

Marquette Transportation Company	Paducah, KY	285	DCB, DB, PUSH	Grain,
coal, salt, fertilizer and rock

Pine Bluff Sand and Gravel Company	Pine Bluff, AR	253	DB, DOB, PUSH
Construction equipment and materials, sand and gravel

Luhr Bros., Inc.	Columbia, IL	245	DB, DOB, PUSH	Crushed limestone
products, rip-rap and heavy construction equipment

Source: USACE, 2005b.

a Vessel type abbreviations: DCB = dry covered barge; DOB = dry open
barge; DB = deck barge; DHTB = double hull tank barge; PUSH = pushboat;
LSB = lash/seabee barge; OTB = other tank barge

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  6 . Total Number
of U.S. Documented Vessels by Service Type.

VESDOC Vessel Service Type	Total Number of Vessels Documented

Commercial Fishing Vessel	28,972

Fish Processing Vessel	35

Freight Barge	23,153

Freight Ship	651

Industrial Vessel (e.g., cable layer, dredge, crane barge)	823

Mobile Offshore Drilling Unit	118

Offshore Supply Vessel	1,114

Oil Recovery	372

Passenger (Inspected)	9,539

Passenger (Uninspected)	2,311

Passenger Barge  (Inspected)	109

Passenger Barge  (Uninspected)	127

Public Freight	6

Public Tankship/Barge	2

Public Vessel, Unclassified	24

Research Vessel	234

School Ship	38

Tank Barge	4,134

Tank Ship	129

Towing Vessel	6,898

Unclassified/Unknown/Unspecified	5,357

Source: VESDOC, 2007

Domestic Commercial Fishing Vessel Numbers

Because the USCG differentiates between commercial vessels and
commercial fishing vessels (see Section 3.2), these two categories of
vessels are dealt with separately in this report.  As described in
Section 2.2.1, VESDOC categorizes documented vessels based on the trade
for which the vessel is licensed.  One of the trade categories is
‘fishery’, which applies to vessels “licensed to engage in the
fisheries trade in the navigable waters of the U.S. and on the Exclusive
Economic Zone” (USCG, 2007b).  Another trade category is ‘limited
fishery only’, but the VESDOC metadata (USCG, 2007b) does not define
this category further.  Battelle has included this latter category in
the commercial fishing vessel totals in the next paragraph.  Any vessel
owned by a U.S. citizen that commercially fishes in U.S. waters must be
documented and, therefore, is included in the most recent VESDOC data.  

The May 2007 VESDOC data indicate that there are 33,550 commercial
fishing vessels licensed to fish in U.S. navigable waters and the EEZ. 
Due to the data problems associated with VESDOC (as described in Section
2.2.1), Battelle was unable to query the database by ‘hailing port’
which would have been a good indicator of the vessel’s geographic area
of operation (USCG, 2007b).  The contact state and/or city of a given
vessel’s managing owner was available and, although the owner’s
state may not in all cases be equivalent to the ‘hailing port’
state, it may also be a reasonable indicator of where the fishing vessel
typically operates.  Figure 3-3 illustrates the number of documented
commercial fishing vessels by owner’s contact state.

Figure   STYLEREF 1 \s  3 -  SEQ Figure \* ARABIC \s 1  3 .  Documented
Commercial Fishing Vessels by Owner’s Contact State.

Source: USCG, 2007a

Foreign Commercial Vessel Numbers

Information on foreign commercial vessels operating in U.S. waters was
more difficult to obtain.  MARAD provides general world fleet
statistics, but does not have data on which waterways world fleet
vessels typically operate.  

One source for the number of foreign commercial vessels visiting U.S.
waters is the U.S. Customs Entrances/Clearances records (U.S. CBP,
2007).  These data are also discussed in Section 4.0, although in terms
of what type of port (domestic or foreign) a vessel had visited
immediately prior to entering the U.S. port at which it was recorded. 
As described in Section 2.3, the 2005 Entrances/Clearances records were
the most recent available from the NDC.  According to these data, there
were a total of 90,328 vessel entrances to a major U.S. port or waterway
in 2005 and 7,726 different vessels made these entrances (U.S. CBP,
2007).  Of the 7,726 unique vessels making entrance, 6,982 flew one of
83 different foreign flags (the remaining 744 flew U.S. flags).  In the
CBP (2007) data, a foreign vessel may have been recorded under more than
one flag; this was due to some vessels changing their flag of registry
during the year and, therefore, being recorded under more than one flag.
Table 3-7 presents the top twenty most frequently recorded flags of
vessels entering a major U.S. port or waterway in 2005.  

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  7 . Top 20 Most
Frequently Recorded Flags Entering U.S. Ports or Waterways in 2005

COUNTRY	TOTAL ENTRANCES

Panama	13,670

United States and territories	11,216

Bahamas	9,682

Liberia	8,569

Canada	4,662

Antigua and Barbuda	4,578

Marshall Islands	3,227

Singapore	3,169

Cyprus	2,745

Norway	2,600

Greece	2,216

Netherlands	2,123

St. Vincent and the Grenadines	1,963

Hong Kong	1,946

Malta	1,839

Bermuda	1,743

Germany	1,641

United Kingdom	1,525

Danish International Register	868

Italy	692

		           Source: U.S. CBP, 2007.

PORT FINDINGS

Information on the busiest ports in the U.S. is useful for understanding
the characteristics of national waterway traffic, of both domestic and
foreign arrivals.  The following sections describe the various available
information on U.S. port traffic, including number of vessel calls, flag
registration of arriving vessels, and the last port of call of arriving
vessels.

Calls to U.S. Ports

Figure 4-1 illustrates the number of vessel calls to U.S. coastal ports
in 2005 by geographic region as provided by MARAD (2006).  MARAD only
recorded self-propelled vessels of greater than 10,000 tons deadweight.

The U.S. Gulf region received nearly 31% of all coastal vessel calls in
2005, followed by the South Atlantic region with approximately 19%. 
Table 4-1 lists the total number of calls made by vessels to all coastal
U.S. ports in 2005 (MARAD, 2006) along with the most frequent type of
vessel calling there.  Table 4-2 shows the top 20 coastal U.S. ports for
2005 vessel calls; these 20 ports will hereafter be referred to as the
‘major ports’.  

Figure   STYLEREF 1 \s  4 -  SEQ Figure \* ARABIC \s 1  1 . 2005 Vessel
Calls to U.S. Coastal Ports by Geographic Region.

Source: MARAD, 2006

North Atlantic: Ports from Eastport, ME to Baltimore, MD

South Atlantic: Ports from Alexandria, VA to Miami, FL

U.S. Gulf: Ports from Key West, FL to Brownsville, TX

Pacific Southwest: Ports from Crockett, CA to San Diego, CA and all
Hawaiian ports

Pacific Northwest: Ports from Barrow, AK to Coos Bay, OR

Puerto Rico: Ports in Puerto RicoTable   STYLEREF 1 \s  4 -  SEQ Table
\* ARABIC \s 1  1 .  2005 Vessel Calls at All U.S. Coastal Ports
Organized by Geographic Region

State	Porta	Number of Calls	Most Frequently Calling Vessels

NORTH ATLANTIC

CT	Bridgeport	87	General cargo vessels

CT	Groton	4	Tanker

CT	New Haven	185	Tanker, General cargo vessels

CT	New London	32	General cargo vessels

MA	Boston	332	General cargo vessels, Tanker

MA	Fall River	1	General cargo vessels

MA	Salem	2	General cargo vessels

MA	Sandwich	2	Tanker

MD	Annapolis	134	General cargo vessels

MD	Baltimore	1,825	General cargo vessels, Roll on-Roll Off cargo vessels

MD	Cove Point	74	Tanker

MD	Piney Point	50	Tanker

ME	Bucksport	2	Tanker

ME	Camden	1	General cargo vessels

ME	Eastport	13	General cargo vessels

ME	Portland	364	Tanker

ME	Sandy Point	1	Tanker

ME	Searsport	19	Tanker

NH	Portsmouth	129	General cargo vessels, Tanker

NY	Albany	1	General cargo vessels

NY	Kingston	2	General cargo vessels

NY	New York	4,902	General cargo vessels, Tanker

NY	Northport	9	Tanker

NY	Northville	47	Tanker

NY	Riverhead	2	Tanker

NY	Stony Point	2	General cargo vessels

PA	Philadelphia	2,998	Tanker, General cargo vessels

RI	Brayton Point	5	General cargo vessels

RI	Davisville	78	Roll on-Roll Off Cargo Vessels

RI	Jamestown	1	General cargo vessels

RI	Newport	1	General cargo vessels

RI	Providence	193	Tanker, General cargo vessels

PACIFIC NORTHWEST

AK	Afognak	95	Roll on-Roll Off Cargo Vessels

AK	Anchorage	150	General cargo vessels

AK	Drift River Term.	1	Tanker

AK	Dutch Hbr.	157	General cargo vessels

AK	Hawk Inlet	2	General cargo vessels

AK	Homer	79	Tanker

AK	Hoonah	5	General cargo vessels

AK	Hydaburg	15	General cargo vessels

AK	Juneau	1	Tanker

AK	Kake	5	General cargo vessels

Table 4–1.  2005 Vessel Calls at All U.S. Coastal Ports Organized by
Geographic Region, continued

State	Porta	Number of Calls	Most Frequently Calling Vessels

AK	Kenai	11	General cargo vessels

AK	Ketchikan	4	General cargo vessels

AK	Klawock	12	General cargo vessels

AK	Kodiak	97	General cargo vessels

AK	Nikiski	143	Tanker

AK	Red Dog	9	General cargo vessels

AK	Seward	7	General cargo vessels

AK	Tolstoi Bay	5	General cargo vessels

AK	Valdez	399	Tanker

OR	Columbia River	2,189	General cargo vessels

OR	Coos Bay	43	General cargo vessels

WA	Anacortes	8	General cargo vessels

WA	Bellingham	2	General cargo vessels

WA	Bremerton	2	General cargo vessels

WA	Cherry Point	209	Tanker

WA	Everett	33	General cargo vessels, Roll on-Roll Off cargo vessels

WA	Ferndale	123	Tanker

WA	Manchester	11	Tanker

WA	March Point	342	Tanker

WA	Olympia	20	General cargo vessels, Roll on-Roll Off cargo vessels

WA	Point Wells	19	Tanker

WA	Port Angeles	277	Tanker

WA	Port Townsend	3	General cargo vessels

WA	Seattle	1,186	General cargo vessels

WA	Tacoma	1,270	General cargo vessels

WA	Westport	7	General cargo vessels

PUERTO RICO

PR	Guanica	1	General cargo vessels

PR	Guayanilla	125	Tanker

PR	Las Mareas	7	General cargo vessels

PR	Mayaguez	1	General cargo vessels

PR	Ponce	19	General cargo vessels

PR	Puerto Rico	9	Tanker

PR	San Juan	1,086	General cargo vessels

PR	Yabucoa	42	Tanker

PACIFIC SOUTHWEST

CA	El Segundo	245	Tanker

CA	LA/Long Beach	5,178	General cargo vessels

CA	Port Hueneme	397	Roll on-Roll Off cargo vessels

CA	S. California light. area	24	Tanker

CA	San Diego	319	Roll on-Roll Off cargo vessels, General cargo vessels

CA	San Francisco	3,871	General cargo vessels

HI	Barbers Point	162	Tanker

HI	Hilo	54	Roll on-Roll Off cargo vessels

HI	Honolulu	586	General cargo vessels

Table 4–1.  2005 Vessel Calls at All U.S. Coastal Ports Organized by
Geographic Region, continued

State	Porta	Number of Calls	Most Frequently Calling Vessels

HI	Kahului	77	Roll on-Roll Off cargo vessels

HI	Kawaihae	1	General cargo vessels

HI	Nawiliwili	11	Roll on-Roll Off cargo vessels

HI	Port Allen	1	Roll on-Roll Off cargo vessels

SOUTH ATLANTIC

FL	Cape Canaveral	2	General cargo vessels, Roll on-Roll Off cargo
vessels

FL	Fernandina	6	General cargo vessels

FL	Jacksonville	1,237	General cargo vessels, Roll on-Roll Off cargo
vessels

FL	Miami	1,299	General cargo vessels

FL	Palm Beach	116	General cargo vessels

FL	Port Canaveral	55	General cargo vessels, Roll on-Roll Off cargo
vessels

FL	Port Everglades	1,182	General cargo vessels, Tanker

GA	Brunswick	243	Roll on-Roll Off cargo vessels

GA	Savannah	2,333	General cargo vessels

NC	Morehead City	36	General cargo vessels

NC	Southport	1	Tanker

NC	Wilmington	600	General cargo vessels, Tanker

SC	Charleston	2,046	General cargo vessels

SC	Georgetown	6	General cargo vessels

VA	Virginia Ports	2,547	General cargo vessels

U.S. GULF

AL	Mobile	811	General cargo vessels

FL	Key West	2	Tanker

FL	Panama City	6	General cargo vessels

FL	Pensacola	19	General cargo vessels

FL	Port Manatee	159	General cargo vessels

FL	Tampa	1,003	Tanker, General cargo vessels

LA	Gulf Gateway Term.	2	Tanker

LA	Lake Charles	701	Tanker

LA	LOOP Term.	401	Tanker

LA	New Orleans	3,749	General cargo vessels, Tanker

LA	Port Fourchon	1	Tanker

LA	Southwest Pass light. area	3	Tanker

MS	Gulfport	39	General cargo vessels

MS	Pascagoula	233	Tanker

MS	Pascagoula light. area	5	Tanker

TX	Beaumont	72	General cargo vessels

TX	Brownsville	158	General cargo vessels

TX	Corpus Christi	989	Tanker

TX	Freeport	759	Tanker

TX	Freeport light. area	2	Tanker, Roll on-Roll Off cargo vessels

TX	Galveston	429	General cargo vessels, Tanker

TX	Galveston light. area	98	Tanker

Table 4–1.  2005 Vessel Calls at All U.S. Coastal Ports Organized by
Geographic Region, continued

State	Porta	Number of Calls	Most Frequently Calling Vessels

TX	Houston	5,891	Tanker, General cargo vessels

TX	Ingleside	107	General cargo vessels, Tanker

TX	Point Comfort	321	Tanker

TX	Port Arthur	1,563	Tanker

TX	S. Sabine Point light. Area	17	Tanker

TX	Smith’s Bluff	1	Tanker

TX	Texas City	1,142	Tanker

 Source: MARAD, 2006.

a Some of the port names in this table refer to groupings of
geographically-similar ports.  This was done to decrease the
unwieldiness of the table and had been done by MARAD in previous years
(MARAD, 2006).  The groupings are described below.

Columbia River

Includes the ports of Astoria, Kalama, Longview, Portland, Rainier,
Vancouver, and Willbridge.  

L.A/Long Beach

Includes the ports of Los Angles and Long Beach.  

New Orleans 

Includes the ports of Ama, Arabi, Avondale, Baton Rouge, Belle Chasse,
Boothville, Braithwaite, Burnside, Chalmette, Convent, Darrow, Davant,
Destrechan, Donaldsonville, Empire, Garyville, Geismar, Good Hope,
Gramercy, Gretna, Harvey, La Place, Magnolia, Marrero, Meraux, Michound,
Myrtle Grove, New Orleans, Norco, Ostrica, Paulina, Pilottown,
Plaquemine, Port Allen, Port Sulfur, Reserve, St. Bernard, St. James,
St. Rose, Taft, Violet, Waggaman, and Westwago.  

Philadelphia 

Includes the ports of Burlington, NJ, Camden NJ, Claymont, DE, Chester,
PA, Delair, NJ, Delaware City, DE, Eddystone, PA, Fairless Hills,
Gloucester, NJ,  Marcus Hook, PA, Paulsboro, NJ, Philadelphia, PA, Reedy
Point, DE, Salem, NJ, Tullytown, PA, Westville, NJ, and Wilmington, DE. 


San Francisco Bay

Includes the ports of Alameda, Antioch, Bencia, Concord, Crockett,
Martinez, Oakland, Pittsburg, Redwood City, Richmond, Rodeo, Sacramento,
San Francisco, Selby, and Stockton. 

Virginia 

Includes the ports of Chesapeake, Hampton Roads, Hopewell, Lynnhaven
Roads, Newport News, Norfolk, Portsmouth, Richmond, and Yorktown

Table   STYLEREF 1 \s  4 -  SEQ Table \* ARABIC \s 1  2 . Top 20 U.S.
Ports by Number of Vessel Calls in 2005.

Coastal Region	Port	State	Number of Calls

U.S. Gulf	Houston	TX	5,891

Pacific Southwest	LA/Long Beach	CA	5,178

North Atlantic	New York	NY	4,902

Pacific Southwest	San Francisco	CA	3,871

U.S. Gulf	New Orleans	LA	3,749

North Atlantic	Philadelphia	PA	2,998

South Atlantic	Virginia Ports	VA	2,547

South Atlantic	Savannah	GA	2,333

Pacific Northwest	Columbia River	OR	2,189

South Atlantic	Charleston	SC	2,046

North Atlantic	Baltimore	MD	1,825

U.S. Gulf	Port Arthur	TX	1,563

South Atlantic	Miami	FL	1,299

Pacific Northwest	Tacoma	WA	1,270

Table 4–2. Top 20 U.S. Ports by Number of Vessel Calls in 2005,
continued.

Coastal Region	Port	State	Number of Calls

South Atlantic	Jacksonville	FL	1,237

Pacific Northwest	Seattle	WA	1,186

South Atlantic	Port Everglades	FL	1,182

U.S. Gulf	Texas City	TX	1,142

Puerto Rico	San Juan	PR	1,086

U.S. Gulf	Tampa	FL	1,003

        Source: MARAD, 2006.

Table 4-2 shows that Houston, TX had more vessel calls than any other
coastal U.S. port in 2005.  

The U.S. CBP data on vessel entrances and clearances (CBP, 2007) provide
information on all U.S. ports (coastal and inland), including the date a
vessel entered a given port (i.e., filed an entrance record), the
vessel’s flag, and the previous port the vessel had called at.  Having
information on the previous port visited by a vessel can help evaluate
the threat of invasive species introductions.  Table 4-3 presents the
number of calls that the previous port was foreign (‘foreign calls’)
and the number of calls that the previous port was domestic (‘domestic
calls’) for the 20 U.S ports with the most total calls in 2005,
according to the CBP data.  The top 20 ports with the most calls in 2005
according to CBP may differ slightly from the MARAD data; MARAD recorded
data only at coastal ports, while CBP recorded data at all U.S. ports. 
In addition, MARAD grouped some of the geographically similar coastal
ports (see Table 4-1) and CBP did not.

Table 4-3 shows that a number of the top 20 U.S. ports primarily receive
foreign calls: Port Everglades, FL; Long Beach, CA; San Juan, PR; and
Seattle, WA.  Elizabeth River, VA was the U.S. port with the highest
percentage of domestic calls, followed by Oakland, CA.  One caveat
presents itself with these data: a domestic call does not necessarily
mean that there is less of an invasive species introduction threat than
a foreign call.  

Table   STYLEREF 1 \s  4 -  SEQ Table \* ARABIC \s 1  3 . 2005 Domestic
and Foreign Vessel Calls at Top 20 U.S. Ports.

U.S Port	Number of Domestic Calls	Number of Foreign Calls	Percent
Domestic Calls	Most Frequently Cited Last Port*

Houston, TX	2,032	3,585	36.2%	Mexico

New York, NY	1,565	3,218	32.7%	Canada

Port Everglades, FL	642	3,665	14.9%	Bahamas

Miami, FL	788	2,937	21.2%	Bahamas

Long Beach, CA	469	2,159	17.8%	Mexico

San Juan, PR	333	2,186	13.2%	U.S. Virgin Islands

Savannah, GA	1,671	725	69.7%	Elizabeth River, VA

St. Thomas, VI	1,235	1,128	52.3%	San Juan, PR

Seattle, WA	142	2,197	6.1%	Canada

New Orleans, LA	1,067	1,222	46.6%	Houston, TX (D); Mexico (F)

Charleston, SC	1,565	709	68.8%	Elizabeth River, VA

Los Angeles, CA	368	1,856	16.5%	Mexico

Baltimore, MD	1,175	812	59.1%	New York, NY

Elizabeth River, VA	1,689	134	92.6%	New York, NY

Table 4–3. 2005 Domestic and Foreign Vessel Calls at Top 20 U.S.
Ports, continued.

U.S Port	Number of Domestic Calls	Number of Foreign Calls	Percent
Domestic Calls	Most Frequently Cited Last Port*

Oakland, CA	1,248	471	72.6%	Los Angeles, CA

Bayou Lafourche, LA	14	1,679	0.8%	Unknown*

Galveston, TX	75	1,520	4.7%	Unknown*

Tacoma, WA	188	1,406	11.8%	Canada

Jacksonville, FL	662	880	42.9%	Bahamas

South Louisiana, LA	332	1,141	22.5%	Mexico

 Source: CBP, 2007

* According to CBP (2007), a port cited as ‘Unknown’ reported its
last port as “high seas”

Receiving Water Characteristics

For each of the top 20 U.S. ports (as determined by total number of
vessel calls and listed in Table 4-3), several sources were consulted to
assess the current water quality conditions.  In the following sections,
each of the top 20 ports are briefly described in terms of their water
quality and general condition.   As described in Sections 2.4.4 and
2.4.5, the sources consulted for the following descriptions included
EPA’s National TMDL database (EPA, 2007a), the 2007 NEP Coastal
Condition Report (EPA, 2007b), and a collection of other sources that
are cited below in the relevant sections.  The water quality
characteristics of the top 20 ports are described below from most vessel
calls to fewest (based on CBP, 2007).

Houston, Texas

EPA’s National TMDL database lists chlordane (in tissue), dieldrin (in
tissue), dioxin, heptachlor epoxide, polychlorinated biphenyls (PCBs)
(in tissue), and sediment toxicity as the pollutants in exceedance of
water quality standards in Port of Houston waters (as of 2004, the most
recently-available year).  According to the mapping feature of the
National TMDL database, the water body segments that comprise the
Houston Ship Channel and the Port of Houston include: Barbour’s Cut,
Houston Ship Channel/San Jacinto River Tidal, Black Duck Bay, Tabbs Bay,
Scott Bay, and Houston Ship Channel/Buffalo Bayou Tidal.  All of these
segments are impaired for one or more of the pollutants listed above. 
In addition, vessels traveling to and from the Port of Houston must
traverse Upper Galveston Bay, which is impaired for bacteria, dioxins,
and PCBs, prior to entering the Houston Ship Channel (EPA, 2007a).

Galveston Bay is designated as an NEP estuary, with the 2007 Coastal
Condition Report describing Galveston Bay as well-mixed and shallow and
strewn with extensive oyster beds.  The water quality in Galveston Bay
is classified as ‘fair-to-poor’, with high DIN and DIP
concentrations being the main causes of excessive chlorophyll a levels
and poor water clarity.  DO concentrations, however, were rated as
‘good’.  Total organic carbon (TOC) concentrations and sediment
toxicity was both rated ‘good’, although sediment toxicity data were
not available for 31% of the estuary.  Finally, sediment contaminant
levels were classified as ‘fair’ (EPA, 2007b).  

According to the Galveston Bay Estuary Program’s water quality
monitoring program, nutrient (e.g., total nitrogen, ammonia, and total
phosphorus) and chlorophyll a concentrations in Galveston Bay, its
sub-bays, and tributaries have been generally declining since monitoring
began in the 1970s, with many areas achieving a ‘ good’ or ‘very
good’ rating.  Other areas, however, especially those areas
surrounding the shipping route through the Bay (e.g., Upper and Lower
Galveston Bay, Houston Ship Channel, Buffalo Bayou) exhibit a ‘fair’
or ‘poor’ rating for nutrients and chlorophyll a.  Enterococcus,
Escherichia coli, and fecal coliform were also found in high
concentrations in many tributaries surrounding Galveston Bay and the
Port of Houston; for many of these tributaries, the bacterial levels
have been consistently high since the 1970s (EPA, 2007b)

New York City, NY

The Port of New York City is comprised of facilities located in both New
York and New Jersey.  EPA’s National TMDL database lists PCBs,
nitrogen, mercury, cadmium, oxygen demand, floatables, and dioxins as
the pollutants in exceedance of water quality standards in Port of New
York and New Jersey waters (as of 2004, the most recently-available
year). According to the mapping feature of the National TMDL database,
the water body segments that comprise the Port of New York include:
Lower East River, Upper New York/New Jersey Harbor, Kill Van Kull,
Newark Bay, and Arthur Kill and tidal tributaries.  All of these
segments are impaired for one or more of the pollutants listed above
(EPA, 2007a).  

The water quality of the New York-New Jersey Harbor Estuary Program
(HEP) is discussed in EPA’s 2007 Coastal Condition Report and is rated
as ‘poor’; however, there are no data available for approximately
62% of the estuarine area.  According to available data, DIN and DIP
levels were elevated over a wide area of the estuary and rated as
‘fair’ and ‘poor’, respectively.  The estuary was rated
‘good’ for chlorophyll a, DO levels, and water clarity.   Sediment
quality, however, was generally considered ‘poor’, with both
sediment toxicity and sediment contaminants being elevated.  TOC in
sediment was rated ‘good’ for a majority of the estuarine area.  On
a positive note, none of the water quality indicators monitored by the
HEP (i.e., fish tissue contamination, coliform bacteria levels,
dissolved oxygen, harmful algal blooms, etc.) has exhibited downhill
trends since monitoring began.  Despite these positive trends, the
overall health of the estuary is rated as ‘poor’ primarily because
of the deteriorating trends in some wading bird and fish populations and
ongoing fish consumption advisories (EPA, 2007b).  

Port Everglades, Florida

EPA’s National TMDL database lists coliforms, DO, and nutrients as the
pollutants in exceedance of water quality standards in Port Everglades
waters (as of 2002, the most recently-available year). According to the
mapping feature of the National TMDL database, the water body segment
that comprises the Port of Port Everglades includes the Intracoastal
Waterway in Dade County (EPA, 2007a).  

Water quality sampling programs managed by the Broward County Department
of Natural Resources and the South Florida Water Management District did
not have stations located in or around the Port of Port Everglades.

Miami, Florida

EPA’s National TMDL database does not list any water quality
exceedances in and around the Port of Miami. Water quality sampling
programs managed by the Miami-Dade County Department of Environmental
Resource Management and the South Florida Water Management District did
not have stations located in or around the Port of Miami (EPA, 2007a).

Los Angeles/Long Beach, CA

EPA’s National TMDL database lists pesticides
(dichloro-diphenyl-trichloroethane [DDT], toxaphene, chlordane, and
dieldrin), polycyclic aromatic hydrocarbons (PAHs), PCBs, zinc, copper,
chromium, lead, mercury, cadmium, nickel, and sediment toxicity as the
pollutants in exceedance of water quality standards in the waters in and
around the ports of Los Angeles/Long Beach (as of 2002, the most
recently-available year).  According to the mapping feature of the
National TMDL database, the water body segments that comprise the Port
of Los Angeles/Long Beach include: Los Angeles Harbor Main Channel, Los
Angeles Harbor Southwest Slip, Los Angeles Fish Harbor, Los Angeles
Harbor Consolidated Slip, Long Beach Harbor Main Channel, and San Pedro
Bay Near/Offshore Zones (EPA, 2007a).

Although the Port of Los Angeles/Long Beach is located adjacent to Santa
Monica Bay, one of the 28 NEPs, the geographic scope of the monitoring
described in the 2007 Coastal Condition Report does not cover the port. 


San Juan, Puerto Rico

EPA’s National TMDL database lists ammonia, fecal coliform, and DO as
the pollutants in exceedance of water quality standards in the waters in
and around the port of San Juan (as of 2004, the most recently-available
year) (EPA, 2007a). 

San Juan Bay is one of the NEPs described in the Coastal Condition
Report (EPA, 2007b).  The overall condition of the Bay was rated as
‘poor’, based on the water quality, sediment, benthic, and fish
tissue indices.  Water column DIN and DIP concentrations were rated as
‘fair’, although data for DIP were unavailable for 78% of the
estuarine area.   73% of the estuarine area was rated as ‘good’ for
chlorophyll a levels and water clarity measurements were found to be
‘fair’ overall.  DO concentrations were listed as ‘fair’ for 57%
of the estuary and ‘good’ for 36%.  Sediment toxicity was ‘poor’
(with PCBs, DDT, 2-ethylhexl phthalate, lead, and mercury among the most
abundant sediment contaminants) and sediment TOC levels were rated
‘good’.  Low benthic species diversity has resulted in a ‘poor’
rating for benthic conditions and, with 40% of fish tissue samples
collected in the estuary exceeding EPA’s advisory levels, the fish
tissue contaminants index was rated ‘poor’ (EPA, 2007b).   

Savannah, GA

EPA’s National TMDL database lists DO and mercury as the pollutants in
exceedance of water quality standards in the waters in and around the
Port of Savannah (as of 2002, the most recently-available year) (EPA,
2007a). According to the mapping feature of the National TMDL database,
the water body segments that comprise the Port of Savannah include:
Savannah River and Savannah Harbor (EPA, 2007a).

St. Thomas, Virgin Islands

EPA’s National TMDL database lists DO, fecal coliform, oil and grease,
and pH as the pollutants in exceedance of water quality standards in the
waters in and around the Port of St. Thomas, U.S. Virgin Islands (as of
2004, the most recently-available year) (EPA, 2007a).  According to the
mapping feature of the National TMDL database, the water body segments
that comprise the Port of St. Thomas include: Hassel Island at Haulover
Cut to Regis Point and Sprat Bay (EPA, 2007a)

Seattle, WA

EPA’s National TMDL database lists total PAHs, pH, total PCBs, and
fecal coliform as the pollutants in exceedance of water quality
standards in the waters in and around the Port of Seattle (as of 2002,
the most recently-available year) (EPA, 2007a). 

In the Coastal Condition Report, the Puget Sound NEP is given an overall
‘fair’ rating.  The water quality index is ‘fair’, with DIN and
DO concentrations rated ‘good’, chlorophyll a and DIP levels rated
‘fair’, and water clarity classified as ‘poor’.  ‘Poor’
sediment toxicity measurements have resulted in a ‘poor’ overall
sediment quality rating, despite a ‘good’ rating for TOC levels. 
Benthic health was given a ‘good’ rating and fish tissue
contamination was rated as ‘fair’, with 14% of the fish having
contaminant levels greater than EPA advisory levels (and the most
frequently detected contaminant being PCBs) (EPA, 2007b).

New Orleans, LA

EPA’s National TMDL database lists fecal coliform as the pollutant in
exceedance of water quality standards in the waters in and around the
Port of New Orleans (as of 2002, the most recently-available year) (EPA,
2007a). 

Charleston, SC

EPA’s National TMDL database does not list any water quality
exceedances in and around the Port of Charleston (EPA, 2007a).  

Baltimore, MD

EPA’s National TMDL database lists PCBs, zinc, and chromium as the
pollutants in exceedance of water quality standards in and around the
Port of Baltimore (as of 2004, the most recently-available year)(EPA,
2007a).  In addition, Middle Chesapeake Bay (through which vessels must
pass en route to the Port of Baltimore) has water quality exceedances
for nutrients. According to the mapping feature of the National TMDL
database, the water body segments that comprise the Port of Baltimore
include: Curtis Bay, Bear Creek, Southern Branch Elizabeth River,
Eastern Branch Elizabeth River, and Indian River (EPA, 2007a)

Elizabeth River, VA

EPA’s National TMDL database lists phosphorus, fecal coliforms, PCBs,
and benthic (unknown) as the pollutants in exceedance of water quality
standards in the waters in and around the Port of Elizabeth River (as of
2004, the most recently-available year) (EPA, 2007a). According to the
mapping feature of the National TMDL database, the water body segments
that comprise the Port of Elizabeth River include: Western Branch
Elizabeth River, Southern Branch Elizabeth River, Eastern Branch
Elizabeth River, and Indian River (EPA, 2007a)

Dedicated to restoring the health of the river, the Elizabeth River
Project has been studying its condition for several years, focusing on
the benthic communities and toxic characteristics.  Several of their
reports have been posted on their website.  The most recent benthic
monitoring report (2005) indicates that, in general, benthic species
diversity and biomass in the Elizabeth River watershed are below
reference condition levels while abundance was often above reference
condition levels and considered excessive. 

The reports characterizes the water quality of the Elizabeth River as
follows: (1) nutrients have a poor status indicating high concentration
levels, (2) there were improvements in long-term trends in total
nitrogen levels and inorganic nitrogen levels, and (3) there were
widespread improvements in long-term trends in total phosphorus levels.
Nitrogen levels are highest in the Southern Branch with smaller
differences between the branches of the river for phosphorus levels.
Chlorophyll levels are good in both the Eastern Branch and Southern
Branch in spite of high nutrient levels and good water clarity.
Chlorophyll levels are fair in the Western Branch with an improving
long-term trend. Bottom dissolved oxygen levels are fair to good in all
branches (Dauer, 2006).

Oakland, CA

EPA’s National TMDL database lists chlordane, DDT, diazinon, dieldrin,
dioxins, exotic species, mercury, PCBs, and selenium as the pollutants
in exceedance of water quality standards in the waters in and around the
Port of Oakland (as of 2002, the most recently-available year) (EPA,
2007a). 

The Port of Oakland is located within the San Francisco Bay NEP and,
therefore, is included in the 2007 Coastal Condition report (EPA,
2007b).  The overall condition of the NEP is rated as ‘fair’, with
water quality in general classified as ‘fair’ to ‘poor’, with
approximately 73% of the estuary rated ‘fair’ and 20% rated
‘poor’.  Chlorophyll a and DO concentrations were ‘good’ in 90%
and 99% of the estuary, respectively.  DIN levels were ‘fair’, while
both DIP and water clarity were rated ‘poor’.  The sediment in the
estuary is in very good condition, with 100% of the estuary rated
‘good’ for sediment toxicity and 96% rated ‘good’ for TOC
levels.  Benthic invertebrate communities are in ‘good’ condition,
while fish tissue contaminants are rated ‘poor’, with 58% of fish
caught exceeding EPA’s guidance values.

Bayou Lafourche, LA

EPA’s National TMDL database lists DO, nutrients, total coliform, and
fecal coliform as the pollutants in exceedance of water quality
standards in the waters in and around Bayou LaFourche (as of 2004, the
most recently-available year) (EPA, 2007a). 

Currently, the state of Louisiana and the Louisiana Department of
Natural Resources is studying a potential reintroduction of Mississippi
River water into Bayou Lafourche.  A water quality monitoring report was
developed in February 2006 in which data collected in support of a
hydrodynamic model were published.  Data were collected via 18 permanent
platforms installed along the bayou which were in data collection mode
from February 2004 until January 2005.  Parameters that were collected
included temperature, specific conductance, water surface elevation
(depth), salinity, and stream velocity, direction, and speed. Data from
this project are available online.

Galveston, TX

EPA’s National TMDL database lists bacteria as the pollutant in
exceedance of water quality standards in the waters in and around the
Port of Galveston (as of 2004, the most recently-available year) (EPA,
2007a). 

The general condition of the waters surrounding the port of Galveston is
described in the Section 4.2.1 discussion of Houston.  However, the
Galveston NEP published a State of the Bay report in 2002 that described
the water quality data and trends in the estuary.  Generally speaking,
concentrations of ammonia-nitrogen and total phosphorus have been
occurring over the past three decades. Nitrate-nitrite data for the
1990s did not exhibit an upward or downward trend, but did indicate
seasonal peaks in concentrations.  Chlorophyll a levels have been
declining over the past two decades and have reached 25% of their 1975
values.  Dissolved metals have declined in the Houston Ship Channel over
the last ten years, although organic contamination in the Channel from
spillage of petroleum products is substantial (Galveston Bay Estuary
Program, 2002).

Tacoma, WA

EPA’s National TMDL database lists total PCBs, bis(2-ethylhexyl)
phthalate, DDT, PAHs, and pesticides as the pollutants in exceedance of
water quality standards in the waters in and around the Port of Tacoma
(as of 2002, the most recently-available year) (EPA, 2007a). 

The Port of Tacoma is located on Puget Sound.  Refer to the Section
4.2.9 discussion on Seattle for more information on the overall
ecosystem health of the waters surrounding this port, according to
EPA’s 2007 Coastal Condition Report.

Jacksonville, FL

EPA’s National TMDL database lists coliforms, nutrients, total
suspended solids, and turbidity as the pollutants in exceedance of water
quality standards in the waters in and around the Port of Jacksonville
(as of 2002, the most recently-available year) (EPA, 2007a). 

South Louisiana, LA

The Port of South Louisiana is comprised of facilities along 54 miles of
the Mississippi River in St. James, St. Charles, and St. John parishes. 
EPA’s National TMDL database lists fecal coliform as the pollutant in
exceedance of water quality standards in the waters in and around the
Port of South Louisiana (as of 2002, the most recently-available year)
(EPA, 2007a). 

DISCHARGE FINDINGS

Discharges Incidental to the Normal Operation of a Vessel

As described in Section 2.5, the vast majority of information on
discharges originating from vessels came from the UNDS reports on
discharges from Armed Forces vessels.  One of the products from Phase I
was a list of the 25 Armed Forces vessel discharges that should require
a MPCD.  EPA and DoD also identified 14 additional discharges that they
determined would not require an MPCD when discharged from an Armed
Forces vessel, based on the nature of the discharge, the environmental
effects, and the economic costs and practicability of a MPCD for an
Armed Forces vessel.  In the following sections, Battelle has included
information on the group of 25 Phase I discharges that should require an
MPCD, except for one: Catapult Water Brake Tank and Post-Launch
Retraction Exhaust.  A catapult is the mechanism used to help launch
aircraft from a carrier and aircraft carriers are exclusively used by
the military.  The 24 UNDS Phase I discharges that should require an
MPCD are listed in Table 5-1, along with a brief description.

On June 21, 2007, the EPA published an Advanced Notice of Proposed
Rulemaking (ANPRM) in the Federal Register (Vol. 72, No. 119, p. 34241)
providing background information on the pending NPDES permitting
program.  The ANPRM requested that commentors provide information or
data sources that might help the EPA better comprehend the universe of
vessels and discharges that will be affected by the new permitting
scheme.  Six commentors provided specific lists and/or descriptions of
discharges that were relevant to certain types of vessels:

Liberty Maritime Corporation (LMC): a civilian company that transports
military and food aid cargo for the U.S. government

Crowley Maritime Corporation (CMC): operates a fleet of vessels,
including roll on-roll off, lift on-lift off, tankers, tugs, and barges.

World Shipping Council (WSC): a trade association that represents all
types of ocean carriers.

Cruise Lines International Association (CLIA): represents the interests
of 24 cruise line companies.

Pacific Seafood Processors Association (PSPA): represents floating
seafood processing vessels.

American Waterways Operators (AWO): a national trade association for the
inland and coastal tugboat, towboat, and barge industry.

Several of these commentors stated that some UNDS vessel discharges that
had not been included in the first draft of this report (i.e., that did
not require an MPCD when discharged from an Armed Forces vessel) were
relevant to specific types of civilian vessels. In light of this new
information, these additional discharges are listed in Table 5-2 and
more detailed descriptions are included in the sections below.  

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  1 .  Phase I UNDS
Armed Forces Vessel Discharges Requiring an MPCD.

Armed Forces Vessel Discharge	Description

Aqueous Film-Forming Foam	Fire-fighting agent used for flammable liquid
fires on vessels.  A concentrated liquid mixed with ambient water to
form a solution which is discharged during planned maintenance and
inspections.

Chain Locker Effluent	Ambient water and debris that collects in the
anchor chain storage locker as a result of anchor chain washdowns,
retrievals, and heavy weather. The liquid collects in a sump and is
removed by a drainage eductor powered by the shipboard firemain.

Clean Ballast	Ambient water that is transferred into and out of
dedicated tanks to adjust a surface ship’s draft and to improve
stability under various operating conditions. The discharge is generated
when the ballast is no longer required and the tanks are partially or
completely emptied.

Compensated Fuel Ballast	Ambient water that is introduced into fuel
tanks to maintain the stability of a vessel by compensating for the
weight of the expended fuel that is consumed. During refueling, this
ambient water is displaced overboard.

Controllable Pitch Propeller Hydraulic Fluid	Hydraulic oil that is
released from controllable pitch propeller (CPP) systems under three
conditions: leakage through CPP seals, releases during underwater CPP
repair and maintenance, or releases from equipment used for CPP blade
replacement.

Deck Runoff	Water runoff from precipitation, freshwater washdowns, and
ambient water that falls on the exposed decks of a vessel such as a
weather deck or flight deck. This water washes off residues from the
deck and topside equipment, can be contaminated with materials from
other deck activities, and is discharged overboard to receiving waters.

Dirty Ballast	Ambient water that is occasionally pumped into empty fuel
tanks for the specific purpose of improving ship stability. Before
taking on ambient water, fuel in the tank to be ballasted is transferred
to another fuel tank or holding tank. Dirty ballast is comprised of
residual

fuel mixed with ambient water. The discharge is generated when the
ballast is no longer required and the tanks are partially or completely
emptied.

Distillation and Reverse Osmosis Brine	Seawater concentrate or
“brine” that is left over by water purification systems that
generate freshwater from seawater for a variety of shipboard
applications including potable water for drinking. This “brine” is
discharged overboard.

Elevator Pit Effluent	Liquid from deck runoff and elevator equipment
maintenance activities that collects in the bottom of elevator shafts.
The liquid waste is either directed overboard, collected for shore-side
disposal, or processed along with bilge water.

Firemain Systems	Ambient water distributed for fire fighting and other
services aboard ships. Discharges of firemain water from normal
operations occur during firemain testing, maintenance and training
activities, anchor chain washdown, and cooling of auxiliary machinery.

Gas Turbine Water Wash	Wash water discharge from cleaning internal and
external propulsion and auxiliary gas turbine components.

Grey Water	Wastewater from showers, galleys, laundries, deck drains,
lavatories, interior deck drains, water fountains, miscellaneous shop
sinks, and similar sources.

Hull Coating Leachate	Antifouling agents that leach into surrounding
waters from hull coatings designed to prevent corrosion and to inhibit
biological growth on the hull surface.

Motor Gasoline Compensating Discharge	Ambient water used to compensate
for expended motor gasoline (MOGAS) used to operate equipment stored on
some vessels. MOGAS is stored in a compensating tank system to which
ambient water is added to fuel tanks as fuel is consumed. The discharge
occurs as a result of refueling when the displaced water is discharged
overboard.

Table 5–1.  Phase I UNDS Armed Forces Vessel Discharges Requiring an
MPCD, continued.

Armed Forces Vessel Discharge	Description

Non-Oily Machinery Wastewater	Generated from the operation of distilling
plants, water chillers, low- and high-pressure air compressors, and
propulsion engine jacket coolers. The discharge is captured in a
dedicated system of drip pans, funnels, and deck drains to segregate the
water from bilge water, and is either drained directly overboard or into
dedicated collection tanks before being discharged overboard.

Photographic Laboratory Drains	Shipboard photographic lab wastes from
processing color and black-and-white film. Typical wastes include spent
film processing chemical developers, fixer-bath solutions, and film
rinse water

Seawater Cooling Overboard Discharge	Seawater used to cool heat
exchangers, propulsion plants, and mechanical auxiliary systems.

Seawater Piping Biofouling Prevention	Anti-fouling compounds such as
sodium hypochlorite introduced in seawater cooling systems to inhibit
the growth of fouling organisms on interior piping and component
surfaces.

Small Boat Engine Wet Exhaust	Ambient water injected into the exhaust of
small boat engines for cooling and to quiet operation. Exhaust gas
constituents are entrained in the injected ambient water and discharged
overboard as wet exhaust.

Sonar Dome Discharge	Some domes that house detection, navigation, and
ranging equipment are filled with ambient water to maintain their shape
and pressure. The discharge occurs when water from inside the dome is
pumped overboard before performing maintenance or repair on the dome and
when materials leach from the dome exterior.

Submarine Bilge water	Sources of bilge water include seawater
accumulation, normal leakage from machinery, and fresh water washdowns
that collect in the bilge. On some submarines, oily wastewater is
separated from non-oily wastewater. The oily wastewater is held for
shore-side disposal and the non-oily wastewater is discharged overboard.

Surface Vessel Bilge water/Oil-Water Separator Discharge	Sources include
condensate from steam systems, boiler blowdowns, water fountains, and
machinery space sinks that drain to the bilge. Bilge water is either
held for shore-side disposal or treated in an oil-water separator before
being discharged overboard.

Underwater Ship Husbandry	Discharge from the grooming, maintenance, and
repair of hulls and hull appendages performed while a vessel is
waterborne. Underwater ship husbandry includes hull cleaning, fiberglass
repair, welding, sonar dome repair, non-destructive testing, masker belt
repairs, and painting operations.

Welldeck Discharges	Water and residuals from precipitation, equipment
and vehicle washdowns, washing gas turbine engines, grey water from
stored landing craft, and general washdowns of welldecks and vehicle
storage areas.

Source: EPA, 1999a.

Table   STYLEREF 1 \s  5 -2.  Phase I UNDS Armed Forces Vessel
Discharges Not Requiring an MPCD.

Armed Forces Vessel Discharge	Description

Boiler Blowdown	Water removed from the boiler system to prevent
particulates, sludge, and treatment chemical concentrations from
accumulating.

Cathodic Protection	Zinc, aluminum, and chlorine-produced oxidants
released during the consumption of sacrificial anodes and the operation
of impressed current cathodic protection systems. The purpose of
cathodic protection is to prevent hull corrosion.

Freshwater Lay-up	Freshwater used to fill condensers when submarine
seawater cooling systems are placed in stand-by mode, or “lay-up.”
While the condenser is in lay-up mode, the water is discharged and
refilled approximately every 30 days.

Table 5–2.  Phase I UNDS Armed Forces Vessel Discharges Not Requiring
an MPCD, continued.

Armed Forces Vessel Discharge	Description

Refrigeration /Air Conditioning

Condensate	Condensate from air conditioning, refrigerated spaces, and
stand-alone refrigeration units. The condensate is collected in drains
and is either discharged directly overboard or held in dedicated tanks
before discharge.

Rudder Bearing Lubrication	Grease and oil used to lubricate rudder
bearings. The grease and oil can be released while the vessel is moving,
when the rudder is used, or when pierside because the oil lubricant is
slightly pressurized.

Steam Condensate	Condensate from steam used to operate auxiliary
systems, such as laundry facilities, heating systems, and other
shipboard systems, that drains into collection tanks and is discharged
overboard.

Stern Tube Seals and Underwater Bearing Lubrication	Lubricants used in
propeller support struts and bearings that can be released to the
environment.

Source: EPA, 1999a

Some of these discharges listed in Tables 5-1 and 5-2 are more likely
than others to be found on civilian commercial and recreational vessels.
 Given the range of sizes and types of vessels that will potentially be
affected by the pending vessel vacatur, the entire scope of discharges
incidental to the normal operation of a vessel that could potentially be
discharged by a vessel to U.S. navigable waters were included here.

As stated in Section 2.5.1, some of the UNDS-identified discharges had
detailed reports available that included extensive information on the
discharge characteristics, while others had only summary reports with
less detailed information.  Each of the discharges is described briefly
below.  A caveat to this information that bears repeating is that the
discharge information provided by EPA and DoD relates to Armed Forces
vessels.  If data on discharge rates or concentrations were available
and are included in this section, they apply specifically to the type(s)
of Armed Forces vessel(s) discussed in the UNDS reports.  

In a similar vein, Battelle’s ability to associate discharges to
particular civilian vessel types was limited, given the specific
applicability of the UNDS reports to Armed Forces vessels.  Some
discharges can be easily connected to certain types of vessels while
other discharges may or may not apply to any number of vessels.  Deck
runoff, for instance, will be a factor for virtually all commercial and
recreational vessels, whereas elevator pit effluent will not be a
discharge for vessels without elevators (i.e., smaller recreational
vessels).  With these caveats in place, the following sections describe
each of the discharges.

Aqueous Film Forming Foam (AFFF)

The information on aqueous film forming foam (AFFF) was obtained from
EPA (1999b) and five comments on EPA’s ANPRM.

Discharge Summary

AFFF is a synthetic firefighting agent used aboard USCG and Navy vessels
and possibly civilian vessels.  Consisting of fluorosurfactants and/or
fluoroproteins, AFFF can extinguish as well as prevent fires by forming
an oxygen-excluding barrier over the area.  AFFF concentrate is mixed
with ambient water to form a 6% dilution and is never discharged from a
vessel in its undiluted form.  The discharge of AFFF, as discussed in
this section, refers to the direct overboard discharging of the AFFF
system.  Some maintenance, inspection, and training activities may
result in AFFF accumulating on the vessel deck; in these cases, the AFFF
becomes a part of other discharges, such as deck runoff, chain locker
effluent, elevator pit effluent, or bilge water.

AWO, CMC, WSC, and the CLIA all cited AFFF as a potential discharge from
some of their vessels.  AWO specifically stated that some of their
towing vessels are equipped with AFFF systems, especially those
transporting flammable liquid cargo.  They also stated that maintenance,
testing, and training activities lead to AFFF being either discharged
directly overboard or discharged onto the deck and then subsequently
washed overboard.  CMC stated that commercial vessels are required by
international and U.S. law to test AFFF systems periodically, although
no specific law was cited.  They also stated that AFFF is discharged
from all commercial vessel types, including unmanned barges.  A comment
by LMC stated that they do not conduct firefighting training using foam
in U.S. waters.

When and Where Discharge Occurs

Discharge of AFFF can occur during planned maintenance and inspection
activities that, on Armed Forces vessels, take place on an annual or
semi-annual basis.  On Armed Forces vessels, these maintenance and
inspection activities occur by discharging the AFFF hose over the
vessel’s side.  Following these maintenance and inspection activities,
any AFFF on the vessel deck is washed down with the firemain and becomes
a part of other vessel discharges.  Maintenance discharges can only
occur when the Armed Forces vessel is outside territorial waters (i.e.,
12 nautical miles [nmi]).  Discharges due to inspections and
certifications can occur anywhere, unless the AFFF has been washed into
the vessel’s bilge tank, which cannot be discharged within 12 nm. 
Civilian vessels may have different self-imposed restrictions for direct
AFFF discharge.

Unless equipped with a fixed extinguishing system that must be tested,
recreational vessels will not have this discharge.  When used to fight
fires on either commercial or recreational vessels, fire-fighting foam
is not considered a discharge incidental to the normal operation of a
vessel.

In their comments to the EPA’s ANPRM, CLIA stated that AFFF discharge
occurs whenever testing and maintenance activities are scheduled, which
happen as often as needed to maintain fire fighting systems, and to
ensure crew proficiency and vessel safety.  However, they also state
that these discharges typically occur outside of 12 nmi from land.

Discharge Rates, Concentrations, and Constituents

Along with the ingredients in the AFFF itself, the discharge will
contain the constituents of the firemain water and the AFFF piping.  The
specific ingredients of the AFFF concentrate will vary by manufacturer. 
EPA (1999b) lists constituents, although they are specific to the brand
of concentrate used by the Armed Forces and are not necessarily relevant
to civilian vessels.  These constituents include: water (which makes up
80% of the ingredients by weight), 2-(2-butoxyethoxy)-ethanol, urea,
alkyl sulfate salts (2 in number), amphoteric fluoroalkylamide
derivative, perfluoroalkyl sulfonate salts (5), triethanolamine, and
methyl-1H-benzotriazole.  As discussed in Section 5.1.10, constituents
of the firemain water in Armed Forces vessels may include residue from
the copper-nickel alloy pipes.  AFFF piping in Armed Forces vessels is
also constructed of copper-nickel alloy; therefore, perfluoroalkyl
sulfonate salts, total nitrogen, bis(2-ethylhexyl) phthalate, copper,
nickel, sulfides, and iron may be discharge constituents.  The results
of sampling by EPA and DoD indicated that each of these pollutants
exceeded the most stringent state water quality standards in the U.S. 
Ambient water from the firemain system has little potential for
harboring invasive species.

Boiler Blowdown

The information on boiler blowdown was obtained from EPA (1999c) and
from four comments on EPA’s ANPRM

Discharge Summary

For steam-powered vessels, onboard boiler systems must be supplied with
feedwater to maintain the water level.  On some Armed Forces vessels, a
treatment is added to the feedwater to prevent corrosion and minimize
scale formation in the boiler system.   As the feedwater is boiled to
produce steam, the concentration of particulates and chemicals (from the
added treatment) increases in the feedwater remaining to be boiled. 
Boiler systems must periodically undergo a ‘blowdown’ to control the
treatment concentrations and to remove accumulated sludge.  A blowdown
involves releasing the water from the boiler and from the ship
altogether, into the ambient water through hull fittings below the
waterline.  Different types of blowdowns release different percentages
of boiler water, but, typically, blowdowns remove between 1% and 10% of
the total volume of water in the boiler.  The UNDS report indicates that
the volume of this discharge from Armed Forces vessels is rarely greater
than 310 gallons and that the discharge is ejected from the vessel at
high pressures (up to 1200 psi) and high temperatures (above 325°F). 
Boiler blowdown discharge can originate from any vessel with steam
propulsion or a steam generator.  

Comments submitted in response to the ANPRM indicated that boiler
blowdown is a discharge associated with some types of civilian vessels. 
LMC, a civilian company that transports military and food aid cargo for
the U.S. government, cited boiler blowdown as one of the discharges 
incidental to the operation of its vessels.  CMC operates a fleet of
vessels, including roll on-roll off, lift on-lift off, tankers, tugs,
and barges.  Their comment indicated that boiler blowdown was a relevant
discharge for their fleet, although they did not specify which types of
vessels.  The WSC is a trade association that represents all types of
ocean carriers and boiler blowdown was included in a non-annotated list
of discharges relevant to their industry.  Finally, the CLIA, which
represents the interests of 24 cruise line companies, cited
“boiler/economizer washdown waste” as a discharge relevant to cruise
ships.  A definition provided with their comment indicates that this
discharge is equivalent to boiler blowdown.

When and Where Discharge Occurs

The UNDS report states that the frequency of boiler blowdown is
dependent on the needs of the particular boiler system.  Therefore, this
discharge can occur whenever and wherever necessary to maintain the
boiler system. In their comment, CLIA stated that, on cruise ships,
boiler blowdowns occur as needed to maintain performance, which is
typically on a weekly or monthly basis.  However, they indicated that
this discharge is nearly always done while underway and as far from land
as practicable.  

Discharge Rates, Concentrations, and Constituents

The constituents of boiler blowdown discharge will be dependent on the
type(s) of anti-scaling and anti-corrosion treatment originally added to
the feedwater.  Numerous constituents found in boiler blowdown
discharges from Armed Forces vessels were defined as priority pollutants
by the EPA: antimony, arsenic, cadmium, copper, chromium, lead, nickel,
selenium, thallium, zinc, and bis(2-ethylhexyl) phthalate.  Other
detected constituents are listed in Table 3 of the UNDS report (EPA,
1999c).  

Thermal modeling using Armed Forces vessel specifications and described
in the UNDS report showed that the high temperatures of the boiler
blowdown discharge did not exceed the thermal mixing zone criteria of
Virginia and Washington State, the only two U.S. states with such
standards.

Cathodic Protection

The information on cathodic protection was obtained from EPA (1999d) and
from three comments on EPA’s ANPRM.

Discharge Summary

According to the UNDS report on this discharge, nearly all Armed Forces
vessels use cathodic protection systems (usually in conjunction with
corrosion-resistant coatings) to prevent steel hull or metal underwater
structure corrosion.  Vessels with hulls made of fiberglass, wood,
aluminum, or other non-ferrous material do not require cathodic
protection systems.  Two types of cathodic protection are most common on
Armed Forces vessels: sacrificial anodes and Impressed Current Cathodic
Protection (ICCP)-based systems.  Sacrificial anodes are physically
connected to an underwater vessel structure or component (which acts as
the cathode).  The anode is preferentially corroded (or
‘sacrificed’) which, via the electrolytic properties of seawater,
produces a flow of electrons to the cathode, thereby preventing the
cathode from corroding.  Sacrificial anodes are used on most Armed
Forces vessels, particularly those with mandatory dry-dock inspection or
overhaul intervals of less than three years.  When immersed, the anodes
continue to corrode and have to be maintained and routinely replaced;
zinc anodes need to be replaced at least every six years.  Anodes can
also be constructed of aluminum.  The ICCP-based mechanism of protection
is identical to sacrificial anodes, except ICCP systems use direct
current (DC) from a source within the vessel in lieu of current supplied
from anodes.  

According to comments submitted in response to EPA’s ANPRM, cathodic
protection system discharge can originate from civilian vessels.  CLIA,
the WSC, and CMC all cited cathode protection discharge as relevant to
the types of vessels they represent in their ANPRM comments.  

When and Where Discharge Occurs

For vessels equipped with sacrificial anodes, the discharge occurs
continuously whenever the vessel’s hull is submerged.  The comment
submitted by CLIA also stated that this discharge occurs continuously

Discharge Rates, Concentrations, and Constituents

Ionized zinc or aluminum can be released into the surrounding water
column as sacrificial anodes are consumed by corrosion.  At the cathode,
the water is reduced, forming hydroxyl ions which can form zinc or
aluminum hydroxide if enough oxygen is present in the water.  ICCP
systems can generate chlorine-produced oxidants (CPOs), but the specific
types will vary according to the specific chemistry or the surrounding
water.  These oxidants can include hypochlorous and hypobromous acids,
hypochlorite and hypobromite, chloro- and bromo-organics, chloride,
bromide, chloramines, and bromamines.  Utilizing a tidal prism modeling
approach, the receiving water concentrations of zinc and CPOs were
estimated and none of the concentrations were found to exceed the most
stringent state water quality standards. 

Chain Locker Effluent

The information on chain locker effluent was obtained from EPA (1999e)
and from four comments on EPA’s ANPRM.

Discharge Summary

Armed Forces vessels, along with other civilian vessels, store their
anchor chain(s) in a below deck compartment (chain locker) when not in
use.  In the locker, the chain rests on a grate below which is a sump
that collects liquids and materials that enter the chain locker via rain
and green water.  Most large surface vessels have at least one chain
locker (EPA, 2003a).  Chain locker effluent is generated during anchor
retrieval (which, according to CLIA’s comment, occurs weekly) or
during storm events, when water may wash over the deck of a vessel.  The
sump in the chain locker is emptied either directly overboard (with
assistance from firemain water) or is drained into the bilge tank for
later disposal.

LMC, CMC, WSC, and CLIA all cited chain locker effluent as a discharge
relevant to their types of vessels.  CLIA further states that this is a
discharge on all the vessels they represent.    

When and Where Discharge Occurs

Navy vessels do not directly discharge chain locker effluent within 12
nmi of shore.  Civilian vessels may have different self-imposed
restrictions for direct chain locker effluent discharge.  

Discharge Rates, Concentrations, and Constituents

Chain locker effluent has the potential to contain marine organisms,
which may have been introduced into the sump from the anchor and chain,
through the firemain system, or via green water.  However, the Navy
practice of washing down the anchor and chain as they are retrieved and
the 12 nmi discharge limit makes the introduction of invasive species
from chain locker effluent unlikely.  Similar practices by civilian
vessels will help prevent species introduction.  Other constituents can
include residue from materials used in the chain locker, such as rust,
paint chips, grease, and zinc, as well as residue from copper-nickel
alloy firemain pipes.  The actual materials used in the construction of
the chain locker or firemain pipes will vary for civilian vessels.

Discharge concentrations and annual mass loadings for chain locker
effluent were not calculated for the UNDS report due to the expected
minimal amount of discharge and the 12 nmi discharge limit followed by
Armed Forces vessels.

Clean Ballast

The information on clean ballast was obtained from EPA (1999f) and from
six comments on EPA’s ANPRM.

Discharge Summary

Clean ballast is water that is taken onboard to assist with vessel
draft, buoyancy, and stability and stored in dedicated ballast tanks
that have never contained anything but ballast water (as opposed to
Compensated Fuel Ballast and Dirty Ballast).  Clean ballast tanks
(sometimes called segregated ballast tanks [SBT]) can be filled from the
firemain or by ballast pumps that take in ambient water.  Large
commercial vessels (e.g., cargo, tankers, ro-ro, passenger) typically
have ballast tanks, although they may not have clean ballast tanks. 
Under recent amendments to MARPOL 73/78 (Regulation 13G), all tankers
must now have SBT configurations or be double-hulled.  SBT arrangements
are associated with smaller volume oil spills because the oil is carried
in multiple tanks.  According to the National Academy of Sciences (NAS)
(2003), approximately two-thirds of the worldwide tanker fleet (crude
and product) uses SBT, although this number has likely increased since
that source’s publication.  

Recreational boats typically do not have ballast water tanks. However,
boats used for wakeboarding are now being marketed with ballast tanks
(e.g., Centurion Boats, Correct Craft) or existing boats can be
retrofitted with expandable, portable ballast tanks (e.g., BoardStop).
Normally, these tanks are filled and emptied with the same source water.

Comments submitted in response to EPA’s ANPRM indicate that clean
ballast discharge is relevant to several different types of vessels. 
LMC, WSC, and CMC all specifically cited clean ballast as their
discharge.  In their comment, American Waterway Operators stated that
their towing vessels are ballasted for stability and trim and that a
large number of their towing vessels are only ballasted with water from
municipal or commercial sources, except in emergencies.  They also
stated that tank barges are purposely ballasted for a variety of
reasons, including to maintain proper trim during loading and unloading
operations, to improve tow configurations, and to permit passage
underneath obstructions such as bridges.  However, tank barges taking up
ballast while at sea for trim purposes is very rare and, when this must
occur, the ballast taken onboard is kept to a minimum.  Because the crew
of a tank barge must transit from the tugboat to the barge to perform
ballasting or deballasting operations, operators will retain ballast
onboard whenever feasible.  If there is an emergency, the operator will
only release enough ballast to continue with safe operations.  

PSPA cited ballast water as a relevant discharge for the vessels they
represent, but it was not specified that clean ballast tanks were used.

When and Where Discharge Occurs

Armed Forces vessels cannot discharge ballast water within 12 nmi of
shore and must perform at least two exchanges prior to entering the 12
nmi zone.  

AWO commented that ballasting and deballasting operations on their
towing vessels are conducted during major shipyard maintenance and to
replace spent fuel (which is stored in separate tanks) to retain vessel
stability.  They also stated that coastal tugboats discharge their
ballast water outside the demarcation line whenever possible or retained
it onboard for disposal at a shore-side facility.  For their tank
vessels, AWO stated that ballast is frequently taken on and discharged
in the same location.

CLIA also cited ballast water as a relevant discharge for the vessels
they represent, although they do not specify whether the ballast tanks
are ‘clean’.  They stated that ballast water is discharged as needed
to ensure the safety of the ship, which, typically, is several times per
week.

Discharge Rates, Concentrations, and Constituents

Ballast water discharged from clean ballast tanks may contain marine
organisms as well as material from inside the tank, piping, or other
machinery.  Ballast tanks filled via the firemain may contain residue
from the firemain pipes.  The actual materials and contents used in
civilian ballast tanks will vary.  Some possible constituents may
include rust inhibitors, flocculant compounds, epoxy coating materials,
zinc or aluminum (from anodes), iron, nickel, copper, bronze, and
silver.  Accumulated sediments from the bottom of the tank may also be
discharged.    

The discharge rate and constituent concentrations of clean ballast water
from civilian vessels will vary by vessel type, ballast tank capacity,
and type of deballasting equipment.  According to a study published by
the Bluewater Network (Maddison, 2006), typical cruise ships have a
ballast capacity of approximately 1,000 metric tons and have a ballast
discharge rate of between 250-300 metric tons per hour.  The Prince
William Sound Regional Citizens’ Advisory Council estimates that oil
tankers can carry between 

Compensated Fuel Ballast

The information on compensated fuel ballast was obtained from EPA
(1999g).

Discharge Summary

Some vessels have a series of connected ballast tanks that store fuel
and, as the fuel is consumed, water is introduced to the same tanks via
the firemain to ‘compensate’ for the lost weight of the spent fuel. 
The water fills in the spaces vacated by the fuel.  Then, as the vessel
is refueled, the fuel, being denser, ‘pushes’ the ambient water back
through the tanks.  At the end is an overflow/ expansion tank with an
overboard discharge pipe; this expansion tank always contains ambient
water and prevents fuel from being accidentally discharged into open
waters if the fuel tanks are overfilled.  Compensated fuel ballast tanks
are only completely emptied during maintenance activities.  

It is notable that none of the commentors that listed the relevant
discharges for their vessel types cited compensated fuel ballast.

When and Where Discharge Occurs

Discharge of compensated fuel ballast water may occur through the
overflow/expansion tank during refueling, which can occur while the
vessel is at port or at sea.  For Armed Forces vessels, at sea refueling
occurs only outside the 12 nmi limit.  Civilian vessels may have
different refueling policies.  

Discharge Rates, Concentrations, and Constituents

Studies on Armed Forces vessels have detected oil in compensated fuel
ballast discharge in concentrations ranging from below detection level
to 370 milligrams per liter (mg/L).  Other research has tested
discharges for a suite of parameters and discovered copper, nickel,
silver, thallium, zinc, benzene, phenol, and toluene were present in
measurable amounts.  Mercury, total petroleum hydrocarbons (TPH), and
hexane extractable material (HEM) (which corresponds to the amount of
oil and grease present) were also detected.  Research conducted by EPA
and DoD determined that several constituents detected in compensated
fuel ballast exceeded the most stringent state water quality standards:
ammonia, nitrate/nitrite, HEM, total phosphorus, mercury, copper,
nickel, silver, thallium, zinc, 2-propenal, and benzene.  According to
EPA (1999g), invasive species are not likely to be introduced during
refueling operations.

	

For Armed Forces vessels, compensated fuel ballast is discharged at a
rate of up to 400 gallons per minute (gpm) per ballast tank group
(maximum of 2,400 gpm per vessel) during at port refueling operations,
which take place approximately twice a year.  Civilian vessels with
compensated ballast tanks will have a variety of discharge rates,
dependant on vessel size and type.  

Controllable Pitch Propeller Hydraulic Fluid

The information on controllable pitch propeller hydraulic fluid was
obtained from EPA (1999h) and two comments on EPA’s ANPRM.

Discharge Summary

Controllable pitch propellers (CPPs) are variably-pitched propeller
blades that can change the speed or direction of a vessel without
requiring the vessel’s main propulsion system to change speed or
direction.  Hydraulic control oil is provided to each CPP hub, which is
surrounded by seals meant to keep the oil from coming into contact with
the surrounding water.  Many civilian ocean-going vessels may use CPP
technology.

Two commenter’s on EPA’s ANPRM cited controllable pitch propeller
hydraulic fluid as a relevant discharge for the vessels they represent.

When and Where Discharge Occurs

Hydraulic oil can leak past the CPP’s protective seals (if they are
worn or defective).  These leaks can occur at any time, while the vessel
is at port or underway in open water, although they are more likely
while the vessel is underway since the seals are under higher pressure. 
Regular maintenance activities on the CPP system, which can occur
portside, can also cause oil discharge.

In their comment, CMC stated that controllable pitch propeller
maintenance activities on the vessels they represent is typically done
while the vessel is in dry-dock.  When dry-docking is not an option,
then maintenance will occur pierside.  

Discharge Rates, Concentrations, and Constituents

Constituents of the hydraulic oil will vary by manufacturer.  Other
potential discharge constituents include copper, tin, aluminum, nickel,
and lead from the piping, hub, and propeller.

Oil leaks from around defective or worn seals are believed to be
negligible.  During maintenance activities, small amounts of oil may be
discharged.  EPA (1999h) estimates that approximately 20 ounces of oil
may be released for every CPP blade that is replaced (the Armed Forces
estimates there are about 30 blade replacements annually).  When the
blade replacement includes removal of the blade port cover (during about
seven of the 30 instances), a worst case scenario of five gallons of oil
may be discharged.  

Deck Runoff

The information on deck runoff was obtained from EPA (1999i) and six
comments on EPA’s ANPRM.

Discharge Summary

The majority of vessel deck runoff is attributable to precipitation,
although deck washdowns and green water washover can also contribute. 
All vessels, regardless of size or type, discharge some amount of deck
runoff.  

Comments submitted in response to EPA’s ANPRM by WSC, LMC, and CMC
cited deck runoff as a relevant discharge from the vessels they
represent.  In their comment, CLIA stated that deck runoff from the
vessels they represent may include detergent or soap residue left behind
from deck or window cleaning.  Deck runoff discharge will occur upon a
rain event or during weekly (or more frequently, as needed) deck
washdowns.  AWO stated that, on their towing vessels, rain water is
allowed to freely and quickly run off the decks.  Accumulated water on
decks can create problems for vessel stability and make deck surfaces
slippery, compromising the safety of the crew.  Tank barges also
generate deck runoff, although AWO’ comment states that an increasing
number of tank barges are being fitted with perimeter spill rails and/or
drip pans.  These technologies are further described in Section 6.6. 
Finally, the same commentor stated that deck and hopper barges also
generate deck runoff and rain water that collects in open, but contained
areas is pumped periodically into waterways.  AWO also listed wash water
as a separate discharge on their towing vessels.  According to the
comment, towing vessels periodically have their topsides washed down
with potable water (or clean ambient water) and biodegradable and
phosphate-free detergent.  

PSPA listed rain, snow, ice, waves, water from fishing gear brought
onboard, and deck washdown water as the types of deck runoff that may be
relevant to the vessels they represent. 

When and Where Discharge Occurs

Precipitation can occur anywhere at anytime and will instigate deck
runoff (unless it is otherwise contained).  Green water washover can
happen virtually anywhere to smaller vessels, whereas larger vessels may
only experience deck washover while at sea or during extreme weather
conditions.  Deck washdowns are typically done while the vessel is at
port or otherwise stationery.  

According to their comment on EPA’s ANPRM, the frequency of AWO water
wash discharges vary greatly by vessel size and service.

Discharge Rates, Concentrations, and Constituents

Vessel decks can accumulate a variety of residues originating from
various on-deck activities.  Topside machinery and refueling operations
may contribute oil and grease to the deck, while general debris (e.g.,
paper, wire, garbage) can also be washed overboard if left unsecured. 
Spilled oil cargo may be present on the decks of some oilers in the
Armed Forces.  Residue from cleaners and detergents used to wash the
deck may be present in runoff, as can soot particles (from fuel burning)
and AFFF remnants.  The specific constituents will vary.     

Discharge rates for deck runoff vary from vessel to vessel and will
depend on the weather as well as the frequency of deck washdowns.  EPA
(1999i) developed a formula to estimate the amount of annual
precipitation-caused deck runoff from Armed Forces vessels which takes
into account the deck surface area, annual precipitation, and the number
of days a vessel is within 12 nmi of shore.  This formula may be useful
for determining reliable deck runoff rates for vessel vacatur purposes;
however, the wide variety of formula inputs that would be required may
not make using the formula realistic.  

Dirty Ballast

The information on dirty ballast was obtained from EPA (1999j).

Discharge Summary

Dirty ballast tanks are similar to compensated fuel ballast tanks in
that the ballast water can come into contact with the vessel’s fuel. 
Unlike compensated fuel ballast, however, dirty ballast is water that is
pumped from outside the vessel directly into the same tank that once
held fuel, once that fuel was been spent and space is available.  When
discharged, the dirty ballast water may contain fuel residuals and
similar constituents.  

It is notable that none of the commentors that listed the relevant
discharges for their vessel types cited dirty ballast.

When and Where Discharge Occurs

The policy of the few Armed Forces vessels that still maintain dirty
ballast systems is to not discharge the dirty ballast water within 12
nmi of shore.  

Discharge Rates, Concentrations, and Constituents

According to EPA (1999j), dirty ballast water constituents are similar
to those found in compensated fuel ballast water.  

Distillation and Reverse Osmosis Brine

The information on distillation and reverse osmosis brine was obtained
from EPA (1999k) and four comments on EPA’s ANPRM.

Discharge Summary

Some vessels have onboard plants that distill seawater into fresh,
potable water or high-purity feedwater.  The remnants of the
distillation process, which can include brine and any residue or
constituents from the distillation plant itself is typically discharged
overboard.  Condensate is also produced during the distillation process,
but this is usually either reused in the boiler system or is collected
as non-oil machinery wastewater.  Anti-scaling treatments as well as
acidic cleaning compounds may also be injected into the distillation
system.  Plants that utilize reverse osmosis (RO) produce water of
lesser purity than distillation, but generate discharges without
anti-scaling or cleaning compounds.  

CLIA, LMC, WSC, and CMC all cited distillation and RO brine as a
relevant discharge from the vessels they represent.  CMC also stated
that distillation systems are installed on most commercial vessels.

When and Where Discharge Occurs

Distilling plants on steam-propelled vessels operate whenever the
vessel’s boilers are operating; therefore, distillation and RO brine
discharge can occur at any time while the vessel is underway or at port.
 According to EPA (1999k), gas- or diesel-powered Armed Forces vessels
rarely operate their distillation or RO plants within 12 nmi of shore. 
However, civilian vessels equipped with these systems have the potential
to operate them anywhere. 

Discharge Rates, Concentrations, and Constituents

Onboard distillation and RO systems discharge brine, which is
essentially concentrated seawater and possessive of the same properties
and constituents of seawater, including dissolved and suspended solids
and metals.  Distillation plants are manufactured of metal that can be
corroded by seawater, particularly at the elevated temperatures at which
these plants are operated; in Armed Forces vessels, this corrosion
process could introduce such constituents as copper, chromium, nickel,
and zinc to the brine.  Plants found on civilian vessels may be
constructed of various materials that may leach into brine prior to
discharge.  RO plants are not operated at high temperatures and are not
expected to release corrosive materials to brine.  Constituents of
anti-scaling compounds utilized by civilian vessels will vary by
manufacturer, although the Armed Forces compounds consist of such
materials as polyacrylates and anti-foaming additives.  EPA and DoD
conducted effluent sampling on a collection of Armed Forces vessels and
detected that the following constituents (along with copper, nickel, and
zinc) exceeded the most stringent water quality standards:  iron, lead,
total nitrogen, and total phosphorus.  These materials may or may not be
present in the discharge from civilian vessels.  The brine mixture will
also be warmer than ambient temperatures, constituting a thermal
discharge.  Thermal plume modeling (EPA, 1999k) indicated that discharge
temperatures may reach a maximum of 120°F and, in the two states used
in the model (Washington and Virginia), the discharge did not exceed
thermal mixing zone standards.  	

Elevator Pit Effluent

The information on elevator pit effluent was obtained from EPA (1999l)
and one comment on EPA’s ANPRM.

Discharge Summary

Large vessels with multiple decks are equipped with elevators to
facilitate the transportation of maintenance equipment, people, and
cargo between decks.  Some vessels may have multiple elevators utilized
for various purposes.  Only elevators that are operated within a shaft
will have a pit at the bottom, along with a sump to collect materials
and liquids that may find their way into the shaft.  Much of what ends
up in the elevator pit and sump is deck runoff along with residue and
materials used in elevator maintenance and repair.  On Armed Forces
vessels, waste that accumulates in elevator pits is removed by gravity
draining, by educting overboard using the firemain, by using a vacuum or
sponges to transfer the waste for treatment as bilge water or graywater,
or by containerizing it for shore disposal.  On Armed Forces vessels,
direct, untreated overboard discharge of elevator pit effluent is rare
and, if necessary, typically occurs more than 50 nmi from shore and only
if the effluent is non-oily.  

The comment on EPA’s ANPRM from WSC simply listed elevator pit
effluent as a discharge relevant to the vessels they represent.

When and Where Discharge Occurs

While the Armed Forces does not discharge elevator pit effluent within
12 nmi of shore, civilian vessels may empty their pits at anytime while
underway or pierside.  

Discharge Rates, Concentrations, and Constituents

Elevator pit discharge will have constituents similar to those found in
deck runoff and firemain water.  On Armed Forces vessels, elevator
maintenance and repair residues may include lubricants, cleaning
solvents, soot, and paint chips.  Tests conducted by EPA and DoD
discovered that some detected constituents from elevator pit effluent
exceeded the most stringent state water quality standards, including
total nitrogen, bis(2-ethylhexyl) phthalate, copper, iron, and nickel,
all of which are present in deck runoff  and firemain water.  

Determining the rates and concentrations of elevator pit effluent
discharge is difficult given the variety of types and sizes of Armed
Forces and civilian vessels as well as the differences in the elevator
maintenance frequency.   

Firemain Systems

The information on firemain systems was obtained from EPA (1999m) and
four comments on EPA’s ANPRM.

Discharge Summary

Most vessels have some sort of fire fighting system, whether this
consists of individual fire extinguishers, as may be found on smaller,
recreational vessels, or built-in water- and foam-distribution systems,
which are more practical on larger vessels.  For this latter category, a
firemain system uses a sea chest to pump ambient water into the vessel,
which can then be distributed via fire hose stations, sprinkler systems,
or AFFF distribution stations.  Firemain systems can be ‘wet’ (i.e.,
water is pressurized and is available on demand) or ‘dry’ (i.e.,
water is unpressurized and not available on demand).  Besides fire
fighting activities, the firemain system can be used for what EPA
(1999m) terms ‘secondary services’, which include deck and equipment
washdowns, machinery cooling water, and ballast tank filling.  Other
activities may require firemain usage on civilian vessels.  This section
describes only firemain water that is discharged directly overboard
during maintenance and inspection activities.  Discharges that contain
firemain water from secondary services are described in their respective
sections.  

Comments on EPA’s ANPRM from LMC and WSC cited firemain discharges as
a relevant discharge from the vessels they represent.  In their
comments, CLIA stated that firemain discharges take place during anchor
chain washdowns, firemain testing, and various maintenance and training
activities.  CMC stated that all of the vessels they represent are
equipped with firemain systems.  

When and Where Discharge Occurs

On Armed Forces vessels, firemains are discharged directly overboard
during testing and maintenance, inspections, training activities, and
anchor chain washdown.  If water demand is low, the firemain system may
also produce bypass discharges to prevent the pumps from overheating. 
Civilian vessels may have other activities that cause the firemain to
discharge water directly overboard.  Other vessel discharges may contain
firemain water (e.g., ballast discharges, AFFF, chain locker effluent,
elevator pit effluent, deck runoff, etc.), but these are discussed in
their respective sections.  

For Armed Forces vessels, the discharge of water from the firemain
system directly overboard typically occurs at any time and any place and
whenever maintenance, repair, testing, inspection, or training
activities are occurring.  Civilian firemain discharge will occur at a
variety of frequencies and locations, dependent on the demands of the
particular vessel and crew.

CMC stated in their comments that while firemain system discharges may
occur both within and beyond 12 nmi from land, typical operating
policies mandate that testing of the system take place only beyond 12
nm.

Discharge Rates, Concentrations, and Constituents

Firemain water contains a variety of constituents.  The firemain pipes
found on most Armed Forces vessels are constructed of copper, zinc, and
nickel, which can be eroded from the system due to high fluid velocity
or abrasive materials being caught in the flow.  Other constituents can
include aluminum, tin, silver, iron, titanium, and chromium, which can
erode from sections of the firemain pumps, valves, and sea chests.  The
firemain systems, and therefore the discharges, on civilian vessels may
not contain these materials.  EPA (1999m) found that (aside from copper,
iron, and nickel) bis(2-ethylhexyl) phthalate, nitrate/nitrite, and
total nitrogen were the constituents that exceeded the most stringent
water quality standards.  Thermal discharge is a risk with Armed Forces
firemain systems used for cooling systems.  Due to the short residence
times of water in most firemain systems, NIS introductions are a minimum
risk.  

Firemain types, configurations, and sizes can vary from vessel to
vessel, a fact that is true for Armed Forces as well as civilian
vessels.  The frequency of use also has bearing on the discharge rate. 
EPA (1999m) estimated that firemain systems on USCG vessels are operated
an average of 5 minutes a week per pump (the USCG is obligated to have
at least two pumps per vessel).  However, the actual discharge rate
varies by the flow rate of the pumps, the number of days the vessel is
in use, etc.  Civilian vessels will have an entirely different set of
variables to consider when determining rate and concentration values. 
Additionally, the actual type of firemain system has bearing on
discharge amounts because continuously discharging wet firemain systems
will produce more discharge than dry firemain systems.

Freshwater Layup

The information on freshwater layup was obtained from EPA (1999n) and
two comments to EPA’s ANPRM.

Discharge Summary

Seawater cooling systems serve to condense low pressure steam from
propulsion plant or generator turbines on some vessels.  When a vessel
is at port or pierside for an extended period of time, the cooling
systems are not circulated, risking the accumulation of biological
growth and reduced system efficiency.  The freshwater layup process
includes removing all seawater from the condensers (using pressurized
air) and filling the condensers with potable water, where it remains
stagnant for two hours before being blown overboard, again using
pressurized air.  Following this flushing process, the condensers are
again filled with potable water, which remains in the condensers for 21
days before being blown overboard.  Following this step, the condensers
are filled with potable water and emptied on a 30-day cycle until the
vessel returns to normal operations.  

Civilian vessels with a seawater cooling system will require freshwater
layup cycles if they are not operated for an extended period.  CMC
stated in their comments that some of their vessels need to be
periodically laid up.  WSC included freshwater layup as one of the
discharges relevant to the vessels they represent.

When and Where Discharge Occurs

When a vessel is pierside or in port for more than three days, the main
steam plant is shut down, the condensers are not circulating, and a
freshwater layup cycle is required.  This discharge will only occur
while the vessel is in port.

Discharge Rates, Concentrations, and Constituents

Freshwater layup discharge will include the constituents of the potable
water along with residual seawater and any residue that has leached from
the condenser while the water is being held.  Potable water may contain
disinfectants like chlorine or chloramine.

Gas Turbine Water Wash

The information on gas turbine water wash was obtained from EPA (1999o)
and one comment on EPA’s ANPRM.

Discharge Summary

On some vessels, gas turbines are used for propulsion and electricity
generation.  To maintain efficiency, the turbines must occasionally be
washed down of the byproducts that can accumulate, including salt,
lubricants, and combustion residuals.  On Armed Forces vessels, a
cleaning compound is added to the freshwater washdown, although civilian
vessel water wash may contain different constituents.  Water wash
discharge may be channeled to a dedicated holding tank for onshore
disposal (in which case no overboard discharge occurs), or the water may
become a component of deck runoff, welldeck discharge, or bilge water.  

CLIA was the only commentor that cited gas turbine water wash as a
relevant discharge to the vessels they represent.  However, they stated
that not every one of their vessels was equipped to produce this
discharge, and, of the ones that are so equipped, this discharge is a
rare occurrence.

When and Where Discharge Occurs

The location and frequency of gas turbine water wash discharge will vary
according to where the used water wash is channeled.  

Discharge Rates, Concentrations, and Constituents

Gas turbine water wash discharge will contain constituents of the
particular cleaning solvent added to the fresh water, which will vary
according to manufacturer.  The Navy utilizes gas path cleaner which may
include naphthalene and other hydrocarbon compounds.  EPA and DoD found
that naphthalene exceeded the most stringent state water quality
standards.  The constituents of cleaners used by civilian vessels will
vary by manufacturer.  

Rates and concentrations of gas turbine water wash discharge vary
according to the frequency of washdown.  Most Armed Forces vessels have
washdowns at least once every 48 hours of operation and EPA and DoD
estimated that approximately 122 gallons of wash is generated for every
turbine washed.  The gas turbine wash practices for civilian vessels
will likely differ.

Grey Water

The information on grey water was obtained from EPA (1999p) and six
comments on EPA’s ANPRM.

Discharge Summary

Grey water is non-sewage wastewater, including water from showers,
baths, sinks, and laundry facilities.  Vessels may collect and store
grey water discharge for later disposal or may continuously discharge
it.  Grey water discharges occur in any vessel equipped with a kitchen
or a bathroom, which can include a large scope of vessels from
recreational boats to large cruise ships.  Since grey water may contain
fecal coliform, Armed Forces vessels frequently treat it as black water.
 

LMC, WSC, PSPA, and CMC all cited grey water (without further comment)
as a relevant discharge from the vessels they represent.  AWO stated
that the amount of grey water generated and discharged from a towing
vessel varies with respect to crew numbers and habits.  They stated that
grey water from the laundry, shower, and kitchen is released directly
overboard from towing vessels on a daily basis, although the detergents
and cleaners used onboard these vessels are biodegradable and
phosphate-free.

When and Where Discharge Occurs

Most Armed Forces vessels without a holding tank discharge grey water
outside of 3 nmi from shore.  However, grey water can be discharged
while pierside if the vessel is not equipped with an alternative
collection system.  Civilian grey water discharge practices will vary.  

In their comment, CLIA stated that grey water was either discharged
untreated from their vessels while underway or it was treated as part of
an Advanced Wastewater Purification System.  No further description of
this system was provided.  

Discharge Rates, Concentrations, and Constituents

Grey water discharges can contain a variety of constituents, including
bacteria, pathogens, oil and grease, detergent and soap residue, metals
(cadmium, chromium, lead, copper, zinc, silver, nickel, mercury),
solids, and nutrients.  Of these constituents, sampling conducted by EPA
and DoD found that ammonia, copper, lead, mercury, nickel, silver, and
zinc exceeded the most stringent state water quality standards.  The
constituents found in civilian vessel grey water is likely to be
similar.  

The volume of grey water generated by a vessel is dependent on the
number of passengers and crew. It is estimated that 30 – 85 gallons of
grey water is generated per person per day (Copeland, 2007). Vessels
that carry a large number of passengers, such as cruise ships, generate
a large volume of grey water, which can be 90-95% of all the liquid
waste onboard.  Large cruise ships can carry thousands of passengers.
For example, Royal Caribbean’s ship, Vision of the Seas, can carry
3,200 passengers and crew generating an estimated volume of 96,000 to
272,000 gallons of grey water per day (Alaska DEC, 2007). 

According to EPA (1999p), Navy designers use a generation standard of 30
gallons per person per day when constructing grey water collection
systems. A Bluewater Network report (Schmidt, 2000) stated that, on an
average one-week journey, a typical cruise ship with 3,000 passengers
and crew generates an estimated 1,000,000 gallons of grey water. 

The Alaska Cruise Ship Initiative (ASCI) was a federal, state, and local
collaborative effort to identify, characterize, and manage waste streams
from cruise ships plying Alaskan waters.  Sampling of large cruise ships
indicated that the sanitation devices onboard these vessels did not
operate effectively.  While the USCG mandates that the type of
sanitation devices installed on these cruise ships must discharge
effluent of no more than 200 fecal coliforms per 100 mL, sampling
results from 2000 showed that the effluent coming from grey water
discharges had concentrations as high as 32 million fecal coliform per
100 mL.  Surprisingly, the fecal coliform concentration in grey water
was twice as high as that detected in sewage effluent (black water).   

Hull Coating Leachate

The information on hull coating leachate was obtained from EPA (1999q)
and four comments on the EPA’s ANPRM. 

Discharge Summary

The hulls of some vessels may be covered with anticorrosive and
antifouling coatings to prevent rust and marine growth, respectively. 
The antifouling coating is applied over the anticorrosive coating and
the latter should not leach into the receiving water, provided the
antifouling coating is intact.  Only vessels that have had their hulls
coated in antifouling material are included as contributors to this
discharge.  

Comments from WSC and LMC on EPA’s ANPRM cited (without further
comment) hull coating leachate as a relevant discharge from the vessels
they represent.  CLIA also cited hull coating leachate, although they
stated that not every one of their vessels generated this discharge. 
CMC stated that all of the vessels they represent use antifouling
compounds on their hulls. 

When and Where Discharge Occurs

Hull antifouling coatings will continuously leach into receiving waters
whenever the vessel is in water.  

Discharge Rates, Concentrations, and Constituents

Armed Forces vessels use very specific types of antifouling coatings
which may not have the same constituents as the coatings applied to
civilian vessels.  However, most vessels use copper- or zinc-based
antifouling coatings and these metals may leach into receiving waters.  

Although it is no longer found on Armed Forces vessels, some civilian
vessels may have tributyltin (TBT)-based antifouling hull coatings. 
While an effective preventative of invasive species introductions, TBT
is extremely toxic to marine life.  

g/L. 

Recent civilian research (Schiff et al., 2003) on fiberglass hulls with
copper-based coating indicated that passive leaching rates (i.e., when
the vessel was stationary and had not been recently cleaned) of copper
were between 3.7 to 4.3 μg/cm2/day.  If the hull had been cleaned
within one day of sampling, the leaching rates were between 15 and 18
μg/cm2/day, with these rates decreasing with each day removed from the
cleaning activity.  While the copper leaching rate was higher around
cleaning activities, the researchers found that only 4-7% of monthly
copper emissions were attributable to cleaning.  The remaining 93-96% of
monthly emissions were from passive leaching.  These rates were
extrapolated to typical recreational vessels: a 9.1m (~30 foot)
motorboat that is cleaned once a month (using the best management
practices described in Section 6.20) contributes from 22 to 26 grams of
dissolved copper per month to the surrounding waters.

Motor Gasoline Compensating Discharge

The information on motor gasoline compensating discharge was obtained
from EPA (1999r).

Discharge Summary

Motor gasoline (MOGAS) is gasoline used as fuel, identical to that which
is put into automobiles.  Some vessels may transport MOGAS-powered
vehicles, equipment, or machinery which may be brought onboard fully
loaded with MOGAS.  MOGAS may also be transported in drums or other
containers or stored in the vessel’s permanent ambient water
compensating tanks, if present.  When a vessel with built-in MOGAS tanks
gets overhauled, it must empty its tanks to pierside trucks, transit 50
nmi offshore and perform three tank exchanges of ambient water before
filling up the tanks completely for the transit back to shore.  When the
MOGAS is reloaded to the vessel, the ambient water that was in the tanks
is discharged.

It is notable that none of the commentors that listed the relevant
discharges for their vessel types cited MOGAS.

When and Where Discharge Occurs

Armed Forces vessels with MOGAS tanks are overhauled prior to
redeployment, which occurs about once annually.  Civilian vessels with
MOGAS tanks may have a different timetable.  The compensating ambient
water is discharged directly overboard as the vessel’s tanks are
refilled pierside.

Discharge Rates, Concentrations, and Constituents

The discharged ambient water may contain traces of gasoline
constituents, which vary depending on the specific manufacturer. 
Generally, gasoline will contain alkanes, alkenes, aromatics, metals,
and additives.  A 1992 study cited in EPA (1999r) detected a variety of
compounds in gasoline, including benzene, toluene, ethylbenzene, phenol,
and naphthalene.  

MOGAS compensating ambient water is discharged at the same rate at which
the fuel trucks refill the tanks.  EPA (1999r) estimated this rate at 50
gpm or less, although the actual rate for civilian vessels will vary
according to vessel and fuel supplier.

The concentration of MOGAS constituents will also vary according to
manufacturer, although EPA (1999r) estimated the concentrations of
various constituents in MOGAS compensating discharge.  Based on the most
stringent state standards, benzene, toluene, ethylbenzene, phenol, and
naphthalene exceeded water quality criteria.  

Non-Oily Machinery Wastewater

The information on non-oily machinery wastewater was obtained from EPA
(1999s) and four comments on EPA’s ANPRM.

Discharge Summary

Non-oily machinery wastewater systems are meant to separate
machine-generated wastewater that must go to the bilge compartment
(i.e., that has an oil content) from the wastewater that can be
collected in tanks before being discharged directly overboard (i.e.,
that has no oil content).  Vessels can have numerous sources of non-oily
machinery wastewater, including (among others) distilling plants
start-up discharge, chilled water condensate drains, fresh and saltwater
pump drains, potable water tank overflows, and leaks from propulsion
shaft seals.  However, the major source is desalination distillation
plant discharge which occurs after the start-up of the distillation
system and before the desired level of salinity has been achieved, when
the discharge ends.  

Comments from WSC, LMC, and CMC on EPA’s ANPRM cited (without further
comment) non-oily machinery wastewater as a relevant discharge from the
vessels they represent.  CLIA also cited scrubber wash water (i.e.,
seawater used to rinse scrubbers) as a discharge which falls into the
non-oily machinery wastewater category, but that only one of their
vessels generated this discharge.  They also stated that the scrubber
wash water was discharged directly overboard after scrubbing operations.
 

When and Where Discharge Occurs

Non-oily machinery wastewater discharge can occur continuously for
machinery located above deck.  Wastewater from machinery located below
deck must be held in tanks and is pumped overboard intermittently. 
Since there is no oil present, the wastewater may be discharged
anywhere.

CLIA stated that their scrubber wash water was discharged within 12 nmi
of land.

Discharge Rates, Concentrations, and Constituents

Constituents of non-oily machinery wastewater discharge include a suite
of classical pollutants, metals, and organics.  Many of the specific
constituents examined in EPA (1999s) exceeded the water quality
standards of the most stringent U.S. state, including copper, nickel,
silver, zinc and a collection of nutrients.  Mercury was also detected,
but concentrations did not exceed the most stringent water quality
standards.

Non-oily machinery wastewater discharge flow rates vary by vessel size
and operation type.  EPA (1999s) estimated discharge rates from
distillation plant start-up to range from 100 gallons per hour (gph) to
over 4,000 gph, depending on the size of the plant.  These rates are not
entirely applicable to the vessels that will be covered under the
vacatur, but the rate variability is instructive.  EPA (1999s) did not
provide rates or concentrations for overall non-oily machinery
wastewater discharge. 

Photographic Laboratory Drains 

The information on photographic laboratory drains was obtained from EPA
(1999t).

Discharge Summary

When a vessel has the capability to develop photographs onboard, there
is accumulated waste associated with the developing process.  Given the
recent move toward digital photography, however, it is expected that
many civilian vessels that once had the ability to process photographs
will now do so digitally and, therefore, without waste.  In the case
that a vessel will retain its ability to manually process photographs,
the amount of accumulated waste is expected to be small enough to be
held onboard for onshore disposal.

It is notable that none of the commentors that listed the relevant
discharges for their vessel types cited photographic laboratory drain
discharge.

When and Where Discharge Occurs

Navy guidance prohibits the discharge of photographic laboratory drains
within 12 nmi from of shore and mandates the containerization of all
discharge for onshore disposal.  Despite the allowance of such disposal
beyond the 12 nmi limit, most vessels containerize all photographic
laboratory drain contents for onshore disposal.  If the drains are
discharged further than 12 nmi from land, additional treatments must be
employed.  Fixer solution must pass through a silver recovery unit prior
to overboard discharge and black-and-white and x-ray effluent must pass
through the ship’s blackwater collection, holding, and transfer
system. Civilian vessels may have different policies for this discharge.
 

Discharge Rates, Concentrations, and Constituents

Photographic laboratory drains may contain constituents found in
developing solutions, fixers, and rinse water (e.g., silver).  EPA
(1999t) provides an extensive table listing some of the potential
constituents of commonly used photographic laboratory solutions.  

Refrigeration/Air Conditioning Condensate Discharge

The information on refrigeration/air conditioning condensate was
obtained from EPA (1999u) and five comments on EPA’s ANPRM.

Discharge Summary

Condensation forms when warm air comes into contact with the cold
refrigeration or evaporator coils of an air conditioning system or
refrigeration unit on a vessel.  The condensation drips from the coils
and collects in drip troughs which typically channel to a drainage
system.  On Armed Forces vessels, condensate that is collected above the
vessel’s waterline is immediately discharged overboard while
condensate collected below the waterline is held onboard for a period of
time before being discharged overboard.  Some vessels may channel
condensate in the drain to other areas, such as the bilge tank or the
sewage system tanks, for temporary holding until those tanks can be
disposed of onshore or discharged overboard according to the relevant
regulations.  Refrigeration and air conditioning systems on Armed Forces
vessels typically have coils constructed of copper. 

In the ANPRM comments, PSPA, CMC, WSC, CLIA, and AWO all cited
refrigeration/air conditioning condensate as discharges that were
relevant to their particular types of civilian vessels.  AWO stated in
their comments that all their towing vessels are equipped with
continuously running refrigeration units and air conditioners which
drain very small amounts of condensation directly overboard. 

When and Where Discharge Occurs

Refrigeration/air conditioning condensate can be discharged wherever and
whenever these systems are in operation.

Discharge Rates, Concentrations, and Constituents

This discharge may contain metals from the refrigeration/air
conditioning coils and drainage systems, including aluminum, bronze,
copper, iron, lead, nickel, silver, tin, and zinc.  Traces of mild
detergent may also be found in this discharge from the cleaning of
refrigerated spaces, as can seawater (used to defrost some cargo spaces)
and freshwater (used to flush residual seawater from these cargo
spaces). 

Rudder Bearing Lubrication Discharge

The information on rudder bearing lubrication was obtained from EPA
(1999v) and three comments on EPA’s ANPRM. 

	Discharge Summary	

Rudder bearings allow a vessel’s rudder to turn freely and, on Armed
Forces vessels, rudder bearings can be either grease-, oil-, or
water-lubricated.  Grease-lubricated rudder bearings on Armed Forces
vessels discharge grease directly to the bilge tank while oil-lubricated
bearings are kept at a slightly positive pressure in relation to the
outside ambient water pressure and will only discharge into the
surrounding water if a leak occurs around the rudder mechanism.  Many
vessels install hull seals where the rudder penetrated the hull to
prevent the type of leaks that could lead to oil discharges. 

Three commentors to the EPA’s ANPRM cited rudder bearing lubrication
discharge as relevant to their types of civilian vessels: CMC, WSC, and
AWO.

When and Where Discharge Occurs

This discharge occurs primarily when the vessel is underway and the
rudder is in use; turning the rudder can cause gaps in the hull seal. 
These gaps can become larger if the rudder is turned sharply or the
vessel is moving at a high rate of speed.  If oil-lubricated rudder
bearings are present, leakage may occur at any time (even when the
vessel is stationery) because the lubricant is slightly pressurized.

Discharge Rates, Concentrations, and Constituents

Depending on the type of rudder bearings in use, this discharge can
cause oil or grease to be released into the water column.  With a
malfunctioning or failing seal, Armed Forces vessels can leak one gallon
of oil per day while at sea or one pint per day while in port.  This
amount of oil does not exceed federal oil sheen standards or the most
stringent state water quality criteria.

Seawater Cooling Overboard Discharge

The information on seawater cooling overboard discharge was obtained
from EPA (1999w) and six comments on EPA’s ANPRM.

Discharge Summary

Seawater cooling systems onboard vessels use ambient water pumped in
directly or through the firemain to absorb the heat from the propulsion
system and auxiliary heat exchangers.  This water is then discharged
back overboard.  Cooling water demand is continuous, particularly for
larger vessels, and seawater spends approximately one minute in the
cooling system before being discharged.  Some vessels add seawater
piping biofouling prevention chemicals to the cooling water to keep
marine organisms from becoming established and clogging the system. 
Strainer plates are used to prevent clogging from larger material; the
strainer plates must occasionally be cleared using low-pressure air or
steam.  Anything that had been caught on these plates would also be
considered a discharge. 

In their comments on EPA’s ANPRM, LMC, WSC and CMC all cited seawater
cooling overboard discharge as relevant discharges from the vessels they
represent. PSPA’s comments also listed cooling activities as producing
discharge, but, along with engine cooling water, they also listed
(without further comment) hydraulic system cooling water, refrigeration
cooling water, and processing factory cooling water as relevant
discharges. CLIA also cited engine cooling water as a relevant discharge
that originates from all the vessels they represent and that this
discharge occurs continuously.  AWO stated that their towing vessels
produced this discharge on a continuous basis.

When and Where Discharge Occurs

Seawater cooling systems are used both while vessels are pierside and
while they are underway.  

Discharge Rates, Concentrations, and Constituents

The potential constituents of seawater cooling overboard discharge
include entrained or dissolved materials from the system itself. 
Although the specific constituents will vary depending on the vessel and
the type of cooling system, EPA (1999w) identified copper, iron,
aluminum, zinc, nickel, tin, titanium, arsenic, manganese, chromium,
lead, and oil and grease as possible contents of the discharge.  Mud,
biota, and other debris that were stuck to the strainer plates may also
be discharged.  The seawater is also being discharged at a higher
temperature than when it was taken up and constitutes a thermal
discharge into the receiving water.  EPA (1999w) estimates that the
thermal difference between seawater intake and discharge can range from
5 to 25°C, with a maximum discharge temperature of 140°C.  

Seawater cooling discharge flow rates vary by vessel size and operation
type.  EPA (1999w) estimated rates ranging from 1,500 gpm for a pierside
destroyer to over 170,000 gpm for an in-transit aircraft carrier.  These
rates are not entirely applicable to the vessels that will be covered
under the vacatur, but the rate variability is instructive.  Constituent
concentrations will also be variable, depending on the residence time,
the quality of the intake water, and the erosion and corrosion of
cooling system components.  However, EPA studies indicated that copper,
nickel, and silver concentrations exceeded the most stringent state
water quality standards.  

Seawater Piping Biofouling Prevention

The information on seawater piping biofouling prevention was obtained
from EPA (1999x) and three comments on EPA’s ANPRM.

Discharge Summary

Seawater cooling systems onboard vessels use ambient water pumped in
directly or through the firemain to absorb the heat from the propulsion
system and auxiliary heat exchangers.  This water is then discharged
back overboard.  To prevent biofouling of the cooling system, low
amounts of chlorinating substances are sometimes injected near the
seawater intakes to kill any organisms that may have been sucked in.   

In their comments on EPA’s ANPRM, WSC cited (without further comment)
seawater piping biofouling discharge as relevant to the vessels they
represent.  CLIA also cites this type of discharge, although they stated
that only 13 of the vessels they represent are so equipped. Finally, CMC
stated that most commercial vessels are equipped with seawater piping
biofouling systems.

When and Where Discharge Occurs

Discharge will occur wherever and whenever a vessel equipped with
biofouling prevention equipment is underway.

Discharge Rates, Concentrations, and Constituents

Seawater that has been discharged after being treated with chlorinating
substances will contain free chlorine and reaction products
(collectively called ‘chlorine-produced oxidants).  These reaction
products include chloride ions, chloramines, free bromine, and
chloroorganics.  EPA (1999x) provided estimates of discharge rates and
concentrations for specific classes of Armed Forces vessels, but these
estimates are not reproduced here.

Small Boat Engine Wet Exhaust

The information on small boat engine wet exhaust was obtained from EPA
(1999y) and five comments on EPA’s ANPRM.

Discharge Summary

Smaller vessels take in ambient water to cool their engines and then
discharge it back into the receiving waters.  The water passes through
the engine and some components of the exhaust transfer to the water
before it is discharged as ‘wet exhaust’.  Both inboard and outboard
engines have this type of cooling system, although inboard engines
discharge their wet exhaust above the water line while outboard engines
discharge underwater.  Inboard engines are usually powered by diesel
while outboard engines run on gasoline.

In their comments on EPA’s ANPRM, WSC, LMC, and AWO listed (without
further comment) small engine wet exhaust as a relevant discharge from
the vessels they represent.  CLIA stated that the boat tenders that
accompany their cruise ships generate this discharge, although only when
in port which can be three to five days a week.  

When and Where Discharge Occurs

This discharge can occur anywhere and will occur anytime an inboard or
outboard engine is operating.

Discharge Rates, Concentrations, and Constituents

Research by EPA and DoD found that the constituents discharged by
outboard engines differ from those discharged by inboard engines, due to
the different fuel types.  For outboard engines, a handful of
constituents were estimated to exceed the most stringent state water
quality standards: benzene, toluene, ethylbenzene, and naphthalene. 
Inboard engines are expected to exceed standards for polycyclic aromatic
hydrocarbons (PAHs), including acenaphthylene, phenanthrene, chrysene,
benzo(a)pyrene, benzo(a)anthracene, benzo(b)fluoranthene,
benzo(k)fluoranthene, and others.  Additionally, wet exhaust can contain
nitrogen oxides, hydrocarbons and other organic compounds, carbon
monoxide, and particulates.  

EPA (1999y) estimates that outboard engines discharge wet exhaust at a
rate of 20 gpm while inboard diesel engines have an estimated discharge
rate of 150 gpm

Sonar Dome Discharge

The information on sonar dome discharge was obtained from EPA (1999z).

Discharge Summary

Sonar domes are attached to a vessel’s hull and protect the equipment
used for navigation and detection.  To equalize pressure within the
sonar dome, freshwater is added to the inside and any water that is lost
is replenished using ambient water from the firemain system. 
Maintenance on the sonar dome, while typically (but not always) done
while a vessel is in dry dock, can involve the release of the inner
sonar dome water.  In addition, the components of the outside of the
sonar dome can leach into the surrounding waters.

It is notable that none of the commentors that listed the relevant
discharges for their vessel types cited sonar dome discharge.

When and Where Discharge Occurs

Discharges from the exterior of the sonar dome occur continuously as
long as the vessel is in water.  Repairs and maintenance to the interior
of the sonar dome (which necessitates the release of the water on the
inside) only occurs (if at all) while the vessel is pierside.  

Discharge Rates, Concentrations, and Constituents

On Armed Forces vessels, the components that make up the outside of
sonar domes can include TBT, plastic, steel, rubber, and antifouling
coatings.  Along with these materials, tin, zinc, copper, nickel, and
epoxy paints may be found on the inside of sonar domes.  Studies
conducted by EPA and DoD indicated that, of these constituents, TBT,
copper, nickel, and zinc exceeded the most stringent state water quality
standards.  Although the firemain system was occasionally used to
replenish lost water from inside the sonar dome, EPA and DoD found that
the constituents found in firemain water negligibly contributed to the
discharge.

The rates of discharge will depend on the size of the sonar dome as well
as the frequency of which repair or maintenance is required.  For Armed
Forces vessels, EPA and DoD estimated that as little as 300 gallons and
as much as 74,000 gallons would be discharged from inside the sonar dome
with every repair event.  This amount will vary for civilian vessels.  

Steam Condensate

The information on steam condensate discharge was obtained from EPA
(1999aa) and from one comment on EPA’s ANPRM.

Discharge Summary

When in port, some Armed Forces vessels utilize shore-based steam
resources to power auxiliary systems (such as laundry or heat).  As the
steam is pumped from boilers on land through the vessels’ steam lines
and to the equipment that requires it, it cools and condenses into
water.  This condensed water collects in insulated tanks before being
pumped overboard.  This discharge only occurs when Armed Forces vessels
are using shore-based steam; condensed water from steam created on ship
is recycled as boiler feedwater.  The UNDS reports refer to the shore
steam capabilities of naval facilities, but it is unclear following a
brief internet search whether shore steam systems are widely available
at civilian ports.  

In response to EPA’s ANPRM, WSC cited (without further comment) steam
condensate as a relevant discharge to the vessels they represent.

When and Where Discharge Occurs

Steam condensate is only discharged when an Armed Forces vessel is in
port and using shore steam resources.  If steam condensate is a relevant
discharge for civilian vessels, the same would be true.

Discharge Rates, Concentrations, and Constituents

Steam condensate is primarily water that contains material from the
piping and heat exchangers.  Depending on the construction of the
vessel, these materials may include metals, organics (e.g.,
4-chloro-3-methylphenol, benzidine, bis(2-ethylhexyl)phthalate), oil and
grease, and volatile residue, among oher classical pollutants.  The
steam condensate may also be discharged at a higher temperature than the
surrounding water column.  Based on modeling activities, EPA and DoD
determined that steam condensate may exceed Washington State’s thermal
water quality criteria, but the exceedance would be brief.  When
discharged, the thermal plume would be narrow and shallow and any
disturbance of the water would cause enough mixing to dissipate the
plume.  

Based on steam condensate discharge sampling, a handful of constituents
exceeded the most stringent state or federal water quality standards. 
Copper exceeded both state and federal standards, while nickel, ammonia,
benzidine, and bis(2-ethylhexyl)phthalate) exceeded the most stringent
state standards.

Stern Tube Seals and Underwater Bearing Lubrication

The information on stern tube seals and underwater bearing lubrication
was obtained from EPA (1999bb) and from three comments on EPA’s ANPRM.

Discharge Summary

On Armed Forces vessels, stern tube seals and bearings are associated
with the propeller shaft; the former prevents water from entering the
vessel and the latter support the weight of the propeller shaft.
Depending on the type of vessel, seawater, freshwater, or oil provides
the lubrication for the bearings and seals.  Seawater lubrication is
delivered via the firemain or the auxiliary seawater cooling main while
freshwater comes from the port water supply, although only rarely is
freshwater used as a bearing and seal lubricant.  

In response to EPA’s ANPRM, WSC, CMC, and CLIA all cited stern tube
seals and underwater bearing lubrication as a relevant discharge for the
vessels they represent.  CMC stated that almost all vessels have stern
tube seals and bearings that require lubrication.

When and Where Discharge Occurs

This discharge is continuous because the stern tube seals and bearings
require constant lubrication.

Discharge Rates, Concentrations, and Constituents

Given that the seawater from the firemain is only very briefly in
contact with the bearings and seals, the majority of the constituents
will be those contained in the firemain or auxiliary seawater cooling
main water and piping systems.  Seawater used for lubrication may
contain bis(2-ethylhexyl) phthalate, copper, nickel, and iron.  If the
shaft is turning, rubber may be contained in the discharge.  Discharge
from freshwater lubrication may contain chlorine as a disinfectant for
the port facility water system.

Discharge sampling indicated that bis(2-ethylhexyl) phthalate, copper,
nickel, and iron exceeded the most stringent state water quality
criteria.  

Submarine Bilge Water

The information on submarine bilgewater was obtained from EPA (1999cc).

Discharge Summary

Similar to the bilge water that collects in surface vessels, submarine
bilge water is a combination of water, effluent, and other materials
that drain from various areas of the vessel to the lowest compartment. 
In Armed Forces submarines, the bilge area consists of a non-oily
collection tank, an oily bilge tank, and a waste oil collection area. 
Non-oily waste is sent via a segregated piping system to the non-oily
bilge tank, where it is discharged directly overboard.  In some Armed
Forces submarine, bilge water that has oil or potentially has oil in it
is sent through a gravity separation system, where the water is settled
out of the oily mixture and discharged overboard.  The remaining oily
substance is sent to the waste oil collection area where it is held for
onshore disposal.  

When and Where Discharge Occurs

The times and places submarine bilge water is discharged depends on
vessel operations, distance from shore, and depth.  Generally, most
Armed Forces submarines discharge all non-oily bilge water outside of 12
nmi of land or hold all bilge water (oily and non-oily) for onshore
disposal.

Discharge Rates, Concentrations, and Constituents

Pearl Harbor Naval Station estimates that 2,000-3,000 gallons of bilge
water are generated per day while an Armed Forces submarine is pierside.
 One class of submarine is estimated to dispose of 31,500 gallons on
shore, zero gallons within 12 nmi of land, and 300,000 gallons outside
of 12 nm, while another class disposes of 54,000 gallons onshore, 80,540
gallons within 12 nmi of land, and 400,200 gallons outside of 12 nm.  

Submarine bilge water effluent sampling has detected oil and grease,
copper, cadmium, lead, nickel, iron, zinc, mercury, lithium bromide,
citric acid, chlorine, phenol, cyanide, sodium bisulfite, and the
pesticides heptachlor and heptachlor epoxide. High total suspended
solids (TSS) and chemical oxygen demand (COD) may also be present.  The
measured levels of oil and grease, copper, nickel, silver, and zinc
exceeded both the federal and state water quality standards, while
mercury, heptachlor, heptachlor epoxide	, chlorine, and cadmium exceeded
the most stringent state standards, but not the federal.

Surface Vessel Bilge Water/Oil-Water Separator (OWS) Discharge

The information on surface vessel bilge water/oil-water separator
discharge was obtained from EPA (1999dd) and from four comments on
EPA’s ANPRM.

Discharge Summary

The bilge is a compartment in a vessel’s hull where water and other
residue originating from the decks and interior of the vessel
accumulate.  According to EPA (1999dd), most of the bilge contents (or
bilge water) in Armed Forces vessels come from vessel machinery and
engine room drainage.    

Comments on EPA’s ANPRM from WSC cited (without further comment)
discharge from the onboard oily water separator as relevant to the
vessels they represent.  CLIA stated that their bilge water is
discharged (after being treated by an OWS) typically several times per
week and that all their vessels have this discharge.  AWO stated that
their towing vessels are equipped with a segregated bilge system, which
keeps oily bilge liquids (e.g., from the vessels’ machinery spaces)
separate from any oil-free water that may accumulate in the bilge areas
surrounding the propeller shafts.  Their oily bilge liquids are stored
and disposed of onshore at the appropriate facility.  

When and Where Discharge Occurs

Armed Forces vessels are not permitted to discharge bilge water unless
it has been treated with an OWS and only then if the oil content of the
bilge water is less than 15 mg/l prior to discharge.  If an OWS is used
and the oil content is below the limit, than bilge water may be
discharged anywhere and anytime.  

Discharge Rates, Concentrations, and Constituents

Several studies on the bilge water content have been conducted on Armed
Forces vessels.  The constituents that were detected included oil,
grease, volatile and semi-volatile organic compounds, inorganic salts,
and metals.  Additionally, on some vessels, effluent from the chain
locker drains into the bilge as do elevator pit effluent and discharge
from the gas turbine water wash.  Schmidt (2000) stated that, on a one
week journey, an average cruise ship with 3,000 passengers and crew can
generate 25,000 gallons of oily bilge water. 

Underwater Ship Husbandry

The information on underwater ship husbandry was obtained from EPA
(1999ee) and from three comments on EPA’s ANPRM.

Discharge Summary

Many vessels are too large to be regularly removed from the water and
any repair or maintenance required on the hull or hull appendages must
occur while the vessel is pierside.  Specifically, EPA (1999ee) defines
underwater ship husbandry to include hull cleaning, fiberglass repair,
welding, sonar dome repair, tests/inspections, masker belt repairs, and
paint operations, as well as other activities that are specific to Armed
Forces vessels only.  All of these husbandry activities are also
conducted on civilian vessels, although the size and type of vessel will
dictate the extent of the maintenance.  In addition, most recreational
and other smaller vessels are removed from the water during husbandry
operations; therefore, underwater ship husbandry discharges may not be
applicable to them.  

In their comments on EPA’s ANPRM, the WSC and CMC both cited (without
further comment) underwater ship husbandry as a relevant discharge from
the vessels they represent.   CLIA stated that hull and propeller
cleaning on all their vessels is conducted annually via remote operated
vehicles or by divers using scrubbers or pressure washers.  They also
state that this cleaning is only done while in port or at anchor.

When and Where Discharge Occurs

Most underwater husbandry is done while the vessel is at port.  The
frequency with which the maintenance and repair activities occur is
dependent on the type of vessel and the nature of the maintenance.  EPA
(1999ee) estimates that Armed Forces vessels receive about one full hull
cleaning annually, with more frequent cleanings of hull appendages
(e.g., propellers).  Fiberglass repair and welding operations on Navy
vessels each occur about twelve times per year fleetwide.

The frequency with which a vessel’s hull needs to be cleaned depends
on a variety of factors, including water temperature, water chemistry
characteristics (i.e., nutrient concentrations), and frequency of use. 
A demonstration project by California Sea Grant (Johnson and Gonzalez,
2006) in San Diego Bay tested the efficacy and other characteristics of
three different types of anti-fouling hull coatings (epoxy,
ceramic-epoxy, and silicone-rubber), including during hull cleaning
activities.  Boats participating in this project included three
powerboats between 28 and 42 feet and three sailboats between 21 and 46
feet in length, representing a range of typical recreational vessels. 
The researchers stated that recreational boats are typically cleaned on
a schedule set by the owners with input from their hull cleaning
companies.  The project boats with epoxy or ceramic-epoxy coatings were
cleaned approximately every 15-18 days, while the vessels with
silicone-rubber coatings were cleaned more frequently: every 7-12 days. 


Another study commissioned by California Sea Grant along with the
California Department of Boating and Waterways (Carson et al., 2002)
evaluated the possible policy options for reducing the use of
copper-based hull anti-fouling paint on recreational boats in San Diego
Bay.  One of the factors they examined was hull cleaning frequency. 
Generally, they found that recreational vessel hulls that were treated
with coatings that were not copper-based (‘alternative paints’)
required more frequent cleaning: from once a week to once every three
weeks.  

Discharge Rates, Concentrations, and Constituents

The constituents discharged due to underwater ship husbandry differ
depending on the specific activity.  For example, hull cleaning may
discharge copper and zinc from the antifouling paint.  Fiberglass,
resins, and hardeners may enter the water during fiberglass repair,
although the specific ingredients in the resins and hardeners will vary
by manufacturer.  Welding activity may introduce metals, including
chromium, iron, nickel, manganese, and beryllium while the repair of the
sonar dome and masker belts may discharge rubber and sealant (the
contents of which will vary by manufacturer).  The constituents of the
particular paint used may also enter the water column.   

Additionally, invasive species that have attached to the vessel’s hull
may be a constituent of the discharge.  Some states have begun to
document the transport mechanisms of the marine invasive species found
in their waters.  Hawaii, for example, recently estimated that about 73%
of the marine invasive species observed in Hawaiian waters were
transported via vessel hulls and 90% of those have become established. 
A recent study also found that 72% of organisms that have been cleaned
off a vessel hull remain viable.   

The variability of maintenance and repair activities, as well as the
variety of vessel sizes and types, makes estimating discharge rates and
concentrations difficult. During each fiberglass repair, approximately
one quart of resin is discharged.  Welding operations each emit
approximately five pounds of metal slag.  Discharges from the other
activities will vary. 	

Welldeck Discharges

The information on welldeck discharges was obtained from EPA (1999ff).

Discharge Summary

A welldeck is typically located at the stern of a large vessel and is a
floodable platform used for launching or loading smaller, satellite
vessels or vehicles as well as to facilitate cargo loading operations. 
The floors of an Armed Forces welldeck are lined with pressure-treated
lumber.  Residues and materials that accumulate on the welldeck can be
discharged via green water washover or the intentional washdown of
vessels or vehicles stored on the welldeck.  The U.S. Department of
Agriculture (USDA) requires that any vessel or vehicle that comes into
contact with foreign soil must be washed down to remove any invasive
species.  These washdowns typically occur on the welldeck while still in
the foreign port, once the vessel has been brought on board the ship or
the vehicle has been loaded.

It is notable that none of the commentors that listed the relevant
discharges for their vessel types cited sonar dome discharge.

When and Where Discharge Occurs

Welldeck discharges can occur at anytime or anyplace.  

Discharge Rates, Concentrations, and Constituents

On Armed Forces vessels, the potential constituents of welldeck
discharges include fresh water, distilled water, firemain water, grey
water, air-conditioning condensate, sea-salt residues, paint chips, wood
splinters, dirt, sand, organic debris and marine organisms, oil, grease,
fuel, detergents, combustion by-products, and lumber treatment
chemicals.  Discharges from civilian vessels will vary depending on the
vessel type and the activity in which the vessel is engaged.  

Pollution Control Technologies and Best Management Practices

The following sections describe PCTs or BMPs available to either lessen
the volume or environmental impact of vessel discharges. Many of the
discharges do not have PCTs because they have never been regulated;
therefore, for some of the discharges listed below, information is
limited.  A handful of the discharges did not have either PCTs or BMPs
and these will not be discussed further in this section: boiler
blowdown, cathodic protection, non-oily machinery wastewater,
refrigeration/air conditioning condensate, rudder bearing lubrication,
steam condensate, stern tube seals and underwater bearing lubrication,
submarine bilgewater, and welldeck discharges.  Focus is put on the
discharges with the most available information.

Aqueous Film Forming Foam

Battelle did not identify any specific PCTs or BMPs for AFFF discharge. 
However, a variety of manufacturers exist (e.g., Kidde, OmniQual,
Amerex) and some foam formulas may have fewer pollutants than others.  

As stated in Section 5.1.1, one Armed Forces BMP for AFFF discharge is
that maintenance discharges may only occur farther than 12 nmi from
shore.  However, inspection and certification discharges have no
distance limit for Armed Forces vessels.  

Chain Locker Effluent

Battelle did not identify any specific PCTs for chain locker effluent
discharge.  

One Navy BMP for chain locker effluent discharge is that chain lockers
may only be washed down beyond 12 nmi from shore.  Civilian vessels may
have different self-imposed restrictions for chain locker effluent
discharge.  A comment in response to EPA’s ANPRM from CLIA provides
two additional BMPs for this discharge.  The anchor chain should be
carefully and thoroughly washed down (i.e., more than a cursory rinse)
as it is being hauled out of the water to remove sediment and marine
organisms.  In addition, chain lockers should be cleaned thoroughly
during dry docks to eliminate accumulated sediments and any potential
accompanying pollutants (EPA, 2003a).

Australia’s Department of Agriculture, Fisheries, and Forestry
commissioned a research study (Taylor and Rigby, 2002) to study vessel
invasive species prevention management practices and some of the
suggested methods pertained to chain lockers (as described in Section
5.1.4, the chain locker has the potential to harbor invasive species).
The suggestions provided in this report included the following:

Chain lockers should include a grate at the bottom, raised about 0.5
meters above the bottom of the locker, with manhole access for cleaning
the space.

Extra washing nozzles should be installed to more efficiently and
completely clean the space.

Prior to entering nearshore waters (preferably in deep ocean), the space
beneath the chain locker should be inspected, cleaned, and pumped out.

Prior to entering nearshore waters, anchor cables should be reinspected
and, upon any sign of sediment or organisms, they should be rewashed.

Chain lockers should be regularly maintained, and painted to prevent
corrosion and rust formation which can trap sediment and organisms.

Clean Ballast

Ballast water PCTs generally fall under one of two main types of process
technologies: solid-liquid separation and disinfection (Lloyds Register,
2007).  Figure 6-1 illustrates these processes. 

Solid-liquid separation involves the separation of suspended solid
material, including larger suspended micro-organisms, from the ballast
water either by sedimentation (allowing the solids to settle out by
weight), or by surface filtration (the pores in the filtering material
being smaller than the size of the particle or organism).

Disinfection removes and/or inactivates organisms using one or more of
the following methods:

Chemical inactivation of the organism

Physicochemical inactivation by irradiation with ultraviolet light (UV),
which prevents an organism from reproducing. Ultrasound or cavitation
(or “microagitation”) are also physicochemical disinfection methods.

Deoxygenation either by displacement of the DO with an inert gas
injection or stripping it by means of a vacuum, asphyxiating organisms.

Most commercial systems comprise two stages of treatment with a
solid-liquid separation stage being followed by disinfection, though
some disinfection technologies are used in isolation. One ballast water
treatment technology also employs chemical enhancement (i.e.,
coagulation/flocculation) prior to solid-liquid separation; another uses
titanium dioxide to intensify UV irradiation. Some of the manufacturers
of ballast water treatment technologies as well as the corresponding
technologies utilized, capital costs, and operational costs are listed
below (Table 6-1).

Figure   STYLEREF 1 \s  6 -  SEQ Figure \* ARABIC \s 1  1 . Types of
Processes Utilized by Ballast Water Treatment Technologies.

Adapted from: Lloyd’s Register, 2007

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  1 .
Characteristics of Example Ballast Water Treatment Systems

Manufacturer	Technology	Capacity (GPM)	Capital Cost ($’,000)	O&M Cost
($/264,172 gal)



	880 GPM	8,806 GPM

	Ecochlor, Inc.	Chlorine dioxide 	>44,029	260	400	60

Electrichlor, Inc.	Filtration + electrolysis/

electrochlorination	>44,029	350	NA	NA

Environmental Technologies, Inc.	Filtration + ultrasound	>44,029	NA	500
5

Greenship	Hydrocyclone + electrolysis/

electrochlorination	>44,029	300	2300	NA

Marenco

Technology Group	Filtration + UV	4,403	135	NA	100

MH Systems, Inc.	Deoxygenation	>44,029	650	950	55

NEI Treatment Systems, Inc.	Deoxygenation + cavitation	>44,029	150	250
50

Nutech 03	Ozonation	>44,029	350	800	320

Table 6–1. Characteristics of Example Ballast Water Treatment
Systems, continued

Manufacturer	Technology	Capacity (GPM)	Capital Cost ($’,000)	O&M Cost
($/264,172 gal)



	880 GPM	8,806 GPM

	Optimarin AS	Filtration + UV	>44,029	500	NA	NA

Resource Ballast Technology	Filtration + electrolysis/

Electrochlorination + cavitation	>44,029	150	250	NA

Severn Trent De Nora	Filtration + electrolysis/

Electrochlorination + reduction	>44,029	350	500	20

Techcross	Electrolysis/

Electrochlorination	>44,029	150	NA	10

Adapted from: Lloyd’s Register, 2007

In the United States, the USCG has requirements for the treatment and
management of ballast water. First, any vessel, including tugs and
barges, equipped with ballast water tanks must file a report with the
USCG 24 hours prior to arrival at a United States port (including inland
ports) (33 CFR. §151.2041). Second, all vessels equipped with ballast
water tanks must have a vessel-specific ballast water management (BWM)
plan (33 CFR. §151.2305(7)).  Lastly, all vessels equipped with ballast
water tanks entering U.S. waters after operating beyond the EEZ must
perform one of the following BMPs (33 CFR 151.2035(b)): 

Open Ocean Exchange: a vessel empties all of its ballast water in the
open ocean.  The vessel then refills its tanks (and often empties and
refills multiple times as a precaution) and proceeds to its destination
ports.  Although organisms may be present in the ballast water, the vast
majority of them will be pelagic and unlikely to survive or thrive in
nearshore environments.  

Retain ballast water on board while the vessel is in U.S. waters: this
virtually eliminates the chance for introduction of invasive species via
ballast water.  All vessels operating in U.S. waters with ballast water
that was taken up within 200 nmi of any coast after operating beyond the
U.S. EEZ must perform either one of the above BMPs, or 

Use an alternative environmentally sound method of ballast water
management that has been approved by the Coast Guard.  

Other BWM practices are mandated under 33 CFR 151.2035(a) and apply to
all vessels with ballast tanks operating on U.S. waters regardless of
whether the vessel left the U.S. EEZ.  These mandatory BMPs include:

Avoiding ballast operations in or near marine sanctuaries, preserves,
parks, or coral reefs

Avoiding ballast water intake:

Where infestation, harmful organisms, and pathogens are located

Near sewage outfalls

Near dredging operations

Where tidal flushing is poor or where a tidal stream is known to be
turbid

In darkness when organisms may rise up in the water column

In shallow water or where propellers may stir up the sediment

In areas with whale pods, convergence zones, and boundaries of major
currents

Cleaning ballast tanks regularly to remove sediment 

Only discharging minimal amounts of ballast water in coastal and
internal waters

Rinsing anchors and anchor chains during retrieval to remove organisms
and sediments at their place of origin

Removing fouling organisms from piping, hull, and tanks on a regular
basis and disposing of any removed substances in accordance with
regulations

Maintaining a vessel-specific ballast water management plan

Training crew in ballast water and sediment management and treatment
procedures.

In addition, USCG has accelerated its efforts to evaluate and approve
prototype and experimental shipboard installations of ballast water
management equipment on vessels, implementing the Shipboard Technology
Evaluation Program in 2004. USCG is also collaborating closely with EPA
in the quantitative evaluation of specific ballast water treatment
systems. The Environmental Technology Verification Program seeks to
accelerate the development of environmental technologies based on
rigorous and credible performance tests conducted according to
standardized protocols. These policy and regulatory efforts continue.

In the international arena, the International Maritime Organization
(IMO) developed the International Convention for the Control and
Management of Ships’ Ballast Water and Sediments which regulates
discharges of ballast water with the goal of reducing the risk of
introducing invasive species. Regulation D-2 of the Convention sets the
treatment standards that systems must meet (Table 6-2). 

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  2 . Ballast Water
Treatment System Standards.

Organism category	Standard

Organisms, > 50 µm in minimum dimension	<10 cells/m3

Organisms, 10 – 50 µm	<10 cells/ml

Organisms, < 10 µm	No standard

Toxicogenic Vibrio cholerae	<1 cfu/100 ml

Escherichia coli	< 250 cfu/100 ml

Intestinal Enterococci	< 100 cfu/100ml

Compensated Fuel Ballast

PCTs and BMPs for compensated fuel ballast discharge are similar to
those described for clean ballast discharge.  Other BMPs are utilized by
the Navy and include filling fuel storage tanks to no greater than 85%
of capacity while in port to prevent overflow through the expansion
tank, limiting the in-port refueling rate to 400 gpm, and positioning
personnel to watch for overflows or monitor fuel levels during
refueling.

Controllable Pitch Propeller Hydraulic Fluid

Battelle did not identify any specific PCTs for CPP hydraulic fluid
discharge.  

EPA (1999h) identified a handful of BMPs employed by Armed Forces
vessels to control and reduce this discharge.  An oil boom is typically
used during underwater CPP activities to contain hydraulic oil leakage. 
The aft third of a vessel (plus an additional 20 feet beyond the stern)
is enclosed within the boom during these procedures.  Additionally, oil
spill response personnel and equipment (e.g., absorbent pads) must be
present while underwater CPP work is underway and, in the event of any
spillage, the oil will be removed from within the boom using vacuum
trucks and other technology.   

Deck Runoff

An internet and literature search performed by Battelle indicated that
there are no deck runoff treatment technologies currently on the market
or in development.  The UNDS Discharge Assessment report on deck runoff
(EPA, 2003b) provided some information on PCTs and BMPs that had been
evaluated for use on Armed Forces vessels.  Several technologies were
assessed, including capture and containment systems, flocculation, water
oxidation, and filter media.  However, for the purposes of the Armed
Forces, none of the PCTs that were evaluated were appropriate at the
time for use aboard military vessels, primarily because none of the
technologies had been developed for use on waterborne vessels.  However,
EPA (2003b) determined that developing and utilizing a topside
management plan (TMP) describing deck runoff pollution reduction methods
and practices was the best strategy for controlling deck runoff at the
time.  

Some Armed Forces fleets have instituted their own BMPs for deck runoff.
 A few Naval ports require the containment of deck runoff that contains
cleaning agents while pierside.  The USCG manually clears its vessels’
decks of debris and garbage prior to conducting deck washdowns.  Armed
Forces oilers must plug up deck openings during the loading and
unloading of fuel cargo and any spillage is directed to the oily waste
treatment system.  Oil spill cleanup kits are also present on these
types of vessels.

In comments on EPA’s ANPRM, AWO stated that an increasing number of
tank barges are being fit with perimeter spill rails fitted with
scuppers (pluggable holes) that permit the runoff of rain water.  During
cargo transfer operations, the scuppers are plugged up, thereby
containing any spilled cargo on deck and preventing it from being
discharged into the water.  After cargo loading is complete, the
scuppers are not unplugged until the accumulated water on deck is
examined for signs of oil contamination (e.g., sheen) or spills of other
materials.  If contamination is detected, the accumulated water is
removed and held for disposal at an onshore facility.  Drip pans are
also found on tank barges underneath the end of the cargo pipeline.  As
cargo is being loaded onto the vessel, small amounts of cargo can be
spilled in the course of connecting and disconnecting transfer hoses. 
The drip pan catches this spillage and the contents are held for
shore-side disposal. 

AWO also stated that deck and hopper barges can collect rain water in
open, but contained spaces.  Clean rain water is routinely pumped
overboard from these spaces, but accumulated water that may be
contaminated is left where it is and the space is covered or contained
to prevent discharge over the side.  The contents are then properly
disposed of onshore.

Dirty Ballast

PCTs and BMPs for dirty ballast discharge are similar to those described
for clean ballast discharge and compensated fuel ballast.  On Armed
Forces vessels, dirty ballast must be screened prior to discharge by an
oil content monitor (OCM) that measures the amount of oil in the water. 
If the oil content exceeds 15 parts per million (ppm), an alarm sounds
and deballasting operations must cease until an OWS can be employed to
reduce the water’s oil concentration.  

Distillation and Reverse Osmosis Brine

During the UNDS Phase I process, EPA and DoD investigated different
pollution control options for distillation and RO brine discharge from
Armed Forces vessels (EPA, 1999gg).  They evaluated five options for
reducing or eliminating the concentrated brine discharge:



Restrict the operation of water purification plants while a vessel is in
port.

Layup non-essential water purification plants with freshwater when in
port.

Require RO technology on new vessels.

Substitute freshwater for seawater in distilling plants on stem-powered
vessels while in port.

Change distillation and RO plant construction materials.

The EPA and DoD concluded that Option 3 was the most desirable option
because RO systems have lower life cycle costs than distillation plants
and do not require chemical feed and cleaning agents.  With no other
source of feedwater, Option 1 may have resulted in compromised vessel
operations or high monetary costs for providing an alternative feedwater
source.  Options 2 and 4, while cost effective and benign to vessel
operations, may not provide the reduced metals concentrations in
discharges needed to meet water quality standards.  The dearth of
available purification equipment constructed from alternative materials
made Option 5 not attractive at the time of the report.  

Elevator Pit Effluent

Battelle did not identify any specific PCTs for elevator pit effluent
discharge, although many Armed Forces vessels will transfer elevator pit
effluent to the bilge tank (if oily), the gray water treatment system
(if non-oily) or contain the effluent for onshore disposal.  In these
cases, the elevator pit effluent will be treated by a bilge treatment
system, a grey water treatment system, or an onshore treatment system. 
Elevator pit effluent is very rarely discharged directly overboard of
Armed Forces vessels without treatment. 

Firemain Systems

Battelle did not identify any specific PCTs for firemain system
discharge.  However, utilizing a ‘dry’ firemain system, rather than
a ‘wet’ one, will minimize the amount of discharge from this source
because ‘dry’ systems are not continuously pressurized and do not
provide water on demand.  Therefore, ‘dry’ systems cannot provide
water for the various other shipboard activities that may need it, such
as engine cooling or anchor chain washdown.  According to EPA (1999m),
‘dry’ firemain systems produce 0.1% of the discharge produced by a
‘wet’, continuously pressurized system. 

Freshwater Layup

Battelle did not identify any specific PCTs for freshwater layup
discharge.  

According to EPA (1999n), rather than discharging directly overboard,
some vessels of the Armed Forces route the used freshwater effluent from
the condensers to the bilge tank, where it can be treated with an OWS. 

Gas Turbine Water Wash

Battelle did not identify specific PCTs for gas turbine water wash
discharge.  

As a BMP, Navy vessels collect gas turbine water wash effluent in a
dedicated tank for onshore disposal.  

Grey Water

Since 2000, the Alaska Department of Environmental Conservation (DEC)
has been closely monitoring the treatment systems of cruise ships in
Alaskan waters.  The most recent data supplied by Alaska DEC (as of
August 2007) indicate that 29 ‘large’ and 17 ‘small’ cruise
ships have been in Alaskan waters so far in 2007.  Very few of the large
ships had separate grey water treatment systems onboard, with about 65%
of them combining grey water with black water prior to treatment.  The
currently available treatment technologies for combined grey water/black
water wastestream consist of methods also utilized by onshore municipal
treatment plants, the most common being biological degradation and
membrane separation. Other technologies employed by vessels with a large
passenger capacity include vibrating membrane filtration,
physical/chemical treatment, and effluent disinfection via electrolytic
oxidation. An example of a treatment system developed by Hydroxyl
Systems, Inc. for cruise ships is found in 

Figure 6-2.  Examples of grey water treatment technologies and
corresponding costs are presented in Table 6-3.

Figure   STYLEREF 1 \s  6 -  SEQ Figure \* ARABIC \s 1  2 . Grey Water
Treatment System

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  3 . Grey Water
Treatment Technology Costs

Technology	Manufacturers	Capacity (gal/day)	Cost ($’,000US)	Sources

Physical/chemical

treatment	Zodiac	21,240	58.3	Shirley Frederick, Zodiac

Membrane bioreactor	Zodiac	14,998	506	Shirley Frederick, Zodiac

Biological treatment	Zodiac	3,460	35	Shirley Frederick, Zodiac

Electrochemical cell/NaOCl disinfection	Severn Trent 

De Nora	14,794	120	George Starolis, Severn Trent de Nora

Biofilm carrier/

dissolved air flotation/filtration	Hydroxyl Systems, Inc.	264,172	2,200
- 2,400	Dan Turner, Hydroxyl 



528,344	2,600 - 2,800



	792,516	3,100 - 3,300

3,100 - 3,300





	1,056,688	3,600 – 3,800

3,600 - 3,800



	

Other vessels are allowed to discharge grey water outside of no
discharge zones. However, the USCG and various state agencies are
promoting BMPs for grey water to minimize the volume of wastewater
discharged. For example, Alaska has established grey water BMPs: 

Limiting wastewater discharges while the vessel is stationary or in port
(i.e., holding water in port)

Discharge only while vessel is greater than one nautical mile from shore
and traveling at a speed >6 knots.

Vessels that cannot hold water (i.e., do not have any or sufficient
holding tank space):

Can minimize grey water production by limiting usage of washers,
dishwashers, etc. while in port and 

Train crew to limit their usage of water while in port.

Several states have developed grey water discharge BMPs for recreational
boats.  Washington State Department of Ecology (1998) recommends, for
example, using biodegradable and low nitrogen, phosphate-free
detergents, providing adequate garbage receptacles to prevent the
overboard disposal of food waste, and avoiding using dish soaps onboard.
 Massachusetts Office of Coastal Zone Management (2001) cites boater
education as a key to preventing grey water discharge pollution, along
with encouraging the use of shore-based dishwashing stations and shower
facilities.  

Hull Coating Leachate

During the UNDS Phase I process, EPA and DoD evaluated a handful of
potential pollution control methods for reducing the discharges
associated with hull coatings from Armed Forces vessels (EPA, 2003c;
EPA, 1999hh).  Three potential options were assessed for feasibility:

Use Less Toxic Fouling Release Coatings.

Control the Maximum Allowable Anti-Fouling Release Rate.

Limit or Eliminate Use of TBT Paints.

EPA and DoD determined that Options 2 and 3 were the most feasible, with
establishing a maximum copper release rate (Option 2) having estimated
costs of $300,000 to $500,000, as long as the coatings with the reduced
release rate were still effective at preventing hull fouling.  Option 3,
which would involve replacing TBT coatings with copper- or
silicone-based coatings, was less desirable because copper coatings may
accelerate the corrosion of aluminum-hulled vessels and silicone
coatings are effective only once a vessel attains a minimum speed. 
However, at the time of the report, silicone-based coatings were not yet
proven effective on Armed Forces vessels, which was the problem EPA and
DoD had with Option 1.  

Today, Option 1 may indeed be a feasible option for many types of
vessels, including civilian.  Silicone-based hull coatings are
non-leaching and the slippery surface they provide cause marine
organisms to slide off when the vessel achieves a minimum speed. 
International Marine Coatings (IMC) currently manufactures
Intersleek®900, a fluoropolymer low-friction coating that prevents most
organisms from latching on to a hull.  Those that do succeed in
attaching are easily removed when the vessel reaches a minimum speed of
10 knots.  IMC estimates that vessels using Intersleek®900 can achieve
approximately 6% in fuel savings (hull fouling can increase drag on a
vessel and decrease efficiency), resulting in reduced air emissions. 
Intersleek®900 is specifically appropriate for large and active
scheduled vessels, such as dry cargo vessels (e.g., container ships,
refrigerated cargo vessels, roll on-roll off ships, vehicle carriers),
tankers, and cruise ships.  Costs for Intersleek®900 are approximately
$100/liter, with a typical liquefied natural gas carrier requiring
13,000 liters, for example (Alperowicz, 2007).  Other manufacturers of
silicone-based hull coatings include PPG Protective and Marine Coatings,
Hempel, Jotun, Wearlon, and SeaCoat Technology, LLC.  

	

g SeaNine™ 211N, manufactured by Rohm and Haas.  SeaNine™ 211N is
specifically recommended for large vessels operating in shipping lanes
or harbors and in marine or brackish environments.  Large recreational
yachts may also benefit from application.  

Finally, a collection of non-coating methodologies are available to
prevent hull fouling, including sonic technology.  Barnaclean™
(manufactured by SeaCure) uses sonic resonance transmitted through the
vessels hull to cause fouling organisms like barnacles to detach and the
rapidly-moving water that surrounds the hull as a result makes it
difficult for algae and other organisms to attach.  According to the
company’s website, to outfit an average-sized boat (34 feet) would
cost less than $2,000.  However, because it is designed to complement
other preventative activities, the company recommends utilizing
Barnaclean in conjunction with some sort of anti-fouling paint.  

BMPs for reducing hull coating leachate discharge during cleaning are
provided in Section 6.26 on underwater ship husbandry PCTs and BMPs. 
However, as described in Section 5.1.16 on hull coating leachate
discharges, passive leaching from vessel hulls coated with copper-based
paints can contribute a significant amount of copper to the water
column.  The researchers for this same study (Schiff et al., 2003)
stress that, due to the heavy contribution of passive leaching to
dissolved copper concentrations, BMPs should focus on changing the type
of hull protection, rather than on hull cleaning activities.  

Motor Gasoline Compensating Discharge

Battelle did not identify any PCTs specific to motor gasoline
compensating discharge.

Similar to compensated fuel ballast, several BMPs are in place on
relevant Armed Forces vessels to prevent or reduce the likelihood of
MOGAS discharge.  First, the MOGAS tanks are only filled to 80% capacity
and the truck supplying the MOGAS is only loaded with the amount of fuel
needed to achieve this capacity.  Fuel loading rates cannot exceed 50
gpm.  Individuals are assigned to visually watch for problems during
refueling.  Containment systems are also deployed around all locations
(e.g., hose connections) where leakages could conceivably occur. 
Civilian measures for preventing MOGAS discharges may vary.

Photographic Laboratory Drains

Battelle did not identify any PCTs that reduce or eliminate discharge
from photographic laboratory drains.

Currently, the Armed Forces may discharge all photographic laboratory
drains outside of 12 nmi from shore; however, the most common procedure
involves collecting such waste for onshore disposal (EPA, 2003d).  The
UNDS team did not identify other PCTs or BMPs for this discharge given
the high unlikelihood of discharge within 12 nm.	

Small Boat Engine Wet Exhaust

During the development of the UNDS Phase I reports, EPA and DoD
researched potential PCTs and BMPs to control small boat engine wet
exhaust on Armed Forces vessels and published a brief report (EPA,
1999ii).  Specifically, EPA and DoD were investigating methods,
practices, or technologies that would reduce or eliminate the discharge
of combustion by-products, including hydrocarbons, VOCs, and oil and
grease, into the water.  After screening several options (all of which
were not described), EPA and DoD determined that wet exhaust discharge
from Armed Forces small boat engines could best be reduced by:

Mandating all new Armed Forces boats with inboard engines be fitted with
a dry exhaust system.

Converting inboard engines on existing Armed Forces boats to dry
exhaust.

Replacing existing outboard engines on Armed Forces boats with
low-emission models.

Option 1 was determined to be a feasible option for vessels with inboard
engines.  There may be some additional costs associated with design, but
additional installation costs would be limited to materials, since the
labor needed to install dry exhaust engines is no different than that
needed to install wet exhaust engines.  The report went on to conclude
that Option 2 was cost prohibitive.  Retrofitting Armed Forces vessels
with dry exhaust systems would require numerous modifications and a
detailed feasibility study.  EPA and DoD estimated that just to retrofit
Navy inboard engines with dry exhaust systems would cost $36 million in
study, design, and installation costs.  This does not include the small
vessels in other branches of the Armed Forces.  Option 3 was estimated
to cost approximately $9 million for Navy boats, with the only negative
determination being that the cost of the conversion may exceed the cost
of the vessel itself.  However, if this option were implemented through
attrition, the annual costs were estimated to be about $34,000.  

Sonar Dome Discharge

Battelle did not identify any PCTs for reducing or eliminating sonar
dome discharge.

The UNDS report (EPA, 1999z) states that most sonar dome repair is done
while the vessel is in dry-dock.  If the repair involves releasing the
inner sonar dome water, this water should be containerized and disposed
of at the appropriate facility.  

Surface Vessel Bilge Water/Oil-Water Separator Discharge

According to EPA (1999cc), Armed Forces vessels are equipped with an
oily waste holding tank where bilge water is retained until it can
either be disposed of onshore or treated with an oil-water separator
discharged overboard.  Oil content monitors evaluate the bilge water as
it passes through the OWS and will sound an alarm if the allowable
concentration of oil is exceeded.  

IMO regulations (MEPC 107(49)) specify that the total oil concentration
(free and emulsified oil) of bilge water cannot exceed 15 ppm if it is
to be discharged overboard.  Most shipboard bilge water treatment
systems involve an oil-water separator (OWS), which separates the oil
and water using mechanical means (e.g., centrifugation, filtration)
and/or employ bacteria to digest the organic material. Because of the
new regulations, manufacturers are frequently combining several
technologies in order to break up oil emulsions as well as to separate
and remove the oil. The following list includes technologies used in
bilge water separation equipment (EPA, 2003e):

Centrifuge and Hydrocyclone: uses high-speed rotation to separate the
heavier liquids and solids from the lighter oils.

Dissolved Air Flotation: uses high-pressure air to separate suspended
solids and insoluble liquids from water.

Evaporation: uses heat to evaporate the water, leaving only oil, sludge,
and other solids.

Biological Treatment: uses microorganisms to digest organic material
from bilge.

Flocculation (Coalescence): using electrical current or separating
agents to cause smaller particles to coagulate and precipitate out of
the solution for later disposal.

Gravity Coalescence: allows oil and water to form separate layers.

Oil-Absorbing Socks: designed to absorb oil and repel water when placed
in bilge water.

Filtration: separates high molecular weight constituents from fluids
using filter media. 

For recreational vessels, discharge of bilge water is allowed outside of
marinas, provided the discharge does not contain oil or oily waste.  A
comment on EPA’s ANPRM cited a bilge treatment system that has been
specifically developed for recreational and other small vessels.  A
pollution control device designed for use in any vessel with a bilge
tank and bilge pump, HarborGard™ prevents petroleum waste that ends up
in the bilge tank from being discharged overboard and potentially
violating federal and state water pollution laws.  According to the
commentor, Paul Clukies of HarborGard, LLC, units can be purchased and
installed on an average-sized recreational vessel for less than $50.  

Their BilgeKleen™ filtering system comes in three different sizes and
is installed on the bilge pump discharge line.  The filter within the
system removes 100% of hydrocarbons from bilge water before it is pumped
overboard and includes a SmartPad™  that can be placed at the bottom
of the bilge tank to absorb any other contaminants.  RGF Environmental
Group, Inc. manufactures an inline bilge filtering system designed for
small- to medium-sized recreational vessels.   Table 6-4 presents the
examples of commercial and recreational bilge water separator
technologies and the corresponding capacities and costs (if available).

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  4 . Bilge Water
Treatment Technology Costs

Technology	Type of Vessels	Examples of Manufacturers	Capacity (GPM)
Capital Cost ($’,000)	Sources

OWS with coalescence and filtering	Facet: Large commercial

RGF: recreational and commercial

Ecologix: commercial	Facet International,

RGF Environmental, Ecologix Env. Systems	0.694 	5	Mike Wood, Facet; 

Bill Speck, RGF; 



	2	10 -23





5	12 -30





8.8 -10	16 -40





44 - 45	27 -55

	OWS with microbial action	Commercial	EnSolve Biosystems	1.04 – 3.75
39 - 99	Jason Caplan, EnSolve

High speed centrifugal separator	Commercial	Alfa Laval EcoStream	8.8	100
Larry Bozha, Alfa Laval

Filter system	Recreational power or sail boats	Mycelx	20 - 66	.14 -.4
www.mycelx.com

Not available	Recreational power or sail boats	HarborGard	Not available
.05	Comment EPA-HQ-OW-2007-0483-0254



The Massachusetts Office of Coastal Zone Management (2001) provided
suggested BMPs for bilge water handling for recreational vessels and
marinas, including making oil-absorbent pads available dockside,
providing bilge vacuum systems for boaters, encouraging the installation
of bilge oil filters, promoting the use of onboard OWSs or providing
portable OWSs, and educating and informing boaters.  Guidance provided
by the Oregon Department of Environmental Quality (2002) adds to these
suggestions by recommending that soap and emulsifiers not be used to
clean a bilge tank; rather, oil-absorbent pads should be used if
discharge directly to a sanitary sewer is not feasible.   They also
suggest that drip pans be kept under the engine compartment to prevent
oil from entering the bilge and that all oil used during repairs should
be contained and disposed of properly onshore.  Numerous other states
provide BMPs for marinas, including Georgia, Washington, and California,


Underwater Ship Husbandry

In the UNDS MPCD report (EPA, 1999jj), EPA and DoD identified four
potential pollution control options for Armed Vessel discharges
associated with underwater ship husbandry:

Underwater Ship Husbandry Management Plan (USHMP)

Variable Cleaning Pressure Equipment

Improved Brushes

Underwater Ship Husbandry Discharge Collection Equipment

Options 1 and 2 were determined to be the most feasible for Armed Forces
vessels.  A USHMP, while useful for the Armed Forces (an organized group
with a clear line of command), may not be as useful for recreational
vessels.  However, companies that own and operate large numbers of
vessels may benefit from defining ship husbandry requirements and
establishing a routine, if such a plan is not already in place.  Option
2 involves using lighter cleaning pressure when removing soft fouling
organisms (e.g., algae, grass) that detach fairly easily.  This would
not only decrease the discharge associated with the cleaning, but
potentially extend the life of the hull coating.  However, this option
only addresses discharges that originate from the hull coating and does
not address other husbandry-related discharges (e.g., fiberglass from
repair work or metals from welding).  

Underwater ship husbandry activities can also cause invasive species to
be detached from a vessel’s hull and introduced to the water column.
Research in New Zealand (Floerl et al., 2004) has indicated that
approximately 72% of organisms that were removed from the hull of a
small vessel (< 49 meters in length) during cleaning activities remained
viable. Scott Godwin of the Hawaii Coral Reef Assessment and Monitoring
Program is one of the few experts on hull fouling as an invasive species
vector.  In a recent report (Godwin et al., 2006), he offers numerous
suggestions for reducing or eliminating the discharge of invasive
species during underwater ship husbandry activities.  One of the most
obvious approaches is to maintain protective anti-fouling coatings or
technologies in top working order, which can be done by increasing the
frequency of shipyard service; however, this can be costly to the owner
is not likely a viable option.  Another management practice he suggests
is to teach port authority personnel how to identify vessels with high
potential for hull fouling invasive species introductions.  These
‘high-risk’ vessels include barges, floating dry-docks, and vessels
from military decommission yards (purchased as scrap metal or for the
fleets of developing nations). Barges, for example, move slowly and
spend considerable time in port, creating a situation conducive to the
settlement and establishment of fouling organisms. Vessel decommission
yards house vessels that have been idle for years and poorly maintained.
 Port authorities should require hull maintenance records for high-risk
vessels and deny port entry based on these records.  For those vessels
unable to produce such documents, a quarantine area could be set up in
deep water greater with remote video or commercial diver inspection
capabilities.   

The California State Lands Commission (CSLC) published a report (CSLC,
2006) in which they compiled the current mandatory or voluntary
management practices in use around the world to prevent invasive species
from being introduced via the hulls of commercial vessels.  Table 6-5 is
reproduced from their report.

Table   STYLEREF 1 \s  6 -  SEQ Table \* ARABIC \s 1  5 .  Global BMPs
for Preventing Vessel Hulls from being Invasive Species Vectors.

Country/State	Management Strategy	Details

U.S. Federal

California	Embedded in ballast water regulation

Embedded in ballast water statute	Rinse anchor chains and anchors at
place of origin

Remove fouling from hull, piping and tanks on a regular basis. 

Dispose wastes in accordance with local, state, and federal law.

Hawaii	Information Framework Targeting High Risk Vessels (Proposed)
Pro-active measures: Education/outreach, vessel arrival monitoring,
evaluation for high-risk arrivals

Re-active measures: Rapid response/investigation of high risk event

Post-event measures: Long term regulations for high-risk events

• Limit time in port

• Vessel quarantine

• Out of water cleaning

New Zealand	Survey (On Ballast Water Declaration Form)	1. When and where
was the vessel last dry-docked and cleaned?

2. Has the vessel been laid-up for 3 months or more since it was last
dry-docked and cleaned? If YES, state when and where. (Also requests
start and end date laid up)

3. Do you intend to clean the hull of the vessel in New Zealand? If YES,
state when and where

	Voluntary Codes of Practice (Fishing Industry)	Chartered foreign owned
or sourced fishing vessels must be substantially free from plant or
animal growth prior to entering New Zealand’s EEZ.

If no assurance, vessel inspected and cleaned before departure.

Otherwise inspected in NZ and if necessary, fouling removed so no
foreign organisms enter the marine environment

Table 6–5.  Global BMPs for Preventing Vessel Hulls from being
Invasive Species Vectors, continued.

Country/State	Management Strategy	Details

Australia	Prohibition

(States/Territories/Ports)	States and territories prohibit in-water
cleaning.

Many require containment and disposal regulations of fouling debris
removed during out-of-water cleaning.

	Regulation

(Vessels less than 25 m)	Keep ancillary gear and internal seawater
systems clean of marine pests and growths

Before departing your last port for Australia…

o Clean hull within one month before arrival OR

o Apply antifouling paint within one year before arrival OR

o Book vessel for slipping and cleaning within one week of arrival
(cleaning should be in a shipway where material removed can be collected
and disposed of away from the sea)

Australia and New Zealand Environmental Conservation Council (ANZECC)
Codes of Practice	In-water hull cleaning prohibited, except under
extraordinary circumstances.

Sea-chests, sea suction grids, other hull apertures may be allowed under
permit, if debris not allowed to pass to water column or sea bed.

Polishing propellers may be allowed under permit.

Merchant Classification Societies	Requirements

(Applies to majority of merchant fleet)	Dry dock requirements vary
somewhat depending on classification society. Generally:

o Dry dock every 5 years. Cleaning and painting is usually conducted,
but is at the discretion of the company.

o Interim in-water cleanings: Periodicity at the discretion of the
company. Typically dependent on results of fuel consumption tests.



California Sea Grant (2003) offers the following BMPs to mariners who
must clean their vessel’s hull while it is still submerged:

Wait 90 days to clean the vessel’s hull after applying new paint. 
Paints release more toxicant when new. 

Soft sloughing or ablative paints release toxicant and paint to water
when cleaned.  On these boats, clean only running gear and zinc anodes. 

Use only soft materials (e.g., piece of carpet, sponge) to clean the
hull. 

Use soft nylon or similar material on rotary brush machines. 

Use stainless steel brushes and pads on non-painted, metal areas only. 

Use more rigorous cleaning pads only as needed to remove hard marine
growth. 

Do not sand or strip hull paint underwater. 

Bring zinc anodes back to shore; recycle or dispose of properly. 

Clean gently to avoid creating a plume or cloud of paint in the water. 

EPA (2001) adds to these suggestions:

Wash boat hulls above the waterline by hand.  Where feasible, remove
boats from the water and clean them where debris can be captured and
properly disposed of.

Attempt to wash boats frequently enough that the use of cleansers will
not be necessary.

If using cleansers, buy and use ones that will have minimal impact on
the aquatic environment.

Switch to long-lasting and low-toxicity or nontoxic antifouling paints.

Avoid in-the-water hull scraping or any abrasive process done underwater
that could remove paint from the boat hull.

Ensure that adequate precautions have been taken to minimize the spread
of exotic and invasive species when boats are transferred from one water
body to another.

Laws, Regulations, and Conventions

A number of international standards, federal laws, and state permitting
schemes exist or are pending that concern some of the discharges covered
in this report.  This section provides information for EPA to consider
during the nationwide permitting framework development, including
whether existing standards, laws, or state programs may become redundant
or ineffectual upon the institution of the new NPDES program.

International and National Laws and Regulations 

Several international treaties and national laws apply to discharges
incidental to the normal operation of a vessel.  While all of the
regulations listed in this section do not necessarily apply to every one
of the discharges described in Section 5.0, depending on the
constituents of the discharge, one or more of the regulations discussed
below may be applicable.  Even if a constituent or discharge is not
directly regulated by any national or international law, a close
examination of the potentially relevant legislation may be informative
and prevent legal repercussions.

International Standards

Annexes I, II, and V of the International Convention for the Prevention
of Pollution from Ships (MARPOL 73/78) may be relevant.  In the U.S.,
these annexes are implemented through APPS, which applies to all
U.S.-flag vessels operating anywhere in the world and to all
foreign-flag vessels operating or at port within U.S. navigable waters. 
In its implementation of MARPOL Annex I, APPS regulates oil discharges
from U.S.- and foreign-flagged seagoing vessels (33 CFR, parts 151, 155,
156, 157).  MARPOL’s Annexes II and V are also implemented by APPS. 
Annex II regulates pollution from noxious liquid substances in bulk (33
CFR 151).  Annex V regulates garbage pollution of the ocean by ships
from operational or accidental causes and restricts the discharge of
maintenance waste, which includes paint chips (33 CFR 151).  

With regard to hull coating leachate, international standards governing
the discharge of copper or zinc antifouling coatings do not exist.  The
International Convention on the Control of Harmful Antifouling Systems
on Ships (AFS Convention) was adopted by the IMO in 2001, although it is
not yet in force.  Once in force, no vessels from signatory nations to
the AFS Convention may bear TBT-based antifouling coatings, unless
covered by an approved sealant (Showalter and Savarese, 2005). 

National Law

As described in EPA (2000), the Oil Pollution Act (OPA) (33 U.S.C. §§
2701 et seq.) is a comprehensive statute designed to expand oil spill
prevention, preparedness, and response capabilities of the Federal
government and industry. It amends §311 of the CWA to clarify federal
response authority, increase penalties for spills, establish USCG
response organizations, require tank vessel and facility response plans,
and provide for contingency planning in designated areas.  OPA prohibits
the discharge of oil or hazardous substances, in such quantities as may
be harmful, into or upon: U.S. navigable waters, adjoining shorelines,
waters of the contiguous zone, or waters which may affect natural
resources in the Exclusive Economic Zone (extending some 200 miles
offshore). Within twelve miles of shore, OPA’s regulations prohibit
the discharge of oil unless it is passed through an oil-water separator,
and does not cause a visible sheen or exceed 15 ppm (33 CFR §151.10).
Beyond twelve miles, oil or an oily mixture may be discharged while
proceeding en route if the oil content of the effluent without dilution
is less than 100 ppm. Vessels are required to maintain an Oil Record
Book, which records, among other things, the disposal of oily residues
and the discharge or disposal of bilge water (33 CFR §151.25).  CWA
§311(b)(5) mandates that any person in charge of a vessel which
discharges or spills oil into the navigable waters of the U.S. must
notify the appropriate federal agency, who will then notify the state(s)
that potentially could be affected.

Individual U.S. states have the authority (under CWA §303(c)) to set
their own water quality standards applicable within state waters and
vessels in state waters must abide by these standards.

The Comprehensive Environmental Response and Community Right-to-Know Act
(CERCLA) may be relevant to some vessel discharges.  CERCLA establishes
notification requirements upon the environmental release of specific
hazardous substances, listed in 40 CFR 302.4.  Petroleum and any
refinery-added substances (e.g., xylene, benzene, toluene) are
specifically excluded from CERCLA due to their coverage under other
regulations.  However, if the vessel vacatur leads to discharges (and
their constituents) being permitted via the NPDES system, CERCLA
liability and reporting provisions will no longer apply to those
permitted discharges.  

g/cm2/day or more prohibited.  In 2004, EPA released ambient water
quality criteria for TBT that, while not legally enforceable, can help
states establish their own water quality standards (Showalter and
Savarese, 2005).

Under the requirements of NISA, the USCG enforces mandatory ballast
water BMPs for all vessels with ballast tanks operating in U.S. waters,
as described in 33 CFR 151.2035(a) and (b).  The specific mandatory
activities are described in the Clean Ballast discharge description. 
Other provisions of NISA include mandatory ballast water reporting
requirements and the funding of treatment technology research.   NISA
technically expired in 2002 (although the specific regulations
promulgated under it remain binding; 33 CFR 151) and, for several years,
bills have been introduced in the U.S. House of Representatives and the
U.S. Senate seeking to reauthorize it as the National Aquatic Invasive
Species Act.  The most recent bill was introduced in the winter of 2007,
but whether the bill will make it out of committee during this
congressional session remains to be seen.

State Law

Some states have developed their own permitting mechanisms, mostly
pertaining to ballast water discharge, or have permitting plans in the
works.  

	

Table   STYLEREF 1 \s  7 -  SEQ Table \* ARABIC \s 1  1 . Current or
Pending State Permitting Systems Pertaining to Vessel Discharges Covered
in this Report.

State	Permitting Systems Pertaining to Vessel Discharges Covered in this
Report

Alaska	AS 46.03.100: permit is required for the discharge of graywater

Pending: Large Commercial Passenger Vessel Wastewater Discharge General
Permit (2007DB0002)

Indiana	Pending: Senate Bill 219 of 2006-- would allow vessels to
operate in the waters of IN only if ballast water and sediment in the
vessel have been sterilized. Ballast discharge would be allowed only
with a permit.

Table7–1. Current or Pending State Permitting Systems Pertaining to
Vessel Discharges Covered in this Report, continued.

State	Permitting Systems Pertaining to Vessel Discharges Covered in this
Report

Maine	General Permit for the Discharge of Graywater or a Mixture of
Graywater and Blackwater from Large Commercial Passenger Vessels to
Coastal Waters (Permit no. W008222-5Y-A-N)

Michigan	Ballast Water Control General Permit No. MIG140000: ballast
water discharges only permitted if in compliance with treatment
requirements and other methods described in the general permit. 

Ships may apply for an individual permit if they prefer to use an
alternate treatment method but they must demonstrate that the method is
both environmentally sound and its treatment effectiveness is equal to
or better than the treatment methods included in the general permit.

Minnesota	Pending: H.F. No. 3705 (2006), Reintroduced S.F. No. 53
(January 2007)—oceangoing vessels with ballast tanks would need a
permit and the vessel is equipped to discharge ballast in compliance
with set rules.

Ohio	Pending: House Bill 298 (2007-2008)-- oceangoing vessels capable of
discharging ballast will not be permitted to operate without a permit,
which will be issued only if it can be demonstrated either that
discharge will not happen or that approved treatment methods will be
used. 

Pennsylvania	Pending: House Bill 1736, Session of 2007-- would require
vessels using PA ports to obtain a permit proving that the vessel cannot
take on ballast water or that it is outfitted with approved treatment
technology.

Wisconsin	Pending: 2005 Assembly Bill 919 (Introduced January 17,
2006)—would require vessels using WI ports to obtain a permit proving
that the vessel cannot take on ballast water or that it is outfitted
with approved treatment technology.

CONCLUSIONS

With the scheduled date for implementation of the vessel vacatur on the
horizon, EPA must fully comprehend the scope of the NPDES permitting
changes that must be instituted.  This report provides an overview of
available information on vessel populations and characteristics, as well
as port statistics and existing information on the various types of
discharges incidental to the normal operation of a vessel.  

Table 8-1 summarizes the statistical findings for vessel and port
information.  

Table   STYLEREF 1 \s  8 -  SEQ Table \* ARABIC \s 1  1 .  Summary of
Statistical Findings for Vessels and Ports.

VESSELS

Recreational

Total Registered Recreational Vessel Population in 2005	12, 942,414

Top 3 U.S. Regions with Largest Recreational Registration in 2005	Great
Lakes

Inland waterways

South Atlantic

Top 3 U.S. States with Largest Recreational Registration in 2005
California

Florida

Michigan

Percent of All Recreational Vessels Mechanically Propelled in 2005	93%

Percent of Mechanically Propelled Vessels Equipped with Outboard Engine
(s) in 2005	70%

Percent of Mechanically Propelled Recreational Vessels < 26 Feet in
Length in 2005	95%

Commercial

Total Cargo/Passenger Vessel Population in 2005	41,028

Percent of Cargo/Passenger Vessels Operating Chiefly on the MS River
System of the Gulf Intracoastal Waterway in 2005	78%

Number of Industrial Vessels (e.g., cable layers, dredges) in 2007	823

Table   STYLEREF 1 \s  8 -  SEQ Table \* ARABIC \s 1  2 .  Summary of
Statistical Findings for Vessels and Ports.

VESSELS

Number of Towing Vessels in 2007	6,898

Number of Offshore Supply Vessels in 2007	1,114

Number of Commercial Fishing Vessels in 2007	33,550

Top 3 U.S. States with Most Documented Commercial Fishing Vessels in
2007	Alaska

Florida

Washington

Top 3 Most Frequently Recorded Foreign Flags Entering U.S. Ports in 2005
Panama

Bahamas

Liberia

PORTS

Top U.S. Region for Vessel Port Calls in 2005	Gulf of Mexico

Percent of All 2005 Port Calls Received in the Gulf of Mexico	31%

Top 3 U.S. Ports for 2005 Vessel Calls	Houston, TX

Los Angeles/Long Beach,CA

New York, NY



For discharges incidental to the normal operation of a vessel, the
discharges that will be relevant for the greatest number of vessels
include clean ballast, deck runoff, grey water, bilge water, hull
coating leachate, small boat engine wet exhaust, and underwater ship
husbandry.  The other discharges may be applicable to a collection of
commercial vessels; however, these seven discharges will likely be of
the highest concern to EPA in light of the vessel vacatur.  

REFERENCES

Alaska Department of Environmental Conservation (DEC). 2007. 2007 Large
Ship Treatment and Discharge Status. Last accessed September 15, 2007.  
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Alperowicz, N. 2007. Akzo Nobel Reinforces Leadership in Marine
Coatings. eChemicalWeekChina. June 20, 2007.  Last accessed September
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California Sea Grant. 2003. Underwater Hull Cleaner’s Best Management
Practices.  Last accessed September 15, 2007.   HYPERLINK
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California State Lands Commission. 2006. Commercial Vessel Fouling in
California: Analysis, Evaluation, and Recommendations to Reduce
Nonindigenous Species Release from the 

Non-Ballast Water Vector.  CSLC, Marine Facilities Division.

Carson, R., M. Damon, L. Johnson, and J. Miller. 2002. Transitioning to
Non-Metal Antifouling Paints

On Marine Recreational Boats in San Diego Bay. University of California
and California Department of Boating and Waterways.

Copeland, C. 2007. Cruise Ship Pollution: Background, Laws and
Regulations, and Key Issues. Congressional Research Service. Last
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Dauer, D.M. 2006. Benthic Biological Monitoring Program of the Elizabeth
River Watershed (2005). Last accessed September 15, 2007.   HYPERLINK
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http://www.elizabethriver.org/Publications/Pub-Detail.asp?ID=22  

EPA. 1999a. Phase I: Uniform National Discharge Standards for Vessels of
the Armed Forces. U.S. Environmental Protection Agency, Office of Water.
EPA-821-R-99-001. 

EPA. 1999b. Nature of Discharge Report: Aqueous Film-Forming Foam. 
Uniform National Discharge Standards Program. 

EPA. 1999c. Nature of Discharge Report: Boiler Blowdown.  Uniform
National Discharge Standards Program. 

EPA. 1999d. Nature of Discharge Report: Cathodic Protection.  Uniform
National Discharge Standards Program. 

EPA. 1999e. Nature of Discharge Report: Chain Locker Effluent.  Uniform
National Discharge Standards Program. 

EPA. 1999f. Nature of Discharge Report: Clean Ballast.  Uniform National
Discharge Standards Program. 

EPA. 1999g. Nature of Discharge Report: Compensated Fuel Ballast. 
Uniform National Discharge Standards Program. 

EPA. 1999h. Nature of Discharge Report: Controllable Pitch Propeller
Hydraulic Fluid.  Uniform National Discharge Standards Program. 

EPA. 1999i. Nature of Discharge Report: Deck Runoff.  Uniform National
Discharge Standards Program. 

EPA. 1999j. Nature of Discharge Report: Dirty Ballast.  Uniform National
Discharge Standards Program. 

EPA. 1999k. Nature of Discharge Report: Distillation and Reverse Osmosis
Brine. Uniform National Discharge Standards Program. 

EPA. 1999l. Nature of Discharge Report: Elevator Pit Effluent.  Uniform
National Discharge Standards Program. 

EPA. 1999m. Nature of Discharge Report: Firemain Systems.  Uniform
National Discharge Standards Program. 

EPA. 1999n. Nature of Discharge Report: Freshwater Layup.  Uniform
National Discharge Standards Program. 

EPA. 1999o. Nature of Discharge Report: Gas Turbine Water Wash.  Uniform
National Discharge Standards Program. 

EPA. 1999p. Nature of Discharge Report: Grey Water.  Uniform National
Discharge Standards Program. 

EPA. 1999q. Nature of Discharge Report: Hull Coating Leachate.  Uniform
National Discharge Standards Program. 

EPA. 1999r. Nature of Discharge Report: Motor Gasoline Compensating
Discharge.  Uniform National Discharge Standards Program. 

EPA. 1999s. Nature of Discharge Report: Non-Oily Machinery Wastewater. 
Uniform National Discharge Standards Program. 

EPA. 1999t. Nature of Discharge Report: Photographic Laboratory Drains. 
Uniform National Discharge Standards Program. 

EPA. 1999u. Nature of Discharge Report: Refrigeration/Air Conditioning
Condensate Discharge.  Uniform National Discharge Standards Program. 

EPA. 1999v. Nature of Discharge Report: Rudder Bearing Lubrication. 
Uniform National Discharge Standards Program. 

EPA. 1999w. Nature of Discharge Report: Seawater Cooling Overboard
Discharge.  Uniform National Discharge Standards Program. 

EPA. 1999x Nature of Discharge Report: Seawater Piping Biofouling
Prevention.  Uniform National Discharge Standards Program. 

EPA. 1999y. Nature of Discharge Report: Small Boat Wet Engine Exhaust. 
Uniform National Discharge Standards Program. 

EPA. 1999z. Nature of Discharge Report: Sonar Dome Discharge.  Uniform
National Discharge Standards Program. 

EPA. 1999aa. Nature of Discharge Report: Steam Condensate Discharge. 
Uniform National Discharge Standards Program. 

EPA. 1999bb. Nature of Discharge Report: Stern Tube Seals and Underwater
Bearing Lubrication.  Uniform National Discharge Standards Program. 

EPA. 1999cc. Nature of Discharge Report: Submarine Bilge Water.  Uniform
National Discharge Standards Program. 

EPA. 1999dd. Nature of Discharge Report: Surface Vessel Bilge
water/Oil-Water Separator Discharge.  Uniform National Discharge
Standards Program. 

EPA. 1999ee. Nature of Discharge Report: Underwater Ship Husbandry. 
Uniform National Discharge Standards Program. 

EPA. 1999ff. Nature of Discharge Report: Welldeck Discharges.  Uniform
National Discharge Standards Program. 

EPA. 1999gg. Distillation and Reverse Osmosis Brine: Marine Pollution
Control Device.  Uniform National Discharge Standards Program. 

EPA. 1999hh. Hull Coating Leachate: Marine Pollution Control Device. 
Uniform National Discharge Standards Program. 

EPA. 1999ii. Small Boat Engine Wet Exhaust: Marine Pollution Control
Device.  Uniform National Discharge Standards Program. 

EPA. 1999ii. Underwater Ship Husbandry: Marine Pollution Control Device.
 Uniform National Discharge Standards Program. 

EPA. 2000. Cruise Ship White Paper. Last accessed September 15, 2007.  
HYPERLINK "http://www.epa.gov/owow/oceans/cruise_ships/white_paper.pdf" 
http://www.epa.gov/owow/oceans/cruise_ships/white_paper.pdf   

EPA. 2001. National Management Measures Guidance to Control Nonpoint
Source Pollution from Marinas and Recreational Boating.  U.S.
Environmental Protection Agency, Office of Water. EPA-841-B-01-005. Last
accessed September 15, 2007.   HYPERLINK
"http://www.epa.gov/owow/nps/mmsp/index.html" 
http://www.epa.gov/owow/nps/mmsp/index.html  

EPA. 2003a. Discharge Assessment Report: Chain Locker Effluent. Uniform
National Discharge Standards Program.

EPA. 2003b. Discharge Assessment Report: Deck Runoff.  Uniform National
Discharge Standards Program. 

EPA. 2003c. Discharge Assessment Report: Hull Coating Leachate.  Uniform
National Discharge Standards Program. 

EPA. 2003d. Discharge Assessment Report: Photographic Laboratory Drains.
 Uniform National Discharge Standards Program. 

EPA. 2003e. Discharge Assessment Report: Surface Vessel Bilge
water/Oil-Water Separator.  Uniform National Discharge Standards
Program. 

EPA. 2007a. TMDL National Database. 
http://www.epa.gov/OWOW/tmdl/index.html

EPA. 2007b. National Estuary Program Coastal Condition Report.
EPA-842/B-06/001.

Floerl, O., N. Norton, G. Inglis, B. Hayden, C. Middleton, M. Smith, N.
Alcock, I. Fitridge. 2004. An investigation of hull cleaning and
associated waste treatment options for preventing the spread of
non-indigenous marine species. Final research report for Ministry of
Fisheries Project ZBS2002-04. 40 pgs.

Galveston Bay Estuary Program. 2002. The State of the Bay: A
Characterization of the Galveston Bay Ecosystem, 2nd Edition. GBEP T-7.
Last accessed September 15, 2007.   HYPERLINK
"http://gbic.tamug.edu/sobdoc/sob2/sob2page.html" 
http://gbic.tamug.edu/sobdoc/sob2/sob2page.html  

Godwin, S., K. Rodgers, and P. Jokiel. 2006. Reducing Potential Impact
of Invasive Marine Species in the Northwestern Hawaiian Islands Marine
National Monument. Hawaii Coral Reef Assessment and

Monitoring Program.  Last accessed September 15, 2007.   HYPERLINK
"http://www.hawaii.edu/HIMB/nwhi_crrp/documents/Godwin_et_al_Invasives_2
006.pdf" 
http://www.hawaii.edu/HIMB/nwhi_crrp/documents/Godwin_et_al_Invasives_20
06.pdf   	 

Johnson, L. and J. Gonzalez. 2006. Nontoxic Hull Coating Field
Demonstration: Long-Term Performance. UCSGEP-SD Fact Sheet 06-3. Last
accessed September 15, 2007.   HYPERLINK
"http://seagrant.ucdavis.edu/watershed/CoatingPerformanceUpdate2006.pdf"
 http://seagrant.ucdavis.edu/watershed/CoatingPerformanceUpdate2006.pdf 


Johnston, C. N. 1999. Re: Petition for repeal of 40 C.F.R. § 122.3(a).
Letter to Carol Browner, EPA Administrator. January 13, 1999.

Lloyd’s Register. 2007. Ballast Water Treatment Technology, Current
Status.

Maddison, B. 2006. Treating Ballast Water from Cruise Ships at the Port
of San Francisco: Options and Feasibility. Bluewater Network. Last
accessed September 15, 2007.   HYPERLINK
"http://www.bluewaternetwork.org/ballastwaterstudy.pdf" 
http://www.bluewaternetwork.org/ballastwaterstudy.pdf  

MARAD. 2006. 2005 Vessel Calls at U.S. and World Ports. United States
Department of Transportation, Maritime Administration, Office of
Statistical and Economic Analysis. April 2006.

Massachusetts Office of Coastal Zone Management. 2001. Massachusetts
Clean Marine Guide; Strategies to Reduce Environmental Impacts. Last
accessed September 15, 2007.   HYPERLINK
"http://www.mass.gov/czm/marinas/guide/" 
www.mass.gov/czm/marinas/guide/  

Navy Research and Development Division. 1997. UNDS Hull Coating
Evaluation. Marine Environmental Support Office, Naval Command, Control
& Ocean Surveillance Center, RDT&E Division (NRaD), 28 February 1997.

NAS. 2003. Oil in the Sea III: Inputs, Fates, and Effects.  National
Academy of Sciences. National Academy Press.  

NBIC. 2004. NBIC Online Database. Electronic publication, Smithsonian
Environmental Research Center & United States Coast Guard.
http://invasions.si.edu/nbic/search.html

NEA et al., v. EPA. 2006. Order Granting Plaintiffs’ Motion for
Permanent Injunctive Relief. Case No. 03-05760SI. Sept. 18, 2006

NMMA. 2007. 2006 U.S. Recreational Boat Registration Statistics.
National Marine Manufacturers Association.

Oregon Department of Environmental Quality. 2002. Best Management
Practices for Oregon Marinas. ODEQ Marina Outreach Team. May 2002.  Last
accessed September 15, 2007.   HYPERLINK
"http://www.devilslakeor.us/text/MarinaBMPs-1.pdf" 
http://www.devilslakeor.us/text/MarinaBMPs-1.pdf  

Schiff, K., D. Diehl, and A. Valkirs. 2003. Copper Emissions from
Antifouling Paint on Recreational Vessels. Southern California Coastal
Water Research Project. Tech. Rpt. 405. Last Accessed September 15,
2007.   HYPERLINK
"http://www.waterboards.ca.gov/sandiego/programs/baycleanup/DiverBMPSCCW
RP.pdf" 
http://www.waterboards.ca.gov/sandiego/programs/baycleanup/DiverBMPSCCWR
P.pdf  

Schmidt, K. 2000. Cruising for Trouble: Stemming the Tide of Cruise Ship
Pollution. Bluewater Network.  Last accessed September 15, 2007.  
HYPERLINK
"http://www.bluewaternetwork.org/reports/rep_ss_cruise_trouble.pdf" 
http://www.bluewaternetwork.org/reports/rep_ss_cruise_trouble.pdf  

Showalter, S. and J.Savarese. 2005. Restrictions on the Use of Marine
Antifouling Paints Containing Tributyltin and Copper.  Sea Grant Law
Center. MASGP 04-052

Taylor, A.H. and G. Rigby. 2002. The Identification and Management of
Vessel Biofouling Areas as Pathways for the Introduction of Unwanted
Aquatic Organisms. Australia, Dept. of Agriculture, Fisheries, and
Forestry, Ballast Water Research Programme. Last accessed September 15,
2007.   HYPERLINK
"http://www.daff.gov.au/__data/assets/pdf_file/0019/9082/ballast_report1
6.pdf" 
http://www.daff.gov.au/__data/assets/pdf_file/0019/9082/ballast_report16
.pdf  

USACE. 2005a. Waterborne Transportation Lines of the United States.
Volume 1: National Summaries. United States Army Corps of Engineers,
Institute for Water Resources. Alexandria, Virginia.  

USACE. 2005b. Waterborne Transportation Lines of the United States.
Volume 2: Vessel Company Summary. United States Army Corps of Engineers,
Institute for Water Resources. Alexandria, Virginia.  

USACE. 2005c. Waterborne Transportation Lines of the United States.
Volume 3: Vessel Characteristics. United States Army Corps of Engineers,
Institute for Water Resources. Alexandria, Virginia.  

USCG. 2007a. Merchant Vessels of the United States (VESDOC). National
Vessel Documentation Center. Revised May 5, 2007.

USCG 2007b. Metadata for Merchant Vessels of the United States (VESDOC).
 National Vessel Documentation Center. Revised May 8, 2007.

U.S. CBP. 2007. 2005 U.S. Customs Vessels Entrances and Clearances.
USACE, Navigation Data Center.
http://www.ndc.iwr.usace.army.mil/data/dataclen.htm

Washington State Department of Ecology. 1998. Resource Manual for
Pollution Prevention in Marinas.  Publication # 9811.



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ATTACHMENT A

State-by-state Recreational Vessel Registration Information



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 http://www.ndc.iwr.usace.army.mil/data/datavess.htm

 http://www.marad.dot.gov/MARAD_statistics/index.html

 http://www.epa.gov/owow/tmdl/index.html

 http://www.epa.gov/owow/oceans/nepccr/index.html 

 There is about a 4,500 vessel difference between vessels with a vessel
service type of ‘commercial fishing vessel’ (Table 3-6) and vessels
with a trade indicator of ‘fishery’.  This may be explained by the
vessel owner’s opinion of what his vessel’s use was.  For example,
‘fisheries trade’ may have meant, to some vessel owners, charter
fishing or other fishing-for-hire activities, not solely commercial
fishing.  Therefore, the true number of commercial fishing vessels
operating in U.S. waters is likely somewhere between 28,972 and 33,550.

 Deadweight is defined as the total weight in metric tons of cargo,
fuel, fresh water, stores and crew which a ship can carry when immersed
to its load line (MARAD, 2006).

 The Coastal Condition Report discussion of the waters surrounding the
port of Houston is also relevant to Galveston Bay (Section 4.2.16).

 Both Seattle, WA and Tacoma, WA are located on Puget Sound.  Therefore,
the estuarine conditions (based on the Coastal Condition report data)
described for Seattle also apply to Tacoma (Section 4.2.17).

 www.elizabethriver.org 

 http://www.bayoulafourche.org/default.asp?id=64

 http://gbic.tamug.edu/sobdoc/sob2/sob2page.html

 These comments included EPA-HQ-OW-2007-0483-0619 (AWO),
EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC),
EPA-HQ-OW-2007-0483-1494 (CLIA), EPA-HQ-OW-2007-0483-1498 (WSC).

 EPA and DoD used state water quality standards to evaluate discharge
constituents and compared the sampling results (when available) to the
state with the most stringent standards for a given constituent.

 These comments included EPA-HQ-OW-2007-0483-1177 (LMC),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-1248 (CMC),
EPA-HQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-1177 (LMC),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

 Green water refers to fresh or salt water that washes over the deck of
a vessel from wave action.

 These comments included EPA-HQ-OW-2007-0483-0619 (AWO),
EPA-HQ-OW-2007-0483-1168 (PSPA),  EPA-HQ-OW-2007-0483-1177 (LMC),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

 This ‘demarcation line’ is not further defined in the comment.

 These comments included: EPA-HQ-OW-2007-0483-1248 (CMC) and
EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-0619 (AWO),
EPA-HQ-OW-2007-0483-1168 (PSPA),  EPA-HQ-OW-2007-0483-1177 (LMC),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

 The comment did not further specify what these ‘open, but contained
areas’ were.

 These comments included: EPA-HQ-OW-2007-0483-1177 (LMC),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HW-OW-2007-0438-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

 This comment was EPA-HQ-OW-2007-0438-1498 (WSC).

 These comments included: EPA-HQ-OW-2007-0483-1177 (LMC),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HW-OW-2007-0438-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-1248 (CMC) and
EPA-HQ-OW-2007-0483-1498 (WSC).

 This comment was EPA-HQ-OW-2007-0483-1494 (CLIA).

 These comments included EPA-HQ-OW-2007-0483-0619 (AWO),
EPA-HQ-OW-2007-0483-1168 (PSPA),  EPA-HQ-OW-2007-0483-1177 (LMC),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-1177 (LMC),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

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 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).

  These comments included EPA-HQ-OW-2007-0483-619 (AWO),
EPA-HQ-OW-2007-0483-1168 (PSPA), EPA-HQ-OW-2007-0483-1248 (CMC),
EPA-HQ-OW-2007-0483-1494 (CLIA), EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-619 (AWO),
EPA-HQ-OW-2007-0483-1248 (CMC), and EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-619 (AWO),
EPA-HQ-OW-2007-0483-1168 (PSPA), EPA-HQ-OW-2007-0483-1177 (LMC),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-1248 (CMC),
EPA-HQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-619 (AWO),
EPA-HQ-OW-2007-0483-1177 (LMC), EPA-HQ-OW-2007-0483-1248 (CMC),
EPA-HQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).

 This comment was EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-1248 (CMC),
EPA-HQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-619 (AWO),
EPA-HQ-OW-2007-0483-1248 (CMC), EPA-HQ-OW-2007-0483-1494 (CLIA), and
EPA-HQ-OW-2007-0483-1498 (WSC).

 These comments included EPA-HQ-OW-2007-0483-1248 (CMC),
EPA-HQ-OW-2007-0483-1494 (CLIA), and EPA-HQ-OW-2007-0483-1498 (WSC).

 Comment No. EPA-HQ-OW-2007-0483-1494

 EPA-HQ-OW-2007-1093 (FedNav, Ltd.)

 Comment No. EPA-HQ-OW-2007-0483-619

 ‘Large’ cruise ships have overnight accommodations for over 250 or
more passengers.

 www.international-marine.com

 www.rohmhaas.com

 www.barnaclean.com

 This comment was EPA-HQ-OW-2007-0483-0254 (Paul Clukies, HarborGard)

 www.harborgard.com

 www.mycelx.com

Work Assignment 4-50		 September 2007

NPDES Vessel Vacatur Findings Report		Revision: Revised Draft

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